Privacy Policy

Fatsoma Limited ("Fatsoma", “we”, “our”) is committed to ensuring that your privacy is protected. This Privacy Policy explains how we use the information we collect about you (or that you provide us with), how you can instruct us if you prefer to limit the use of that information and procedures that we have in place to safeguard your privacy. For the purposes of this policy, the term “Promoter” is used to refer to event creators using our Services to create and promote events. The term “Customers” shall be used to refer to an individual who attends, or consumes information in relation to, an event. Promoters, Customers and other third parties who use our services are referred to in this policy as “Users”, “you” or “your”.

We provide an online marketing platform that Promoters may use to market to or stay in contact with Users and Customers, including creating and sending emails and push notifications. We provide a transactional website and mobile application where individuals can buy tickets to events put on by the Promoters who use our platform to sell tickets to their events. Promoters may also partner with other promoters on the Fatsoma platform to co-promote events.

For the purpose of the Data Protection Act 1998, the General Data Protection Regulation and any and all domestic legislation implementing the Regulation into English Law (the "Data Protection Laws"), Fatsoma of 6th Floor, The Hive, 47 - 49 Lever Street, Manchester M1 1FN is a Data Controller and will be Data Controller in relation to a User’s Personal Data in certain circumstances, which are set out below.

Fatsoma as a Data Controller and a Data Processor

Under our terms and conditions and this Privacy Policy, we may act as either a Data Controller or a Data Processor in respect of your Personal Data, depending on the applicable circumstances.

Where you create an account with us to organise your events (i.e. you are acting as a Promoter) or to explore the services we offer, Fatsoma will be a Data Controller in respect of the Personal Data that you provide as part of our account. We will also be a Data Controller of the Personal Data that we have obtained about the use of our applications or platform, which could relate to any User.

If you register for an event as a Customer, we will process your Personal Data to help administer that event on behalf of the Promoter (for example processing payments, sending confirmation and promotional communications) and to help the Promoter in the promotion of their Event and future events. Alternatively, where you are a user of a Promoter and the Promoter imports your contact information into our Server as they wish to invite you to an Event or to use our platform, we will process your Personal Data to administer the Promoter’s event or the Promoter’s request In such circumstances, Fatsoma provides the systems for Promoters but does not control the Personal Data that is requested from an individual nor are we responsible for the continued accuracy of this Personal Data.

Any questions you may have in this set of circumstances regarding the use of your data should be directed at the Promoter. Where you no longer wish to be contacted by a Promoter through our platform, you can unsubscribe from any communications you receive from Fatsoma as set out above (see “You have the right to object to direct marketing”). In addition, in these circumstances, where you wish to update any inaccuracies in your Personal Data on our system, or wish for your Personal Data to be deleted from our system, you can contact either us or the Promoter (see “You have the right to correct any inaccurate or incomplete Personal Data” and “You have the right to be forgotten” above).

For full details of the processes carried out by Fatsoma on behalf of a promoter view the Promoter Process Registry.

You can contact us at support@fatsoma.com with any questions you may have about privacy or data protection.

Please note that links from our website may take you to external websites not covered by this policy. We recommend that you check their privacy policies yourself before submitting any personal information. We will not be responsible for the content, function or information collection policies of these external websites.

1. The information we collect and how we collect it

You are not required (by law or by any contract with us) to provide personal information to us via this website. We will only require you to provide personal information to us where it is necessary for us to provide you with a service (such as where you create an account with us).

Information about all users
Information we collect about you

We may receive personal information about you whenever you contact or engage with us. For example, by doing the following:

• creating and using a registered account on our website
• creating an account, or accessing our website/platform using a third party account (for example a social media account)
• using and browsing our website
• telephoning, texting, writing by post or emailing us

This information may include the following:

• normal identification information, such as your full name, date of birth, age, gender, marital status;
• contact information, such as your postal address, email address and telephone number;
• social media identification information, such your Facebook page address, your Twitter handle, your Instagram handle and profile picture;
• additional information relevant to your use of our site and services, or your event or services, such as your marketing preferences, survey responses and feedback

Please note that Fatsoma will not store credit or debit card information from payments made through our services other than where it is necessary for us to complete our obligations to you.

In addition, we also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services. You can find out more information about this information we collect in section 4 below.

Information we collect from other sources

We may collect information about you from other sources. This may include for example information you have shared publicly, including on social media.

In addition, you can also create your Fatsoma account using, or connect your Fatsoma account to, your accounts on third party services such as Facebook, Twitter or Instagram. In the event that this occurs, we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy. For example, if you connect with our platform using Facebook, we store your Facebook I.D., your first name, surname, email, location, pages you have “liked” and profile picture we can see which brands you have liked on Facebook and invite you to follow them on Fatsoma.

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.

Information we receive from other sources

Sometimes you will have given your consent for other websites, services or third parties to provide information to us.

For example, this could include information we receive about you if you follow a Promoter’s page/website we operate or any other services we provide, in which case we will have informed you when we collected this data that it may be shared. We will also have told you for what purpose we will share your data.

It could also include information from third parties that we work with to provide our products and services, such as payment processors, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.

Information about Promoters
Information we collect about you

In addition to what is set out above, where you are a Promoter then we may collect additional information about you.

For example, where you use our payment processing services we will collect financial information from you (for example your bank account details and address) as necessary to facilitate payments received for your events. In addition, we may collect any information which is required for tax purposes.

Information we receive from other sources

Along with the information set out above, we may also collect or receive Personal Data from third party sources, such as other websites, your bank, our payment processing partners and our credit reference agencies.

Information from Promoters

Where you are a Promoter and you use our services and platform, you may import into our system Personal Data you have collected from your customers. We have no direct relationship with these individuals or any person other than you and for that reason, as is set out in the terms and conditions of our website, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals.

Information about Customers
Information we collect about you

As a Customer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of a Promoter.

If you register for a paid event, you will provide financial information (e.g. your credit card number and expiration date, billing address etc.), some of which may constitute Personal Data. Please note that as set out above, Fatsoma will not store this credit card information for as long as is necessary to complete our obligations towards a Customer.

Also, Promoters can create event registration pages to collect information from Customers regarding their registration for a Promoter’s event listed on our Services. Fatsoma does not control the Promoter’s registration process nor any Personal Data that a Promoter collects. Personal Data collected on behalf of Promoters is provided to the Promoter of the applicable event in accordance with the provisions set out below.

Information we receive from other sources

We may also collect or receive Personal Data from third party sources, such as Promoters, other Customers, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.

2. How do we use the personal information we collect?

We take data protection law seriously, so below we have set out exactly how and why we use your information, and what our legal basis is to be able to use your information in each way.

We need all the categories of information listed above to allow us to enter into and perform our contract with you*, to enable us to comply with legal obligations⁑, and in order to pursue legitimate interests of our own or those of third parties⁂ (provided your interests and fundamental rights do not override those interests). The situations in which we will process your Personal Data are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information.

• Verifying your identity (*, ⁑, ⁂)
• To enable you to access the services we provide (*, ⁂)
• To enable you to create an account on our website/platform (*, ⁂)
• Making a decision and processing a ticket purchase. (*)
• Determining the terms of a ticket purchase. (*)
• Administering any agreement we have entered into with you. (*)
• Administering any agreement you have entered into with another party on our platform (*)
• Administering our payment processing services, including the receipt of payments from Customers and the making of payments to Promoters or other Users (*, ⁂)
• To contact you about any events or other offers you have expressed an interest in (⁂)
• To contact you about any events, offers or services which we feel may be of interest to you, including where we use information we obtain through you accessing Fatsoma through a social media account (⁂)
• To contact you in the event of an issue with your use of our site (*, ⁂)
• Dealing with any complaints you may have (*, ⁂)
• Business management and planning, including accounting and auditing. (⁑, ⁂)
• Conducting performance reviews, managing performance and determining performance requirements. (⁂)
• Complying with health and safety obligations. (⁑, ⁂)
• Complying with our tax obligations (⁑, ⁂)
• To detect and prevent fraud, money-laundering and other crimes. (⁑)
• To monitor your use of our systems to ensure compliance with our IT policies. (⁂)
• To ensure our systems interact successfully with social media platforms including Facebook, Twitter and Instagram (⁂)
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. (⁂)
• To conduct data analytics studies to review and better understand users use of your website and services (⁂)
• To review and improve the performance of our website, systems, processes and staff. (⁂)
• To interact and respond to any communications you send us, including social media posts that you tag us in. (⁂)
• To let you know about any important changes to our business or policies. (⁂)
• To protect your interests, or the interests of others (such as in the event of criminality such as identity theft, piracy or fraud). (⁑, ⁂)

Providing our services

It is necessary for us to use personal information about you to enter into and perform the contracts that we make with you, such as when you are purchasing a ticket using our website with us, you establish yourself as a Promoter on our site or you create your own website using our services. Using your information in this context is necessary so that we can:

• provide you with information about your event/an event you are attending and any other of our services
• verify your identity
• deal with any complaints you may have
• contact you about any changes to your event/an event you are attending or that we make to our products or services
• administer our website, including troubleshooting problems, analysing statistics, conducting research and tests and keeping the site secure
• where you are a Promoter or otherwise advertising an event:
  • provide you with information on the attendees at your event
  • ensure you receive payments owed to you in relation to an event
  • contacting you to bill and collect any money owed to us
  • syncing your social media account or page with your Fatsoma account
  • to inform you of other services we offer

Where you create your account, or you obtain from us any other service that we offer free of charge, it is necessary for us to use your personal information and we have a legitimate interest in providing these services to you. Using your information is necessary so that we can:

• provide you with information about our products and services, including the forthcoming events that may be of interest based on the brands which you follow; and
• provide you with other news and information from Fatsoma.

We may use automated decision-making and profiling to tailor the information we provide to you to your specific circumstances. For example, when you create an account you may or may not receive certain communications from us based on the preferences you select when you complete your account details on our website.

Telling you about other products or services that we think may be of interest to you

We may use your information to identify and tell you about our products or services that we think may be of interest to you.

We may also use your information to invite you to participate in market-research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to receive market-research communications, we will respect this.

Whether you choose to receive marketing communications, or market-research communications is entirely up to you. You can choose to receive both, none, or just one or the other. Your choice will not affect any products or services that you have purchased from us, nor will it affect any quotes for products or services you buy in future.

You can update your preferences by using the links in any of our emails to you, or by getting in touch with us.

Making our business better

We always want to offer the best products, services and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it.

In this context, we will only use your information where it is necessary so that we can:

• review and improve our existing products and services and develop new ones;
• review and improve the performance of our systems, processes and staff (including training);
• improve our site to ensure that content is presented in the most effective manner for you and for your computer; and
• measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

Contacting you

We want to stay in touch with you! Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes.

We will only use your information in this respect where it is necessary so that we can:

• interact and respond to any communications you send us, including where you use our contact us form and any social media posts that you tag us in
• let you know about any important changes to our business or policies

Verifying your identity

We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.

Protecting you and others from harm

We may use your information where it is necessary to protect your interests, or the interests of others. This may include in the event of criminality such as identity theft, piracy or fraud.

Synchronising Fatsoma with social media platforms (Fatsoma acting as a Data Processor)

Where we are acting as a Data Processor on behalf of you as a Promoter, and you add a database of contact information or sync your social media account/page to our system, we have and may access the data on this database and the data on users who “like” or “follow” your social media account/page. These “likes” or “follows” will be used to suggest to those Users who have a Fatsoma account that they may wish to follow your Fatsoma page.

If a User chooses to use the social share link in an email campaign or push notification they receive, this will allow the User to share your email content (as a Promoter) with individuals whose data is not within your database or who do not currently “like” or “follow” your social media account/page or Fatsoma page. If the recipient of this content consequently purchases a ticket to your event, or chooses to “like” or “follow” your social media account they will be added to your database and will consequently be contacted by Fatsoma to like your Fatsoma page (should that individual have a Fatsoma account).

3. Who do we share your personal information with?

Sharing your information within our company

We share the information that you provide to us with our staff so that we can provide our products and services to you.

Sharing your information with third parties

When a Customer requests to follow a Promoter on our website, we share your data with that Promoter in order for them to provide you details of events and offers that you may be interested in. When you choose to follow a Promoter that Promoter will be a Data Controller as defined under the General Data Protection Regulation and the Data Protection Act [1998/2018].

Promoters are allowed to use our system to contact Customers of their current and past events, so you may receive emails from our system that originate from such Promoters that we send on their behalf. If a Customer registered for an event using our platform, their email address is available to the Promoter of that event.

Promoters may also import contact information they have from external sources and send communications through our platform to those individuals, we and will deliver those communications to those individuals on the Promoter’s behalf. The Promoter and not Fatsoma is responsible for sending these communications. The Customer has the right to opt out of such communications at any time, as is set out below.

Promoters may also partner with other Promoters on the Fatsoma platform to Co-Promote events whereby they recommend similar events by other Promoters to their Customers.

In addition to the above, there are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

• required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;
• necessary to protect the safety of our employees, our property or the public;
• necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; and
• proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.
• Sometimes, we share your information with our third-party providers, who help us provide and support our Services. Examples of third-party providers include payment processors, email marketing platforms, hosting services and content delivery services. Please click here for our up to date list of third party processors. We have contracts with each of these providers that specify that they will only use your data for the purposes of performing the services we have contracted them for. Anonymised data is also used for the purposes of website and app analytics.

4. IP Addresses, Cookies, Pixels Tags and Web Storage

We may collect information about your computer, including where available your IP address, operating system, browser type, statistics on your activities on our platform, information on how you came to our platform and data collected through Cookies, Pixel Tags, Web Storage and other similar technologies.. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. The information we collect includes which pages you view and which links you follow, details of the hardware and software that you are using to access the site and any passwords that you use on our website. This enables us to:

• estimate our audience size and usage pattern.
• store information about your preferences, and so allow us to customise our site according to your individual interests.
• speed up your searches.
• recognise you when you return to our site.
• re-marketing our services

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Our website is not intended for children and we do not knowingly collect data relating to children.

5. Where we store your Personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. Fatsoma will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, our terms of use and the applicable data protection legislation

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted (using SSL technology). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

In addition, where you are a Promoter and import your database of personal information into our system, your database is stored on our secure servers. We do not, under any circumstances, sell or give access to your database. If an individual whose information is on your database complains or contacts us, we might then contact that person. Only authorised employees of Fatsoma have access to view this Personal Data. Please note that you may export (download) your database from us at any time.

Please note, if we detect abusive or illegal behaviour related to your database, we may share your database or portions of it with affected ISPs or anti-spam organisations.

6. Notice of Security Breach where Fatsoma is a Data Processor

Where a security breach causes an unauthorised instruction into our system that materially affects data which Fatsoma holds in its role as a Data Processor for a Promoter (see below), then Fatsoma will notify the Promoter as soon as possible and later report the action we took in response. Under the terms of the GDPR and any and all domestic legislation incorporating the Regulation into English law, we will also inform the ICO within 72 hours of any breach.

7. Disclosure of your information

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
• If Fatsoma or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Fatsoma, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8. Updating your details

All personal information entered into Fatsoma can be edited and changed by you at any time. Alterations can be made in the settings area.

9. Your rights

You have the right to cancel your membership

You have the right to cancel your membership at any time. This can be done by contacting support@fatsoma.com.

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch with us.

You have the right to access your Personal Data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

• why we have been using your information;
• what categories of information we were using;
• who we have shared the information with; and
• how long we envisage holding your information

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.

You have the right to correct any inaccurate or incomplete Personal Data

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can update your information by contacting support@fatsoma.com so that we can correct our records.

Where your Personal Data is imported into our server by a Promoter, you may also wish to contact that Promoter in order for them to correct any inaccuracies in their records.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

• the information is no longer needed for the original purpose that we collected it for
• you withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
• you object to us using your information and we have no overriding reason to keep using it
• we have used your information unlawfully
• we are subject to a legal requirement to delete your information

In those situations you have the right to have your Personal Data deleted. If you believe one of these situations applies to you, please get in touch with us. Where you submit a request for us to delete your Personal Data, we will remove your data from our systems within a reasonable time.

In addition, where a Promoter is the Data Controller in relation to Personal Data which you wish for us to delete from our systems, we will also notify the Promoter of your request. Where this applies, you may also request the deletion of your Personal Data by contacting the Promoter.

You have the right to have a copy of your data transferred to you or a third party in a compatible format

Also known as Data Portability, you have the right to obtain a copy of your Personal Data for your own purposes. This right allows you to move, copy or transfer your Personal Data more easily from one IT system to another, in a safe and secure way.

This right shall only apply where:

• we are processing your information for the purposes of entering into or performing a contract; or
• you have provided consent for us to process your information.

If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. Each communication you receive from us will contain a link for you to unsubscribe to future communications if you would not like to receive any direct marketing from us or a Promoter. In addition, you may change your marketing preferences at any time by logging into your account and updating your settings.

Where you have signed up for a Fatsoma account, or connect your Fatsoma account, with another social media account whose features include social notifications, you will receive these social notifications. You can manage these social notifications by amending your settings for these accounts, or by disabling the integration between these accounts.

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:

• when we tell you about products or services that are similar to ones that you have already bought;
• when we use you information to help us make our business better; and
• when we contact you to interact, communicate or let you know about changes we are making.

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your Personal Data for these purposes.

In order to exercise your right to object to our use of your data for the purposes above, you can click the “unsubscribe” link which is set out in each of our communications to you, which will enable you to unsubscribe to communications. Alternatively, you can update your preferences in relation to direct marketing within your Fatsoma account, or on the Fatsoma account.

You have the right to restrict how we use your Personal Data

You have the right to ask us to stop using your Personal Data in any way other than simply keeping a copy of it. This right is available where:

• you have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this;
• you have objected to us using your information for our own legitimate interests and we are in the process of considering your objection;
• we have used your information in an unlawful way, but you do not want us to delete your data; or
• we no longer need to use the information, but you need it for a legal claim.

If you believe any of these situations apply, please contact us at support@fatsoma.com.

You have rights related to automated-decision making and profiling

Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us at support@fatsoma.com.

10. Changes to this Privacy Policy

If we change our Privacy Policy we will post the changes on this page, and may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. We will also contact you to inform you that changes have been made to this policy. Regularly reviewing this page will ensure that you are always aware of what information we collect and how we use it. Continued use of the service will signify that you agree to any such changes.

11. Contacting Fatsoma and making a complaint

We welcome your views about our website and our Privacy Policy. If you would like to contact us with any queries or comments, or to complain about our collection or use of your Personal Data, please contact support@fatsoma.com.

In addition you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website if you wish to lodge a complaint with the ICO.