Privacy Policy

Wasserman is committed to ensuring that your privacy and personal data are protected. This Privacy Policy, together with our terms of use, set out how Wasserman EMEA LLP, trading as Wasserman Hospitality Sales use and protect any personal data that you give us, including when you visit our website, purchase a product, register as a Wasserman client, or join a live event.
 
By visiting this website, you are accepting and consenting to the practices described in this privacy policy. You can withdraw consent at any time by writing to us at [email protected]. Wasserman may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
 
WHO WE ARE

Wasserman Group (“Wasserman Group”) comprising of Wasserman EMEA LLP, trading as Wasserman Hospitality Sales and Wasserman Media Group LLC, the parent company and its directly and indirectly controlled affiliated companies. Wasserman Media Group LLC is a Delaware limited liability company in the United States of America.
 
This Privacy Policy is issued on behalf of Wasserman Group (“Wasserman“, “we“, “us” or “our”). 
 
DATA CONTROLLERS

Wasserman EMEA LLP, trading as Wasserman Hospitality Sales an English company (number OC368517) with its registered office at 10a Greencoat Place, London, United Kingdom, SW1P 1PH, United Kingdom. 

Wasserman Media Group, LLC, trading as Wasserman Hospitality Sales US is a Delaware limited liability company with its registered office at 10900 Wilshire Blvd., Ste. 1200, Los Angeles, CA 90024, United States. 

1.) About Our Privacy Policy

Our Privacy Policy:
– sets out how Wasserman uses and protects any personal data that you give us;
– describes our collection, use, disclosure, retention and protection of your personal information;
– sets out how we look after your personal data when you visit any website, application or service which references it;
– covers any electronic form of communication (such as email) or any other form of correspondence or platform linking to this Privacy Policy;
– covers any of our applications or services that do not have a separate privacy policy for which we are responsible for controlling or processing personal data; and
– will tell you about your privacy rights and how the law protects you.
 
It is important that you read this Privacy Policy together with any other specific privacy policy or fair processing policy we may provide on specific occasions, (such as your becoming a customer), when we will collect or process personal data about you. This is so that you are fully aware of how and why we are using your data.
 
We have appointed a data privacy champion, Luke Robinson who is responsible for overseeing questions in relation to Our Privacy Policy.
 
Data Protection Legislation

Our Privacy Policy complies with the data protection and privacy laws and regulations in any relevant jurisdiction from time-to-time that are applicable including, without limitation, the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq., as amended, including its implementing regulations and the California Privacy Rights Act of 2020 (“CCPA”), the General Data Protection Regulation (EU 2016/679) (“EU GDPR”) as well as the retained EU law version of the EU GDPR (the “UK GDPR”), and the Data Protection Act 2018 (together the “Data Protection Legislation”) as at the above date of Our Privacy Policy.
 
Where you provide us with your personal information in any of the ways described below, you agree that we may collect, store and use it:
a) in order to perform our contractual obligations to you;
b) based on our legitimate interests for processing your data (such as for internal administrative purposes, data analytics and benchmarking, direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or
c) based on your consent, which you may withdraw at any time, as described in Our Privacy Policy.

2.) The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. (Can also include Sensitive Data relating to confidential, private and medical details).

Demographic Data includes preferences and interests.

Contact Data includes name as well as billing address, delivery address, email address and telephone numbers.

Financial Data includes job titles, place of work, bank account and payment card details, correspondence and similar data that might identify a person.

Content Data includes information stored on your Device, including login information, photos, videos or other digital content, check-ins.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, (namely Device Data below).

Device Data includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

Profile Data includes your interests, preferences, feedback and survey responses.

Usage Data includes details of your use of any of our applications or your visits to our website including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. Also includes Cookie Data (see our Cookie Policy)

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences or other information relevant to customer surveys or offers.

Special Category Data including dietary requirements. 
 
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from sanction lists, credit agencies, search information providers or public sources (e.g. for customer due diligence purposes) but in each case as permitted by applicable laws.
 
We may monitor and record our communications with you.
 
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with Our Privacy Policy.
  
Providing us with information about others

If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.

If you fail to provide personal data

Where we need to collect personal data by applicable law, or under the terms of an agreement we may have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to our website, applications or services or extend credit to you). In this case, we may have to terminate any licence you have with us but we will provide you with prior written notice should this be the case at the time.

3.) How is your personal data collected?

We use different methods to collect data from and about you including through:

Information you give us. 

This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms (by paper or electronically on our apps or website), or by corresponding with us (for example, by post, phone, email, chat or otherwise). It includes information you provide when you register to use our website, download or register an application, apply for our products or services (or those of our clients/third parties), when you enter or apply for tickets or hospitality packages for  an event, subscribe to any of our services, search for an application or service, share data via an application’s functions, enter a competition, promotion or survey, or and when you report a problem with our services, our website or give us some other feedback. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. 

Each time you visit our website or use one of our applications or services we will automatically collect personal data including Technical, Device, Content and Usage Data. We collect this data using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Information we receive from other sources including third parties and publicly available sources. 

We may receive personal data about you from various third parties and public sources such as analytics providers like Google, advertising networks, credit agencies or search information providers as set out below:
– Device Data from the following parties: (a) analytics providers; (b) search information providers;
– Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
– Identity and Contact Data from data brokers or aggregators;
– Identity and Contract Data from legitimate third parties that, to the best of our knowledge, are permitted to sell us marketing lists; 
– Identity and Contact Data from publicly available sources such as government and corporate websites. 

4.) How we use your personal data

We use your personal data when the law allows us to do so. Most commonly we will use your personal data to better understand your needs and provide you with a better service, and in particular for the following reasons:
– where we need to perform a contract we have with you or are about to enter into with you (including ensuring that a particular order and/or sale is fulfilled).
– dealing with your enquiries and requests. 
– where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
– carrying out market research campaigns.
– where we need to comply with a legal or regulatory obligation.
– to improve our services and to customize our services, website or app according to your interest.
– to provide research and insights services for ourselves or to our clients, including feedback on live events, responses to marketing strategies, the public’s interest in activities.
– to send you promotional materials or newsletters about us or our clients (where you have opted in to such communications).
– where you have consented before the processing.
 
We may share your information with selected third parties, including: clients, business partners, event partners and venues, suppliers and sub-contractors for the performance of any contract we enter into with them or you. We will get your express opt-in consent before we share your personal data with any company outside the Wasserman Group for marketing purposes.
 
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email, SMS, or text message. You have the right to withdraw consent to marketing at any time by contacting us using any preference centres we give you access to or by sending us an email to [email protected].
 
Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
 
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which applications or services and offers may be relevant for you for marketing by us or by Wasserman Group companies. You may receive marketing communications from us if you have requested information from us or engaged with us for services and you have not opted out of receiving that marketing.
 
We may also share your information with our contracted third parties with whom we have data processing terms to carry out services for us on a subcontracted basis. We or they may wish to contact you for this purpose by telephone, post, SMS or email.
 
You have the right to withdraw that consent at any time by contacting us using any preference centers we give you access to or by sending us an email to [email protected]. You can also unsubscribe from any email marketing using the links provided in the emails Wasserman Group may send to you.
 
Cookies, Analytics and Traffic Data

For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.
 
Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
 
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.) Disclosures of your personal data

For the purposes set out in Our Privacy Policy we may share your information with the parties set out below for the purposes set out above:
– Internal third parties such as any company within the Wasserman Group;
– External third parties such as our service providers and agents (including their sub-contractors) or third parties which process information on our behalf so that they may help us to provide you with the services and information you have requested or which we believe is of interest to you;
– External third parties to comply with our regulatory or legal obligations such as auditors, professional advisors, government departments, regulators, law enforcement agencies so that they may detect or prevent crime or prosecute offenders, any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order)
– Specific third parties where you have a relationship with that third party, and you have consented to us sending information;
– External third parties for marketing purposes where you have consented or where there is a legitimate business interest;
– Specific third parties such as another organization to whom we may choose to sell, transfer or merge parts of our business or our assets. (If a change happens to our business, then the new owners may use your personal data in the same way as set out in Our Privacy Policy); and
– Specific third party being another organization to whom we may transfer our agreement with you.
 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6.) International Transfers

We ensure your personal data is protected by requiring all our Wasserman Group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Whenever we transfer your personal data out of the UK, we only transfer your personal data to a country outside the UK where:
– Any transfer within the Wasserman Group is protected by intra-group Data Transfer Agreements;
– The UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. 
– There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
– A specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy. 

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to Our Privacy Policy and your duty to inform us of changes” below.

By using our website, applications or services or by interacting with us in the ways described in Our Privacy Policy, you consent to the transfer of your information outside the EU, Switzerland or UK where needed for the purposes set out in Our Privacy Policy. Please contact us if you want further information on the above at all.

EU nationals or from another jurisdiction
If you are based within the EU, Switzerland or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
– the right to be told how we use your information and obtain access to your information;
– the right to have your information rectified or erased or place restrictions on processing your information;
– the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
– the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
– where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
– the right to object to any decisions based on the automated processing of your personal data, including profiling; and
– the right to lodge a complaint with the supervisory authority responsible for data protection matters in your country.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to our ability to verify your request and certain other limitations:
– Information about You: You may ask for us to state what categories of personal information about you we have, and the categories of sources from which we collect your personal information;
– Receive a Copy of Your Data: You may request the categories and specific pieces of information (if any) we have about you, the categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties with which we have shared personal information in the previous 12 months.
– Delete Your Data: You may request that we delete the personal information we have collected from you.
– Do-Not-Sell: You may opt out of our sale(s) of your personal information, as “sale” is defined by CCPA. Please see above for more information. 
– Non-Discrimination: California law prohibits discrimination against you for exercising your privacy rights. 

Note: Where certain technologies rely on your data to provide the Services, the absence of that data may impact the operation of the Services. 

How to Exercise Your Rights. To exercise any of the above rights, please follow the instructions below.

If you have any other request you wish to submit to the privacy team, you may submit a general information request via [email protected].

7.) Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our applications, website or services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
 
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.
 
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
We will do our best to protect your personal information, but we cannot guarantee the security of your information which is transmitted to our website via an internet or similar connection.

8.) Data retention

How long will you use my personal data for?
 
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
 
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
 
By law we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for tax purposes.
 
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.) Your legal rights

Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data, for example, you may be able to:
– request access to your personal data.
– request correction of your personal data.
– request erasure of your personal data.
– object to processing of your personal data.
– request restriction of processing your personal data.
– request transfer of your personal data.
– withdraw consent to processing of your data.

If you wish to exercise any of the rights set out above, please contact us at [email protected]. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Children

We do not knowingly collect information from children who are under 13 years old. If you are a parent or guardian of a child who is 13-18 years old and using our Services, please send us an information request to opt in or request deletion of any personal information we may have collected about the child. If you are a parent or guardian of a child who is under 13 years old and using our Services, please contact us to arrange for deletion of any personal information we may have collected about the child.

Opting Out of The Sale of Your Personal Information

WE DO NOT SELL YOUR PERSONAL INFORMATION FOR MONEY.

However, sometimes we share your data with sponsors, vendors, and third party advertising networks. These transfers, which are used to provide you with certain services and/or to more effectively provide you with personalized services (including advertising), can be deemed a sale under some data privacy laws.

You may opt out of the sale of your personal information by emailing via [email protected]. You will be asked to provide certain information to us in order to exercise this option so we can verify your identity and locate your records with us.

Please note that your decision to opt out of the sale of your personal information may impact the availability and quality of some of the services provided to you. 

All requests must be verified. Some requests, including receiving a copy of your data or requests made by an agent claiming to be acting on your behalf, are subject to heightened requirements. If we cannot verify your identity based on the information provided, a request for a copy of your data shall be treated as a request for information and if we cannot verify your identity, a request to delete personal information may be treated as a request to opt-out of the sale of personal information.

You may designate an authorized agent to make a request on your behalf. An Authorized Agent must have written documentation of their authority to act on your behalf, such as a Power of Attorney.

10.) Glossary
 
Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
 
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
 
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
 
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties means other companies in the Wasserman Group acting as processors and who are based throughout the world and provide IT and system administration services and undertake leadership reporting.

External Third Parties means 
a) Service providers acting as processors based throughout the world who provide IT and system administration services,
b) Hosting providers acting as processors based throughout the world who provide IT and system administration services, 
c) Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers based throughout the world who provide consultancy, banking, legal, insurance and accounting services, and
d) Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
 
Your Legal Rights

You have the right to:

– Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

– Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

– Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

– Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. If you object, this may affect our ability to provide certain services and/or solutions for your benefit. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

– Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
a) if you want us to establish the data’s accuracy;
b) where our use of the data is unlawful but you do not want us to erase it;
c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

– Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

– Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11.) General

Links to other websites

Our website or app may contain links to other websites of interest. However, once you have used these links to leave our site or app, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Changes to Our Privacy Policy and your duty to inform us of changes

Our Privacy Policy is regularly reviewed and updated. This version was last updated on the date noted below.
 
If you would like to withdraw consent, or if you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Further Information and Our Contact Details

If you have any queries about how we treat your information, the contents of Our Privacy Policy, your rights, how to update your records or how to obtain a copy of the information that we hold about you, please contact our Data Privacy Champion using the details set out below.

Full name: Luke Robinson
 
Email address:    [email protected]
 
Postal address:    10a Greencoat Place, London, United Kingdom, SW1P 1PH 
 
ICO

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
 
Wasserman Group, trading as Wasserman Hospitality Sales 
 
September 2024