GDPR transparency notice for TX.IS


TX Corporation Limited, trading as TX.IS, (we) are registered in England and Wales under company number 07735542 and have our registered office at 34b York Way London N1 9AB.


1  What is the purpose of this document?


1.1  We are committed to protecting and respecting your privacy. This transparency notice sets out the basis on which any personal data we collect about all users of our app (you), or that you provide to us through our app, will be processed by us.


1.2  We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.


1.3  This policy (together with our end-user licence agreement as set out at https://tx.is/terms/end-user (EULA) and any additional terms of use incorporated by reference into the EULA, together our (Terms of Use) applies to your use of:


1.3.1  TX.IS is a mobile application software (app) available on Google Play and Apple App Store via our site at https://tx.is (app site), once you have downloaded or streamed a copy of the app onto your android or iOS mobile telephone or handheld device (device).


1.3.2  Any of the services accessible through the app (services) that are available on the app site or other sites of ours (services sites), unless the EULA states that a separate transparency notice applies to a particular service, in which case that transparency notice only applies.


1.4  You may adjust the privacy settings on the app at any time to control and restrict visibility of your information at your discretion.


1.5  TX Corporation sells tickets on behalf of its clients (event organisers). This transparency notice sets out how we share your information with event organisers but it also applies to visitors of our services sites who do not download or stream our app and do not register or do not purchase tickets.


1.6  This transparency notice should be read in conjunction with our Cookies policy.



2  Information we may collect from 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).


There are special categories of more sensitive personal data which require a higher level of protection (see section 3).


2.1  We may collect and process the following information about you:


Information you give us (submitted information)


2.2  You may give us information by registering with us or providing information via the app site and the services sites (together our sites), or by corresponding with us by phone, e-mail or otherwise.


2.3  The information you give us may include:


2.3.1  your name, address, e-mail address and phone number;


2.3.2  information you provide when you register to use the app site, download or register the app, subscribe to any of our services, buy, sell or transfer tickets via the app, share data via an app's social media functions and enter a competition, promotion or survey;


2.3.3  your photograph (optional);


2.3.4  information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, and check ins, (Content Information);


2.3.5  all information you upload to your ticket wall; and


2.3.6  when you report a problem with the app, our services or any of our sites. If you contact us, we will keep a record of that correspondence.


2.4  If you buy or sell tickets via the app, payment is managed by one of our payment providers so we do not hold billing information such as credit card details but we may receive a token that references the payment transaction / details.


Information we collect about you and your device


2.5  Each time you visit one of our sites or use our app we will collect the following information:


2.5.1  we may collect information about your preferences and the types of events you are interested in;


2.5.2  technical information, including 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 your time zone setting (Device Information);


2.5.3  information stored on your Device, including the Content Information listed at 2.3.4; and


2.5.4  details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information)].


Location Information


2.5.5  We also use GPS, wifi and Beacon technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work.


2.5.6  If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting help@tx.is.


Information we receive from other sources


2.6  We may receive information about you from third parties as follows:


2.6.1  we collect information from our sister company Tixtu about your ticket purchase information;


2.6.2  we collect information for event organisers, promoters or other agencies from whom you purchase tickets and who have agreed to share ticket information with TX.IS;


2.6.3  from sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies;


2.6.4  from social media or other service providers we use. This would apply where, for example, you post on our Facebook page or interact with us using one or our apps; and


2.6.5  we may also collect information from access control providers at venues where the access control provider confirms that a TX.IS ticket has been used to enter the relevant venue.


Unique application numbers


2.7  When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.



3  Particularly sensitive personal information


3.1  If you register for our verification service we may also collect, store and use the following special categories of more sensitive personal information:


3.1.1  information about your race or ethnicity (when showing your passport to access control providers to verify your identity).


4  What are the legal bases for us to use your personal information?


4.1  We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:


4.1.1  where it is necessary to perform the contract we have entered into with you;


4.1.2  where we need to comply with a legal obligation;


4.1.3  with your consent;


4.1.4  where it is necessary for our legitimate interests, or those of a third party, to ensure the smooth running of our or their business. We are allowed to do this as long as our or their activities do not disproportionately intrude your privacy; and/or


4.1.5  where we need to protect your interests or someone else's interests.


4.2  Some of the above grounds for processing your personal information will overlap, and there may be several grounds which justify our use of this information.



5  How we use your information


5.1  We will use your information primarily to perform our contract with you. To do this, we will process your personal information in the following situations:


5.1.1  to provide you with our services;


5.1.2  to enable you to transfer or re-sell tickets to other users (subject to TX or promoter restrictions);


5.1.3  to enable you to access the app's social media functions, for example to help you find friends;


5.1.4  if we have your permission, to provide you with information about other events, products and services which we think may be of interest to you;


5.1.5  to improve the services we offer to you and others, for example, where you provide us with feedback;


5.1.6  for legal reasons such as fraud prevention and to check that you are complying with our terms and conditions and to enforce our legal rights;


5.1.7  to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and


5.1.8  to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.



6  Sharing your information


6.1  We may share your information with third parties as follows:


6.1.1  When you buy, sell or transfer tickets we will need to tell the event organiser. We will, in particular, need to tell them that you have purchased tickets for their event, the number of tickets purchased and any other information which might be relevant;


6.1.2  We may also need to share your information with others who provide services in connection with events. For example, we may need to give your name and booking details to the access control provider at an event for the purposes of validating the ticket before entry.


6.1.3  The event organiser may also use the information we give them to tell you about products and services which may be of interest to you. You should check the event organiser's own privacy policy for more information.


6.1.4  Where we have your permission, we may share information about your interests and preferences with other event organisers. For example, if you book an event with one event organiser we may tell another event organiser about that booking so that they can tell you about their own events which may interest you.


6.1.5  We share information with our sister company Tixtu. To read more about how Tixtu uses your personal information please see the Tixtu transparency notice at https://www.tixtu.com/about/privacy-policy.


6.1.6  We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.


6.1.7  If we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.


6.1.8  If we have a legal obligation to do so or for the purposes of fraud protection and credit risk reduction.


6.1.9  We may share your data with third-party service providers (including contractors and designated agents), and other businesses that provide certain services on our behalf. The following activities are carried out by third-party service providers: IT support, mailing services, user authentication and mobile device notification services.


6.1.10  We use Google Analytics, Firebase Crashlytics and Firebase Performance Monitoring to collect crash data and performance data from your app, and then review and analyse that data in the Firebase console in order to improve our service to you.


6.1.11  All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.


6.1.12  If you object to our sharing or continuing to use your personal information with any specific third party please contact us at help@tx.is.



7  Your duty to inform us of changes


7.1  It is important that the personal information we hold about you is accurate and current. Please keep us informed if any of your personal information changes during your relationship with us by updating your information via preferences on the app.



8  Change of purpose


8.1  We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


8.2  Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.



9  Automated decision-making


9.1  You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have first notified you.



10  Where will we store your personal information?


10.1  Any personal information that you submit to us will be held on secure servers, based within the European Economic Area (EEA).


Transferring information outside the EEA


10.2  We use Google Analytics, Firebase Crashlytics and Firebase Performance Monitoring to evaluate the performance of our app and improve the service we offer you. We may transfer information about you outside the EEA for this purpose. We will only do so where necessary and as permitted by law.


10.3  Google and its wholly-owned subsidiaries (including Google Analytics, Firebase Crashlytics and Firebase Performance Monitoring) has certified that it complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European member countries and subject to enforcement by the Federal Trade Commission. For more information about this protective measure, please visit the following: https://www.google.de/intl/en/policies/privacy/frameworks/.



11  Data security


11.1  We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.



12  How long will we use your personal information for?


12.1  We will keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


12.2  For all users, we will keep your personal information in our database for as long as you are an active member of TX.IS, unless you tell us otherwise plus up to 12 months for our internal processes to securely review and delete inactive records.


12.3  We will retain anonymised transaction data relating to ticket purchases for auditing purposes to determine how many tickets were sold for any particular event.


12.4  Please note that if you request for your personal information to be deleted then we will no longer be able to provide our services to you, and you will no longer be able to access any tickets for future events.



13  Your rights in relation to our processing of your personal information


13.1  You have the right to be informed about what we are doing with your personal information. We do this by providing you with this Transparency Notice. If we change what we are doing we will provide you with an updated version of this notice.


13.2  You have the right to object to the processing of your personal information.


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


13.4  If the personal information we hold about you is incorrect or out of date you can ask us to correct it.


13.5  You have the right to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you ask us to delete your personal information we will not be able to provide our services to you.


13.6  You have the right to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position, or if our processing is unlawful but you do not want us to erase your personal information, or for some other limited circumstances. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. If you ask us to restrict our use of your personal information, we may not be able to provide you with our services.


13.7  You can also ask us to send another organisation information that you have provided to us in a format that can be read by computer.


13.8  Where we rely on consent to process your personal information you have the right to withdraw that consent.


13.9  If you want to exercise any of your rights please contact help@tx.is.


13.10  We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).



14  Changes to this transparency notice


14.1  We reserve the right to update this transparency notice at any time, and we will provide you with a new transparency notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.


14.2  If you have any questions about this transparency notice, please contact help@tx.is.



15  Complaints procedure


15.1  If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office: ico.org.uk.



16  Cookie policy


16.1  Our app and service sites uses cookies to distinguish you from other users of the app, app site, app store or services sites. This helps us to provide you with a good experience when you use the app or browse any of the sites and also allows us to improve the app and our sites. By continuing to use the app and browse the sites, you are agreeing to our use of cookies.


Information about our use of cookies


16.2  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.


16.3  You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.


16.4  Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.


16.5  We use the following cookies:


16.5.1  to manage your login to the app; and


16.5.2  to optionally remember your username.


Google Analytics:


16.6  We also use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate visitors' use of our site.


16.7  Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using the our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.


16.8  For more information on Google Analytics please go to https://www.google.com/analytics/analytics/