1 General
1.1 In this Privacy Policy agreement, we explain how we, Localoca Ab (future ‘Localoca’ or ‘We’), treat the personal data of our customers.
1.2 The Privacy Policy includes the use of the Localoca website localoca.io (future "Home Page") and the Localoca application (future "App"). For future reference, all services Localoca offer are collectively called "Service".
1.3 Localoca acts as an intermediary between sellers, or authorised representatives to the seller (future ‘Merchant’), who sell or market tickets to events and similar products (future ‘Product’), and buyers using the Service to browse, reserve, and purchase the Merchant’s Products (future ‘Buyer’).
1.4 This Privacy Policy agreement states the personal data processed by Localoca and what obligations and rights Localoca, Merchants, Buyers and subcontractors have in regards to the processing and storing of personal data.
1.5 In all processing of personal data, Localoca complies with the general EU Data Protection Regulation, the Finnish Law on Data Protection and other Finnish applicable legislation. The laws can be reached here: Data Protection Regulation (EU 2016/679) https://eur-lex.europa.eu/eli/reg/2016/679/oj, Data Protection Act (2018/1050) https://www.finlex.fi/fi/laki/ajantasa/2018/20181050
1.6
2 Data Controller
2.1 The Data Controller is Localoca Inc. (Business ID 2978106-6).
Localoca Inc.'s address is Tykistökatu 4b, 20520 Turku, c/o Sparkup.
Email: support@localoca.io
For personal data related questions please contact privacypolicy@localoca.io
3 What personal data does Localoca collect from people using the Service?
3.1 The personal data collected by Localoca can be divided into two groups:
1. Information and data submitted by the user to Localoca when using the Service, and
2. Other information
3.2 To the first group, that is "1. Information and data submitted by the user to Localoca when using the Service", include the following personal data
- Identification information such as name, age, sex and place of study
- Contact details such as e-mail, telephone number and address
- Login credentials, user name and encrypted password
- Encrypted payment details needed to make a purchase
o Payment data is never stored by Localoca. These are always stored and processed by licenced payment service providers.
- Information provided in application forms, such as diet, other participants’ names, comments and similar information
- Geographical position
- Purchase history and preferences
- Customer service contact, rating and conversations
- Product and Merchant ratings
- Any other information collected with the consent of the user, such as responses to competitions or questionnaires
3.3 To second group "2. Other information" include the following data
- IP address and cookies
- Sign-in information through the third-party services Facebook, Google and Apple
- Information regarding Product delivery, Product status, forwarding information, time, activation location, and validation time
- Statistics and data related to the Purchaser's use of the Service, such as number of clicks
- Browser or appliance type and ID, operating system and software version
3.4 Localoca can interconnect information from both groups to impersonate and enhance the user experience.
3.5 Localoca, as an intermediary in the transactions, acts as a processor on behalf of the Merchant. For the service to function, it is important that both Localoca and the Merchant have access to personal data. Merchants only have access to information essential for the purchase, execution and delivery of the Product, and statistics.
4 When does Localoca collect information about the user?
4.1 We collect information about the user when he or she visits, uses, registers, buys, subscribes to news, fills in forms, or writes information or other text onto our Service. We can also receive personal data from third parties and subcontractors, such as when logged on via third party services (Facebook, Google and Apple).
5 How do Localoca and the Merchant use the user's information?
5.1 Localoca can use the user’s personal data as following:
- For purchase, delivery and refund of Products and for validation
- To register and create a Localoca user account
- To protect against abuse and ensure the use and functionality of the user’s Localoca user account
- In order to verify that the purchaser belongs to a specific school, workplace or similar group, so that the Buyer can access exclusive groups and benefits
- To develop the functionality of the Service and improve the experience for the user
- In order to manage and execute the user’s purchase safe and quick
- To impersonate the Buyer's experience and to deliver relevant content to him or her
- For targeted marketing
- To arrange a competition, campaign, survey, or other function in the Service
5.2 The Marchant can use the Buyer’s information as follows:
- For the delivery, execution, presentation and validation of the Product
- To keep record of participants attending their events, for example at check-in
- To contact the Buyer regarding information about a Product
- To keep statistics
- In order to have access to other essential information necessary for the delivery, execution, refund and presentation of the Product purchased by the Buyer, and of the relevant documents
6 How do we protect the user’s data?
6.1 The user’s personal data is confidential, and anyone in Localoca who handles such information is bound by professional secrecy.
6.2 Merchants who have access to personal data are subject to the same conditions and have access only to the information set out in point 5.2.
6.3 Personal data is protected by secure and encrypted connections such as SSL and HTTPS and anonymity. In addition, firewalls and password protection are used.
6.4 Regular scans are performed on the Service to detect and correct suspicious activity.
6.5 Any breach of confidentiality is notified without delay to the relevant authorities and contracting parties.
7 Cookies
7.1 Cookies is a text file stored in the user's browser when visiting a web page. Cookies are used to identify past users and visitors, for impersonation, for security, and for analysis.
7.1.1 There are various types of cookies, for example, those required for the functionality of the web page, such as not having to sign in every time you update the page, and third-party cookies that a web page places on behalf of another company.
7.2 Localoca, like most other services and web pages, use cookies or similar storage technologies in the Service. We request permission for the use of cookies on the visitor always at the first visit, before the use of our Service is possible. The agreement applies to each browser separately. If the cookies are deleted from the visitor's browser, the Service again asks for permission the next time the visitor visits the Service.
7.3 The information we collect is used for functionality and to improve the Service, to direct relevant content and marketing, and to understand and save the user's settings for future visits.
7.3.1 For example, we use cookies to remember and process the Products in the Buyer's customer basket. They are also used to help us understand the user's preferences based on past or current site activity, enabling us to offer you an enhanced experience. Localoca also uses cookies to compile data and analyses about website traffic and interaction so we can improve the service.
7.4 Localoca can also use trusted third-party services and subcontractors that track this information on behalf of Localoca. These third party services are, if used, mentioned in the request for authorisation for the use of cookies on the user.
7.4.1 Third-party services apply their own data protection policy and their own user conditions, and Localoca is in no way responsible for the processing of the user's data by these parties. We always try to protect the privacy of the user on our Service and welcome any response regarding these third-party services or their terms and conditions.
7.5 To avoid sending cookies when using the Service, you can choose your computer to warn you each time a cookie is sent, or you can choose to completely turn off the cookies. You do so through your browser and the settings are most easily found using the browser's Help menu. Remember, each browser collects its own cookies.
7.6 Localoca uses Google Analytics to compile data and analyses on site traffic and interaction so we can improve the Service. You can prevent Google Analytics from using your information by installing a Google Analytics-opt-out extension to your browser. The add-on can be downloaded free of charge from Google.
7.7 Disabling cookies will remove some features from the Service. This degrades the user's experience and may impair the functionality of the service. Some cookies, that are needed for the basic function of the service, cannot be removed.
8 Is your personal data transferred to someone else?
8.1 We will not sell, or otherwise pass on, your personal information unless we notify you in advance. This does not include the transfer of information to our Merchants or contracting parties that help us run the Service or serve the user, as long as these contracting parties agree to keep your personal information confidential in accordance with this agreement.
8.2 One important subcontractor to Localoca is the payment service providers. Localoca will not store or collect your payment data itself, but all confidential payment information will be stored with payment service providers. These payment service providers comply with the standards set by PCI-DSS, which are managed by the PCI Security Standards Council, and are bound by strict legislation.
8.3 Localoca uses Google Analytics, which allow Localoca to keep statistics on visitors on the website. You can prevent Google Analytics from using your information by installing a Google Analytics-opt extension to your browser.
8.4 We are allowed to share your personal information when we consider it essential to comply with the law or to protect our rights, property or security or that of others.
8.5 Information that does not identify the user may be provided to other parties for marketing, advertising or other use.
8.6 In the event of a possible merge, that Localoca is bought by a third party or similar activity, all personal data may be transferred to the relevant parties. We will notify you before any transfer of personal information, as required in such a case.
8.7 Personal data can be transferred to countries outside the EU and the EEA to enable the functionality of the Service, for example to subcontractors. When transferring personal data to countries outside the EU and the EEA, we ensure that all data is protected in accordance with data protection law and in accordance with good practice.
9 How long does Localoca store your personal information?
9.1 We will only keep your personal information for as long as necessary for the purposes specified in this Privacy Policy.
9.2 We keep and use your information to the extent necessary to comply with our legal obligations, for example, whether we need to keep your data to comply with laws or resolve any disputes.
10 User Rights
10.1 The user has the right to access, update or delete the personal information Localoca has regarding the user.
10.2 The user has the right to correct and complete personal information Localoca has about the user.
10.3 The user has the right to object the use of personal information stored by Localoca, for example for direct marketing.
10.3.1 Objection to direct marketing does not prevent Localoca from sending essential information required for the use of the Service, such as the delivery of Products.
10.3.2 Objection against newsletters or other advertising to which the user has given consent is made directly in the newsletter or by contacting Localoca.
10.4 The user has the right to restrict Localoca's right to use personal information concerning the user.
10.5 The user is entitled to transmission of personal information of the user.
10.6 The user may withdraw his or her consent on the use of personal information concerning the user.
10.7 The user may refuse to any impersonation in the Service. Your data will then only be used for the basic services such as fraud detection, execution of purchases and similar activities.
10.8 For the purpose of any of the above, the user must be in contact with Localoca at the following e-mail address: privacypolicy@localoca.io
10.9 Localoca is entitled to verify the user concerned and to ask for further information in order to implement the above paragraphs.
10.10 The user is entitled to lodge a complaint with the DPA if the user feels that Localoca is in breach of this Privacy Policy or Finnish or EU law. Localoca asks the user to always first contact privacypolicy@localoca.io regarding privacy issues.
Contact details of the data protection authority:
Office Of The Data Protection Ombudsman
00521 Helsinki
tietosuoja@om.fi
+358 (0)29 566 6700
11 Entry into Force, Amendment and Termination
11.1 This Privacy Policy enters into force on July 1st 2019 and is in force until further notice.
11.2 If newer terms are available, the newest terms shall apply. In the event of earlier conditions being contrary to newer conditions, the newer conditions shall apply.
11.3 Localoca reserves the right to change the terms of this Privacy Policy at any time.
11.3.1 In the event of major changes to these conditions or to other terms of use published by Localoca, a reasonable period must be allowed for the user to accept the new conditions before they enter into force. The new conditions will enter into force on the informed date, with or without the consent of the user.
11.3.2 The user has the right to refuse the new conditions, but for continued use of the Service, the conditions must be approved. If the user denies these or newer conditions, Localoca has the right to suspend or permanently delete the user’s account.
11.3.3 The continued use of the Service by the user, despite the notification of new conditions, shall be understood as an acceptance of the conditions.
12 Language of the Privacy Policy
12.1 This Privacy Policy is found in Swedish, Finnish, and English. In the event of a conflict between different language versions, the Swedish version shall apply.