The Service is operated by Invajo AB, a company incorporated under Swedish law whose principal place of business is at Grev Turegatan 30, 114 38 Stockholm.
Through the Services, Invajo provides a simple and quick means for registered users who are event Organizers and/or event administrators (“Organizers”) to create event registration by including the relevant information related to the event, booking info, prices, and other web pages related to their events, to promote those pages and events to visitors or browsers of the Services and to get free or paid bookings, solicit donations and sell merchandise related to those events to users who wish to make bookings, purchases or donations from or to such events (including to free events) (“Attendees”). We refer to Organizers, Attendees and other visitors and browsers of the Services collectively as “Users” or “you.”
2. Our principles
We do our best to protect your privacy by using security technology appropriately.
This means that:
- We make sure that we have appropriate security measures to protect your information.
- We make sure that when we ask another organization to provide a service for us, they have appropriate security measures.
- The personal information we need from you as a user to run the service is limited. The main part of personal information is collected by other users in the context of being an Organizer.
- The personal information an Organizer wants and/or needs to collect for the purpose of creating/managing an event is up to the Organizer; Invajo will only try to affect this if this may make it easier for you as a User to use the Service.
- If you as a User don’t want to provide personal information to a specific Organizer or related to a specific event we always recommend you to not complete a booking and/or contact that specific Organizer.
- We will collect and use individual user details only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to run the service, as well as manage payments and subscriptions.
- We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
- We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.
- If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be done with the relevant protection (stated under Swedish law) being in place.
3. Personal data that we collect
Collection of personal data
We collect Personal Data about you when you use the Services. This data consists of the information you actively provide us with, and the information which becomes available to us when you use the Service. The Personal Data we may collect includes without limitation your name, address, email address, phone number and other information that enables Users to be personally identified.
We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services. For more on this, see Section 5.
When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as Personal Data until such time as it can no longer be associated with you or used to identify you.
We also obtain data by recording your use of the Service. This means, without limitation, that we track how, what and when a User navigates and/or uses specific pages, sections and functionalities of the Service. This database is accessible only to employees at Invajo, or our third-party partners, who maintain the databases and analyse the data for the purposes described in Section 4.
As an Organizer, we collect some additional Personal Data from you.
- Information you provide to us: Name, contact information, organisation information. In some cases, we may collect your credit card information (e.g., your credit card number and expiration date, billing address, etc.), some of which may constitute Personal Data, to secure certain payments. In addition, if you use our third party service providers’ payment processing services, they will collect financial information from you (e.g., your bank account information or an address to send checks) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
- Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as other users, third party websites, your bank, our payment processing partners and credit reporting agencies.
As an Attendee, we collect some additional Personal Data from you.
- When you initiate or execute a booking and provide personal information it will be collected by the Organizer and Invajo.
- What personal information you need to provide in the booking is determined by the Organizer. The exceptions are when information is needed to identify a User or needed to be able to complete a booking.
- Other personal information that will be collected by Invajo is, without limitation, information about your browser, device, and ip-address.
- If a payment is related to the booking, we will not store any financial information that is within PCI DSS compliance scope in processing the payment with 3rd party payment processors (Stripe).
Information you provide to us: If you register for a paid event, we will collect, but not store, financial information from you (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data. We will not store any financial information that is within PCI DSS compliance scope.
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Organizers, other Attendees, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.
Survey Information: We may also collect some anonymized survey information from attendees to feed qualitative results back into the events and platform.
Your correspondence with Invajo
If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it (such as name, e-mail, phone number, contact information and any personal identifiable information you provide in free text form) and use it to respond to your inquiry; to notify you of publications or other services; or to keep a record of your complaint, question, request, and the like. As always, if you wish to have Invajo “erase” your personal information or otherwise refrain from communicating with you, please contact us at email@example.com.
Note: if you ask Invajo not to contact you by email at a certain email address, Invajo will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.
4. How and why we use / process your personal data
Invajo uses your personal data for the main purpose of providing you with the Service. Below you will find a list of sub-purposes, to give you a better and more clear idea of why we process information about you.
Access and Use: If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to monitor your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to monitor your ongoing qualification to use such Services.
Personalized Content: The information about organizers’ use and preferences is analysed and evaluated to help us understand what kind of services you might be interested in. With the help of this data, your organizer profile is placed into a certain segment that fits your user behaviour; we will then be able to offer you personalized content based on what segment you are in, i.e. based on what events you host, what functionalities you use, etc.
Communication and Marketing: Where it is in accordance with your marketing preferences and/or use of the Service, we may use Organizer Personal Data to contact you in the future for our marketing purposes, including without limitation, to inform you about services we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and to display personalized content and advertising on or off the Services that we believe might be of interest to you.
Statistics and Service improvement: We may use your Personal Data and other Non-Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
Allowing Organizers to communicate with you: We allow Organizers to use our communication tools, e.g. emails and sms’, to contact Attendees for their upcoming, current and past events, so you may receive communication from our system that originate with such Organizers. If you have made a booking via the Services, your personal and contact information is available to that Organizer. However, Organizers may also import contact information they have from external sources and/or send communications through the Services to those contacts and we will send such communication to those recipients. See “Opt Out from Electronic Communications” below on how to opt out of such communications.
Communicating with you. By providing us with your contact information (phone number, email etc.) we can contact you if there are any issues with the Service. We will also contact you with information about updates in the Service, suggestions to improve and/or adjust event related settings, our newsletter, support issues, etc.
As mentioned above in Section 3, when you correspond with us through any kind of communication, we may retain such correspondence and the information contained in it (such as name, e-mail, phone number, contact information and any personal identifiable information you provide or that is provided automatically by the Service) and use it to respond to your inquiry.
5. When and how we share information with others
We share your personal data with your consent or as necessary to complete any transaction or provide you with any offers you have claimed.
Organizers: When you make a booking via the Service, Personal Data entered by you, other or automatically will be collected by us and the Organizer of the event. As an Organizer you are always responsible for the personal information you collect. This responsibility applies to other persons to whom you grant access to that personal information as well.
Legal Requirements: We may share your Personal Data if required to do so by law in order for example to respond to any request from law enforcement, a court order or a government agency, or other legal obligation (including in response to public authorities to meet national security or law enforcement requirements), or if we have good reasons to believe that access, use, retention or disclosure of such information is reasonable necessary to:
- Comply with a legal obligation, court order or public authority decision.
- Protect or defend our rights, safety, interests or property of Invajo or our business partners or our users.
- Prevent or investigate possible wrongdoings in connection with the Services.
New owner: If the ownership of some or all parts of Invajo, our Service or other properties and resources will change, the information might be transferred to the new owner.
6. Data subject rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.
If you wish to confirm that Invajo is processing your personal data, or to have access to some of the Personal Data Invajo may have about you, please contact us at firstname.lastname@example.org.
You may also at any time write to Invajo Grev Turegatan 30, 114 38 Stockholm.
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Invajo might have received the data from Invajo; what the source of the information was (if you did not provide it directly to Invajo); and how long it will be stored.
You have a right to correct (rectify) the record of your personal data maintained by Invajo if it is inaccurate. You may request that Invajo erase that data or cease processing it, subject to certain exceptions.
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Invajo processes your personal data. When technically feasible, Invajo will - at your request - provide your personal data to you or transmit it directly to another controller.
Reasonable access to your personal data will be provided to you at no cost upon request made to Invajo at email@example.com.
We will consider and respond to all requests in accordance with applicable law.
If access cannot be provided within a reasonable time frame, Invajo will provide you with a date when the information will be provided. If for some reason access is denied, Invajo will provide an explanation as to why access has been denied.
7. Your Choices
Limit the data you share: You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to open an account, create an event or make bookings, personal contact information will be required.
Invajo Marketing Communications: Invajo may send you electronic communications marketing or advertising for the Services themselves, or events on the Services, to the extent you have registered for the Services or made a booking to an event created on the Services. You can also “opt out” of receiving these electronic communications by using our “Unsubscribe” functionality for such electronic communication. In addition, you may also manage your contact information by logging in (or signing up and then logging in), and manage your settings or if applicable, use the self service update in the booking confirmation page.
Communications from Organizer: Organizers may use our communication tools to send electronic communications to contacts, including Attendees who have made bookings for their events. Although these electronic communications are sent through our system, Invajo does not determine the content or the recipients of these electronic communications. Organizers are required to use our tools only in accordance with all applicable laws.
When booking: Personal Data is collected when you make a booking. In case you have questions about such information, want to adjust or delete any such information, always contact the Organizer of that specific event.
Don’t complete a booking if you don’t trust the Organizer or for any other reason don’t want to add personal information required for that specific booking.
In order to provide transparency regarding that your personal information will be managed by both the Organizer and Invajo, all bookings made in the Service that relates to you as a User, will be gathered, displayed, reachable and (if applicable) editable under a separate section in the Service.
If Personal Data is collected by Invajo (and not an Organizer via an event), please contact us at firstname.lastname@example.org if you have any questions about the data processing.
8. Security of your information
To help protect the privacy of data and personally identifiable information you transmit through use of the Service, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you.
In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
9. Data storage and retention
Personal data handled by Invajo is stored and processed in the region in which you live, or in other countries where Invajo, its affiliates, subsidiaries, partners or suppliers are active. We take steps to ensure that the information we collect in accordance with this Policy is dealt with in accordance with the provisions of this Policy and in accordance with applicable laws where the information is available.
If we were to transfer your personal data to third countries, i.e. countries outside the EU/ EEA, we will enter into agreements and take other measures in accordance with applicable legal requirements.
Invajo retains Personal Data for the purposes mentioned in Section 4 and stores this data as long as you are registered to use the Services. You may close your account via the Service or by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact the Organizer of the specific event to which your data relates. For other matters regarding personal information, contact Invajo via email@example.com.
Aggregated data: Aggregated data is collected and processed to monitor and evaluate user trends concerning the Service. This means that information about your booking, interaction and navigation history is collected and then anonymized in a way that means we cannot link the information back to you any longer. We use this anonymous information about how our users use our services for statistics, service improvement and product development of the Service. This data will be completely anonymous and does not constitute personal data. It may therefore be stored a longer time than your personal information.
Anonymization means that data once was personal information is stripped away of anything that may connect it to an individual, as well as being severed from anything that in the future might make it possible to reconnect this data to an individual. This depersonalization treatment of data is one step further than the process of pseudonymization, which means keeping certain information apart, to make it harder to identify an individual using this data. Invajo will anonymize Personal Data after 12 months.
12. Questions, concerns or complaints
Responsible for users of our Service lies with:
Grev Turegatan 30, 114 38 Stockholm
The responsibility for a specific event lies with the applicable Organizer and we refer your questions, concerns and request to them. You may find their contact information on their Organizer page.
To ask questions or comment about our Policy and our privacy practices at:
Grev Turegatan 30, 114 38 Stockholm
We will take reasonable steps to work with you to attempt to resolve your complaint.
May 2018: Clarifications due to the entry into force of the new Data Protection
Regulation (“GDPR”) on May 25, 2018. The updated Policy will automatically enter into force for all existing customers and visitors on May 25, 2018. Your continued use of our Website from that date will be subject to the new Policy. The Policy has also been revised to be concise, clear, comprehensible, and easier to understand.
June 2021: Clarifications to PII data collection and handling.