Privacy Policy – Entertainment Technology Partners

Entertainment Technology Partners Privacy Policy

Effective Date: 03-15-2024

1.0 Introduction

Entertainment Technology Partners is a technology company headquartered in Orlando, Florida, which focuses on providing services to a global collection of exceptional independent brands in the events and entertainment industry.

For more information about our services, please refer to our website: https://etp.net/

This Privacy Policy is applicable to Entertainment Technology Partners and its brands (“we,” “our,” or “us”) as related to our services, which collectively include:

the use of this site and our other sties: https://etp.net/ (“website”)
the use of the application website https://order.lmg.net/ (“application”)
social media messages and marketing campaigns and
the use of our products and services.

This Privacy Policy sets out the essential details relating to your personal data relationships with Entertainment Technology Partners as:

A website visitor
An end user of the application (“end user”)
A prospective client
A job applicant and
Partners

Clients contract the use of our application and give access to their employees and other third parties, as solely decided by them, by creating users who access the application with their email address and credentials. The clients’ administrators grant end users roles, which result in different permissions and access rights to the information held in the Client account.

2.0 Personal Information We Collect

2.1 Information You Choose to Provide to Us

WHEN

We may ask you to provide personal information when:

You use the website to download articles, data sheets or eBooks.
You request a free trial or demo.
You refer a friend to us.
You connect with us directly via phone calls or video conferencing platforms.
We or Client Account Administrators grant you access to the application.
You or Client Account Administrators upload or enter personal information into the application.
You participate in a marketing or sales promotion.
You attend trade events and other industry networking events.
You register or attend a webinar or other event.
You participate in programs we may offer from time to time.
You participate in chats.
You pay for our services.

If you choose to provide us with a third-party’s personal information (the person’s name, email and company) when taking part in our referral program, you represent that you have the third-party’s permission to do so.

WHAT

We collect personal information that may include first and last name, business email address, phone number and/or company name.

As an end user of the application, we collect your name, business email address and any comments you make in the application.

In addition, we may collect data uploaded by you, your employer or other users of the application that may be required to use Entertainment Technology Partneres services. We expect all users to follow their organization’s privacy policy and any applicable regulatory requirements when uploading, accessing and using personal information into our application. The data uploaded may include personal information like:

Employee names, email addresses and contractual agreements
Vendor names, email addresses, contractual agreements or other personal data necessary for Entertainment Technology Partners services
Customer names and email addresses used to provide services within Entertainment Technology Partners’s platform

As a job applicant, we may also collect your resume and cover letter.

Further information, including specific obligations of the Entertainment Technology Partners, can be found in the Service and/or Data Processing Agreements.

2.2 Information We Collect Automatically

WHEN

We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology.

For further information about the types of cookies we use, you can access our Cookie Policy at this link https://etp.net/cookie-policy/

WHAT

The information collected includes:

access times
the pages you view
the links you click on
the search terms you enter
actions you take in connection with any of the visited pages
your device information such as IP address, location, browser type and language
the Uniform Resource Locator (URL) of the website that referred you to our website and
the URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

2.3 Information We May Collect From Third Parties

WHEN

We may combine the information we collect from your direct interactions with us with information obtained through other third-party sources. We also obtain and/or purchase lists from third parties about individuals and companies interested in our products.

WHAT

The personal information collected includes your name, email address, business address, job title, company name, and telephone number.

3.0 How We Use Personal Information

We use your personal information to:

Deliver the contracted services and allow full use of the application functionality as purchased by the clients.
Deliver training and support to our application end users and/or carry out the transactions you have requested.
To communicate with you directly through emails, calls, chats and video conferencing.
Process payments for application subscriptions.
Send communications to you about:
- New application features and upgrades.
- Our services and offerings.
- Event announcements.
- Product notices and changes to our terms and policies.
- Particular programs in which you have chosen to participate.
- Promotional offers and surveys.
- Scheduling demos and managing free trials.
Advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.
Carry out market research to understand how to improve our services and their delivery.
Create and manage marketing campaigns.
Generate sales leads and increase our market share.
Analyze user clicks and usage of the application and website to improve user experience and maximize usage of our services.
Manage our website and application to maintain and deliver the contracted functionality and services.
Enforce our website and application terms and/or separate contracts (if applicable) with you
Prevent fraud and other prohibited or illegal activities.
Protect the security or integrity of the website, application, our business or services.
Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.

Please note that sometimes we may record the video conferencing call in which you participate to analyze and improve our staff’s communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page.

We do not sell your information to any third party.

4.0 How We Share Personal Information

Our Application and Services

If you are an end user of our application, your personal information may be viewed by other users with access to the application.

Service Providers

We use third parties to help us provide our services. They will have access to your information as collected by the website or the application, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission.

Service Provider Name	Business Purpose	Information Collected by the Service Provider	Data Location
Sendgrid	Sending Communicaction Emails	Email Address and Name	USA
Authorize.net	Payment Processing	Payment Information	USA

Legal Disclosures

It is possible that we may need to disclose personal information when required by law, subpoena or other legal processes as identified in the applicable legislation.

We attempt to notify our clients about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

Change in Control

We can also share your personal data as part of a sale, merger, change in control or in preparation for any of these events.

Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5.0 How We Secure Personal Information

We are committed to protecting the security of all of the personal information we collect and use.

We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit.

6.0 Your Rights

We provide the same suite of services to all of our clients and end users worldwide.

We offer the following rights to all individuals regardless of their location or applicable privacy regulations.

For personal information we have about you, you can:

Access your personal information or request a copy.

You have the right to obtain information about what personal information we process about you or to obtain a copy of your personal information.

If you have provided personal information to us, you may contact us to obtain an outline of what information we have about you or a copy of the information.

If you are an end user of the application, you can log in to see the personal information in the account or approach your employer for more information.

You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it.

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

Change or correct your personal information.

You have the right to update or correct your personal information or ask us to do it on your behalf.

You can edit your information through the user account in the application or ask us to change or correct it by contacting us at info@etp.net.

Delete or erase your personal information.

You have the right to request the deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you.

Object to the processing of your personal information.

You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes.

Ask us to restrict the processing of your personal information.

You may have the right to ask us to limit the way that we use your personal information.

Export your personal data.

You have the right to request that we export to you in a machine-readable format all of the personal information we have about you.

We do not process personal information through the use of automated means.

If you would like to exercise any of the rights described above, please contact us at info@etp.net.

You also have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory.

7.0 How Long We Keep Your Personal Information

We retain information as long as it is necessary to provide the services to you and our clients, subject to any legal obligations to further retain such information.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law.

The information we retain will be handled following this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data. This information may provide insights that are commercially valuable to {{organization.name}}, such as statistics of the use of the services.

8.0 Other Important Information

We process data in locations The United States of America and rely on legally-provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations. We provide the capability for the return, transfer and/or disposal of personal data in a secure manner.

We will only collect and process your personal data where we have a lawful reason for its collection.

When you visit our website and provide us with your personal information, we collect and use it with your consent.

As an application end user, you consent to our collection of your personal information when you log in for the first time. However, your employer has control of the account and may upload and share additional personal information. Your employer’s responsibility is to ensure that collecting, using and sharing the personal information uploaded to the application complies with all applicable legislation.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at info@etp.net.

How to select your communications preferences

You may choose to receive or not receive marketing communications from us. Please click the “Unsubscribe” link in the email we sent you to stop receiving marketing communications.

You may choose which information we collect automatically from your device by controlling cookie settings on your browser or by selecting your preferences through our Cookie Policy.

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

9.0 Contact Information

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at <XXXX update contact information here>.

Appendix

A.1 For Individuals Based in the European Economic Area (EEA), United Kingdom (UK) and Switzerland

If you are based in one of these jurisdictions, Entertainment Technology Partneresis the controller of your personal data collected in the following instances:

When you visit our websites: https://etp.net/
When we process your personal data for sales and marketing purposes

Entertainment Technology Partneresis a processor of all personal data processed on the application, on behalf of our clients. We only process the personal data under their direction. Please contact your employer or the organization that granted you access to the application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

Consent: We will ask for your express and informed consent every time we collect your personal data on this legal basis.
Contractual basis: We process the personal data as necessary to fulfill our contractual terms with you or our clients.
Legitimate interest: We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation.

You have the following rights under the GDPR:

Be informed about the collection and use of your personal data
Access your personal data
Correct errors in your personal data
Erase your personal data
Object to the processing of your personal data.
- This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.
Export your personal data
Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).
Not to be subject to a decision based solely on automated decision making

We process personal data in The United States of America and share it with our service providers in The United States of America and other jurisdictions. We use standard contractual clauses, approved by the European Commission or competent UK authority (as applicable), as the data transfer mechanism for transferring personal data from the EEA or UK to other countries subject to data transfer requirements. See the table of our service providers here. (link to the table above)

You may contact us at info@etp.net or you may contact our EU Data Representative at: info@etp.net

You may also lodge a complaint with your local supervisory authority:

EU Data Protection Authorities (DPAs). See their contact details here National Data Protection Authorities.
Information Commissioner’s Office (ICO)
Swiss Federal Data Protection and Information Commissioner (FDPIC).

A.2 For Individuals Based in The United States

Under the California Privacy Rights Act (‘CPRA’) – which amended and expanded on CCPA, Connecticut Data Privacy Act (‘CTDPA’), Virginia Commonwealth Data Protection Act (‘CDPA’), Utah Consumer Privacy Act (‘UCPA’), and the Colorado Privacy Act (‘CPA’), consumers may be able to exercise the following rights in relation to the personal information about them that we have collected (subject to certain limitations at law):

The right to access/know any or all of the information relating to your personal information that we have collected, processed or disclosed in the preceding 12 months (upon verification of your identity). For details on the categories of personal information we have collected and/or shared, refer to section “2.0 Personal Information We Collect” and “4.0 How We Share Personal Information” in the notice. Entertainment Technology Partnereswill provide a copy of the consumer’s personal data in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance.
The right to request the deletion of personal information we have collected from you.
The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.
The right to opt-in to personal information sales to third parties for consumers under the age of 16. However, we do not sell personal information of minor consumers.
The right to opt-out of sharing of personal information to third parties now or in the future. To view the information we have shared in the preceding 12 months, refer to section “4.0 How We Share Personal Information” in the notice.
The right to request rectification/correction of inaccurate personal information, considering the nature and purposes of the processing of the information. (Not Applicable under UCPA)
The right to limit use and disclosure of sensitive personal information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer. (Applicable under CCPA, as amended by CPRA)
The right to opt-out of the processing of sensitive personal information (I.e., data that reveals ethnic or racial origin, mental or physical health diagnosis, religious beliefs, sexual orientation, or citizenship or immigration status. (Applicable under UCPA)
The right to opt-out of targeted advertising. (Applicable under CPA, CTDPA, UCPA, VCDPA)
The right to opt-out of profiling in connection with automated decisions. (Applicable under CPA, CTDPA, UCPA)

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner. Additionally, Entertainment Technology Partnereshas established processes (including reviewing business processes, systems and resources on a periodic basis) to ensure consumers who exercise any of the above rights under US state privacy laws are not discriminated against.

A.2.1 How to Exercise Your Consumer Rights

To exercise any of your right mentioned above, please submit a request by contacting us at info@etp.net.

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request where we cannot verify your identity or locate your information in our systems or as permitted by law. In this case, we may request that you provide additional information reasonably necessary to authenticate you and your request.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Entertainment Technology Partneresclient that uses our application and services, please direct your requests and/or questions directly to your employer or former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Entertainment Technology Partneresapplication by a Entertainment Technology Partneresclient, please direct your requests and/or questions directly to the Entertainment Technology Partneresclient that gave you access.

If Entertainment Technology Partneresdoes not take action on your Consumer Rights Request within the 45 days, or in the event of an extension, within the maximum 90-day response period, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision. For opt-out or limit use and disclosure requests submitted under the CCPA, Entertainment Technology Partnereswill respond as soon as feasibly possible, with up to a maximum of 15 days.

For consumers residing in Virginia, within 60 days of receipt of an appeal, and for consumers residing in Colorado, within 45 days of receipt of an appeal, Entertainment Technology Partnereswill inform the consumer, in writing, of any action taken/not taken in response to the appeal, including an explanation of the reasons for the decisions. If the appeal is denied, Entertainment Technology Partnereswill provide consumers with an online mechanism, if available, or another method which allows the consumer to contact the Attorney General to submit a complaint.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 13. If you believe that a child under 13 may have provided us their Personal Information, please contact us at info@etp.net.