Last updated: September 20, 2020
Please see Section 10 for contact details of the Data Controllers above.
Table of Contents
- Information We Collect
- How We Use Information We Collect
- Sharing & Disclosure
- Other Important Information
- Third Party Partners & Integrations
- Your Rights
- Operating Globally
- Contact Us
1. Information We collect
There are two general categories of information we collect.
1.1 Information You Give to Us
Information that is necessary for the use of the Attractr Platform. We ask for and collect the following personal information about you when you use the Attractr Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information. When you sign up for an Attractr Account, we require certain information such as your first name, last name, email address, and date of birth.
- Profile and Listing Information. To use certain features of the Attractr Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
- Communications with Attractr and other Members. When you communicate with Attractr or use the Attractr Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
1.1.2 Information you choose to give us. You may choose to provide us with additional personal information in order to obtain a better user experience when using Attractr Platform. This additional information will be processed based on your consent.
- Additional Profile Information. You may choose to provide additional information as part of your Attractr profile (such as user profile details). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
- Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Attractr Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Attractr Platform.
2. How We Use Information We Collect
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Attractr Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop the Attractr Platform
- Enable you to access and use the Attractr Platform.
- Enable you to communicate with other Members.
- Operate, protect, improve, and optimize the Attractr Platform and experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and account notifications.
- To operate, protect, improve, and optimize the Attractr Platform and experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the Attractr Platform, your search and booking history, your profile information and preferences, and other content you submit to the Attractr Platform. We process this information given our legitimate interest in improving the Attractr Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with our legal obligations.
- Resolve any disputes with any of our Members and enforce our agreements with third parties.
- Enforce our Terms of Service and other policies.
- In connection with the activities above, we may conduct profiling based on your interactions with the Attractr Platform, your profile information and other content you submit to the Attractr Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Attractr Platform if such processes detect a Member or activity that we think poses a safety or other risk to the Attractr Platform, other Members, or third parties. We process this information given our legitimate interest in protecting the Attractr Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing
- Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Attractr or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
- Personalize, measure, and improve our advertising.
3. Sharing & Disclosure
3.1 With Your Consent
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Attractr Account or when you participate in promotional activities conducted by Attractr partners or third parties.
3.2 Sharing between Members
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as an Artist submit a booking request, certain information about you is shared with the Studio, including your full name and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the booking, like your phone number.
- When you as a Studio have a confirmed booking, certain information is shared with the Artist to coordinate the booking, such as your full name, phone number, and Studio address.
3.3 Profiles, Listings, and other Public Information
The Attractr Platform lets you publish information, including personal information, that is visible to the general public. For example:
- Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
- Listing pages are publicly visible and include information such as the Studio’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
- After completing a booking, Artists and Studios may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Attractr Platform (such as the Listing page).
- If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Attractr Platform, that content is publicly visible. Based on our legitimate interest to promote the Attractr Platform we may display parts of the Attractr Platform (e.g., your Listing page) on sites operated by Attractr’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed. Information you share publicly on the Attractr Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights
Attractr may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Attractr, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Attractr, its employees, its Members, or members of the public.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Attractr’s property, its Members and the Attractr Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.5 Service Providers
Attractr uses a variety of third party service providers to help us provide services related to the Attractr Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
3.6 Social Media Platforms
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Attractr Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. The social media platforms with which we may share your personal data are not controlled or supervised by Attractr. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such a provider. Please note that you may, at any time, ask Attractr to cease processing your data for these direct marketing purposes by sending an email to [email protected].
3.7 Business Transfers
3.8 Aggregated Data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1 Analyzing your Communications
We may review, scan, or analyze your communications on the Attractr Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on Attractr's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Google Maps/Earth
5. Third Party Partners & Integrations
The Attractr Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Attractr doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Attractr, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Rights
You may exercise any of the rights described in this section before your applicable Attractr Data Controller by sending an email to [email protected]. Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Managing Your Information
You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Attractr Account).
6.3 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Attractr Platform to you, you can request that we erase your personal information and close your Attractr Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Attractr Account for fraud or safety reasons, we may retain certain information from that Attractr Account to prevent that Member from opening a new Attractr Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Attractr may keep some of your information for business reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Attractr Platform, even after your Attractr Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Attractr Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by Attractr you may withdraw your consent at any time by changing your Account settings or by sending a communication to Attractr specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Attractr override your own.
6.6 Objection to Processing
In some jurisdictions, applicable law may entitle you to require Attractr to not process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, Attractr will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time ask Attractr to cease processing your data for these direct marketing purposes by sending an email to [email protected].
7. Operating Globally
7.1 Other Means to Ensure an Adequate Level of Data Protection
If you are a resident in the EEA and data is shared with corporate affiliates or third party service providers outside the EEA, we have - prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on request.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Attractr Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Attractr Account, please contact us following the instructions in the Contact Us section below.
10. Contact Us