We Respect Your Privacy
Thanks for visiting Token! Your privacy and the security of information that we collect is of utmost importance to us. This policy is intended to help you understand:
- What information we collect about you
- When we collect information about you
- How we use the information we collect about you
- How we share information that we collect
- How we store and secure the information we collect
- How to access and control your information
- Other important privacy information
This policy also explains your choices about how we use personal information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. By accessing any of our Services, you provide consent to the collection and use of the information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information when you register for your online account and load funds to your event wristband. We keep track of your preferences when you select settings within the Services.
Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you use certain sections of the Services. For example, when you pre-load funds to your event wristband, you provide payment information, such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, and how you interact with others on the Services.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources
We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.
Token and Related Companies: We receive information about you from companies that are owned or operated by Token, in accordance with their terms and policies.
Token Partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.
How does Token collect information about you?
Generally, we collect personal information when you use one of our Services, such as one of the examples below:
- your attendance at, or engagement at events that use our RFID wristbands to facilitate access control, cashless payment, social activations or lead capture solutions;
- you access one of the Token Online Services, such as the pre-event top up, or refund portal for an event using our RFID wristbands;
- indicate that you wish to receive news, offers or other marketing material from Token;
- make an inquiry or a complaint;
- visit one of our websites;
- have other dealings with us, for example, via social media or in person, over the phone or when you write to us.
In certain circumstances, we may also collect personal information about you in the course of combining and analysing different data sets which, in and of themselves, may not contain personal information.
Sometimes we collect personal information about you from other sources, for example:
- our related companies which include Ticketbooth Pty Ltd, Ticketbooth Limited and Audiencetools Pty Ltd;
- people registering for an account, or applying for a refund on your behalf;
- our business clients such as venues and promoters; or
- third party suppliers and contractors who assist us to operate our business, such as:
- information technology suppliers
- marketing and digital services suppliers
- research and development organisations
- data partners
- analytics consultants; and
- publicly available sources of information
Also, from time to time Token collects personal information about individuals who are not customers. This is usually where we collect the name and business contact details of a person who is the contact in a government agency or company with whom we deal. Token’s policy is to only use personal information collected from non-customers for the main business purpose for which it was collected.
How does Token use the information that we collect about you?
Generally, Token only uses personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services: We use information about you to provide the Services to you, such as our RFID wristbands and technology, and to monitor the use of such Services.
For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. In some cases, we apply these learnings across our Services to improve and develop similar features or to better integrate the services you use.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services. We also provide tailored communications based on your activity and interactions with us. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying Token ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests.
Customer support: We use your information to resolve technical issues you may encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
As noted later in this policy this information will be shared and may be used by parent companies, subsidiaries and/or affiliates for purposes consistent with this policy.
From time to time, there may be other purposes for which we collect, hold, use and disclose your personal information. We will tell you about these at the point of collection.
How does Token share the information that we collect?
We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
Sharing with other Service users
When you use the Services, we share certain information about you with other Service users.
Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organisation, and such organisation wishes to establish an account or site, certain information about you including your name, contact info, content and past use of your account may become accessible to that organisation’s administrator and other Service users sharing the same domain. If you are an administrator for a particular site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
Community Forums: Our websites offer publicly accessible blogs, such as the Token Blog. You should be aware that any information you provide on these websites – including profile information associated with the account you use to post the information – may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
Token Partners: We work with third parties who provide consulting, sales, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with payments, to provide localised support, and to provide customisations. We may also share information with these third parties where you have agreed to that sharing.
Social Media Widgets: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
With your consent: We share information about you with third parties when you give us consent to do so.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Token, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Sharing with affiliated companies
Token and Related Companies: We share information we have about you with other Token corporate affiliates in order to operate and improve products and services and to offer other Token affiliated services to you. This includes companies that own or operate the services listed here.
How does Token store and secure the personal information it collects?
Token may hold your personal information in electronic or hard copy format or a combination of both. This personal information may be combined or linked with other information held about, or which we attribute to you.
We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Information storage and security
Your personal information, even if collected within your home country, may be transferred to and stored in a country that is not the same as where it was collected on a temporary or permanent basis.
We protect the personal information we collect in a secure database stored by our third party data storage provider. Data collected online is stored in a two-step authenticated, encrypted private access only bucket. Token also employs firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems.
Token employees are required, as a condition of their employment, to treat personal information held by Token as confidential, and to maintain the confidentiality of that personal information. They are also required to sign in and use a password when accessing Token systems, and are only granted access to parts of the system, or subsects of personal information, as required.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
For Residents of California – California Consumer Privacy Act (CCPA)
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that Token disclose certain information to you about our collection and use of your personal information over the past 12 months. You can make this request by emailing [email protected] Your request will be responded to within 45 days. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We only use personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.
- Provide you a different level of quality of goods or services.
- Suggest that you may receive a different price rate for goods or services or a different level of quality of goods or services.
In the preceding twelve (12) months, Token has sold the following categories of Personal Information:
Category A: Identifiers [NO]
Category B: California Consumer Records Personal Information categories [NO]
Category C: Protected classification characteristics under California or federal law [NO]
Category D: Commercial information [NO]
How long we keep information
How long we keep information we collect about you depends on the type of information provided. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
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.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, if you are a user who originally set up the Organisation, we may retain your data as the original owner of that Organisation.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control the information that Token collects about you?
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.
If you would like to access, correct or delete information we hold about you, or opt-out of communication, please contact our Privacy Officer.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted.
Other important privacy information
How to contact our Privacy Officer
Our Privacy Officer can be contacted by:
- email at [email protected]
- mail at Token Systems Pty Ltd, PO Box 388, Strawberry Hills, NSW 2012, Australia
Last updated 1 Jan 2020