Introduction

RSRVIN Technologies Ltd, a company incorporated and registered under the laws of the Republic of Cyprus with registration number HE [xxxxxx] and having its registered office at Pandoras 26, Larnaca, 6042, Cyprus, (“us” or “we”) is strongly committed to privacy issues and wants to be transparent about the data it collects and how data is used. During the course of our Business Relationship (as defined below) with you, we collect and process personal data. In particular, the personal data which is processed by us is that of natural persons who are users and/or visitors of our website and/or mobile application, service providers, contractors and/or business affiliates as well as personal data of any other individuals, including but not limited to authorised representatives, beneficial owners, shareholders and any other stakeholders of the users and/or visitors of our website and/or mobile application, service providers, contractors and/or business affiliates, being legal entities (“you”).

During the course of our Business Relationship, we collect and process personal data. We are a data controller in respect of such personal data. This means that we are responsible for determining the purposes and means of the processing of such personal data.

For the purposes of this Privacy Notice, 'Personal data' means any information relating to an identified or identifiable natural person and 'Processing' means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, storage, use, disclosure, erasure or destruction. 'Business Relationship' means our commercial and/or business and/or other relationship with you including, but not limited to, for the provision of our services to you and the various transactions entered into between us and you from time to time.

Pursuant to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”), the Law providing for the the protection of natural persons against the processing of their personal data and the free movement of such data of 2018 (Law 125(I)/2018), as amended and other applicable data protection laws, as amended from time to time, we are required to notify you of the information contained herein.

Our Principles

When we process your personal data, it is:

1. Processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency');

   This means that we provide information to you in respect of the processing of your personal data (transparency), that the processing matches the description given to you (fairness), and that it is based on at least one of the lawful basis set out in the GDPR (lawfulness).

2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; ('purpose limitation');

   This means that we specify exactly what personal data is collected, the purpose of use and limit the processing of personal data to only what is necessary to meet the relevant purpose.

3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation');

   This means that we do not process any personal data over and above what is required.

4. Accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ('accuracy');

   This means that we have in place processes for identifying and addressing out-of-date, incorrect or unnecessary personal data.

5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed ('storage limitation');

   This means that wherever possible, we process personal data in such a way that limits or prevents identification of the data subject.

6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ('integrity and confidentiality').

Categories of Personal Data

We process the following categories of personal data:

Users

1. Contact information, such as first name, last name, telephone, e-mail address;

2. Personal characteristics, such as gender, date of birth;

3. Login information, such as email used for login and password;

4. Financial information, such as bank account number/details, data on transactions;

5. Usage and booking details, such as profile picture, preferred location for related suggestions, favorite venues and events, subscribed venues and events for updates or marketing purposes, reviews posted, time of booking, venue booked, number of people on booking, specific seating booked, event booked, ticket name, ticket price, ticket layout name (seating arrangement), ticket type, number of people (admitted by ticket), ticket currency;

6. IP address, device specifications such as FCM token for push notifications and other information relating to how you browse our website or use our mobile application and geocode for current location;

Venue Owners

1. Venue details such as the official name of the venue, the URL of the venue's website (if applicable), venue type (restaurant, night club, bar etc.), and location: the physical location of the venue, including country, state (if applicable), city, postcode, timezone and specific street address;

2. Contact phone number: A required contact number for the venue;

3. Official country and address of registration: Required information for the venue's legal registration;

4. Details of accountable person, such as full name, the role or position of the accountable person within the organization, an email address for business communication;

5. Subscription type;

6. Usage and booking management information such as venue description, venue location coordinates, venue images, layouts, reservation minutes (minimum duration), special occasion times, operational status, time table and venue tags; event name, event description, event layout (seating arrangement), special guests, event tags, ticket names, number of available tickets, ticket prices, ticket durations, total tickets sold, total amount collected out of sold tickets, ticket to reservation correlations (if applicable), ticket currencies, event start and end timestamps, event images, minimum age allowed, event hosting venue, event status; reservations booked along with booking user's information, menus published, events organized, data analytics based on past bookings' information and venue profile clicks and likes, reviews posted along with answers replied, advertisements published, marketing campaigns launched and application locking passcode;

Event Organizers

1. Event details such as the name of the event being organized, a link to the event's dedicated page (if applicable), the event type and location: area or venue where the event is hosted;

2. Contact phone number: A required phone number for the event's primary contact;

3. Details of legal entity/person of event organiser, such as registration address of the legal entity behind the event, information for the event's legal registration;

4. Details of accountable person on behalf of the organiser, such as full name of the accountable person, the role or position of the accountable person within the organization and an email address for business communication;

5. Usage and booking management information such as event description, event layout (seating arrangement), special guests, event tags, ticket names, number of available tickets, ticket prices, ticket durations, total tickets sold, total amount collected out of sold tickets, ticket to reservation correlations (if applicable), ticket currencies, event start and end timestamps, event images, minimum age allowed, event status; advertisements published and application locking passcode;

Advertisers

1. Advertisement details such as the name of the advertised product of service, a link to the advertised product or service's dedicated page (if applicable) and advertisement type;

2. Company Phone Number: A required phone number for the advertiser;

3. Registration address of the legal entity behind the advertised product or service;

4. Details of accountable person on behalf of the advertiser, such as full name of the accountable person, their role or position within the organization and an email address for business communication;

5. Usage and advertisement information such as redirection URL (by clicking on the advertisement's image), targeted audience's age range, gender and locality, advertised image, duration, estimated reach (users), total price to be paid, advertisement status and advertisement's performance data and produced submetrics (views, clicks etc.); application locking passcode;

Special Categories of Personal Data (sensitive data)

In certain cases we may collect and process special categories of personal data which is information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or data concerning sex life or sexual orientation. We shall process such data subject to your documented consent and/or where the processing is necessary for the establishment, exercise or defence of legal claims relevant to us.

If during the course of our Business Relationship there is a change in your personal data, you must ensure that the above details (as and where applicable) are updated by contacting us as soon as practically possible. If we request from you to be provided with certain personal data, we kindly request that such information is provided at your earlier convenience. If you fail to provide us with the personal data requested, we may not be able to perform or be prevented from complying with our obligations under our Business Relationship and/or any agreement entered into and/or exchanged between us and you.

Purposes of Processing

We will process your personal data (as and where applicable) for the purposes of (i) meeting our obligations under our Business Relationship and/or any agreement entered into and/or exchanged between us; (ii) operation, management and control of the affairs of our business and its purposes; (iii) general planning and organisation of our business; (iv) maintaining our IT systems, including our human capital, administrative and management systems, processes and policies; (v) maintaining and developing our Business Relationship with you; (vi) maintaining and developing our business with the users and/or visitors of our website and/or mobile application (vii) the carrying out of surveys and direct marketing (including via our website and/or mobile application); (viii) management, planning and organisation at work; and (ix) complying with any requirement of law and/or regulation and/or of any competent authority or professional body (where applicable) of which we are a member.

Lawful Basis of Processing

We are committed to your privacy. As part of the values we stand for, we will always consider your fundamental rights as a data subject. We process your personal data for the purposes mentioned above on the lawful basis that (i) the processing is necessary for compliance with a legal obligation to which we are subject (e.g. KYC requirements); (ii) the processing is necessary for the performance of an agreement which you have entered into with us and in order to take steps at your request prior to entering into the said agreement(s); (iii) you have given consent (if and where applicable); and (iv) the processing is necessary for the purposes of the legitimate interests pursued by us.

Such legitimate interests include, inter-alia, our business and/or commercial interests and the management, operation and marketing of our business and/or our exercise or defence of legal claims and/or the prevention of fraud and money laundering activities and/or to disclose information to other data recipients such as our service providers, auditors and technology providers and/or to comply with obligations or internal policy requirements of our business, and/or to monitor and improve our relationships with you and/or to keep our internal records and/or to monitor communication to/from you using our systems and/or to protect the integrity of our IT systems.

Where we decide and/or are obliged to rely on explicit consent to process your personal data, including for the processing of personal data of a child to offer information society services which is below the age of fourteen (14) years, we will contact the relevant data subject and/or the holder of parental responsibility over a child (making reasonable efforts to verify this), where applicable, to request this accordingly. In case consent is relied solely upon to achieve a lawful basis of processing of your personal data, you will have the right to withdraw this consent at any time.

Disclosure of Personal Data

We disclose your personal data to the following categories of recipients:

1. our service providers, contractors and/or other business associates;

2. our auditors, administrators, lawyers, tax advisors, valuators, consultants, accountants, investment advisors, credit reference and fraud prevention agencies and other professional advisors (as shall be engaged from time to time);

3. our IT service providers and other companies who assist us with the effective operation of our business by providing technological expertise, file storage and record management, logistic services and solutions and other subcontractors;

4. persons acting on behalf of beneficial owners, shareholders and any other stakeholders of our users and/or visitors of our website and/or mobile application, service providers, contractors and/or business affiliates/associates, being legal entities, including but not limited to payment recipients, beneficiaries, account nominees, correspondent and agent banks;

5. banks and/or other financial institutions, payment services providers, and insurance companies; and

6. public and regulatory authorities and other competent authorities of which we are a member and/or are licensed under (where applicable), for the purposes described above.

When we transfer personal data to countries located outside of the EEA, we carry out such transfers (i) to a recipient who is in a country which provides an adequate level of protection for personal data or (ii) to a recipient who is in a country which does not provide an adequate level of protection for personal data, under appropriate safeguards pursuant to the provisions of applicable data protection laws (e.g. under an agreement in the form of standard data protection clauses adopted by the European Commission), the form of which is available at https://commission.europa.eu/system/files/2021-06/1_en_annexe_acte_autonome_cp_part1_v5_0.pdf. In some (occasional) cases we may carry out such transfers where (a) we have obtained the explicit consent from the relevant data subject in respect of the proposed transfer, provided that the data subject has been informed of the possible risks of such transfer (due to the absence of an adequacy decision and appropriate safeguards); (b) the transfer is necessary for the performance of a contract entered into between the data subject and us, or (c) the transfer is necessary for the performance of a contract concluded in the interest of the data subject and entered into between us and another person or (d) the transfer is necessary for the establishment, exercise or defence of legal claims.

Your Rights as a Data Subject

1. Right of access - you have the right to request a copy of the information that we hold about you.

   You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Such additional information includes, inter alia, details of the purposes of the processing, the categories of personal data concerned and the categories of recipients of the personal data. The right to obtain a copy of your data shall not adversely affect the rights and freedoms of others.

2. Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.

   You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

3. Right to be forgotten (right to erasure) - where certain criteria are met you can ask for the data we hold about you to be erased from our records.

   In some circumstances you have the right to obtain the erasure of your personal data without undue delay. Those circumstances include cases where (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based solely on consent; (iii) you object to processing which is based on our legitimate interests and there are no overriding legitimate grounds for the processing; (iv) the processing is for direct marketing purposes; (v) the personal data have been unlawfully processed; and (vi) the personal data have to be erased for compliance with a legal obligation to which we are subject.

   The above shall not apply where processing is necessary (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation which requires processing by a law to which we are subject; (iii) for reasons of public interest; or (iv) for the establishment, exercise or defence of legal claims.

4. Right to object - you have the right to object to certain types of processing.

   You have the right to object on grounds relating to your particular situation, to the processing of personal data to the extent that such processing is based on being necessary (i) for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (ii) for the purposes of the legitimate interests pursued by us or by a third party. If you make such a request, we will cease to process the personal data unless we have compelling legitimate grounds for the processing, or the processing is for the establishment, exercise or defence of legal claims.

5. Right of portability - you have the right to have the data we hold about you transferred to another organisation.

   You have the right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format and the right to transmit those data to another data controller. However, please note that this right to data portability only arises where (a) the processing is based on consent (as and where applicable) or is necessary for the performance of a contract to which you are a party; and (b) the processing is carried out by automated means (as and if applicable). In conforming to such requests, we will not adversely affect the rights and freedoms of others.

6. Right to withdraw consent - where the processing is based on your written consent you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

   To the extent that the legal basis for our processing of your personal information is consent (as and where applicable), you have the right to withdraw that consent at any time, such withdrawal will not affect the lawfulness of processing before the withdrawal.

7. The right to lodge a complaint to a supervisory authority

   You have a right to lodge a complaint with the Office of the Commissioner for the Protection of Personal Data in Cyprus at any time.

Retention of personal data

We shall process and store your personal data for as long as you have a Business Relationship with us and for six years (6) thereafter and/or as required under applicable law. Your personal data may be retained for longer periods for the purposes of our legitimate interests in case of any legal process commencing prior to the completion of the six-year (6) period. Your personal data will be retained and securely destroyed in accordance with our data retention and destruction policy and applicable laws.

Security

As part of our privacy policy, we process personal data which is adequate, relevant and limited to what is necessary in relation to the purposes mentioned above. We as well as any sub-contractor we are doing business with implement appropriate technical and organizational measures to ensure an adequate level of security appropriate to the applicable risk. Such measures aim to prevent unauthorized or unlawful processing, accidental loss, destruction or damage of personal data and include inter-alia, pseudonymization and encryption of personal data.

Our Website

We use a number of cookies on our website for analytics and for remarketing features, which inter-alia allow us to better track usage of our website and to reach users who have previously visited our website. In doing so, we may collect and/or process personal data of visitors to our website, which is adequate, relevant and limited to what is necessary. Further information about how we use cookies on our website can be found on our Cookie Policy which is available at https://info.rsrvin.com/cookiepolicy

Further Information

Further information and/or queries and/or requests regarding the processing of your personal data and any of your rights (where applicable) in respect of your personal data, can be requested by contacting us in writing as follows:

By e-mail: [email protected]

By post: Pandoras 26, Larnaca, 6042, Cyprus

Amendments

This Privacy Notice is kept under regular review and is updated from time to time. We will, where appropriate, notify you about amendments as soon as practically possible.