This Privacy Policy (hereinafter the "Policy") explains how Evenue OÜ collects, uses, retains and protects Personal Data in connection with the use of the Venueplace platform, and the rules that apply to content, reviews, comments, images and other materials created by users or Hosts on the Platform.
This Policy replaces the previous Evenue privacy policy and content and publishing policy. Details on the use of cookies and similar technologies are set out in the integral annex to this Policy, the "Cookie Policy".
This Policy applies together with the Venueplace platform General Terms, the Host Agreement, the Customer Service Agreement and the terms of the specific booking. In the event of conflict, this Policy shall prevail on matters relating to the processing of Personal Data, unless otherwise provided by law.
1. Data Controller and contact details
1.1. The Data Controller of Personal Data in respect of Platform administration and processing related to user accounts, bookings, payment intermediation, customer support, security, content moderation and Platform development is the user's contracting entity, i.e. the Evenue Group company designated in the Venueplace platform General Terms according to the location of the event venue:
Evenue OÜ, registry code: 16084878, VAT number: EE102972007, address: Niine tn 7-3, 10414 Tallinn, Estonia; e-mail: [email protected], data protection contact: +372 53479514
For processing related to event venues located in Latvia, the Data Controller is SIA Evenue, registry code: 40203738052, address: Sudrabu Edžus iela 26, Riga, LV-1014, Latvia, e-mail: [email protected].
Evenue OÜ and SIA Evenue form the Evenue Group (parent company Evenue OÜ) and have concluded a joint controllership arrangement (Article 26 GDPR) regarding the joint operation of the Platform. The essence of the arrangement is available upon request.
1.2. The Host may be an independent Data Controller to the extent that it determines the purposes and means of processing the Customer's Personal Data, for example for the provision of the Service, invoicing, handling claims or compliance with statutory obligations.
2. Whose data are processed
2.1. Evenue may process the data of the following persons:
Customers who use the Platform to book an event venue or an ancillary service;
Hosts and their representatives, employees, contact persons, beneficial owners or other persons connected with the Host;
Visitors and users of the Platform, including persons who leave reviews, comments or other content;
Persons who communicate with Evenue's customer support or submit enquiries, complaints, notices or appeals.
3. Personal Data processed
3.1. Account and contact data
name, username or name of the company's representative;
e-mail address, telephone number and other contact details;
data on the creation and management of the account, including technical identifiers related to authentication;
where necessary, data required to verify authority of representation, identity or business reliability.
3.2. Booking and service data
date, time, duration, type and purpose of the event;
event venue, Host, number of participants, ancillary services, special requests and restrictions;
booking price, advance payment or deposit, cancellation terms and booking-related notices;
information related to the booking exchanged between the Customer and the Host in the Platform's communication environment.
3.3. Payment and billing data
payment amount, payment status, payment date and general data on the payment method;
data forwarded by the payment service provider necessary for identifying, confirming or refunding the payment;
data related to invoicing, reporting and accounting.
Evenue does not retain full card numbers or card security codes. Card payments and other payment solutions are processed through the relevant payment service provider.
3.4. Usage, device and security data
IP address, device type, browser type, operating system, log data and event logs;
time of use of the Platform, activities, queries, error messages and security logs;
information necessary to detect fraud, misuse, security incidents or system failures.
3.5. Content and communication data
reviews, comments, objections, notices, complaints and customer support correspondence;
service descriptions, prices, terms, photos, texts and other materials added to the Platform by the Host;
data related to moderation, notices and appeals.
4. Purposes and legal bases of processing
Purpose | Data processed | Legal basis |
Creation and management of the account | account, contact and authentication data | performance of the contract; legitimate interest |
Intermediation of bookings and support for the performance of the Service Agreement | booking, communication and contact data | performance of the contract |
Collection, refund and settlement of payments | payment and billing data | performance of the contract; legal obligation |
Platform security, fraud prevention and prevention of misuse | usage, device, log and verification data | legitimate interest; legal obligation |
Publication of content, moderation and handling of infringements | content, communication and usage data | legitimate interest; legal obligation; performance of the contract |
Customer support, enquiries and complaints | communication and booking data | performance of the contract; legitimate interest |
Drafting, bringing or defending legal claims | relevant account, booking, payment, content and communication data | legitimate interest; legal obligation |
Marketing and newsletters | contact details, consent status and preferences | consent or legitimate interest to the extent permitted by law |
Where processing is based on consent, the user may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
5. Sharing of data
5.1. Evenue shares Personal Data only to the extent necessary for the functioning of the Platform, for the performance of bookings, for the intermediation of payments, for ensuring security, for compliance with statutory obligations or for the protection of legitimate interests.
With Hosts: the Customer's name, contact details, booking data and other information necessary for the provision of the Service are shared.
With Customers: information about the Host is shared to the extent necessary for making a booking, using the Service and exercising contractual rights.
With payment service providers: information necessary for processing, confirming, refunding or preventing fraud in payments is shared.
With IT, cloud, analytics, customer support and security service providers: data are shared to the extent necessary to provide the service.
Between Evenue Group companies (Evenue OÜ and SIA Evenue): data are shared to the extent necessary for the operation of the shared Platform, provision of customer support, ensuring security and intra-group reporting.
With public authorities, courts, dispute resolution bodies or law enforcement authorities: data are disclosed where this is necessary to comply with a legal obligation or to protect rights.
5.2. Evenue does not sell Personal Data to third parties.
6. Roles of Hosts and Customers in the processing of Personal Data
6.1. The Service Agreement concluded through the Platform is between the Customer and the Host. Evenue processes the data for Platform administration, intermediation of the booking, collection of payments in the name and on the account of the Host, and provision of a secure technical environment.
6.2. The Host processes the Customer's Personal Data independently to the extent that the Host uses the data for the provision of the Service, communication with the Customer, issuing invoices, resolving claims, complying with statutory obligations or organising its own service.
6.3. The Host must ensure that the Customer's data are used only for lawful purposes, to the minimum extent necessary and securely, and that the data are not disclosed to third parties without a legal basis.
7. Publication of content, intellectual property and moderation
7.1. General principles
Content added to the Platform, including reviews, comments, images, service descriptions, prices, terms and other materials created by users or Hosts, must be lawful, accurate, relevant, consistent with good morals and related to the purpose of the Platform.
The person publishing the content is responsible for ensuring that they have the right to publish the content and that the content does not infringe the rights of third parties, including rights related to the protection of personal data, copyright, trademarks, business secrets or reputation.
7.2. Prohibited content
It is prohibited to publish or transmit on the Platform any content that, inter alia:
contains false or misleading information, fake reviews or manipulated ratings;
contains defamation, insults, threats, incitement to hatred, discrimination, violence or the promotion of unlawful activity;
contains Personal Data without a legal basis, including contact details, addresses, personal identification codes, financial data, health data or other special categories of data;
contains spam, extraneous advertisements, affiliate links, coupon offers or sales offers unrelated to the Platform's services;
infringes copyright, trademarks, business secrets or other rights of third parties;
damages the security or operation of the Platform, or the rights or reputation of Evenue, the Host, the Customer or any third party.
7.3. Reviews
A review must be based on actual usage experience and must be honest, relevant and lawful. The Host may not leave a review of itself, influence the Customer's review or offer payment, discounts or other benefits in exchange for positive feedback. The Customer may not demand benefits from the Host for amending, deleting or not publishing a review.
7.4. Right to use content
By publishing content on the Platform, the publisher grants Evenue a non-exclusive licence to use, display, store, process, technically adapt and make available to the public the relevant content to the extent necessary for the functioning of the Platform, the intermediation of bookings, the promotion of services, the moderation of content and the protection of Evenue's rights.
Photos, texts, price lists and service descriptions uploaded by the Host may be used by Evenue on the Platform and in Evenue's marketing channels to the extent provided for in the Host Agreement or as separately agreed by the parties.
7.5. Moderation and notifications
Evenue may moderate content automatically and/or manually in order to identify content that is prohibited, unlawful, misleading, spam, infringing Personal Data, or in conflict with the Platform's terms.
Evenue may temporarily restrict, remove or change access to content where Evenue, acting in good faith and reasonably, considers that the content may infringe the law, this Policy, the Platform's terms or third-party rights.
Any person who considers that content published on the Platform is unlawful or infringes their rights has the right to submit a notification to Evenue at [email protected]. The notification must allow sufficient identification of the content and contain the notifier's contact details for further communication.
Where Evenue removes or restricts content, Evenue shall, where possible, notify the relevant user of the reason for the removal or restriction and provide an opportunity to lodge an appeal, where such opportunity arises from applicable law or from the operating logic of the Platform.
8. Data retention
8.1. Evenue retains Personal Data only for as long as is necessary for fulfilling the purpose of processing, complying with legal obligations or protecting rights.
Account data are generally retained until the account is closed, unless longer retention is necessary to comply with a legal obligation or to defend a claim;
Booking, payment and billing data are generally retained for up to seven (7) years for the fulfilment of accounting and tax obligations;
Customer support, complaint and dispute-related data are retained until the limitation of the claim or the conclusion of the proceedings;
Security and log data are retained for a reasonable period necessary for the security of the Platform, fraud prevention and incident investigation;
Marketing data are retained until withdrawal of consent or until the user opts out of marketing communications.
9. Transfers of data outside the European Economic Area
Where Personal Data are transferred outside the European Union or the European Economic Area, Evenue uses appropriate safeguards, including the European Commission's standard contractual clauses, an adequacy decision, certified service providers or other mechanisms permitted by law.
10. User rights
10. 1. Under applicable law, the user has the right to:
receive information about the processing of their Personal Data and access the data;
request the correction of inaccurate or incomplete data;
request the erasure of data where there is no legal basis to retain them;
request restriction of processing;
object to processing based on legitimate interest;
withdraw consent, where the processing is based on consent;
submit a complaint to the Estonian Data Protection Inspectorate (aki.ee, [email protected]) or, where the user is located in Latvia, to the Latvian Data State Inspectorate (Datu valsts inspekcija, dvi.gov.lv).
10.2. To exercise these rights, you may contact Evenue at [email protected]. Before fulfilling a request, Evenue may ask for additional information to identify the person or to clarify the request.
11. Security
11.1. Evenue applies reasonable technical and organisational security measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include encrypted connections, access restrictions, log management, backups, monitoring, fraud detection and risk assessment.
11.2. The user is responsible for the confidentiality of their account data and authentication means and must notify Evenue without delay if they have reason to believe that their account has been misused.
12. Cookies and similar technologies
12.1. Evenue uses cookies and similar technologies on the Platform. The purposes, categories, retention periods and user choices regarding the use of cookies are described in the integral annex to this Policy, the "Cookie Policy".
12.2. Non-essential cookies are used only with the user's consent, where consent is required by law. The user can change their preferences in the cookie banner or in the browser settings.
13. Amendments to the Policy
13.1. Evenue may update this Policy where the operation of the Platform, the methods of data processing, the content moderation procedure, the use of cookies, legislation, case law or the guidelines of supervisory authorities change.
13.2. Material changes affecting user rights or the principles of Personal Data processing will be communicated to users within a reasonable time before the changes enter into force, where practicable or required by law.
14. Contact
Questions regarding privacy, processing of Personal Data, removal of content, lodging an appeal or the use of cookies may be sent to: Evenue OÜ, e-mail: [email protected], data protection contact: +372 53479514. For event venues located in Latvia: SIA Evenue, e-mail: [email protected].