Evenue privacy policy

1. Controller and contact details

The controller of personal data for the operation of the Platform and for processing related to user accounts, bookings, payment mediation, customer support, security, content moderation and development of the Platform is:

A Host may be an independent controller to the extent that the Host determines the purposes and means of processing Client personal data, for example for providing the Service, invoicing, handling claims, or complying with statutory obligations.

2. Whose data is processed

Evenue may process the data of the following persons:

• Clients who use the Platform to book a venue or additional service;
• Hosts and their representatives, employees, contact persons, beneficial owners or other persons related to a Host;
• visitors and users of the Platform, including persons who leave reviews, comments or other content;
• persons who interact with Evenue customer support or who submit inquiries, complaints, notifications or appeals.

3. Personal data processed

3.1. Account and contact data

• name, username or name of the company representative;
• email address, phone number and other contact details;
• account creation and management data, including technical identifiers related to authentication;
• where necessary, data required to verify representation rights, identity or business trustworthiness.

3.2. Booking and service data

• date, time, duration, type and purpose of the event;
• venue, Host, number of participants, additional services, special requests and restrictions;
• booking price, advance payment or deposit, cancellation conditions and booking-related notices;
• booking-related information exchanged between the Client and the Host in the Platform's messaging environment.

3.3. Payment and billing data

• payment amount, payment status, payment date and general payment method data;
• data transmitted by the payment service provider that is needed to identify, confirm or refund a payment;
• data related to billing, reporting and accounting.

Evenue does not store full card numbers or card security codes. Card payments and other payment solutions are processed via 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;
• Platform usage time, actions, requests, error messages and security logs;
• information needed to detect fraud, misuse, security incidents or system errors.

3.5. Content and communication data

• reviews, comments, replies, notifications, complaints and correspondence with customer support;
• service descriptions, prices, terms, photos, texts and other material added to the Platform by Hosts;
• data related to moderation, notifications and challenges.

4. Purposes and legal bases of processing

Where processing is based on consent, the user may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

5. Data sharing

Evenue shares personal data only to the extent necessary for the operation of the Platform, performance of bookings, mediation of payments, ensuring security, fulfilment of legal obligations or protection of legitimate interests.

• Hosts receive the Client's name, contact details, booking data and other information needed to provide the Service.
• Clients receive information about the Host to the extent needed to make a booking, use the Service and exercise contractual rights.
• Payment service providers receive information needed to make, confirm, refund or prevent fraud in payments.
• IT, cloud, analytics, customer support and security service providers receive data to the extent needed to provide their service.
• Public authorities, courts, dispute resolution bodies or law enforcement receive data where necessary to comply with a legal obligation or to protect rights.

Evenue does not sell personal data to third parties.

6. Roles of Hosts and Clients in personal data processing

The Service Agreement concluded through the Platform arises between the Client and the Host. Evenue processes data for the operation of the Platform, mediation of bookings, collection of payments on behalf and for the account of the Host, and provision of a secure technical environment.

The Host independently processes Client personal data to the extent that the Host uses the data for providing the Service, communicating with the Client, issuing invoices, handling claims, complying with statutory obligations or operating its own service.

The Host must ensure that Client data is used only for a lawful purpose, to the minimum extent necessary and securely, and that the data is not disclosed to third parties without a legal basis.

7. Content publication, intellectual property and moderation

7.1. General principles

Content added to the Platform, including reviews, comments, images, service descriptions, prices, terms and other material created by users or Hosts, must be lawful, accurate, relevant, in line with good practice and related to the purpose of the Platform.

The publisher of content is responsible for having the right to publish that content and ensuring that the content does not infringe third-party rights, including those related to data protection, copyright, trademarks, trade secrets or reputation.

7.2. Prohibited content

The following content is prohibited on the Platform, among others:

• false or misleading information, fake reviews or manipulated ratings;
• defamation, insults, threats, incitement to hatred, discrimination, violence or promotion of illegal activities;
• personal data without a legal basis, including contact details, addresses, ID codes, financial data, health data or other special categories of data;
• spam, unrelated advertisements, affiliate links, coupon offers or sales offers that are not connected to the Platform's services;
• content that infringes copyright, trademark rights, trade secrets or other third-party rights;
• content that harms the security or operation of the Platform or the rights or reputation of Evenue, a Host, a Client or any third party.

7.3. Reviews

A review must be based on actual experience of using the service and must be honest, relevant and lawful. A Host may not review itself, influence a Client's review or offer payment, discount or any other benefit in exchange for positive feedback. A Client may not demand benefits from a Host in exchange for modifying, deleting or withholding 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 such content to the extent necessary for the operation of the Platform, mediation of bookings, presentation of services, content moderation and protection of Evenue's rights.

Photos, texts, price lists and service descriptions uploaded by a Host may be used by Evenue on the Platform and in Evenue's marketing channels to the extent provided in the Host agreement or as separately agreed between the parties.

7.5. Moderation and notifications

Evenue may moderate content automatically and/or manually in order to detect prohibited, illegal, misleading or spam content, content breaching personal data rules, or content otherwise inconsistent with the Platform's terms.

Evenue may temporarily restrict, remove or change access to content where Evenue in good faith and reasonably believes that the content may breach 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 violates their rights is entitled to send a notification to Evenue at info@venueplace.com. The notification must allow the content to be sufficiently identified and must include the notifier's contact details for further communication.

Where Evenue removes or restricts content, Evenue will, where possible, inform the relevant user of the reason for the removal or restriction and offer the opportunity to lodge an appeal, where such opportunity follows from applicable law or the logic of the Platform.

8. Data retention

Evenue retains personal data only for as long as necessary to fulfil the purposes of processing, to comply with legal obligations or to protect rights.

• account data is generally retained until the account is closed, unless longer retention is required to comply with a legal obligation or defend a claim;
• booking, payment and billing data is generally retained for up to seven (7) years for accounting and tax compliance purposes;
• customer support, complaint and dispute data is retained until the claim becomes time-barred or the proceeding is concluded;
• security and log data is retained for a reasonable period needed for Platform security, fraud prevention and incident investigation;
• marketing data is retained until consent is withdrawn or until the user opts out of marketing communications.

9. Transfers outside the European Economic Area

Where personal data is transferred outside the European Union or the European Economic Area, Evenue applies appropriate safeguards, including European Commission Standard Contractual Clauses, an adequacy decision, certified service providers or other mechanisms permitted by law.

10. User rights

Under applicable law, the user has the right to:

• receive information about the processing of their personal data and access that data;
• request the correction of inaccurate or incomplete data;
• request erasure of data where there is no legal basis for its retention;
• request restriction of processing;
• object to processing based on legitimate interest;
• withdraw consent where processing is based on consent;
• lodge a complaint with the Estonian Data Protection Inspectorate at info@aki.ee or at aki.ee.

To exercise these rights, contact Evenue at info@venueplace.com. Evenue may request additional information to verify the requester's identity or clarify the request before fulfilling it.

11. Security

Evenue applies reasonable technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures may include encrypted connections, access controls, log management, backups, monitoring, fraud detection and risk assessment.

The user is responsible for keeping their account credentials and authentication tools confidential and must inform Evenue without delay if the user has reason to believe that their account has been misused.

12. Cookies and similar technologies

Evenue uses cookies and similar technologies on the Platform. The purposes, categories, retention periods and user choices regarding cookies are described in the integral annex to this Policy, the Cookie policy.

Non-essential cookies are used only with the user's consent where consent is required by law. The user may change their preferences via the cookie banner or browser settings.

13. Changes to this Policy

Evenue may update this Policy where changes occur in the operation of the Platform, the methods of data processing, the content moderation procedure, the use of cookies, applicable law, case law or guidance from supervisory authorities.

Significant changes that affect user rights or the principles of personal data processing will be communicated to users within a reasonable period before the changes take effect, where practically possible or required by law.

14. Contact

Questions regarding privacy, processing of personal data, content removal, lodging an appeal or the use of cookies can be sent to: Evenue OÜ, email: info@venueplace.com, data protection contact: +37253479514.