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PRIVACY POLICY

1. Introduction

This privacy policy describes how Audience Engage Oy ("we", "us", or "our") collects, uses, and shares information from users of the Keino mobile application and related services (collectively, the "service"). We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we process your personal data and what rights you have regarding your data.

2. Information We Collect

Our service may collect the following information:

User-Provided Information

• Registration information (name, email address, phone number)
• Payment information (processed securely through Stripe)
• Profile information
• Messages and content sent through the service
• Information from event organizers: Event details, descriptions, dates, locations, ticket types, and prices.
• Information from ticket buyers: Details about purchased tickets and the events they pertain to.

Automatically Collected Information

• Location data (when you give the app permission to use your location, e.g., to find nearby events)
• Device identifiers and other technical information about your device
• Service usage information (e.g., app interaction patterns, web shop visits)
• Camera data (used with your permission for scanning ticket QR codes; images are processed locally and not stored)
• Error reporting and diagnostic information

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve our service
• To facilitate the purchase and delivery of tickets
• To enable event organizers to manage their events, view sales data, and access attendee lists
• To enable communication between organizers and ticket buyers
• To process payments and provide customer support
• To provide event recommendations or information based on preferences or location (with your consent)
• To customize your experience and provide personalized content
• To analyze service usage and improve our service
• To send you service-related notifications and marketing messages (if you have given consent)
• To detect and prevent fraud and abuse
• To comply with legal obligations

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under the GDPR (General Data Protection Regulation):

• Performance of a Contract: We process data that is necessary to fulfill our service agreement with you. This includes managing registration, enabling ticket purchases and delivery, and facilitating event management for organizers.
• Consent: When we ask for your consent for specific processing activities, such as sending marketing communications, using optional location data, or setting non-essential cookies, we process your data based on that consent. You can withdraw your consent at any time.
• Legitimate Interest: We process data based on our legitimate interests, for example, to develop and improve our services, generate analytics, prevent fraud, and ensure security. We always balance our legitimate interests against your rights and freedoms.
• Legal Obligation: We process data to fulfill our legal obligations, such as retaining transaction records as required by accounting laws.

5. Cookies and Other Tracking Technologies

We use cookies and similar technologies (such as local storage) on our website and in our app to improve your user experience, analyze service usage, and ensure functionality.

• Essential Cookies: These are necessary for the basic functions of the service, such as login and shopping cart functionality.
• Analytics Cookies: These help us understand how users interact with our service so we can improve it (e.g., Google Analytics). Data is often collected anonymously.
• Functional Cookies: These enable a more personalized experience, such as remembering language preferences.

You can manage cookie settings through your browser settings. Note that disabling essential cookies may affect the functionality of the service. We may also ask for your consent for non-essential cookies via a separate cookie banner.

6. Information Sharing and Third Parties

We may share your information with the following parties:

• Event Organizers: We share necessary ticket buyer information (such as name, email, purchased tickets) with the organizer of the event for which the user purchased a ticket, enabling the organizer to manage the event, verify access, and communicate with attendees. In this context, the event organizer acts as a data controller for this data, and we act as their data processor.
• Service Providers: We use third parties that help us provide services, such as:
  • Firebase (Google): for authentication and app backend services. Read more about Google's privacy policy: https://policies.google.com/privacy
  • Stripe: for payment processing. Read more about Stripe's privacy policy: https://stripe.com/en-fi/privacy
  These service providers process data on our behalf and according to our instructions.
• Authorities: We may disclose information if required by law or in connection with legal proceedings
• Business Transfer: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transfer
• Partners: We may share your information with our partners to provide services

We do not sell your personal data to third parties.

7. Protection of Your Information

We use reasonable technical, administrative, and physical measures to protect the personal information we collect. However, no method of transmission over the internet or electronic storage method is 100% secure.

8. Your Rights

In the European Economic Area (EEA) and other areas covered by applicable data protection laws, you have the following rights:

• Access: The right to know what personal data we have about you
• Rectification: The right to request correction of inaccurate data
• Deletion: The right to request deletion of your data ("right to be forgotten")
• Restriction: The right to request restriction of processing of your data
• Data Portability: The right to receive your data in a structured, commonly used format
• Objection: The right to object to processing of your data in certain situations
• Withdrawal of Consent: The right to withdraw your consent at any time

You can exercise these rights by contacting us via email at support@keino.io. We aim to respond to requests as soon as possible, usually within one month.

9. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this privacy policy, unless a longer retention period is required or permitted by law. Examples of retention periods:

• User account information is retained as long as the account is active or until you request its removal.
• Transaction and payment data is retained for the period required by Finnish accounting legislation (typically 6 years from the end of the financial year).
• Analytics and log data may be anonymized or deleted after a shorter period (e.g., 1-2 years) when no longer needed for service improvement or troubleshooting.

10. Children

Our service is not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so that we can take appropriate action.

11. International Data Transfers

Your information may be transferred to and processed in countries where data protection laws may differ from those in your country. In these cases, we ensure that your information is transferred in accordance with appropriate safeguards.

12. Changes to the Privacy Policy

We may update this privacy policy from time to time. We will notify you of significant changes by posting the new privacy policy and, if necessary, by notifying you via the app or email.

13. Contact Us

If you have any questions about this privacy policy or the processing of your data, please contact us:

Audience Engage Oy (KEiNO.io)
Linnankatu 3
20100 Turku, Finland
Email: support@keino.io
Business ID: 2786950-7