Other Covered Entities

PatronManager, LLC
ShowClix

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 10/13/2016
Next Certification Due Date: 10/22/2022
Data Collected: NON-HR

Purpose of Data Collection

Applicant collects data for account registration, use of certain products or services offered by Applicant, upon visiting Applicant's web pages to customize advertising and content seen and/or to fulfill requests for certain products and services and/or to contact persons about specials and new products. Users of our event registration services agree to volunteer some information about themselves so we can provide the highest level of service to them. This information may include name, email address, mailing address, phone, as well as other information required to complete the registration process. Additional information may be collected for functional, marketing and analytical purposes about user behavior including IP addresses, approximate geographic regions, browsers, operating systems, and other device characteristics.

Privacy Policy

Non-HR Data

Description:

Privacy Policy This Privacy Policy covers Patron Technology’s treatment of personally identifiable information that Patron Technology Inc. (“Patron Technology”) collects when you are on the Patron Technology site (www.patrontechnology.com), and when you use Patron Technology’s services. This policy also covers Patron Technology’s treatment of any personally identifiable information that Patron Technology’s business partners share with Patron Technology or that Patron Technology may collect on a partner’s site. This Privacy policy also covers our collection, use and disclosure of personal information that we collect through our service. The use of information collected through our service is limited to the purpose of providing the service for which our client has engaged Patron Technology. This policy does not apply to the practices of companies that Patron Technology does not own or control or to people that Patron Technology does not employ or manage. Privacy Shield Patron Technology participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Patron Technology is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. Patron Technology is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Patron Technology complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Patron Technology is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Patron Technology may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted. ‍ 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 Patron Technology disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Your Ability to Edit and Delete Your Account Information and Preferences), 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. ‍ NON-DISCRIMINATION 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. ‍ Information Collection and Use Patron Technology collects personally identifiable information when you register for a Patron Technology account, when you use certain Patron Technology products or services, when you visit Patron Technology pages, and when you enter promotions or sweepstakes. Patron Technology may also receive personally identifiable information from our business partners. When you register with Patron Technology, we ask for your company name, address, email address, phone number, and additional business-related information. Once you register with Patron Technology and sign in to our services, you are not anonymous to us. Patron Technology also automatically receives and records information on our server logs from your browser including your IP address, Patron Technology cookie information, and the page you requested. Patron Technology uses information for three general purposes: to customize the advertising and content you see, to fulfill your requests for certain products and services, and to contact you about specials and new products. In the case your information is processed by Patron Technology on behalf of a client, personally identifiable information such as name, address, email address, and phone number may be processed in the sole discretion of the Patron Technology client based upon the services subscribed to by the client. ‍ Information Sharing and Disclosure We will share your personally identifiable information with third parties only in the ways that are described in this privacy policy. Patron Technology will not sell or rent your personally identifiable information to anyone. Patron Technology may send personally identifiable information about you to other companies or people when: we have your consent to share the information; we need to share your information to provide the product or service you have requested; we need to send the information to companies who work on behalf of Patron Technology to provide a product or service to you. These companies provide services to us, such as hosting our email systems, providing hosting for streaming media content, and the back-up of our data. Unless we tell you otherwise, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us in providing our service to you. Some of our pages utilize framing techniques to serve content from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.patrontechnology.com. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site. We may also disclose your personally identifiable information if Patron Technology is involved in a merger, acquisition, or sale of all or a portion of its assets, and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information. Your information may be shared with a third party for the following business purposes: Auditing - Advertising analytics, Auditing legal and regulatory compliance Security - Detecting security breaches, Protecting against fraud and malicious activity, Taking action against wrongdoers (e.g. fraudsters and hackers) Debugging - Identifying and fixing technical errors Short-term uses - Contextual ad customization that does not involve or contribute to profiling Performing services - Account maintenance, Customer service, Processing transactions, Marketing Internal research to develop or demonstrate technology Testing or improvement of any service or device “owned, manufactured, manufactured for, or controlled by” the business. In the preceding twelve (12) months, Patron Technology 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] ‍ Tracking Technologies As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do link this automatically collected data to other information we collect about you. Patron Technology and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. ‍ To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: Digital Advertising Alliance (DAA)’s self-regulatory opt-out page and mobile application-based “AppChoices” download page‍ European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page‍ Network Advertising Initiative (NAI)’s self-regulatory opt-out page ‍‍ Links to 3rd Party Sites Our Site includes links to other Web sites whose privacy practices may differ from those of Patron Technology. If you submit personally identifiable information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit. ‍ Social Media Widgets Our Web site includes Social Media Features, such as the Facebook Like button and other interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. Security The security of your personally identifiable information is important to us. If you enter sensitive information (such as credit card numbers) on our registration forms, we encrypt that information using secure socket layer technology (SSL). To learn more about SSL, follow this link: ‍http://en.wikipedia.org/wiki/Secure_Sockets_Layer We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100 percent secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can email us at privacy@patrontechnology.com. Testimonials From time to time, we post customer testimonials on our Web site, which may contain personally identifiable information such as the customer’s name. In this case, we obtain the customer’s consent prior to posting the testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@patrontechnology.com. Blogs Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personally identifiable information from our blog or community forum, contact us at privacy@patrontechnology.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Our blog is also managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact of login into the third party application if you want the personally identifiable information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy. Promotions From time to time, we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary, and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as ZIP code). Communications from the Site – Newsletters If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for privacy, we provide you a way to unsubscribe within each newsletter. In addition, we also offer you the ability to edit and delete your account information (see next section). Your Ability to Edit and Delete Your Account Information and Preferences Upon request Patron Technology Inc. will provide you with information about whether we hold any of your personal information or are processing information that we have collected from you. You may access, correct, or request deletion of your personal information by emailing privacy@patrontechnology.com Patron Technology gives you the ability to edit your Patron Technology Account Information and preferences at any time by notifying us of the changes you wish to make by emailing privacy@patrontechnology.com. You may request deletion of your Patron Technology account or information by emailing privacy@patrontechnology.com. Please note that for personal information about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity–which determined the means and purposes of processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal information. All inquiries will receive responses within 30 days of our receipt of them. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. Please be advised that some statistical information may possibly remain in our archived records after your account has been deleted. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For California Residents: 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. Changes to this Privacy Policy We may update this Privacy Policy and its updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Effective Date of this Privacy Policy: 1/1/2020 For questions or comments on this policy email privacy@patrontechnology.com or write Privacy Manager, Patron Technology, Inc., 10675 Perry Hwy, #1316, Wexford, PA 15090

Effective Date: 1/1/2020
Description:

Privacy Policy This Privacy Policy is intended to help users of the ShowClix Service ("you") understand the information ShowClix ("we") collect from our website: www.showclix.com and how we use such information. The ShowClix Service ("the Service") encompasses the breadth of all ShowClix technology and services, including but not limited to ticket sales, event registration, access control, and client and customer service. By using the ShowClix Service, you are consenting to the use of your information as set forth in this policy. This Privacy Policy also covers our collection, use and disclosure of personal information that we collect through the Service. The use of this information collected through the Service is limited to the purpose of providing such service for which our client has engaged ShowClix. 1. What information do we collect? As part of the process of registering for an event, ticket buyers, or attendees, must agree to volunteer some information about themselves. This information may include name, email address, mailing address, phone, as well as other information required to complete the registration process. In the case your information is processed by ShowClix on behalf of a client, personally identifiable information such as name, address, email address, and phone number may be processed at the sole discretion of the ShowClix client based upon the services subscribed to by the client. In addition to information volunteered by users, ShowClix collects additional information about user behavior on ShowClix properties. This information includes IP addresses, approximate geographic regions, browsers, operating systems, and other device characteristics. ShowClix utilizes cookies and similar tracking techniques to recognize you for functional, marketing, and analytics purposes to improve our service. For a complete understanding of how cookies are used, please review our Cookie Policy. ShowClix does not knowingly collect personal information on children under the age of age 13. ShowClix Terms of Service prohibits children under the age of 13 from submitting personal information to ShowClix. If you believe data has been collected about a child under 13 years of age, please notify privacy@showclix.com 2. Why do we collect this information and how do we use it? First and foremost, information is collected to help us deliver the highest level of service to our users. Here are some of the specific ways in which we accomplish that: Use for Specific Purpose: Information provided for a specific purpose will be used for that purpose. Most commonly, this applies to information provided during the registration process, which will be used to fulfill your request to attend an event (for example, processing payments). Communication: ShowClix and event organizers may use the information you provide to communicate with you. Often, this communication channel exists to share important information, such as cancellation warnings, about the events you are attending. ShowClix and event organizers may also contact you to promote related events and other information. You can opt out of receiving marketing communications at any time, either during the checkout process or later in your account settings. ShowClix's Business: In order to continuously improve the product and the Service, we will use information provided to measure the performance of the Service to understand the ways in which our services are being utilized. Information can also be used for ShowClix's business, including but not limited to fraud prevention, business performance, and customer and market analysis. Event Organizers' Business: Some information will be shared with event organizers for business purposes, including but not limited to event access control, marketing and communication with attendees, and customer and market analysis. Personalization: ShowClix may use the information provided to deliver more personalized services, including but not limited to advertisements, local event recommendations, and content. The basis for ShowClix processing this information can be for one of the following reasons: Consent: You have given us specific consent to process your data by accepting our terms of service. Contract: You have entered into a contract with ShowClix and we are processing the data to fulfill the duties of that contract. Legitimate Interest: ShowClix and event organizers using ShowClix have a legitimate interest to collect and process that data. Most often these interests are related to the logistics or security for an event you are affiliated with. 3. How is this information shared? ShowClix may share your information with other parties in limited circumstances: Event Organizers: When you purchase a ticket or register as an attendee for an event, we will share your information and associated analytics with the organizer of that event. Vendors, Consultants, Service Providers: ShowClix works with vendors, consultants and service providers to perform business-related functions. These engagements can include payment processing, risk management services, analytics services, marketing services, software consultation, and others. During these engagements, we may need to share information provided in order to perform business-related functions. These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements, and are not allowed to use PI they receive from us for any other purpose. Legal Requirements: Where required by law, ShowClix may share certain information with law enforcement, courts, or government agencies. Business Transfer: In the event of a sale, merger, or change in control, we may also share your personal data as part of that business transfer. 4. What choices do I have about my information? As a user of ShowClix, you have some choices related to the use of your information. Any requests related to your information should be directed to privacy@showclix.com. You have the ability to opt-out of receiving marketing communication. You may do so at any time by submitting a request to privacy@showclix.com. You have the ability to see the data you have provided to ShowClix. You can do so at any time by logging into your account. Upon request, we will confirm whether we hold or are processing information that we have collected from you. Individuals within the European Union or European Economic Area are entitled to additional choices as a result of the data privacy law known as the EU General Data Protection Regulation, more commonly referred to as "GDPR". The following are those additional choices. Access and Export: As stated above, you have access to view your data at any time by logging into your account. You may also request a machine readable format export of your data by contacting privacy@showclix.com. Limit Use: You can request that we limit the use of your data by contacting privacy@showclix.com. Rectification: If you find inaccuracies in your information, you have the ability to request that those inaccuracies be corrected by submitting a request to privacy@showclix.com. Removal: You can request that your data be removed from the ShowClix system by contacting privacy@showclix.com. For legal, accounting, and safety reasons, some data may not be able to be immediately removed or anonymized. For example, to comply with anti-money laundering laws, we may be required to maintain personal information tied to financial transactions. Such data may only be able to be removed after a minimum required data retention period. 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 ShowClix 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 privacy@showclix.com. 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. NON-DISCRIMINATION: 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, ShowClix 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] Privacy Shield Notice ShowClix participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. ShowClix is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. ShowClix is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. ShowClix complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, ShowClix is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ShowClix may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. For questions or comments on this policy email privacy@patrontechnology.com or write Privacy Manager, Patron Technology, Inc., 10675 Perry Hwy, #1316, Wexford, PA 15090 Changes to this Privacy Policy We may update this Privacy Policy and its updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Updated May 10, 2021

Effective Date: 5/10/2021

Verification Method

TRUSTe

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Patron Technology, LLC at:

Mark Famiglietti
VP, Data Security and Privacy Compliance
Patron Technology, LLC
650 Smithfield St, Floor 13, Pittsburgh, PA 15222
10675 Perry Hwy, #1316
Wexford, Pennsylvania 15090

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Patron Technology, LLC to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Patron Technology, LLC regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission