PRIVACY POLICY

Last Updated: December 4, 2017

1. Who We Are. Jujamcyn Theaters Productions LLC, and its parent and affiliated companies (“Jujamcyn”), are theatrical producers and theater owners with primary offices located in New York City. Lucky Seat is an unincorporated subdivision of Jujamcyn that operates services (including, without limitation, digital lotteries) oriented towards advertising, marketing, and promoting the sale of tickets to live events. The terms, “Lucky Seat”, “Us”, “We”, and “Our”, as used throughout this Privacy Policy, refer to the Lucky Seat subdivision of Jujamcyn.
IF YOU ARE LOCATED WITHIN THE EUROPEAN ECONOMIC AREA (“EEA”): For the purposes of the European General Data Protection Regulation (“GDPR”), Jujamcyn shall be considered the data controller of your PII (as defined in Section 5 below).

2. Why We Have Instituted This Privacy Policy. Lucky Seat has created this Privacy Policy (“Policy”) to be as transparent as possible with regard to how We obtain, maintain, and ultimately use information provided to Us by consumers like You (“You”, “Yours”). The Policy applies to all information provided to Us by You through any means. For purposes of illustration only, this Policy applies to all users of Our website(s), all Our services including Our services provided through third party branded apps (e.g. digital lottery service) or otherwise made available via telephone and any transactions that take place in person, or by postal or electronic mail (collectively, “Site”, “Sites” or “Our Sites”).
IF YOU ARE LOCATED WITHIN THE EEA: please also see Section 15 of this Policy which sets out the additional information the GDPR requires Us to provide to You to explain our processing activities and your rights in relation to those activities.

3. Where this Policy Applies.Transactions that transpire on Our Sites occur, or are deemed to occur, within the United States of America (“USA”). This Policy shall be governed by the privacy and other laws and regulations of the USA and any other mandatory laws and regulations (including without limitation the GDPR). Lucky Seat makes no representation or warranty that Our Sites or services operate in accordance with the laws of any other nation, or that they or any part thereof, is appropriate for use in any particular nation or political subdivision (collectively referred to as “Nation”). Those who access and use Our Sites from another Nation do so at their own initiative and risk and are responsible for complying with all local laws, rules and regulations of the Nation from which Our Sites are accessed. Your use of Our Sites is Your acknowledgement that Our Sites and the products and services rendered by Us are subject to the laws and regulations of the USA and any other mandatory laws and regulations (including without limitation the GDPR).

We reserve the right to change, modify, add, or remove (“Change”) provisions of this Policy and We will endeavor to notify You of any such material Change. Any such Change shall be effective immediately. Please check back from time to time to ensure continuing familiarity with the most current version of Our Policy. You can determine whether this Policy has been revised since Your last visit to Our website by referring to the “Last Updated” legend at the top of this Policy.

4. Your Acknowledgement of this Policy.Please read this Policy carefully. Your use of Our Site or Your use of other means of providing Your PII to Us constitutes Your acknowledgement of the terms and conditions of this Policy without limitation, qualification or change. If You do not agree with this Policy or any other policy on Our Sites, or in Our printed materials, do not use Our services or Sites. Use of Our Sites is also governed by our Terms and Conditions, located at https://www.luckyseat.com/terms.php

5. What Information We Collect.Lucky Seat uses SSL or “Secure Sockets Layer”, an industry standard protocol, for completing online transactions including when We gather information from You. We collect two (2) types of information from You through the use of Our Site: “Personally Identifiable Information” (or “PII”) and “Non-Personally Identifiable Information” (or “Non-PII”).

A. Personally Identifiable Information Includes. Generally, you may provide us with PII when you enter into a lottery through the Site(s), by email or contacting us, by responding to marketing or other communications, or some other means. PII is information that identifies or can identify You as an individual, whether by itself or in combination with other information. The PII We collect from You when You enter a lottery may include Your first and last name, postal address, zip code/post code, telephone number, e-mail address, age, and similar information you provide which may be relevant to your enquiry. In some cases, depending upon the technology You employ to gain access to the Internet and ultimately, Our Sites, Your Internet Protocol (“IP”) address may be deemed by some jurisdictions as PII. In addition some non-personally identifiable PII, as referred to in Section 5.B., may be deemed to be PII to the extent that it is combined or cross-referenced with other PII. B. Non-Personally Identifiable Information. Non-PII is anonymous and does not identify You personally. Non-PII is generally collected through the Site from four different sources: Internet protocol addresses and web logs; cookies; pixel tags and other similar technologies; and other Non-PII that You voluntarily provide (as explained below). When You visit and interact with the Site, We and third parties with whom We have contracted to provide services to Us, may collect Non-PII (for example, a catalog of the Site pages You visit). i. IP Protocol Addresses and Web Logs. Our Site’s web servers may automatically collect the Internet Protocol (IP) addresses and log files of visitors. Your IP address is an identifying number that is automatically assigned to Your computer by Your Internet Service Provider (ISP). This number may be identified and logged automatically in Our server log files whenever You visit Our Sites, along with the time(s) of Your visit(s) and the page(s) that You visited. This information is collected in an aggregate form only and does not contain any PII. Collecting IP addresses is standard practice on the Internet and is done automatically by many sites.  ii. Pixel Tags. We and Our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted e-mail messages to track Your use of Our Site in order to provide You with more useful information and a more personalized experience the next time You visit. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags do not contain any PII and allow Us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when an e-mail has been opened.  iii. Cookies. We and Our third party service providers use a standard technology called a “cookie” to collect information about how You use the Site. Cookies reside on Your computer and help the Site recognize Your computer’s browser as a previous visitor. On occasion Our Site may also set a “session cookie” which helps Us administer the Site. The session cookie expires when You close Your browser and does not retain any information about You after it expires. Our Site also uses analytics cookies, which collect information about how You use our Site, including the pages You have visited and the links You have followed. We only use this information for Our own internal analytical purposes and not for marketing purposes. The analytics cookies used on our Site are set out below:

Cookie Name Purpose Duration
Google Analytics cookies. Find out more here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_ga Our Site employs cookies from Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. Google Analytics cookies are used to collect information about how visitors use Our Site. The cookies collect information in an anonymous form. We use the information to compile internal reports and to help us improve Our Site. Google holds this information and provides us with access to it. The _ga cookie is used to distinguish one visitor to Our Site from another and helps Us to understand if You have visited Our Site before. Two years from set/update.

If You do not want information collected through the use of cookies, You should be able to modify Your browser preference to provide You with choices relating to cookies. You can also use a browser plugin, available at https://tools.google.com/dlpage/gaoptout?hl=en, to opt out of all cookies used with Google Analytics tracking software, which We use on the Site. If You choose to reject cookies, You may be unable to use certain Site services (e.g., those services that require You to log on to the Site in order to participate). Understand that technology is ever changing and We move forward and employ the latest forms of technology to assist Us in providing Our customers with better experiences. More general information about cookies can be found here: www.allaboutcookies.org/.
Your continued use of Our Sites is Your consent to us using cookies in the manner described above.
IF YOU ARE LOCATED WITHIN THE EEA: By using the Sites You acknowledge that We may store and access essential cookies on your computer or other device. Essential cookies are cookies which are essential for the operation of our Sites. Further, where You give permission, We may also store and access certain non-essential cookies on your computer or other device. These cookies are not essential to the operation of our Sites but allow Us to provide additional functionality or to gather additional information about Your use of our Sites. You are not obliged to give consent to Our use of non-essential cookies and We will not place such cookies until You have given Your consent. If You wish to block or delete cookies, or You would like to withdraw consent to Our use of non-essential cookies, You can find out how to do so in the above paragraph.

6. How Information We Collect Is Used. We know You want Your PII that You share with Us to be protected from unauthorized use. That’s why We take appropriate security measures to help safeguard this information from unauthorized access and disclosure. For example, we use firewalls to help prevent unauthorized access to Your PII.

We want You to feel confident when using Our Site. However, You should know that no system is completely secure. Although We use industry accepted and commercially reasonable efforts to secure Your information, there is always a chance that it will not always remain secure. For example, avoid sending PII through insecure e-mail. We will not ask You to send Us any financial information via electronic mail.

A. Non-Personally Identifiable Information. We may use Non-PII to measure the number of visits to, and, average time spent on, the Site, and the pages viewed, as well as to diagnose problems with Our servers and to administer the Site in general. The resulting information may be used to analyze and improve the features and functionality of the Site.

We reserve the right to share such Non-PII, with any number of third parties (for example, advertisers), who are not part of the Lucky Seat family on an aggregated or other basis that does not disclose any of Your PII. In some instances, We may combine Your Non-PII with PII (such as embedding e-mail addresses in cookies). If We do combine any Non-PII with PII, the combined information will be treated as PII. This “combined” PII is not shared with third parties, except as described in this Policy.

B. Personally Identifiable Information.

i. Provision of the Site. The PII You provide may be used to administer lotteries, sweepstakes, promotions, surveys or other Site features, as well as tailor Your Site experience to Your interests, to show You content in which You may be interested and to display the content according to Your preferences. Unless we are prohibited by applicable law, we may also share Your PII within the Lucky Seat business family and any entity with which the foregoing parties have an agreement or arrangement to jointly operate a digital lottery business (a “Joint Operator”) in order to provide our services to You. To the extent We do so, We make sure that Your PII receives the same level of protection as it does on Our Sites. All companies affiliated with Us and any Joint Operators comply with applicable privacy and security laws applicable to them and, at a minimum, in any commercial e-mail they send to You, will give You the opportunity to choose not to receive such e-mail messages in the future. Please note that such sharing may involve the collection, use, storage, or disclosure of PII outside the US. FOR CANADIANS: Please note that such sharing may involve the collection, use, storage or disclosure of PII outside of Canada in the U.S. and therefore Your PII may be subject to access under the laws of that jurisdiction. IF YOU ARE LOCATED WITHIN THE EEA: we will not share your PII with third parties for their own marketing purposes without Your consent.

ii. Marketing Communications. When You enter a digital lottery or use Our other services, becoming a customer of Us, You will to the extent permitted by applicable law be automatically enrolled to receive future communications from Us. Unless You opt out, We may use Your PII to send You information about Us and/or Our services, as well as promotional material on behalf of companies within Our business family, any Joint Operator and select partners, where and as long as permitted by applicable law. IF YOU ARE LOCATED WITHIN THE EEA: we or third parties will only use your PII to send you electronic marketing (including via email or social media) about products or services you may be interested in with Your consent.

iii. Administrative Matters. We reserve the right to contact You in the event of a change in the Policy or to notify You of other administrative matters in connection with the Site or Our business (e.g., contacting You to facilitate, complete or confirm a transaction), where permitted by applicable law. Where this information facilitates, completes or confirms a transaction with Us, or where this information may be otherwise important to Your use of the Site, You may not opt-out of receiving such communications, except where applicable law requires.

iv. Fulfillment of Requests. We may use Your PII to fulfill the purpose for which such PII was provided (e.g., to confirm Your entry or fulfill Your transaction). Once You have registered with Our Site, forms may sometimes be pre-populated with Your PII in order to facilitate a transaction between You and Us on subsequent visits.

v. Internal Business Purposes. We may also use Your PII for Our internal business purposes, such as to target advertising, for data analysis, and for other internal purposes. We will also use Your PII to comply with Our legal obligations, to enforce Our legal rights, to protect the rights of third parties and in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of Our assets.

vi. Purchases. From time-to-time We may offer merchandise, ticket purchase opportunities and/or other products or services for sale from one of Our e-commerce partners. To the extent the merchandise, ticket purchase opportunities and/or other products or services are offered by one of Our e-commerce partners, such e-commerce partner will be collecting and using the PII You provide. For more information regarding Your transactions with Our e-commerce partners, please refer to Section 8.A. below.

vii. Online Surveys and Feedback .From time to time, We may invite You to provide feedback about Us and Our products and services in the form of online or postal surveys. We will collect PII when doing so. We use this information to help Us improve the quality of customer service provided by Our staff. We also use Your survey responses to monitor the quality of Our products and services and to assist with the selection of future product and service lines.

viii.Sweepstakes and Other Promotions. We may administer lotteries, conduct online surveys and/or offer sweepstakes or other promotions on the Site (each referred to as a “Promotion”), and We may collect PII when doing so. We use Your PII to administer the Promotion including in relation to the award and distribution of prizes. We may use Your PII to contact You regarding Your Promotion entry, or to contact You if You win a Promotion (if applicable), where permitted by applicable law. You should carefully review the Promotions rules (if applicable) in which You participate through the Site, as they may contain additional important information about Lucky Seat’s use of Your PII. To the extent such rules conflict with this Policy, such rules will govern that particular Promotion.

xi.Facebook Custom Audiences or similar. We may serve ads on third party services (including social media platforms) that are targeted to reach people on those services who are identified in our data bases. This is done by matching common factors between Our data bases and the data bases of third party operators. For example, we use Facebook’s “Custom Audience” services which allow Us to show advertisements on Facebook to people whose information and email addresses We already have because they have already subscribed to receive Our emails or have entered into a digital lottery. To enable this form of marketing, Your encrypted email address is shared with Facebook, under the terms of their Facebook Customer Audiences services. If You no longer wish to see Our Facebook Custom Audience ads, You can opt out by sending an email, from the email address you are opting out, to Our email address provided in the paragraph entitled “Contacting Us Regarding Our Sites”. Include Your name and email address in the body of the email and specify that You would like to opt out of Our Facebook Custom Audience advertisements. IF YOU ARE LOCATED WITHIN THE EEA: we shall only use your PII to send you such target advertising with Your consent.

7. How Personally Identifiable Information We Collect Is Disclosed

A. Affiliate Communications and Third Party Communications. Unless You opt out, or we are prohibited by applicable law, We may share Your PII with Our affiliates, including Our Joint Operators and other digital lottery partners, venues, producers, promoters, presenters or sponsors of events, artist representatives and fan clubs, teams, leagues and others who are involved in or bring You events. When You enter a digital lottery or use other services on Our Site, You consent to allow Us to provide Your PII to these event providers and their contractors. We share this information so these event providers may send You announcements and notifications of events, products or services that might be of interest to You, where permitted under applicable law. For further information, please see the “Opt-Out Policy” section below. IF YOU ARE LOCATED WITHIN THE EEA: Please note that we or selected third parties will only use your PII to send you electronic marketing (including via email or social media) about products or services you may be interested in with Your consent.

B. Service Providers. We work with third parties who provide services including but not limited to data analysis, digital lottery administration, order fulfillment, credit card processing and other services of an administrative nature. We want You to know that We reserve the right to share Your PII with such third parties for the purpose of enabling these third parties to provide such services to Us so that We may provide Our services. We take reasonable steps to ensure these third parties treat PII in a manner comparable to how We do so.

C. Online Surveys/Sweepstakes. We may share PII collected in connection with Promotions conducted through Our Sites with the third-party sponsor(s) and/or the prize provider(s) of any such Promotions (irrespective of whether such Promotions are hosted by Us), or the Joint Operators, or otherwise in accordance with the rules applicable to such Promotion, in each case as may be necessary to provide You with the Promotion. You should carefully review the rules, if any, of each Promotion in which You participate through the Site, as they may contain additional important information about a sponsor’s or other third parties’ use of Your PII. To the extent such rules conflict with this Policy, the rules of the particular Promotion shall apply. IF YOU ARE LOCATED WITHIN THE EEA: Please note that we will only share your PII with third party sponsor(s), prize provider(s) and/or Joint Operators to enable them to send you electronic marketing (including via email or social media) about products or services you may be interested in with Your consent.

D. Other Purposes.We and our Joint Operators also may disclose Your information:

i. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or another government agency; to establish or exercise Our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, We may raise or waive any legal objection or right available to Us.  ii. When We believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Our company, Our users, Our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce Our Site terms and conditions or other agreements or policies.  iii. In connection with a substantial corporate transaction, such as the reorganization or sale of Our business, a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.

8. Collection of Information by Affiliates

A. Transactions With E-Commerce Partners, Vendors and Advertisers. When You provide PII to one of Our Site’s e-commerce partners, vendors or advertisers, this transaction will occur in connection with the site of the e-commerce partner, vendor or advertiser, not on the Site, and, as such, the PII You provide is collected pursuant to and controlled by the privacy policy of such e-commerce partner, vendor or advertiser. Lucky Seat is not responsible for such parties’ privacy policies and We encourage You to familiarize yourself with the applicable privacy policy of the e-commerce site with which You transact business or to contact the operator of such site for more information.

The third party collecting Your PII will share such PII with Us so that We can review Your information and, if applicable, respond to Your query. Please note that We have no obligation to respond to all queries submitted. Any PII that We receive from such third party will be treated in accordance with this Privacy Policy.

B. Third Party Links. The Site may contain links to third-party Internet Sites, which are not owned or operated by Us. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Us. If You provide any PII through any such third-party Site, Your transaction will occur on such third party’s site (not the Site) and the PII You provide will be collected by, and controlled by the privacy policy of, that third party. We are not responsible for the privacy practices or the content of such third-party sites, including such sites’ use of any PII that You provide to them. We strongly encourage You to become familiar with the privacy practices of those sites.

9. Opt-Out Policy

A. Communications. When You supply Us with PII, from time-to-time, in Our discretion, You may be asked to indicate whether You are interested in receiving information from Us, about special offers in connection with the Site, from Lucky Seat affiliates, Joint Operators and/or Our advertisers and other partners. Unless You opt out to receive such communications, We may, from time to time, send You such marketing communications. IF YOU ARE LOCATED WITHIN THE EEA OR YOU ARE A CANADIAN RESIDENT: Notwithstanding the foregoing, We will not send you such marketing communications by electronic means unless You have expressly consented to receive electronic marketing and have not withdrawn Your consent in accordance with the following.

If You no longer desire to receive the commercial e-mails We send, You will be given the opportunity to opt out of receiving such messages in the future by clicking on the link at the bottom of the e-mail that says “unsubscribe,” “opt out”, or “To update your email preferences or to be removed from our lists”. It may take up to 10 days for Us to process an opt-out request. Even if You have unsubscribed from receiving third party promotional e-mails from Us, We may send You other types of important e-mail communications without offering You the opportunity to opt out of receiving them, where permitted by law. These may include customer service announcements, administrative notices, digital lottery administration for the purpose of contacting entrants in relation to a digital lottery, and surveys. Please note that opting out of receiving promotional e-mail communications will affect only future communications from Us. If We already provided Your information to a third party before You changed Your preferences or updated Your information, You may have to change Your preferences directly with that third party as well.

B. Affiliate and Third Party Communications. From time-to-time, You may be provided with the opportunity to opt-in to receive offers directly from Our affiliates and third parties. Once You have opted in to such opportunities, unless You opt out to accept any such offer(s), any PII provided to Us for such purposes may be shared with third-party partner(s), to allow such third parties to provide You with valuable information You may enjoy. If You would prefer that We no longer share Your PII with Our affiliates and/or with third parties for their marketing purposes, You may opt-out of such future sharing at any time by following the procedure above, provided however, You may not be able to opt out of certain third party offers that are displayed on Our Site except where applicable law requires. IF YOU ARE LOCATED WITHIN THE EEA: Please note that we will only share your PII with Our affiliates and third parties so to enable them to send you electronic marketing (including via email or social media) about their offers, products or services you may be interested in with Your consent.

10. Use of This Site by Children Under the Age of 13 Prohibited. Lucky Seat is a family oriented business. We adhere to the principles set forth in the Children’s Online Privacy and Protection Act (“COPPA”), as amended, and ask You, if a parent or guardian of minor children, to familiarize yourself with the prescribes of COPPA. Our Sites are not developed with the intention that they will be used by minors and specifically, they are not directed to children aged thirteen (13) or younger. We request that any person aged thirteen (13) or younger not use Our Sites. If a parent or guardian believes that his or her child may have provided Us with PII, for example, by misrepresenting his or her age, that parent or guardian should contact Us at privacy@luckyseat.com with the particulars of the information We are alleged to have collected. If We determine that Your child under the age of thirteen (13) years old has provided Us PII We will immediately delete all such information. For additional information regarding the use of the Internet by minors visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting kids’ privacy online http://www.onguardonline.gov/topics/kids-privacy.aspx
IF YOU ARE LOCATED WITHIN THE EEA: Our Sites and the commercial products and services that We offer are not specifically targeted at children, although We appreciate that they may appeal to children. If You are under the age of 18, We ask that You obtain Your parent’s or guardian’s consent before submitting any personal information to Us or requesting any products or services from Us. If You are a parent or guardian of a child under 18, please ensure that You supervise Your child’s use of Our Sites and Our products and services and ensure they obtain Your consent before submitting any personal information to Us or requesting any products or services from Us. For the purpose of safeguarding the rights, interests and freedoms of children, We may ask You to verify Your age in order to continue using Our Sites and/or any of Our products and services You may have requested.

11. Security of Your PII. We employ reasonable security measures consistent with standard industry practice, for PII collected through Our Sites, including physical, electronic and operational measures to maintain security and prevent unauthorized access. While We take reasonable and appropriate steps to safeguard PII under Our control, unfortunately, no data transmission over the Internet or method of storing data can be guaranteed to be one hundred percent secure. As such, We cannot guarantee that PII supplied by You will not be accessed on Our servers, or intercepted while being transmitted to Us over the Internet. We, Jujamcyn, and Jujamcyn’s affiliates and Joint Operators assume no liability for any damages You may suffer as a result of interception, alteration or misuse of information during such transfers. If You have reason to believe that there has been any breach of the security of the Site, please contact Us at privacy@luckyseat.com.

12.Limitation of Liability. Lucky Seat, Jujamcyn and Jujamcyn’s affiliates and Joint Operators will not under any circumstances be liable to You for any consequential, incidental or special damages (including but not limited to lost revenue or profits) arising out of Your use of Our Sites, even if apprised of the likelihood of such damages occurring. Notwithstanding the foregoing, Lucky Seat’s liability is limited to the actual cost of any product or service purchased by You through Our Sites. Nothing in this Policy limits or excludes Our liability to You for: (i) death or personal injury caused by our negligence or the negligence of our employees, officers, agents or subcontractors; (ii) fraud or fraudulent misrepresentation; or (iii) any other liability which cannot be limited or excluded by applicable law.

13. Contacting Us Regarding Our Sites. If You have any questions concerning this Policy, Our privacy practices or Your PII, You may send them by e-mail to privacy@luckyseat.com. Please note that e-mail communications will not necessarily be secure; accordingly You should not include credit card information or other sensitive information in Your e-mail correspondence with Us. You must send any official correspondence to:

Jujamcyn Theaters Productions LLC (d/b/a Lucky Seat) 246 West 44th Street New York, NY 10036

14. Your California Privacy Rights. If You are a California resident, You have the right to request information about how We share certain categories of PII with third parties. California law gives You the right to send Us a request at a designated address to receive the following information:

A. the categories of information We disclosed to third parties for their direct marketing purposes during the preceding calendar year; B. the names and addresses of the third parties that received that information; and C. if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

15. Additional information applicable to You if You are located within the EEA.
A. Legal basis for processing.
Under the GDPR, We are required to tell You the legal basis We are relying on to process Your PII for the purposes set out in this Policy and, in particular, the purposes set out in Section 6.
Where Your PII is completely anonymized, We do not require a legal basis to use it as the information will no longer constitute PII that is regulated under data protection laws. However, our collection and use of such anonymized PII may be subject to other laws where your consent is required. Please see the Section about Cookies above.
The below table explains our legal basis for such processing:

Purpose of processing Legal basis
Provision of the Site It is necessary for us to use Your PII to perform Our obligations in accordance with any contract that We may have with You or it is in Our legitimate interest or a third party’s legitimate interest to use PII in such a way to ensure that We provide the products and services You have requested in an effective and efficient way.
Marketing Communications We will only send You marketing communications by email and other electronic means where You have consented to receive such communications by that method, or where We have another lawful right to do so. We will only pass Your PII to third parties for their own marketing purposes where You have consented. Where We are processing Your PII in connection with personalized marketing (i.e. to decide what sort of marketing to send you based on Our understanding of Your interests), it is in Our legitimate interest to use Your PII for marketing purposes.
Administrative Matters It is necessary for Us to use Your PII to perform Our obligations in accordance with any contract that We may have with You or it is in Our legitimate interest or a third party’s legitimate interest to use PII in such a way to ensure that We provide the products and services You have requested in an effective and efficient way.
Fulfillment of Requests It is necessary for Us to use Your PII to perform Our obligations in accordance with any contract that We may have with you or it is in Our legitimate interest or a third party’s legitimate interest to use PII in such a way to ensure that We provide the products and services You have requested and respond to Your requests and enquiries in an effective and efficient way.
Internal Business Purposes Where we use your PII in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. We have a legal obligation to use Your PII to comply with any legal obligations imposed on Us, such as a court order.
Purchases It is necessary for Us to use Your PII to perform our obligations in accordance with any contract that We may have with You.
Online Surveys and Feedback It is in Our legitimate interest to use the PII provided by You in Your feedback or survey response for the purposes of improving Our products and services and the quality of the service provided by Our staff.
Sweepstakes and Other Promotions It is necessary for Us to use Your PII to perform Our obligations in accordance with any contract that We may have with You (e.g. the terms and conditions applicable to the promotion to which You may be asked to agree as a condition of entry) or it is in Our legitimate interest to use Your PII to enable You to participate in any prize draws, prize competitions and other promotions We may run from time to time.
Facebook Custom Audiences or similar remarketing services We will only send You marketing communications using the Facebook Custom Audiences or similar remarketing services where You have consented to receive such communications.

B. How We Obtain Your Consent. Where Our use of your PII requires Your consent, You can provide such consent either at the time We collect Your personal information following the instructions provided or by informing Us using our details in the Contacting Us Regarding Our Sites section above.

C. Duration of processing. Regarding PII We have processed in connection with the supply of Our products and services to any person or organization, We will retain PII relevant to that supply of products or services for six years from the date of supply and in compliance with Our obligations under the GDPR (or similar legislation around the world). We may then destroy such files without further notice or liability. Regarding any other PII We have processed, We will retain relevant PII for three years from the date of Our last interaction with the relevant person or organization and in compliance with Our obligations under the GDPR (or similar legislation around the world). We may then destroy such files without further notice or liability. If any PII is only useful for a short period (e.g. for a specific marketing campaign), We may delete it at the end of that period.

D. Sharing PII. We will only share PII with others when We are legally permitted to do so. When We share PII with others, We put contractual arrangements and security mechanisms in place to protect the PII and to comply with Our data protection, confidentiality and security standards. We explain the types of third parties with whom we share Your PII in the relevant sections of this Policy above.

E. Transfers of your PII outside the EEA. We are a U.S. organization and many of Our suppliers are U.S organizations. Therefore when you submit PII through our Sites, Your PII will be transferred to the United States of America where it will be stored and processed by Us and, where applicable, our suppliers and other third parties referred to in this Policy for the purposes specified in this Policy. The laws of the United States of America may not offer the same standard of legal protection for Your PII that You enjoy in Your own country. However, We will comply with Our legal and regulatory obligations in relation to Your PII including having a lawful basis for transferring Your PII and putting appropriate safeguards in place to ensure an adequate level of protection for Your PII where it is transferred outside the EEA.

F. Your rights. You have the following rights in relation to the PII we hold about You:
Your right of access: If you ask us, we will confirm whether we are processing your PII and, if so, provide you with a copy of that PII (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification: If the PII we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your PII with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your PII with so that you can contact them directly.
Your right to erasure: You can ask us to delete or remove your PII in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your PII with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your PII with so that you can contact them directly.
Your right to restrict processing: You can ask us to block or suppress the processing of your PII in certain circumstances, such as where you contest the accuracy of that PII or you object to us processing it. It won’t stop us from storing your PII, though. We will tell you before we lift any restriction. If we have shared your PII with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your PII with so that you can contact them directly.
Your right to data portability: You have the right, in certain circumstances, to obtain PII you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object: You can ask us to stop processing your PII, and we will do so, if we are: (i) Relying on our own or someone else’s legitimate interest to process your PII, except if we can demonstrate compelling legal grounds for the processing; (ii) Processing your PII for the purposes of personalised direct marketing; or (iii) Processing your PII for the purposes of non-personalised direct marketing.
Your rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your PII, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our details in the Contacting Us Regarding Our Sites section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your PII, please contact us using our details in the Contacting Us Regarding Our Sites section above. You can also report any issues or concerns to Your local data protection regulator. In the UK, that is the Information Commissioner’s Office (“ICO”). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Any question You may have regarding Your privacy on Our Sites should be made in writing and sent to, privacy@luckyseat.com or using our other contact details in the Contacting Us Regarding Our Sites section above.

For information regarding protecting Your data online, refer to the Federal Trade Commission’s website located at www.ftc.gov.

Last Updated:  July 23, 2018

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