Italy Privacy Policy for DICE Users

ITALY: PRIVACY POLICY FOR CUSTOMERS

This information was updated on November 06, 2023.

Please read this privacy policy if you use the DICE mobile software application (the “App”) or the DICE website (together with the App, the “DICE Platform”) in Italy.

This information applies to customers and users of the DICE platform, as well as to any other person whose data may be processed, with the exception of our employees, candidates, event partners and/or artists, who may consult them at inside the Platform The information dedicated to them says.

This policy explains how DICE Group (“DICE”, “we” or “us”) uses your personal data to provide the services available on the DICE Platform.

If you have any questions about this policy, please contact us at [e-mail]. From time to time, we may need to update this policy and will notify you of any updates in the DICE Platform Help Center. If we make changes to the way we use your personal data, we will notify you by posting a notice on the DICE Platform and/or by sending you an email to the email address you provided when you registered.

1. WHO WE ARE

1.1 DICE comprises several group companies, including DICE FM Holdings Ltd and DICE FM UK Ltd (98 De Beauvoir Road, London N1 4EN UK), Boiler Room (UK) Limited, DICE FM Inc (USA), DICE FM SPAIN SLU ( Spain), DICE FM SASU (France), DICE FM Italy SRL (Italy), DICE FM GmbH (Germany), DICE FM Australia Pty Ltd (Australia), DICE FM Canada Limited (Canada) and DICE FM India Private Limited (India) (the "DICE Group").

1.2. We are an agency that sells tickets via the DICE Platform on behalf of promoters, organizers, managers, artists and venues of music, entertainment, sporting and similar events (the "Event Partners").

2. OVERVIEW

2.1. By virtue of the General Data Protection Regulation, Regulation (EU) 2016/679 (the “ GDPR ”) (and any other law applicable in Italy), DICE is the “Data Controller” when you use the DICE Platform.

2.2. DICE and the Event Partners act as independent data controllers. DICE and the Event Partners are not joint data controllers, except in some situations where data is controlled jointly (for example with regard to pixels/cookies on third-party websites).

2.3. This privacy policy explains how we use your personal data collected when you use the DICE Platform.

3. THE LEGAL BASIS OF THE PROCESSING OF YOUR DATA

3.1. DICE processes your data to provide you - and to allow you to use - the services on the DICE Platform. These services are governed by our Terms of Purchase and Terms of Use.

3.2. Some of your data, including photographs and audio and video recordings of the events, will be processed on the basis of DICE's legitimate interest in successfully providing you with a personalized view of the events. Legitimate interest is also the legal basis of processing for in-app analytics data processing (except where your consent is required) so that we can improve and monitor app performance, user activity and account or website logs, etc., prevent fraudulent or other malicious activity and produce website visitor logs for cybersecurity and/or error monitoring purposes. Legitimate interest is also the legal basis for processing in the formation of your profile on the Dice Platform. We also rely on our legitimate interest to collect your date of birth, to ensure that you are authorized to purchase tickets, as some events can only be attended by those aged 18 and over, and to share some aggregate information with partners of the event for their internal statistical and sales monitoring purposes. We may also rely on legitimate interest to share with our Event Partners any personal information required for public health reasons pursuant to any legal obligations to which our Event Partners are subject and, in some circumstances, to share limited data with third parties on the basis of their legitimate interest, for example, when a ticket is resold to a third party user on an alternative platform. Legitimate interest is also our legal basis for sending you reviews or post-event surveys to complete after attending an event, or if you have contacted our fan support team, to help make DICE even better.

For the purposes of processing personal data on the basis of legitimate interests, we have conducted a Legitimate Interest Assessment to ensure that individual interests do not override such legitimate interests.

3.3. We will ask for your consent if we share your data with third parties for any reason not mentioned in this policy and which is not absolutely necessary to allow you to use the DICE Platform. We will also ask you for consent in certain other cases, for example to use your location to sync your music library or to send you notifications and to access your phone contact list as part of the “Limited right to transfer tickets” feature ( see clause 10 of our Conditions of Purchase), as well as for market research or any other survey that does not fall within post-event reviews, but you will of course have the right not to give your consent.

3.4. We may ask for your consent in other cases where we process your data. You can withdraw your consent at any time by contacting us at [e-mail]. Please note that the withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.

4. INFORMATION COLLECTED

4.1. To help us manage your registration and ticket sales, we will process and store all personal information you provide to us when you register on the DICE Platform and all personal information that is generated when you browse and use the DICE Platform. We also use this information to analyze trends in your behavior, as this helps us determine your preferences, habits, tastes, geographic location and favorite artists and events, so as to maximize your use and enjoyment on the DICE Platform; this is the Discovery function. We may also collect certain information from email communications between you and DICE and maintain it in separate records. To find out more about how we use your personal data, see clause 6 below.

4.2. The types of personal information we collect may include:

1. Contact data - including name, gender, email address, telephone number, ID, postal address and date of birth. You will also have the option to add these details for each holder of a ticket purchased via the DICE Platform ("Additional User Data"), giving DICE or our Event Partner the ability to contact each ticket holder even after the event, if necessary for public health reasons. This is a security precaution in case the organizer needs to contact attendees. DICE will retain this information for up to 30 days after the event. Please note that the organizer may have a different retention period, so contact them or check their privacy policy for more information.
2. Payment Card and Billing Information - When you purchase tickets through the DICE Platform, we need your payment and billing information (such as your address and zip code) so we can handle the processing and shipping of your ticket orders. tickets;
3. Location data - we may collect your IP address and, if you allow us to connect to your device's geolocation functionality, we may collect your GPS data. We will use location data to improve personalized recommendations on the DICE Platform about events happening near you. You can deactivate the App's ability to access your geolocation at any time through the general or privacy settings of your device;
4. Your images or recordings - we may obtain photographs, audio or video recordings of events listed on the DICE platform. We may reproduce and/or publish your image, or share it with the event partner to reproduce and/or publish (as part of an overall event photograph) on the DICE Platform and in other promotional materials, social networking channels and other materials relating to the DICE Platform;
5. Your preferences - we may collect information about your purchasing history, events you have seen, attended, inquired about, joined the waiting list, shared or invited third parties to, as well as any feedback you may have given or reviews you have submitted;
6. Music Library (for example, Spotify or Apple Music) - if you allow us to connect to your music library, we may collect and hold information on your musical interests so we can improve the personalised recommendations through the DICE Platform and invite you to artists special experiences;
7. Your interactions with us - any information you send to us, for example, by email, responding to surveys or via social media, customer service communications, may be stored in our systems; And
8. Technical information - when you use the DICE Platform, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, IP address, strictly necessary cookie information and details about the page you viewed. required. We also collect information regarding your use of the DICE Platform, mobile device information, and browser information.
9. Feedback - when we conduct a survey, we may collect your views, opinions and suggestions.

5. COOKIES

5.1. Our website and app use cookies to distinguish you from other users of our website and app. This helps us provide you with a good experience when you browse our website and when you use our app and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or your device's hard drive (if you agree). Cookies contain information that is transferred to your device's hard drive.

5.2. We use the following cookies on our website and/or app:

1. Strictly necessary cookies. These are cookies that we need to make our website and app work. They include, for example, cookies that allow you to log into secure areas of our website and app, use a shopping cart or use e-billing services. Among these cookies we also include a combination of first-party and Google Analytics tracking cookies that allows us to assign purchases to partners, which is necessary for us to fulfill our obligations under these agreements, since our business model depends on it . This data is intended for internal use only and is set for short expiration periods. You can contact us at [e-mail] or contact our Data Protection Officer at [e-mail] for further information.
2. Analytical/performance cookies . They allow us to recognize and count the number of visits and to see how those who visit our website or app navigate while using them. This helps us improve the way our website and app work, for example by ensuring that users easily find what they are looking for.
3. Preference cookies . These cookies help us personalize and improve your experience. They are used to recognize important information about your preferences so that we can personalize our content for you. Although they are not essential for our website to function, without them some functions of our site may not be available.
4. Profiling cookies . These cookies record your visit to our website, the pages you have opened and the links you have followed. We use this information to make our website and the advertisements displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Where this information is used for marketing purposes, we will first ask for your consent.
5. Marketing cookies . These are cookies that are used to target advertising to you (behavioral targeting), which include the Facebook Conversion API through which data is shared with us and/or our event partners for marketing purposes, as well as with Facebook /Half.

5.3. When you use our website for the first time, you are given the option to accept or reject cookies that are not strictly necessary. By using the checkboxes on the cookie banner, you consent or refuse the use of cookies by category, as indicated in this policy. You can also change your cookie consent at any time by accessing the cookie banner or emailing us at [e-mail]. You can set your preferences the first time you visit our website and at any time through our cookie banner or by contacting us on [e-mail].

5.4 The cookies described above will be installed when you download the app or visit the site. If you have any questions, you can contact Dice at [e-mail] or our DPO at [e-mail] before downloading the app. You can change your cookie preferences at any time by contacting us at [e-mail].

5.5 Please note that when you access or use our services through third-party websites, such as the websites of our event partners, we may share certain information with them when you take certain actions in the checkout flow. We will not use any cookies or pixels for these purposes. These third parties or Event Partners will only be able to use this data for marketing purposes if you provide your consent on their website. We may not be able to delete your data in new sessions if we have no way of identifying you.

5.6 You can delete all cookies that are already present on your device by deleting your browser browsing history. This will delete all cookies from all websites you have visited. Browsers also allow you to control access to cookies. You can find links below that provide information on how you can do this in relation to the main browsers:

Microsoft Edge:	https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Internet Explorer:	https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Chrome:	https://support.google.com/chrome/answer/95647?hl=en-GB
Firefox:	https://support.mozilla.org/en-US/kb/delete-browsing-search-download-history-firefox
Safari:	https://support.apple.com/es-es/guide/safari/manage-cookies-and-website-data-sfri11471/mac

5.7 Our use of cookies is proportionate to the result we intend to achieve and limited to what is necessary to achieve the purposes indicated in this policy.

1. Session cookies. They allow us to recognize and connect a user's actions during a browsing session. They are temporary and expire at the end of your browser session, normally when you exit the browser.
2. Persistent cookies. This category includes all cookies that are stored on the user's device between one session and another. All persistent cookies have an expiration date written into their code, but their duration may vary for each category or specific cookie. The persistent cookies we use normally expire after six months. If you need more information about the lifespan of a particular cookie we use, please contact us on [e-mail] .

6. USE OF YOUR PERSONAL INFORMATION

6.1. In addition to the purposes described above in clause 4.1, we use your personal data to:

1. manage and provide you with the DICE platform;
2. communicate with you via email, SMS, in-App notifications and via push notifications regarding your purchases on the DICE Platform, including, for example, tickets and the events to which they relate;
3. process your purchase orders for tickets and other items other than tickets purchased through the DICE platform;
4. provide you with a higher level of content, service, marketing and support. For example, we may need to use your information to administer your account or to provide you with information in connection with any purchases or events in which you have expressed interest;
5. administer and provide any competitions available to you through the DICE Platform and communicate with you regarding such competitions. If you enter a competition, we encourage you to read the rules and/or terms and conditions relating to that competition, as these may include specific terms relating to the use of your personal data.
6. to profile the individual and demographic trends of the events you attend or the interest you show in certain events and artists. This helps us make recommendations of similar events, artists, or artists that you might be interested in (via the Discovery feature or otherwise). We do this through assumptions based on an analysis of the information we have, including events you've seen, waitlists you've signed up for, and tickets you've purchased. For example, if you purchased tickets to an event, we may show you other events of that specific genre or type, or events from similar artists. Similarly, we may share your email address with social media providers and search engines to show you and other users more relevant ads on the social media sites of which you are a member and on the search engines you use.
7. Other users at DICE. Any DICE users with your phone number will be able to see whether you have an account with DICE when using certain features, such as sending tickets to a friend.

6.2. We also use data for operational purposes, such as:

1. to provide customer service and respond to requests for information;
2. to verify your identity when picking up tickets at a venue, to check that minimum age requirements are met, or to check that restrictions on ticket resale have been complied with;
3. to send you important information regarding our services, or other technical notices, updates, security alerts, and support and administrative messages; And
4. where necessary or appropriate under any applicable law, to enforce our rights or to appropriately respond to requests from law enforcement and any other governmental/administrative authorities.

6.3. As explained in clause 3, we process your personal data under the following legal bases:

1. consent;
2. to perform a contract you have entered into;
3. our legitimate interest or that of an Event Partner or other third party, including to improve the performance of the DICE Platform and to improve your experience on the DICE Platform; and/or
4. to comply with a legal obligation.

6.4. Where we rely on your consent to process your personal data (for example, marketing), you can withdraw your consent at any time by emailing [e-mail] or in any other way explained in this privacy policy. If you withdraw your consent, this will not affect the lawfulness of any processing that took place prior to your withdrawal of consent.

7. MARKETING

7.1. We may send you marketing communications via email and push notifications. When you sign up, we will ask you if you agree to (1) receive updates about contests, prizes and what's happening at DICE, which may include updates on events, artists, new features, merchandise, offers and more; and (2) participate in surveys, fan tests, and more. You can choose to accept marketing communications and push notifications when you register on the DICE Platform. If you change your mind about receiving any marketing emails from us, you can change your preferences in the communications control center in the App (called 'Messages') or unsubscribe from emails by following the unsubscribe directions provided in the footer of each of them. If you do not want to receive push notifications from us, you can opt out by changing your preferences in the 'Messages' control center in the App or change the appropriate settings directly on your mobile device. To access the communications control center ('Messages') you must have the App version 3.17.0 or higher.

7.2. If you choose not to receive these marketing communications, we may still process your personal data for other purposes, as set out in Articles 5 and 6 above.

7.3. When you register, we will also ask you whether you consent to receiving marketing messages from our Event Partners and other third parties involved in the provision of an event for which you have purchased tickets. If you consent to receiving such marketing messages, we will transfer your data, such as your email address, city or full residence, full name and date of birth to the relevant Event Partner or third party so that they can contact you for this purpose. If you change your mind and do not want to receive such marketing messages, you can opt-out by contacting the third party directly or by unsubscribing using any available or similar “unsubscribe” link in such third party's emails. Alternatively, to opt-out of marketing messages from all third parties, you can change your preferences in the communications control center in the App (called 'Messages'). We will notify the relevant third parties of your change in preferences, normally within 7 business days. Please note that it may take additional time for each third party to process your request.

7.4. When you sign up, we'll also ask you if you agree to participate in surveys, fan tests, and more.

8. DISCLOSURE OF YOUR INFORMATION

8.1. We will not sell or rent your personal information to anyone without your express consent, but, in order to perform our part of the contract under our Terms and Conditions and our legitimate interests, we may share your personal information in the ways described below :

1. Agents and Suppliers – We employ other companies/individuals to perform functions on our behalf, such as our payment processing providers and data analytics providers. We do not share your personal data with our agents or suppliers, except as necessary to enable them to provide a service to us.
2. Third Parties - We may integrate with other third party products and services, such as Spotify, to enable certain features of the DICE Platform. We do not share your personal data with them except to the extent necessary to enable them to perform functions that require integration.
3. Competition partners - in the event of promotion of competitions or other prize events, through the DICE Platform, we may process your personal data to manage your registration and contact you if you are a winner, on the basis of what is indicated in the relevant rules or terms and conditions. We may share your name and country of residence with anyone who is entitled to ask us for winner's details and we may use your name and likeness in publicity materials as we see fit. We may share your personal data with our competition partner to enable them to administer the competition (for example to arrange for the prize to be delivered to the winner).

Analytical tools	We may share your personal data with analytics and search engine providers.
Administration and support tools	We may share your personal data with supporting software providers.
Sending email	We may share personal data with email service providers.
CRM	We may share your personal data with CRM providers
Payment processing	We may share your personal data with online payment processing providers.
Messaging and collaboration tools	We may share your personal data with messaging and collaboration software providers.
Online survey tools	We may share your personal data with online survey tool service providers.
Any person who joins a Group through the “Groups” feature.	Your name, as it appears in the DICE app, will be visible to anyone who joins a Group you are part of through DICE's “Groups” feature.

4. Event Partner - We are a ticketing agency, so we sell event tickets on behalf of the Event Partner. Therefore, we need to share your personal data with them and with other parties involved in providing the event (such as the venue) so that they can provide you with information about the event, such as last minute changes or for validation purposes of the ticket when accessing the event. We may also need to share your information with them in terms of sales control, access control, for the provision of relevant event information and for aggregate statistics. Event partners may access customer information such as name, email address, ID, country of origin and telephone number, and we may share this information with them if this is necessary to comply with legal requirements or obligations to which they are subject. subjects. For the purposes of marketing cookies (see clause 5.2.5 for more information), we may also share your hashed email address and phone number, action name (either "Purchase", "Initiate Payment" or "Page View") and the DICE event ID. We are not responsible for the actions of third parties, and if you wish to object to a third party's use of your personal information, you should contact them directly.

5. Artists - If you follow certain artists using the App, we may also share your information with them. We are not responsible for the actions of third parties and if you wish to object to a third party's use of your personal information, you should contact them directly.

6. Cookie providers - where third party cookies or similar technologies are used, we may share your data with the relevant cookie provider if you have agreed to the cookie being set. Please see clause 5 for further information.

7. Other reasons - We may also share your personal information with a buyer or potential buyer of our business and in some circumstances, we may be required to disclose your personal information, for example, by law, court or law enforcement request or to enforce our legal rights or to prevent fraud or touting.

9. INFORMATION ABOUT OTHER INDIVIDUALS

9.1. If you provide information (including personal information) to us on behalf of someone else, you confirm that the other person has given you permission to act on their behalf and has given their consent in relation to whether you can:

1. provide us with your personal data;
2. receive any data protection notices on your behalf; And
3. 3. give consent to the transfer of their personal data abroad.

9.2. We will need to see proof of this consent, so we will ask you to provide DICE with the written authorization you have received or the document demonstrating the power to represent them. If these documents are not available, we may accept any suitable alternative.

9.3. If the personal data have not been obtained directly from the interested party, please refer to what is reported in this information.

10. SECURITY AND INTERNATIONAL DATA TRANSFERS

10.1. We are committed to ensuring that your information is treated confidentially and securely and have put in place appropriate measures to ensure the security of your personal data.

10.2. The personal data we collect about you may be transferred to - and stored in - destinations located outside the European Economic Area (EEA) where the laws on processing personal data may be less stringent than those in your country. It may also be processed by staff operating outside the EEA who work for us or for one of our agents or suppliers.

10.3. Currently, the personal data collected is stored in data centers and cloud networks that are located or hosted in Ireland.

10.4. When your personal data is transferred to parties located outside the EEA, we will evaluate and take appropriate measures to ensure that these third parties provide adequate security of that personal data and respect your privacy rights. These safeguards are intended to ensure a similar degree of protection wherever your data may be transferred and may include:

1. the transfer of your personal data only to countries that are deemed to provide an adequate level of protection for personal data based on the indications of the European Commission; or
2. by entering into standard contractual clauses approved by the European Commission and which give personal data the same protection as within the EEA (for example, if you transfer your data to the USA).

If you would like more information on the security measures used, please contact us at [e-mail] .

11. DATA RETENTION

11.1. We may retain your personal data for as long as is necessary for the purposes for which it is processed or as otherwise required by applicable law. If you close your account on the App and/or Website, stop using the DICE Platform, or our agreement with you under the Terms of Use is terminated, we will delete your information as it no longer relevant, but we may need to continue to process your personal data as required by applicable law, in order to establish, exercise or defend legal claims, where appropriate.

11.2. We calculate the appropriate retention period for your data by considering the nature and sensitivity of the data, the purposes for which we are processing it and any applicable legal retention periods. Using these criteria, we regularly review the personal data we hold and the purposes for which it is stored and processed. Once processing has been completed, we can securely delete or anonymize your personal data.

11.3. We may delete your account or specific information before deactivating your account if we believe it is no longer relevant or if an account has been inactive for more than one year. Purchase history can be deleted after 7 years.

If you would like more information about our retention periods, please contact us at [e-mail] .

12. YOUR RIGHTS

Pursuant to Articles 15 et seq. of the GDPR and any equivalent law in Italy, you are entitled to certain rights relating to our processing of your personal data, as described below.

12.1. You may request details of personal information which we hold about you under data protection laws. If you would like a copy of this information, please write to us at [e-mail].

12.2. If you think that any information we have on you is incorrect or incomplete, please write to us at [e-mail] as soon as possible. We will correct or update any information as soon as possible.

12.3. You have the right to request deletion of your data, as well as the right to deactivate your account (in which case only your user ID and ticket history will be retained for our records). We are not required to delete information as necessary to establish, exercise or defend legal claims or to comply with the law.

12.4. You have the right to restrict processing if your data is processed incorrectly but does not need to be erased for a reason listed in Article 18 (1) of the GDPR.

12.5. Until a download option based on universally recognized standards has been developed, you can exercise your right to data portability by obtaining your data. You can do this by writing to us at [e-mail].

If you want to exercise these rights, please write to us at [e-mail] .

13. CONTACT AND COMPLAINTS

If you have any complaints about how we handle your personal information, please contact us at [e-mail]. If we are unable to resolve your complaint and you wish to take it forward, you can do so by contacting the Guarantor for the Protection of Personal Data (Privacy Guarantor).

14. CONTACT DETAILS OF THE DATA PROTECTION OFFICER

DICE has appointed a Data Protection Officer (DPO) who you can contact if you have any questions or concerns about DICE's policies or practices regarding personal data. The name and contact information of DICE's data protection officer are as follows:

Aphaia Ltd

The Brew

Eagle House

163 City Rd London EC1V 1NR UK

Contact email: [e-mail] Contact telephone: (+44) (0)20 3917 4158