EventsOS Privacy Policy

Introduction

EventsOS is a Registered (In the Republic of Kenya) trade mark of Identigate Integrated Solutions Limited (“EventsOS” or “We”, “us”), respect your privacy and we are committed to protecting your privacy through our compliance with this policy. 

This policy describes our practices in connection with information that we collect through our EventsOS software platforms and applications (collectively our “Applications”) as well as EventsOS’s privacy practices in relation to the use of EventsOS’s website www.eventsOS.co.ke

This policy also describes your data protection rights, including a right to object to some of EventsOS’s processing. The Policy does not apply to information collected by any third party, including through any third-party application or content (including advertising) that links to or is accessible from our applications or websites.

This policy applies to the following classification of individuals that interact with EventsOS:

CUSTOMERS: Customers are individuals that are employees or associates of EventsOS’s direct customers (for example, event planners, travel buyers and meeting space providers), including customer personnel that are assigned a login ID and are authorized to access and use our Applications pursuant to an active EventsOS agreement, or under a temporary evaluation license, if available. Additionally, Customers include individuals who self-register to access our Applications.

CUSTOMER BUSINESS CONTACTS: Customer Business Contacts are individuals that interact with our Customers through our Applications. These include our Customers’ current and prospective clients, members, attendees, sponsors, exhibitors, marketing partners, hotel guests or other business contacts. For example, Customer Business Contacts include individuals that register for an event organized by a Customer, download an event-related mobile app, participate in a virtual event organized by a Customer, complete an online survey, or make a hotel or meeting space reservation using one of EventsOS’s Applications.  

VISITORS: Individuals and prospective customers who interact with our websites (for instance, to access our Supplier Network without registration (as a non-Customer), to read about EventsOS products and services, download a white paper, or sign up for an online demo), as well as those who attend EventsOS marketing events (for instance, EventsOS CONNECT®, EventsOS live events and webinars) and whom we meet at a tradeshow or learn about through a referral from third parties or other external sources. 

What types of personal data do our Customers collect?

Our Applications are flexible and allow our Customers to collect a variety of personal data from and about their Customer Business Contacts, including name, organization, title, postal address, e-mail address, telephone number, fax number, social media account ID, credit or debit card number and other information including but not limited to meal preferences, interests, opinions, activities, and occupation. We encourage Customer Business Contacts to review the Customers’ privacy policies to further understand the types of data collected.

If you do not agree with our policies and practices, you may choose not to use our Applications.

How do our Customers collect personal data?

Customers can use our customizable Applications to collect personal data in a variety of ways as outlined in the examples below. We encourage Customer Business Contacts to review the Customers’ privacy policies to further understand their methods of collecting the personal data.

• When Customer Business Contacts voluntarily and explicitly enter personal data into our Applications.
• When our Customers enter Customer Business Contacts into our Applications, when permitted, including by having a legitimate business interest or obtaining explicit consent from a Customer Business Contact.
• Automatically, as Customer Business Contacts interact with our Applications, using commonly used information gathering technologies such as cookies.

How do our Customers use personal data?

If a Customer Business Contact chooses to use our Applications to conduct business with a Customer (for example: register for or check into an event, respond to an online survey, download a mobile application), any information provided in connection with that interaction will be transferred to, and under the control of, the Customer.

Customers will also have access to information (including personal data and Application usage data) related to how Customer Business Contact interact with the Applications they use. In such instances, the Customers act as data controllers towards the Customer Business Contact, under Kenya’s Office of the Data Protection  Commissioner data protection laws and regulations.  Therefore, EventsOS cannot and does not take responsibility for the privacy practices of Customers.

The information practices of our Customers are governed by their privacy policies. We encourage Customer Business Contacts to review the Customers’ privacy policies to understand their practices and procedures.

Does EventsOS use or sell personal data collected by our Customers?

EventsOS does not use personal data of our Customer Business Contacts for any purposes other than to provide services that our Customers have contracted us to provide through our Applications, as noted below, to improve our services, or as required or permitted by law. EventsOS does not sell personal data of our Customer Business Contacts.

How does EventsOS collect and process personal data from our Customers and their Customer Business Contacts?

We collect personal data from our Customers in order to facilitate communication and delivery of the Applications that our Customers are interested in or contract us to provide. For example, we may collect Customer contact information, whether through the execution of a contract, use of our services, a form on our website, queries submitted to our chat agent, an interaction with our sales or customer support team, sign up for an event, or a response to one of our surveys or marketing emails. We may also collect credit card information (e.g., credit card number and expiration date, billing address, etc.) or other customary bank information needed for billing and payment purposes.

We may record Customer telephone (or video) calls made to our Client Services team for legitimate business interests related to providing Customer support, compliance with laws, training, and quality assurance. Where required by law, we will obtain consent from Customers before proceeding with the recorded telephone or video call.  We retain such recordings until 90 days after the date of recording unless otherwise needed for contract implementation or further employee training.

We and our vendors collect Customer usage information about how our Customers interact with our Applications. This includes which webpages you visit, what you click on, when you perform certain actions, what language preference you have, what you buy, and so on.

We process Customer’s and their Customer Business Contacts’ personal data in the following manner:

• To disclose to our subsidiaries and affiliates for the purpose of providing services to our Customers and their Customer Business Contacts.
• To disclose to contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain and support our Applications for our Customers and their Customer Business Contacts, such as, for example, payment processors and data center or Web hosting providers. EventsOS does not share, sell or trade any information with such third parties for any promotional purposes.
• To deliver the services that our Customer has contracted us to provide through our Applications. Some examples include:
• If a Customer Business Contact uses one of our Applications to register for an event, we will use their provided e-mail address to send them information and announcements relating to that event.
• If a Customer Business Contact uses one of our Applications to pay for event registration fees or other products and services using their credit cards, we will pass the credit card information to payment card processors to validate the payment information and complete the transactions.
• When a Customer submits an RFP to a meeting space provider listed on the EventsOS Supplier Network, or to a Customer’s Business Contact as directed by the Customer, EventsOS will contact that venue, management company or Customer Business Contact and disclose information, which contains personal data, necessary for it to respond to the RFP.
• When a Customer reserves a meeting space or hotel room at a venue utilizing EventsOS’s InstantBook service, EventsOS will share necessary personal data with the venue directly or via that venue’s technology platform, in order to complete the booking directly with Customer.
• When a Customer or Customer Business Contact uses their social media credentials to share information on their social media platform or to log into one of our Applications, we will share information with their social media account provider. The information we share will be governed by the social media site’s privacy policy. 
• To disclose to event organizers, exhibitors, or other attendees, as directed by a Customer or consented to by a Customer Business Contact, such as by consenting to having an exhibitor scan their event badge to share their contact information, opting-in or clicking to give consent to receive exhibitor information, or actively consenting to share information in a EventsOS Application (e.g., name, contact information, profile picture, survey responses, Q&A features, comments, messages, poll responses, etc.).
• As instructed by Customer, to connect Customer Business Contacts with one another by relying on matching algorithms to recommend compatible Customer Business Contacts for optional business networking.
• To deliver to a third party in the event of a merger, divestiture, restructuring, recapitalization, reorganization, dissolution or other sale or transfer of some or all EventsOS’s assets, whether as a continuing operating business or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by EventsOS about our Customers and Customer Business Contacts is among the assets transferred.
• For our internal business purposes that include administering access and use of our Applications, data analysis, securely identifying Customers upon logging onto an Application, enhancing or modifying our Applications, determining the effectiveness of our promotional campaigns, billing for Services, and operating our business.
• As we believe to be necessary or appropriate:  (a) under applicable law, including laws outside your country of residence; (b) to respond to requests from public and government authorities including public and government authorities outside your country of residence; and (c) to protect against or identify fraudulent transactions.
• For other purposes when Customer Business Contacts provide explicit consent.

We aggregate information about (i) Customers and Customer Business Contacts, and (ii) the use of our Applications in order to improve our Applications and to create benchmark and other business intelligence products. None of the aggregated information contain personal data (i.e., does not identify any individual).

What is the legal basis for EventsOS to process personal data?

For individuals that are from the Republic of Kenya, European Economic Area (EEA) or other regions that stipulate a lawful basis for processing personal information (such as under Kenya Data Protection Act, 2019, GDPR Article 6), our legal basis for collecting and using their personal information will depend on the nature and circumstances of the processing activity. Where we are the processor for our Customers, our legal basis may be fulfilment of a contract or consent. Where we are the controller, our legal basis will be consent or legitimate interest where the processing is in our legitimate interests and not overridden by the individual’s data protection interests, or fundamental rights and freedoms. These interests are to provide individuals with access to the Applications and features of the Applications; to send them information they have requested; to ensure the security of our Applications by trying to prevent unauthorised or malicious activities; or to enforce compliance with our terms of use, contracts and other policies. 

How long does EventsOS store personal data collected by our Customers?

Unless otherwise provided in our contract with our Customer, we process the data until 90 days after the termination of the contract, at which time we remove it from our production environment. Within 13 months, we remove the data from our backup media.

How can a Customer Business Contact access, correct or delete their personal data?

In Kenya and various countries, including countries in the EEA, as well as in some U.S. states, upon their request, Customer Business Contacts have the right to access their personal data and, if necessary, have it amended, deleted or restricted. Customer Business Contacts can also ask for some types of personal data to be delivered to them, or another organization they nominate, in a structured and machine-readable format. 

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent. See the EventsOS contact section below. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Customer Business Contacts in the EEA also have the right to complain to a supervisory authority for data protection in the country where they live, or where they work – although we hope that we can assist with any queries or concerns you have about our use of your personal data.

EventsOS processes Customer Business Contacts’ data under the direction of our Customers and has no direct control or ownership of the personal data we process. Customers are responsible for complying with any regulations or laws requiring notice, disclosure or obtaining consent prior to transferring the data to EventsOS for processing purposes. Any Customer Business Contact that seeks to access, correct or delete data, should direct their query to the Customer. If the Customer requests EventsOS to delete, rectify or access the personal data of a Customer Business Contact to comply with data protection regulations, EventsOS will process this request within the required time under the applicable regulation or law.

We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In such instances, we will inform the Customer about the legal obligations that prevent us from fulfilling the request. 

How can a Customer access, correct, or delete their personal data?

Customers have the same rights to access, correct or delete their personal data as outlined above.

Any Customer can access, correct or delete their data, or their Customer Business Contact data by submitting a request on our website at https://www.EventsOS.com/personal-data-requests. EventsOS will process this request within the required time under the applicable regulation or law.

We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In such instances, we will inform the Customer about the legal obligations that prevent us from fulfilling the request.

We will maintain an audit history of any requests to access, correct or delete personal information to maintain a record of compliance with regulatory requirements.

• Commercial information, including records of products or services purchased or considered.
• Internet or other electronic network activity information.
• Geolocation data.
• Audio and visual information, such as customer service call recordings and photographs.
• Professional or employment-related information.
• Education information.
• Contents of SMS/text messages and chats.
• Inferences drawn from any of the information identified above.

This information is collected and used for the purposes disclosed in this Privacy Policy. EventsOS may have disclosed a Customer’s or Visitor’s, name, title, or business contact information to host venues (e.g., restaurant or hotel) or event sponsors of EventsOS marketing events in the 12 months immediately preceding the posting of this updated privacy policy.

EventsOS may have disclosed any of the above categories of personal information pursuant to an individual’s consent or under a written contract with a service provider for a business purpose in 12 months immediately preceding the posting of this updated privacy policy.

How does EventsOS use cookies and similar technologies?

Cookies and Web Beacons

We and authorized third parties use cookies or similar automatic data collection technologies as individuals interact with our Applications to collect certain information about their equipment, browsing actions and patterns, including:

Details of your visits to our Applications, such as the date and time you access our Applications, length of time you spend on our Applications, websites that linked to our Applications or websites linked from our Applications, the resources and content that you access and use on the Applications.

Information about your computer and internet connection, such as your IP Address, computer type, screen resolution, language, Internet browser type and version. 

Below are the technologies we use for automatic data collection. We do not use any of these technologies to collect information from Customer Business Contacts for marketing or advertising purposes.  Our Customers may add cookies or other similar technologies through our Applications for their own purposes, including for marketing purposes.

Browser Cookies.  A cookie is a small file placed on a computer hard drive.  Web browsers can be configured to restrict or entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device.  Information on how to do this is provided by the web browser’s help/reference section. Limiting or restricting certain types of cookies may prevent a Customer or Customer Business Contact from using certain portions of our Applications, depending on how the browser settings are configured.  For example, event registration cannot be completed successfully if cookies are disabled in the web browser. Unless the browser setting has been adjusted so that it will refuse cookies, our system will issue cookies when the browser interacts with our Applications.  For more information about cookies and how to disable them, see www.allaboutcookies.org.

Duration.  Browser Cookies are either “session” or “persistent” in duration.  A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. Session cookies allow website operators to link the actions of a user during a browser session.  A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted.  A persistent cookie will be reactivated when a user returns to the website which posted the cookie. We use persistent cookies to help customize your web experience when you return to a web page or our website.

Neither of these cookies can read or access other cookies or any data from a user’s hard drive. Further, neither of these cookies alone will personally identify a user; however, a cookie will recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and individuals who log in to their EventsOS accounts will be individually identifiable to particular Applications using session cookies.

Purpose.  Our website uses cookies that serve the following purpose types:

Strictly necessary (essential). Strictly necessary cookies make our website work, they are essential for the website to perform its basic functions.

Performance.  Also known as “statistics cookies”, and including analytics cookies, performance cookies collect information about how you use a website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.

Functionality.  Also known as “preferences” cookies, these cookies allow a website to remember choices you have made in the past, like what language you prefer.  They are used to enhance the user experience of the website but are non-essential to their use, but without these cookies, certain functionality may become unavailable.

Marketing.  These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

Web Beacons.  Pages in our Applications and our e-mails will contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs).  Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email.  Web beacons permit us to track online movements of web users, for example: to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).  This enables EventsOS to provide a website experience more tailored to our users’ preferences and interests.

At this time, we do not respond to browser ‘do not track’ signals, as we await for a uniform standard put forth by regulators or the privacy industry.  EventsOS earnestly considers an individual’s independent right to determine how their personal data is processed and continues to monitor developments in this area.

Advertising

We use information collected from our venue sourcing Customers to enable us to display advertisements from our Hospitality Cloud Customers to their target audience of users through our network or our advertising service providers.  As one example, meeting space providers purchase advertisements that are presented selectively through the EventsOS Supplier Network to meeting planners who have previously awarded a minimum volume of meetings business to that provider or to competing venues in the target metropolitan area.  Even though we do not disclose personal data for these purposes, if the venue sourcing user clicks on or otherwise interacts with an advertisement, the advertising Hospitality Cloud Customer assumes that the venue sourcing user meets its target criteria. While we and our Hospitality Cloud Customers leverage this technology to advertise to Customers, we never use our Customer’s information to advertise to Customer Business Contacts.

How does EventsOS process data from Visitors?

EventsOS processes Visitor data separately and distinctly from the way we process Customer and Customer Business Contact data. By visiting our websites, attending EventsOS marketing events or providing us with your personal information, Visitors consent to the collection, processing and storage of their personal information as described in this section.

Visitor Personal Data Collected

EventsOS collects personal data including name, title, postal address, e-mail address, telephone number, social media account ID, company information (including financial and billing information when purchasing EventsOS services), survey responses, message board posts, chat messages, contest entries and promotional enquiries. We may collect this Visitor information through a form on our website, queries submitted to our chat agent, an interaction with our sales or customer support team, when signing up for an event, or a through a response to one of our surveys or marketing emails. We use this information to provide you with additional details about our services, conduct research, provide whitepapers or to contact you after your visit.

We also collect personal data from third party sources, such as third parties from whom we have purchased business contact information, public databases, joint marketing partners, and social media platforms.  In some cases, EventsOS may combine personal data you have provided to us with personal data collected from other sources.  We use this data to improve our websites and advertising, and to identify prospective marketing opportunities.  For example, if a Visitor elects to connect her social media account to her account for our websites, certain personal data from the social media account will be shared with us, which may include personal data that is part of the Visitor’s profile or her friends’ profiles.

If you elect to do so, when you provide a reference, we collect personal information about your contacts, such as:

Name

Work email

Organization

Phone number

City of residence

ZIP code

When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided.

If you believe that someone else has provided us with your personal information and you would like to request us to remove it from our database, please submit a request at https://www.EventsOS.com/personal-data-requests. Additionally, we and our analytics service providers collect personal data from cookies and similar technologies to collect information about the pages Visitors view, links Visitors click on, Visitors’ web browser information, Visitors’ IP address and other actions Visitors may take when accessing our websites.

EventsOS’s Use of Visitor Personal Data Collected

EventsOS processes Visitor personal data to:

• Analyze how our websites are accessed;
• Personalize your browsing experience and present products or features that may be more applicable to you;
• Identify website technical problems;
• Discover, investigate and remediate fraudulent or illegal activity;
• Transmit notices related to product, service, or policy changes;
• Respond to your product and service inquiries;
• Send you information such as product announcements, newsletters, whitepapers, other relevant offers, and upcoming promotions or events (where required, dependent on jurisdiction, we will seek and obtain your explicit consent before sending marketing emails);
• Plan and host EventsOS corporate events, host online forums and social networks in which Visitors may participate;
• Analyze and identify new prospects;
• Create tailored advertising, sales and promotional programs; and
• Bill customers for our services and assess the financial capability of prospective customers to afford EventsOS’s solutions.

Storing of Visitor Personal Data

Where we process Visitor personal data for marketing purposes or with Visitor consent, we process the data until the Visitor asks us to stop. It typically takes up to 30 days to implement your request, but in no event longer than required by applicable law. EventsOS will not retain Visitor personal data longer than the statutory retention period permitted in the local jurisdictions where EventsOS services are marketed and provided. Where EventsOS retains Visitor personal data, we also keep a record of when Visitors have asked us not to send direct marketing or to process Visitor data indefinitely so that we can respect the Visitor’s request in the future.

Sharing of Visitor Data

EventsOS may share information with third party service providers contracted to provide services on our behalf as well as third parties who resell EventsOS services.

EventsOS may also engage with business partners to jointly offer products, services or other programs such as webinars or whitepapers and from time to time, we may share personal data if you purchase or show interest in any jointly-offered products or services.

EventsOS will only share personal data of Visitors or Customers who attend a EventsOS marketing event with third parties if a) the Visitor explicitly consents, b) the Visitor permits their badge to be scanned, or c) it is permissible under applicable law.

Access, correct or delete Visitor data

Visitors have the same rights to access, correct or delete their personal data as do our Customers

Any Visitor that seeks to access, correct or delete data, can do so by submitting a request on our website at https://www.EventsOS.com/personal-data-requests. EventsOS will process this request within 30 days.

We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In such instances, we will inform the Visitor about the legal obligations that prevent us from fulfilling the request. 

We will maintain an audit history of any requests to access, correct or delete personal information to maintain a record of compliance with regulatory requirements.

How does EventsOS publicize changes to its Privacy Policy?

We will update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this website thirty (30) days prior to the changes becoming effective, or by email (sent to the e-mail address specified in your account) seven (7) days prior to the changes becoming effective. However, any changes to the Privacy Policy are effective immediately upon publication for new Visitors, Customers and Customer Business Contacts. We encourage you to periodically review this page for the latest information on our privacy practices.