Privacy Policy

1. Who We Are

222VZN is the data controller responsible for the personal data collected through the 222VZN mobile and web applications. For privacy-related inquiries, contact us at privacy@222vzn.com.

 

2. Data We Collect

We collect the following categories of personal data:

A. Account and Profile Information

• Full name or stage name, email address, and password (stored in hashed form).

• Profile photo / avatar image you upload.

• Biography, genre preferences, location, and social links (if provided).

• Role type: Artist or Promoter.

• For Promoters: company name and company description.

B. Booking and Transaction Data

• Booking requests, fee offers, negotiation history, and final agreed terms.

• Payment amounts, currency, payment status, and timestamps.

• Payment method details (handled by Stripe — we do not store raw card numbers; see Section 5).

• Payout history associated with your account.

C. Communications

• Messages you send and receive within Deal Rooms.

• Booking activity log entries (e.g., "Accepted", "Counter-offer received").

• Support correspondence with our team.

D. Technical and Usage Data

• Device type, operating system, and app version.

• IP address and approximate geographic location derived from IP.

• Session activity, screen views, and feature interactions (for crash reporting and improvement).

• Push notification tokens (if you grant permission).

E. Data You Provide Voluntarily

• Performance media (photos, videos) uploaded to your profile.

• Event images and event details entered by Promoters.

• Reviews or ratings submitted about other users (if this feature is enabled).

 

3. Legal Basis for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area, United Kingdom, or another jurisdiction with similar data protection law, we process your data on the following legal bases:

• Contract performance: Processing required to provide the booking marketplace service you signed up for.

• Legitimate interests: Fraud prevention, security, and improving the Platform — balanced against your rights.

• Consent: Sending optional marketing communications or using optional analytics features.

• Legal obligation: Retaining transaction records to comply with financial, tax, and audit regulations.

 

4. How We Use Your Data

• Create and maintain your account.

• Enable booking requests, Deal Room messaging, negotiation, and payment.

• Process and display your public profile to other users (Artists appear to Promoters; Promoter event information appears to Artists).

• Send transactional notifications (booking requests, status changes, messages) via in-app alerts and email.

• Detect and prevent fraud, abuse, and violations of our Terms of Service.

• Comply with legal obligations including tax reporting and payment record-keeping.

• Respond to support requests and resolve disputes.

• Improve the Platform through anonymised aggregate analytics.

• Send service-related emails (account updates, payment receipts, security alerts).

 

5. Third-Party Services and Data Sharing

We share your data only as necessary to provide the Platform and under appropriate data protection agreements:

Supabase (Database and Authentication) — All platform data is stored in Supabase-managed PostgreSQL databases. Supabase acts as a data processor under our instruction. Data is stored in the US. Supabase is SOC 2 Type II certified.

Stripe, Inc. (Payments) — All payment processing is handled by Stripe. When you add a payment method, Stripe collects and tokenizes your financial data; we receive only a token and limited metadata. Stripe is PCI DSS Level 1 certified. Stripe's Privacy Policy is available at stripe.com/privacy.

Expo / React Native (App Infrastructure) — Our apps are built with Expo. Push notification tokens may be transmitted through Expo's notification service. Expo's Privacy Policy is available at expo.dev/privacy.

Analytics and Error Monitoring — We may use crash reporting and performance monitoring tools (such as Sentry or equivalent). These services receive technical data only (device, OS, anonymised session info) and no personally identifiable financial data.

We do NOT sell, rent, or trade your personal data to third parties for marketing.

 

6. Profile Visibility

Artist profiles (name, bio, genres, location, media, and average rating) are visible to logged-in Promoters on the Explore page and in their booking flow. Promoter display names and event titles are visible to Artists in booking requests and Deal Rooms. We do not display email addresses or payment information publicly.

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7. Data Retention

• Active accounts: retained as long as your account is open.

• Booking and payment records: retained for a minimum of 7 years to satisfy financial and tax obligations.

• Deal Room messages: retained for 3 years after the booking date for dispute resolution purposes.

• Deleted accounts: profile data deleted within 30 days of deletion request; financial records retained per the legal minimums above.

• Inactive accounts: we may delete accounts with no activity for 24 consecutive months after 30 days' notice by email.

 

8. Your Privacy Rights

• Depending on your jurisdiction, you may have some or all of the following rights:

• Access: Request a copy of the personal data we hold about you.

• Rectification: Correct inaccurate or incomplete data.

• Erasure ("Right to be Forgotten"): Request deletion of your data, subject to legal retention obligations.

• Restriction: Ask us to pause processing in certain circumstances.

• Portability: Receive your data in a structured, machine-readable format.

• Objection: Object to processing based on legitimate interests.

• Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

• Non-discrimination (CCPA/CPRA): California residents have the right not to be discriminated against for exercising privacy rights.

To exercise any of these rights, email privacy@222vzn.com. We will respond within 30 days (or within the statutory deadline required in your jurisdiction). We may ask you to verify your identity before processing the request.

 

9. Children's Privacy

The Platform is not directed to, and we do not knowingly collect personal data from, individuals under 18 years of age. If you believe a minor has provided us with personal data, contact us immediately at privacy@222vzn.com and we will delete it promptly.

 

10. Data Security

We implement industry-standard safeguards including:

• TLS/HTTPS encryption in transit for all API and web traffic.

• Supabase row-level security (RLS) policies ensuring users can only access their own data.

• Hashed password storage (managed by Supabase Auth / bcrypt).

• Limited internal access to production data on a need-to-know basis.

• Payment data isolation via Stripe tokenization — raw card details never touch our servers.

No system is 100% secure. In the event of a data breach affecting your rights and freedoms, we will notify affected users and applicable regulators as required by law.

 

11. International Data Transfers

Our infrastructure is primarily US-based. If you access the Platform from outside the United States — including from the EEA or UK — your data will be transferred to and processed in the United States. We rely on Standard Contractual Clauses and our processors' own compliance frameworks (Supabase, Stripe) to provide adequate data protection for such transfers.

 

12. Cookies and Tracking (Web)

• Our web application may use:

• Essential session cookies: Required for authentication and security. No consent required.

• Analytics cookies: Used to measure usage and improve the product. You can opt out via your browser settings.

• No advertising or cross-site tracking cookies are used.

Mobile apps use local device storage only; no third-party advertising SDKs are included.

 

13. Push Notifications

We send push notifications for booking updates, messages, and deal-room activity. You can disable push notifications at any time through your device's system settings. Revoking notification permission does not affect your ability to use the Platform; you will still receive in-app alerts when the app is open.

 

14. Links to Third-Party Services

Our Platform may contain links to third-party websites or services (e.g., artist portfolio sites, event venues). This Privacy Policy does not apply to those third-party services, and we encourage you to review their privacy practices independently.

 

15. California Privacy Rights (CCPA/CPRA)

California residents have the right to know what personal information we collect, to request deletion, to opt out of sale (we do not sell data), and to non-discrimination. To submit a request, email privacy@222vzn.com with the subject line "California Privacy Request".

 

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by in-app notification or email at least 14 days before they take effect. Your continued use after the effective date constitutes acceptance of the updated Policy.

 

17. Contact and Complaints

For any privacy questions or to exercise your rights: Email: privacy@222vzn.com

If you are located in the EEA or UK and believe we have not handled your data in compliance with applicable law, you have the right to lodge a complaint with your local data protection authority (e.g., the UK ICO at ico.org.uk or your relevant EU supervisory authority).