Beta Privacy Notice

This Notice provides the first layer of privacy information for Buyers and Attendees using Fomomento during the limited beta. It applies when a person visits a public Event page, completes a free or paid registration, places an Order, claims a ticket, receives Event-related communications, manages a ticket or checks in through the Platform. More detailed information about Event-related Processing is provided in the Organizer's event-specific privacy notice. Information about Processing carried out by Fomomento for its own purposes is provided in the Fomomento Privacy Policy.

Capitalised terms not defined in this Notice have the meanings given in the Terms of Service or, in the case of data-protection terms, in the GDPR.

  1. Who is responsible for Personal Data

    1. The Organizer identified by name and contact details on the Event page or in the relevant registration or ticket-access flow is the Controller of Personal Data relating to the Event. The Organizer determines the purposes and legal bases of that Processing and the applicable retention periods.

    2. Fomomento OÜ, registry code 17490570, with its registered office at Tartu mnt 67/1-13b, Kesklinna linnaosa, 10115 Tallinn, Estonia, provides the Platform and normally Processes Event-related Personal Data on the Organizer's behalf under a Data Processing Agreement.

    3. Fomomento acts as a separate Controller only for limited Processing for which it determines its own purposes and essential means, including delivery and security of public Platform interfaces, abuse prevention, direct support and compliance with legal obligations. That Processing is described in the Fomomento Privacy Policy.

  2. What Personal Data are used and why

    1. Depending on the Event and the function used, the Personal Data may include a name, email address, optional organization details, Order and ticket information, payment method and payment-status metadata, pro forma or refund records, registration answers, attendance, ticket-claim and check-in status, an email address confirmed by the Attendee in the ticket-access flow and the time of that confirmation, one-time access-code records, identity confirmation records, hashed ticket-access session records, communication and delivery status, and limited device, session and security information. Fomomento does not receive full payment-card details or hold ticket-sale funds. The relevant flow indicates which fields are required and which are optional.

    2. Personal Data may be obtained directly from the Attendee, from another authorised person providing details for an Attendee, from the Organizer, from a relevant integrated provider and automatically from the device and interaction with the Platform.

    3. Event-related Personal Data are used to display and administer the Event, receive and confirm a free or paid registration, create and administer an Order, record card or bank-transfer payment status, issue a ticket, manage attendance and check-in, send confirmations and operational Event updates, provide support, protect the Platform and prevent fraud or misuse.

    4. The Organizer's event-specific privacy notice identifies the Organizer, explains the purposes and legal bases of Event-related Processing and provides the other information required by applicable data-protection law. The Platform makes that notice available in, or immediately accessible from, the relevant flow before Personal Data are submitted. If information lawfully marked as required is not provided, registration, Order processing, ticket access or check-in may not be completed.

    5. If the Organizer collects health information or another special category of Personal Data, the Organizer's event-specific privacy notice and concise information presented with the relevant question identify the Organizer as Controller and explain the data, specific purpose, legal basis and withdrawal route before the answer is submitted. If Processing is based on explicit consent, that consent is requested through a separate, unticked control and is not combined with acceptance of the Terms or acknowledgement of a privacy notice. The privacy information remains available before consent is given; providing that information does not itself constitute consent, and consent does not replace the duty to provide the information.

    6. Where the Organizer relies on consent or permission for photography or filming, inclusion on a public Attendee list, disclosure of details to sponsors or electronic marketing, the person is asked to make a separate and voluntary choice for each relevant purpose after receiving information about the intended use or disclosure. Refusal or withdrawal does not affect ticket purchase, ticket access or attendance unless the relevant Processing is objectively necessary for the Event and another lawful basis applies.

  3. Recipients and international transfers

    1. Event-related Personal Data may be available to the Organizer and its authorised Team Members and may be Processed by Fomomento and providers supporting hosting, databases, authentication, content delivery, security, email, error monitoring and other functions enabled for the Event. Personal Data may also be disclosed where required by law or necessary to establish, exercise or defend legal claims.

    2. Core application and database services are configured in the European Economic Area. Some providers operate globally or outside the European Economic Area. The Organizer's event-specific privacy notice and the Fomomento Privacy Policy provide further information about relevant transfers and safeguards. Card payment information is provided directly to Stripe, while a bank-transfer payment is made directly to the Organizer's bank account using the payment instructions provided for the Event.

  4. Retention and security

    1. The Organizer determines how long Event-related Personal Data are needed and states the applicable period or criteria in the event-specific privacy notice. Fomomento retains, returns or deletes those data in accordance with the Organizer's documented instructions and the Data Processing Agreement. Personal Data for which Fomomento acts as Controller are retained in accordance with the periods or criteria in the Fomomento Privacy Policy.

    2. Fomomento applies technical and organisational measures appropriate to the risk, including access restrictions, authentication and session controls, encryption in transit and, where appropriate, at rest, logical segregation, backups, logging, incident response and supplier management.

    3. During check-in without an internet connection, a limited Event-specific roster and check-in queue may be stored in encrypted form on a device used by the Organizer's staff. The local data excludes raw email addresses, registration answers and payment data. Successfully synchronised queue records are deleted after server confirmation, and the limited roster is deleted on expiry or another wipe event described in the Data Processing Agreement.

  5. Messages, cookies and analytics

    1. The Platform may send confirmations, ticket and ticket-access messages and operational updates concerning the Event, including changes to its schedule, venue or access arrangements. Fomomento does not use these beta communications for its own direct marketing. Any marketing communication sent by an Organizer requires its own lawful basis and privacy information.

    2. At the date of this Notice, Fomomento uses only device storage or access needed for authentication, security, language preferences and functionality requested by the User. Fomomento does not use third-party advertising trackers or active product-analytics cookies during the beta. Further information is provided in the Fomomento Privacy Policy.

  6. Rights and complaints

    1. Subject to the conditions and exceptions in the GDPR, a Data Subject may request access to, rectification or erasure of Personal Data, restriction of Processing and data portability, and may object to Processing based on legitimate interests. Where Processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of Processing carried out before withdrawal.

    2. A request concerning an Event, registration, ticket, registration answer, attendance or check-in should be sent to the Organizer using the contact details displayed in the relevant Event flow. If Fomomento receives such a request and can identify the Organizer, Fomomento will forward it and provide the assistance required under the Data Processing Agreement. A request concerning Processing for which Fomomento acts as Controller may be sent directly to Fomomento.

    3. Questions or requests concerning Processing for which Fomomento acts as Controller may be sent to privacy@fomomento.events.

    4. A Data Subject has the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of habitual residence, place of work or alleged infringement.

  7. Data about another person and children

    1. Where a person completing a registration provides basic details for another Attendee, the Organizer is responsible for ensuring that the person is authorised to provide those details and that the Attendee receives the applicable privacy information. A statement made by the person completing the registration does not amount to consent on behalf of another competent adult. Health-related information about such an adult should be obtained directly from that adult through an appropriate individual flow.

    2. An Event may involve Attendees who are children. The Organizer is responsible for the applicable legal basis, age-appropriate privacy information and any authorisation required from a holder of parental responsibility. Fomomento Processes the child's Event-related Personal Data on the Organizer's behalf.

  8. Further information

    1. The Organizer's event-specific privacy notice is made available on the public Event page and before Personal Data are submitted through the relevant checkout, registration, ticket-access or ticket-management flow. Fomomento records the version made available in connection with the relevant Order or ticket claim. The Organizer is responsible for keeping the notice accurate and for communicating any material updates where required by applicable law. Fomomento’s Privacy Policy is available at fomomento.events/privacy.