1. Introduction.
We are LULHAM LTD. (“we”, “our” and “us”) and we operate under the name of Sin City. Artists, record labels, merchandisers, venues and promoters (“Sellers”) use us to power their online stores and websites (our “Services”). Your privacy is important to us and we are committed to protecting and respecting your privacy. This Privacy Policy is intended to help you better understand how we collect, use and store your “Personal Data” – defined as information that can be associated with or which relates to a person and/or could be used to identify a person.
Sin City collects and processes information on three main user groups:
1. Sellers (e.g. an artist who has created a Sin City-powered store)
2. Customers (e.g. a fan who buys something from an artist or venue via a Sin City-powered store)
3. Service Providers (e.g. a fulfilment service provider)
When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of a Seller using our services. This is an important distinction for EU data protection law purposes and is explained in more detail in Section 15 below.
Sin City will never sell on your Personal Data to third parties and if you choose to consent to receiving marketing emails from Sin City you will be able to unsubscribe at any time. Please note that Sin City does not control the practices of its Sellers and it is their responsibility to follow all applicable data protection laws.
“Non-Personal Data” as used in this Privacy Policy is any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.
By using any of Sin City’s services, or by dealing with a Seller using Sin City’s services, you are agreeing to the terms of this Privacy Policy and, as applicable, the Sin City Terms and Conditions for Sellers or Customers.
LULHAM LTD. is a company incorporated in England and Wales under company number 09714727. Our address is C/O Sin City Nightclub 14/16 Dillwyn Street, City Centre, Swansea, Wales, SA1 4AQ.
If you have any questions or concerns at any time you can contact us at the above address or via info@sincityclub.co.uk
2. Personal Data That We Collect.
2.1 All Users.
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with enquiries or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address” email addr”ss and other information that enables Users to be personally identified.
Information we automatically collect: We also automatically collect certain technical data that is sen’ to us from the computer, mob’le device and/or browser through which you access the Services (“Automatic Data”). Automatic Data, includes without limitation, a unique identifier ‘ssociated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies.
When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
2.2 Sellers.
As a Seller we will collect additional Personal Data from you.
Information you provide to us: We will collect financial information from you (e.g., your bank account information or billing address) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as third party websites, your bank, our payment processing partners and credit reporting agencies.
2.3 Customers.
As a Customer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of a Seller (see Section 15 below for more information).
Information you provide via the Sin City Services: If you buy items (such as tickets, merchandise) from a Seller, you will provide Personal Data (e.g. your name, address, email). Personal Data collected on behalf of Sellers is provided to the Seller in accordance with section 4.5 below: “How We Disclose and Transfer Your Personal Data: Sellers”.
Some Sellers may set customised fields at checkout requesting additional Personal Data from Customers. Sin City is not responsible for the content of the additional fields requested nor the Personal Data they collect. Sellers may use additional third party integrations on their sites, which is outside the control and responsibility of Sin City.
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Sellers, other Customers, social media or other third party integrations, our payment processing partners or other third parties.
2.4 Service Providers
Service Providers are specific individuals or businesses that have agreed to the terms of the Sin City Terms and Conditions to work with Sin City to provide associated services such as order fulfilment, print on demand manufacturing or ticket insurance products.
Information you provide to us: We will collect financial information from you (e.g., your bank account information or billing address) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Sellers, other Customers, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.
3. How We Use Your Personal Data.
We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:
3.1 Specific Reason.
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
3.2 Access, Use and Provision of Services
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Da’a to provide you with access to or use of the Services or functionality and to analyse your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity to use certain portions of the Services, we will use that information to grant you access to use such Services. Similarly, if you supply Personal Data in the course of an ecommerce transaction, we will use that Personal Data to fulfil that transaction and supply you with the items/events you have purchased, or to help you to do so (such as via abandoned cart functionality).
3.3 Internal Business Purposes.
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
3.4 Marketing Communications.
You will only receive marketing emails from Sin City if you have opted in to receive them. We will make sure it is clear when you can make these choices, for example, we have boxes you need to select if you want to receive marketing at checkout. You will always be able to unsubscribe from any marketing emails from Sin City.
Sin City (or Sellers where applicable) may email you with reminders or warnings relating to your account or purchases, most commonly for the purposes of providing customer support.
If you are a Seller using Sin City’s services, we do not use the Personal Data we collect from you or your customers to independently contact or market to your customers. However, Sin City may contact or market to your customers if we obtain their information from another source, such as from the customers themselves. We may contact you, as a Seller, to inform you about our Services.
You can opt out at anytime by clicking “unsubscribe” in the email or by contacting info@sincityclub.co.uk.
Sin City provides a mailing list signup widget and sign up option in the site’s footer and at checkout for Sellers’ Customers to join the Seller’s mailing list. For example, if you are signing up to a mailing list for a band, it will state clearly who that band is. If you sign up for the band’s mailing list, that data will be passed to the band and it is then their responsibility to ensure they follow all data processing regulations. Sin City will not contact you for marketing purposes (unless you also join our mailing list).
3.5 Other Purposes.
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.
3.6 Aggregated Personal Data.
In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behaviour based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.
4. How We Disclose And Transfer Your Personal Data.
4.1 No Sale.
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.
4.2 Business Transfers.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Sin City (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.
4.3 Parent Companies, Subsidiaries and Affiliates.
We may also share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.
4.4 Agents, Consultants and Service Providers.
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Sin City to perform certain business-related functions. These companies include fulfilment providers, payment processors, online chat and email providers, money transfer services, database service providers, backup and disaster recovery service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
4.5 Sellers.
When transacting on Sin City, you are buying from a Seller that is typically an artist, one of their partners, or a music…