GREEN ROOM 360 Pty Ltd ACN 679 360 591 ("Greenroom", “we”, “us” or “our”) is committed to providing quality services to you and to respecting your privacy.
This privacy policy ("Privacy Policy") sets out how we collect, use, process, store, share and disclose your Personal Information (as defined in section 1 below) from the operation of our website at www.greenroom360.com ("Website"), our Greenroom 360 platform being a SaaS platform and app relating to the music industry allowing managers, artists, industry stakeholders and fans to operate and interact ("Greenroom 360") and related services (each of the Website, Greenroom 360 and related services, together the "Services").
Please note that if you are a Greenroom customer or user of Greenroom 360, when you signed up for any of our Services, you agreed to our Terms of Use by entering into an agreement with Greenroom, which includes obligations in this Privacy Policy.
We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles ("APPs") contained in the Privacy Act 1988 (Cth) and the General Data Protection Regulation (EU 2016/679) (the "GDPR"), and if applicable, the California Consumer Privacy Act ("CCPA"), the California Privacy Rights Act ("CPRA") and any other relevant laws pertaining to privacy of individuals in jurisdictions which our Services are available (collectively, "Privacy Laws").
We are a data controller for the purposes of the GDPR, but in some circumstances may be a data processor. We ensure that we will take all necessary and reasonable steps to comply with the relevant Privacy Laws and to deal with inquiries or complaints from individuals about compliance with the relevant Privacy Laws.
By accessing and using our Services, you freely and expressly consent to the collection, use, processing, storage and disclosure of Personal Information by us as set out in this Privacy Policy.
Information collected by Greenroom
Personal information is any information relating, directly or indirectly, to an identified or identifiable natural person (“Personal Information”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
The type of Personal Information we collect from you includes, without limitation, the following:
- Identification and Contact Details: your full name, mailing address, email address, telephone number(s), date of birth, gender, profession, role and place of work.
- Billing Information: credit or debit card information using a third-party payment provider and your ABN (if relevant).
- Traffic Information: your device ID, device type, geo-location information, computer and connection information, screen resolution, site usage, session information, statistics on page views, acquisition sources, traffic to and from the sites, ad data, IP address and standard web log information.
- Product Information: details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries.
- Provided Information: any additional information relating to you that you provide to us, directly or indirectly, through use of our Services or through customer surveys anonymously.
- Content: any information which you view, engage, publicly post or upload to Greenroom 360 or social media sites via our Services.
- Survey/Feedback Information: information you provide to us through customer surveys or requests for feedback.
- Biographical Information: information provided when you inquire about or apply for a position with Greenroom.
- Other: any other Personal Information that may be required in order to facilitate your dealings with us, including but not limited to any preference, including Artists followed, managed, user rankings, events attended, purchasing and spend information and any other usage and engagement data through the course of using our Services.
How we collect your Personal Information
We will collect Personal Information only by lawful and fair means and never in an unreasonably intrusive way. Generally, we will collect your Personal Information:
- Directly from you, where you provide information to us or interact with us;
- Automatically in the course of using our Services; and
- From our business partners or other third-party sources that provide consumer data, such as information about your interests, demographic information, and marketing details.
If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our Services as requested.
We require individuals to provide accurate, up to date and complete Personal Information at the time it is collected.
How we treat Personal Information that is also sensitive Personal Information
We are not allowed to collect sensitive Personal Information or special categories of Personal Information (as defined under the relevant Privacy Laws) from you without first obtaining your consent, such as any sensitive personally identifiable information (such as information related to racial or ethnic origin, sex life or sexual orientation, political opinions, religious or other beliefs, genetic or biometric data, health, criminal background or trade union membership). If you do provide any sensitive Personal Information, and where no exceptions apply, we require that you provide express consent to us collecting that information as part of you using our Services.
Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including:
- Providing services for a purpose that is directly related to the primary purpose for which the sensitive information was collected; and
- Data analytics purposes.
Sensitive information may also be used or disclosed if required or authorised by law.
Information about users under the minimum legal age
Our Services are not intended for users under the minimum legal age in your country to lawfully use Greenroom 360. Any Personal Information found to have been provided by a user that is under the minimum legal age in your country to lawfully use Greenroom 360, without parent or guardian consent, will be removed as soon as possible and we will cease the use of that Personal Information and deactivate any related account.
How your Personal Information is used
We use, process and disclose your Personal Information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):
- Providing our Services to you;
- Administering, protecting, improving or optimising our Services;
- Managing, operating and improving our Services and growing our business, including data analytics, conducting research for understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, advertisements and publications, and diagnose or fix technology problems;
- Creating industry reports from de-identified data;
- Verifying your identity or age;
- Billing you for purchasing our products and services;
- Informing you about our Services, products, services, rewards, surveys, contests, or other
- Promotional activities or events sponsored or managed by us;
- Responding to any inquiries or comments that you submit to us;
- Accessing, recruiting and hiring staff;
- Performing any other function that we believe reasonable and necessary to protect the security or proper functioning of our Services;
- Any other purpose you have consented to; and
- Any use which is required or authorised by a relevant Privacy Law, including detecting, investigating and preventing conduct which may violate our policies, are fraudulent or illegal and protect the rights of Greenroom, you or others.
Where we:
- Have your express consent;
- Have a legal basis; or
- Are otherwise permitted by relevant Privacy Laws,
- We may use and process your Personal Information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.
At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at
support@greenroom360.comWho we may need to disclose your Personal Information to
We may disclose your Personal Information to the following:
Outsourcing Companies: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 5.
Analytics: as a part of providing you with, measuring and improving our Services, we may engage with analytics providers who collect information utilising tracking technologies on our Website, Greenroom 360 and software to measure visits and traffic on our Website, Greenroom 360 or servers which provide you the Services.
Related Bodies: we may share information with other entities in the Greenroom corporate group, our related bodies corporate and associates (including, for example, Glasshouse Venture Studio Pty Ltd (ACN 655 397 023)), for purposes consistent with this Privacy Policy.
Employees, Contractors and Partners: we may share information with our employees or contractors for the provision of our Services or other agents and business partners consistent with this Privacy Policy.
Consented Parties: any person or entity to whom you have expressly consented to us disclosing your Personal Information to.
External Advisors: our external business advisors, auditors, lawyers, insurers and financiers.
Payment Providers: our payment processing service provider to enable billing transactions.
Legal: any person or entity to whom we are required or authorised to disclose your Personal Information to in accordance with the relevant Privacy Laws.
We will only disclose any Personal Information you have provided to any entity outside of the Greenroom corporate group if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy. This may include, but is not limited to, disclosing information to the following service providers:
- IT service providers;
- Data storage providers to collect and process data;
- Web-hosting and server providers;
- Debt collectors;
- Maintenance or problem-solving providers;
- Agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you;
- Payment systems operators,
(each a “Service Provider”).
When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to any of the above Service Providers, including data processors. We will take steps reasonably necessary to ensure your Personal Information is treated securely and will only be processed in accordance with this Privacy Policy.
When we refer to ‘processing’ in this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.
We use reasonable endeavours to ensure that each recipient receiving your Personal Information is bound by the relevant Privacy Laws.
How we store and protect your Personal Information
We use all reasonably necessary measures to protect the information we collect through our Services which are stored electronically. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical, electronic and managerial procedures such as the pseudonymisation and encryption of Personal Information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We also apply these principles to the way we collect, store and use the personal information of our users, customers or clients.
However, we cannot guarantee the absolute security of any Personal Information transmitted over the internet and therefore you disclose information and Personal Information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your Personal Information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.
If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.
What is our legal basis?
Under the GDPR, we must have a legal basis to process Personal Information collected from individuals residing in the European Union. We rely on several legal bases to process your Personal Information, including:
- Where it is necessary to provide you with access to, and use of, the Services;
- For our legitimate interests to provide, operate and improve our Services;
- Where you have freely and expressly consented to the processing of your Personal Information by us, which you may withdraw at any time; or
- Where we are under a legal obligation to process your Personal Information.
Cross-border disclosure of Personal Information
We may disclose your Personal Information to third-party recipients located in or outside of the jurisdiction in which Personal Information is provided in order to provide our Services to you. As at the date of this Privacy Policy, such third-party recipients are located in other countries whose laws may not be recognised by the EU Commission as providing an adequate level of protection to Personal Information. It is possible that additional third parties from other countries may be recipients in the future.
In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
When entering into a transaction with us you consent to your Personal Information being disclosed or transferred to such third-party recipients and you acknowledge and agree that we will take such steps as are reasonable in the circumstances to ensure that the information that is transferred or disclosed to the third-party recipients will be treated in a manner that is consistent with the relevant Privacy Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by a third-party recipient of the relevant Privacy Laws.
Direct marketing and communications
- Have your express consent (which you may withdraw at any time by contacting us in writing at support@greenroom360.com;
- Have a legal basis; or
- Are otherwise permitted by relevant Privacy Laws,
We may use and process your Personal Information to send you information about our Services as well as other products and services we believe may be suited to you and your interests or we may invite you to attend special events.
At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at
support@greenroom360.com.Cookies
We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. By accessing or using this Website, you agree that we can store and access Cookies in accordance with this Privacy Policy. You will be able to accept or reject the collection of Cookies by us.
Cookies are small files that can be stored on and accessed from a user’s device when the user accesses a website. They enable authorised web servers to recognise you across different websites, services, devices and browsing sessions.
Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our sites with personal information, this information may be linked to the data stored in that Cookie.
We may use Cookies to enable users to access and use our Website, Greenroom 360 and Services, including to:
- Identify users of our Website, Greenroom 360 and Services;
- Process user requests;
- Improve user experience;
- Remember user preferences on our Website, Greenroom 360 and Services;
- Monitor the use of our Website, Greenroom 360 and Services and for analysis of our user base;
- Facilitate communication with users;
- Control access to certain content on our Website, Greenroom 360 and Services; and
- Protect our Website, Greenroom 360 and Services.
You can delete and refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website, Greenroom 360 and Services.
Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Website.
Choices regarding Your privacy
You may be provided with choices with how we collect and process your information, including:
- Opting out or adjusting preferences for Cookies when your device accesses the Website; customising your browser settings to disable or reject Cookies across the internet. It’s important to note that deleting Cookies or declining them in your browser settings might affect the functionality of our Website, Greenroom 360 and Services; and
- Using your mobile device’s operating system to select options on how it collects and utilises your information for interest-based advertising, if accessing the Services from a mobile device.
Notices specific to certain jurisdictions
We are dedicated to ensuring that individuals in certain jurisdictions have access to their privacy rights as provided by the Privacy Laws of your jurisdiction. We have set out details below dependent on your location.
Australia
You have the right to both ask:
- For access to Personal Information that we hold about you; and
- That we correct Personal Information we hold about you.
If you ask, we must within a reasonable timeframe (being within 30 calendar days) give you access to your Personal Information and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.
We will notify you in writing and explain our reasons if we refuse to give you access to, or correct, your Personal Information.
European Economic Area
For the purposes of the GDPR, we are a ‘data controller’ of your Personal Information. Under the GDPR, an individual residing in the European Union has enhanced privacy rights, including the right to:
- Require us to correct any Personal Information held about you that is inaccurate or incomplete;
- Require the deletion of Personal Information concerning you in certain situations;
- Data portability for Personal Information you provide to us;
- Object or withdraw your consent at any time to the processing of your Personal Information; object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; or
- Otherwise restrict our processing of your Personal Information in certain circumstances.
Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.
We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.
If you believe that we hold Personal Information about you that is not accurate, complete or up to date, then you may request that your Personal Information be amended. We will respond to your request to correct your Personal Information within a reasonable timeframe, and you will not be charged a fee for correcting your Personal Information.
If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.
California
If applicable, for users who are resident in California, we do not sell your Personal Information for any commercial purposes.
Under the CCPA, Californian residents are given the right to know what type of Personal Information has been collected by us about them, and if this Personal Information has been disclosed for purposes set out in this Privacy Policy in the last 12 months.
We set out below the categories of information we collect (utilising terms as defined in the CCPA).
Information we may collect and disclose:
- Identifiers: This includes names, addresses (both physical and email) personal identifiers (including online, internet protocol addresses, or other similar identifiers;
- Personal Information categories under the California Customer Records statue (Cal. Civ. Code §1798.80e):This includes names, signatures, physical characteristics, address, telephone numbers, state identification numbers, education, employment, bank account numbers, credit card number, debit card number.
Information we will not collect or disclose:
- Protected Classification characteristics under Californian or federal law: this includes age, race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical conditions, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information;
- Biometric Information: Genetics, physiological behavioural or biological characteristics;
- Internet or similar network activity: History or search history;
- Geolocation date: Physical location or movements;
- Employment: Current or past employment history;
- Education: Information that is not publicly available as defined in the California Family Education Rights and Privacy Act (20 U.S.C section 1232g, 34 C.F.R, Part 99).
Californian residents also have specific rights provided by the CCPA set out below:
- A right to access your Personal Information collected, used and disclosed by us in the past 12 months;
- A right to request that we move, copy or transmit your Personal Information stored by us to another location;
- A right to delete any of your Personal Information collected and stored by us, and, by extension, a service provider to us;
- A right to correct any of your Personal Information collected and stored by us; and
- A right to non-discrimination for the exercise of your privacy rights under the CCPA.
If you are a resident of California and wish to exercise any of your rights under the CCPA, please contact us at
support@greenroom360.com. California residents maintain the right to exercise the rights given to them under the CCPA.
When you provide any information to us, we ask that you provide sufficient:
- Information that allows us to reasonably verify you or are an authorised representative of that person; and
- Detail such that we understand and can evaluate your request.
We will always endeavour to respond to you within a reasonable time period after receipt of a request. If we require additional time or have been delayed, we will communicate with you directly. All our communications will be via email and any disclosures we provide will only cover a 12-month period preceding your request. If applicable, any response from us may also provide a reason why we cannot comply with a request.
Access, Management or Deleting your Personal Information
Subject to some exceptions provided by the relevant Privacy Laws, you may request access to your Personal Information in our customer account database, or seek correction of it, by contacting us at
support@greenroom360.com. Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.
We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.
If you believe that we hold Personal Information about you that is not accurate, complete, or up to date, then you may request that your Personal Information be amended. We will respond to your request to correct your Personal Information within a reasonable timeframe, and you will not be charged a fee for correcting your Personal Information.
If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.
Third Party Sites and Services
Our Services may contain links to other third-party websites and services including social media networks. We do not have any control over those websites and services and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites or services. This Privacy Policy applies solely to information collected by us via our Services.
Contacting Us
If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at
support@greenroom360.com or send mail to: GREEN ROOM 360 Pty Ltd, PO Box 208, South Melbourne, VIC, Australia, 3205
Notices and Revisions
We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice. To extent permitted by law, all changes and clarifications will take immediate effect, after the posting of the amended Privacy Policy on the Website.
Enforcement
We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personally identifiable information that cannot be resolved between us and the individual.
Last updated: December 2024
