Business data
Data Processing Terms
These terms describe how Lepews LLC processes attendee and event information on behalf of MyPass Clients. A signed data processing addendum may supplement these terms where required.
1. Roles and instructions
For personal information a Client submits to provide VIP access services, the Client is generally the controller or business and Lepews LLC is its processor or service provider. Lepews processes that information only to provide, secure, maintain, and support MyPass; follow documented Client instructions; and meet legal obligations.
2. Processing details
Processing may include collecting, organizing, storing, retrieving, displaying, transmitting, updating, validating, exporting, and deleting data. Data subjects may include Client personnel, VIP attendees, guests, artists, event staff, and business contacts. Data may include identification and contact information, event and access details, schedules, communications, pass identifiers, validation records, and technical logs.
3. Client responsibilities
The Client is responsible for the lawfulness, accuracy, and scope of its instructions and data; providing required privacy notices; responding to attendee requests; establishing retention requirements; and ensuring that its use of MyPass complies with applicable law.
4. Confidentiality and security
Lepews requires personnel with access to Client data to protect its confidentiality and uses administrative, technical, and organizational safeguards designed for the nature of the Service and information processed. More information appears in the Security Overview.
5. Service providers
Lepews may use service providers to support hosting, infrastructure, email delivery, digital wallet functionality, analytics, support, security, payment processing, and integrations. Lepews remains responsible for requiring providers that process Client personal information to protect it consistently with applicable contractual obligations.
6. Assistance
Taking into account the nature of processing and information available, Lepews will reasonably assist the Client with verified data-subject requests, security incidents, legally required assessments, and regulator inquiries. Additional work may be subject to agreed fees where permitted.
7. Security incidents
Lepews will notify the affected Client without undue delay after confirming a breach of Client personal information where notification is required. Notice will include available information reasonably needed for the Client to meet its obligations.
8. Return and deletion
On account deletion or termination, Lepews will delete or return Client personal information according to Client instructions and the commercial agreement, except where retention is required for legal, billing, security, backup, or dispute-resolution purposes.
9. International transfers
Where processing involves a restricted international transfer, the parties will use an applicable lawful transfer mechanism. A Client requiring jurisdiction-specific contractual clauses should contact Lepews before submitting regulated data.
10. Contact and additional terms
Requests for a signed data processing addendum, security information, or provider details may be sent to [email protected]. If a signed data processing addendum conflicts with these public terms, the signed addendum controls.