# PRIVACY POLICY

# This Privacy Policy applies to the Products and the Website.

# Last Updated and Effective: November 27, 2023

OTS EVENTS, L.P., (“OTS”, “we”, “us” and “our”) an affiliate of Jamestown L.P., offers a mobile application and operates a website where users can download the app and obtain information and services related to or in connection with our Virtual New Years Eve experience (collectively, the “Products”). We describe our Products including our website, mobile app, platform, content, services, and any product or service that links to this Privacy Policy—in our Terms of Service (opens new window). This Privacy Policy explains how we treat information from or about you, including how we collect, use, and share information on our Products.

What kind of information do we collect?
How do we use information?
How is information shared?
Cookies and Other Tracking Technology
How do we respond to legal requests and prevent harm?
Information for California Residents
Information for Virginia, Colorado, Connecticut and Utah residents
Security
How will we notify you of changes to this policy?
Contact Information

# 1. What kind of information do we collect?

Personal information is information that relates to or can be used to identify you, either alone or in combination with other information. The personal information collected through the Products include:

1) Information Automatically Collected. We collect information automatically when you are connected to the Products. Depending on how you access and use Products, we collect information such as:

a) Information about your interactions with Products, like information about the people, content, apps, features, or other experiences you interact with, including information collected through or from content provided by our third-party partners;
b) Information collected in or through cookies, local storage, pixels, and similar technologies on the website (additional information about these technologies is available below in the section titled Cookies and Other Tracking Technologies);
c) Information about how you access our website, including information about the type of device you're using (such as a computer, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing;
d) Information about the features you interact with on the Products. For example, we receive information about your Products usage, such as interactions with recommended pages, which browser features you use, crash reporting data, and other statistics related to your Products usage; and e) Technical system information such as crash logs which may contain your user ID, device ID, IP address, local computer file path, feature quality, amount of time it takes to load a feature, and whether you use a certain feature.

2) Information You (and others) Provide. We collect the information you (and others) give us when using Products. For example:

a) When you register to use Products, we ask for information such as your email address.
b) We collect information about the people, content, and experiences you connect to and how you interact with them across our Products. c) When you post, share or communicate with us or other Products users on our Products, we receive and store those communications and information associated with them, such as the date a post was created.
d) When you communicate with us, you may provide us with information like your email address and location.

3) Information From Third Parties. We also receive information about you from third parties, including third-party apps, developers, other online content providers, and marketing partners that provide us statistics about the effectiveness of advertisements prompting to the website or app store to download our app.

The following provides examples of the type of information that we collect from you and how we use that information:

Context	Types of Data	Legal Basis for Collection and Use of Data
Account Registration	We collect your email address when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We provide account related functionalities to our users upon consent when creating an account.
Non-essential third-party cookies and third party tracking	We use third-party cookie and tracking technology to collect information about your use of our website for marketing and statistical purposes.	We display a cookie banner to make you aware that non-essential cookies might be integrated on our website. If you continue to use this website without changing your browser’s cookie settings, you agree to this use of cookies.
Email Interconnectivity	If you receive email newsletters from us, we use certain tools to capture data related to when you open our message or click on any links or banners it may contain.	We have a legitimate interest in understanding how you interact with our communications to you. You can withdraw your consent to receive our email newsletters at any time by clicking on the “unsubscribe” link in such email communications.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List	When you sign up for one of our mailing lists we collect your email address.	We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Mobile Devices	We collect information from your mobile device, such as unique identifying information broadcast from your device, when visiting our website.	We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

# 2. How do we use information?

In addition to the uses set forth above, we use personal information as set out below and to provide our Products to you and our partners for the following purposes:

To provide and personalize our Products. We have a legitimate interest in using the information we collect to provide you with our Products. For example, we use this information to:

a) Provide you with content, apps, and other experiences;
b) Create accounts and user profiles;
c) Communicate with you about our Products;
d) Provide technical support; and e) Notify you about updates to our Products; and

To improve and develop your experience and our Products. We have a legitimate interest in using the information we collect to understand and improve our Products. For example, we use the information to:

a) Solicit and analyze input and feedback about our Products;
b) Identify and address technical issues on our Products; and c) Improve and develop our features.

To communicate with you. We have a legitimate interest in using the information we collect to respond to your inquiries, provide customer services, send you updates about events and your account, and otherwise as needed to manage and administer your use of the Products.

To market to you. We use the information we collect to send you promotional messages and content about Products and related experiences on and off our Products. Where required by law, we do this with your consent. We also use this information to measure how users respond to our marketing efforts. If you would like to opt out of receiving marketing emails, please click the unsubscribe link at the bottom of any of our email messages to you.

To promote safety, integrity and security. We have a legitimate interest in using the information we collect to verify accounts and activity, combat harmful conduct, detect and prevent bad experiences, maintain the integrity of our Products, and promote safety and security on and off our Products. For example, we use information collected to investigate suspicious activity or violations of our terms or policies, detect when someone needs help, and protect our or others’ rights or property.

# 3. How is information shared?

Our Products help you engage with the ecosystem and others that interact with it. To provide and support our Products, information we have about you is shared in certain circumstances. Here is who can see information about you when you and others use our Products.

Public Information. Certain information you post to your Products profile, such as your Username and avatar, will be public and visible to people on and off our Products. Your Username is a unique identifier you choose to identify yourself on our Products.

Service providers. We share the information we collect with vendors, service providers, and other partners, who work at our direction to support the Products (such as hosting our Products, analyzing the way people use our Products, , providing customer service, or sending electronic communications for us). For example, we utilize a service provider to develop and maintain the Products.

Permission. If you choose to share, stream, upload, or post your experience or information from our Products on a third party platform, the information and content will be managed according to the privacy policy and terms of use of the third party platform. Please take caution when sharing your information and content. Once shared, you may not be able to remove or edit the information. We may also share your personal information in situations where you consent to us doing so.

Law enforcement or legal requests. We share information with law enforcement or in response to legal requests in the circumstances outlined in Section 5 below.

We may also share de-identified or aggregate data with others. De-identified data means information where we have removed your name and other data that could reasonably be used to identify you. Aggregate data is data that has been combined with other data so that it doesn’t identify any specific person.

# 4. Cookies and Other Tracking Technology

Products may collect information by using technologies and methodologies, such as tags, web beacons or other similar technologies that enable tracking as you browse the Products. Cookies are small files used by many websites that reside on your computer’s hard drive and store information about your use of a particular site.

Generally, we use first-party and third-party cookies for the following purposes: to make our Products function properly; to provide a secure experience during your use of Products; to collect passive information about your use of Products; to measure how you interact with our marketing campaigns; to help us improve Products; and to remember your preferences for your convenience.

We may use the following types of cookies on our Products:

Strictly Necessary Cookies – These cookies are essential because they enable you to use our Products. For example, strictly necessary cookies allow you to access secure areas on our Products. Without these cookies, some Products cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Products to work and they cannot be disabled.
Functional Cookies – We use functional cookies to remember your choices so we can tailor Products to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences. We do not use functional cookies to target you with online marketing.
Performance or Analytical Cookies – These cookies collect passive information about how you use Products, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize Products. We do not use these cookies to target you with online marketing.

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Products by taking the steps outlined below:

First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of Products may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org (opens new window).
Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices (opens new window). Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers (opens new window).

Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

# 5. How do we respond to legal requests and prevent harm?

We access, preserve and share information with regulators, law enforcement or others in response to a legal request (like a search warrant, court order or subpoena), if we have a good faith belief that the law requires us to do so. This includes responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. Information we receive about you, including your location, web behavior, and financial transaction data related to purchases made on or through our Products, can be accessed, processed and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from Products accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other term violations.

# 6. Information for California Residents

This Section applies only to California residents and contains the information that the California Consumer Privacy Act, as amended, and its regulations, (“CCPA”) requires us disclose. This Section describes our collection, use and sharing practices in relation to personal information of California residents, and informs California residents of their rights with respect to that Personal Information. We do not sell your personal information, and we do not rent or share your personal information with third parties for such third parties’ direct marketing. We do not collect or process sensitive personal information as defined in the California Civil Code Section 1798.140 for the purpose of inferring characteristics about a consumer.

i. Categories of Personal Information we collect may include: You can find a list of the categories of information that we collect and share in the table below.

ii. Sources of Personal Information

In addition to descriptions of sources elsewhere in this policy, we receive personal information from the information that you and others provide, from your device(s), and from our partners. The categories of sources from which we’ve collected or received Personal Information include:

You: We collect information you provide when you use our Products, including when you sign up for an account. We also collect information about how you use our Products, such as information about the people, activities, content, apps, features, or other experiences you interact with.

Other people: We also collect content and information that other people provide when they use the Products. This can include information about you, like when they send us an abuse report that refers to you.

Your device(s): We collect information from and about the devices you use to access our website, including information about the type of device you're using (such as a desktop, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing.

iii. How can you exercise your rights provided under the CCPA?

Under the CCPA, you have the following rights:

The right to request that we disclose to you the specific pieces of personal information that we have about you;
The right to request that we disclose to you the categories of personal information that we have collected about you;
The right to request that we disclose to you the categories of sources from which the personal information is collected,
The right to request the categories of personal information that we sold or disclosed for a business purpose;
The right to request the categories of third parties to whom the personal information was sold or disclosed for a business purpose;
The right to request the business or commercial purpose for collecting or selling personal information;
The right to opt-out of the sale or sharing of your personal information to third parties;
The right to request that we delete any personal information about you which we have collected from you;
The right to request the correction of inaccurate personal information;
The right to limit the use of sensitive personal information to what is necessary and reasonably expected;
The right to not be discriminated or retaliated against following opt-out or exercise of other rights described above.

You can make a request using the web form, email or toll-free phone number listed in the “Contact Information” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request. Upon receipt of a request, we will first need to determine that the individual making the request is the individual about whom we have collected personal information. The specific steps in the verification process will depend on the type and sensitivity of the request. After verification, we will review the request and contact you if any follow-up information is needed to process your request. We will then determine whether your request can be fulfilled or whether there are exceptions that apply. We will respond to your request within the time frames set forth in the rules. Information received from you during the request process will be maintained for record-keeping purposes but will not be used for any other purpose. Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must provide either a copy of the signed permission given to you by the individual or a power of attorney executed in accordance with California law.

CALIFORNIA INFORMATION SHARING DISCLOSURE California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not sell your personal information, and we do not rent or share your personal information with third parties for such third parties’ direct marketing. The table below indicates the categories of personal information we collect and transfer in connection with the cookie technology used on our website. In addition, we may disclose information when requested to government entities, auditors, lawyers, consultants, and other parties as required by law concerning any category (e.g., in response to a subpoena).

Categories of Personal Information We Collect	To Whom We Disclose Personal Information for a Business Purpose
Identifiers – This may include your email address or online identifiers.	Affiliates or subsidiaries Business partners Data analytics providers Government entities, as may be needed to comply with law or prevent illegal activity Internet service providers Joint marketing partners
Internet or other electronic network activity information – This may include information regarding an individual’s interaction with an internet website or application.	Affiliates or subsidiaries Business partners Data analytics providers Government entities, as may be needed to comply with law or prevent illegal activity Internet service providers Joint marketing partners

# 7. INFORMATION FOR VIRGINIA, COLORADO, CONNECTICUT AND UTAH RESIDENTS

In addition to California, other US States have also passed comprehensive consumer data privacy laws. The laws have several provisions in common, such as the right to access, correct, and delete personal information.

To exercise your consumer rights under such privacy laws, please make a request using the web form, email or toll-free phone number listed in the “Contact Information” section below. We will need certain minimum information in order to process your request, including your name, email, state and country of residence, your relationship to us, and the nature of your request.

Personal Information is used for the purposes described in Section 1, and may be shared for the business and commercial purposes described in Section 2. We do not sell your personal information, and we do not rent or share your personal information with third parties for such third parties’ direct marketing.

# 8. Security

We maintain physical, electronic, and procedural safeguards reasonably designed to protect the personal information while it is within our control. You should be aware that, unfortunately, no system can be 100% secure. There will always be a risk that your personal information gets compromised. We also depend on you to keep your account information secure by keeping your password confidential and taking precautions to keep others from accessing your account. Please notify us immediately if you become aware of any unauthorized access to or use of your account. In the event that we are required by law to inform you of a security incident involving your personal information we may notify you electronically or in writing, if permitted to do so by law.

# 9. How will we notify you of changes to this policy?

We may periodically modify this Privacy Policy and will promptly post an updated Privacy Policy on https://support.vnye.com/privacy-policy/ (opens new window) showing the date of the update. Please check regularly for the most recent version of our Privacy Policy. You agree that the act of posting a revised Privacy Policy electronically on the website satisfies our obligation to deliver the Privacy Policy to you. Your continued use of the Services after such posting constitute consent to the collection and use of your information as described in the then-current Privacy Policy. If you disagree with any changes made to this Privacy Policy you will need to stop using the Services. We will keep prior versions of this policy which you may request via email to Privacy@jamestownlp.com. You agree that the act of posting a revised Privacy Policy electronically on the website satisfies our obligation to deliver the Privacy Policy to you.

# 10. Contact Information

If you have any questions or concerns about our privacy practices or wish to exercise your rights with respect to your personal information, please direct your inquiry to:

Jamestown, L.P.
675 Ponce de Leon Avenue, 7th Floor
Atlanta, Georgia 30308
Email: Privacy@jamestownlp.com
US Toll Free: +1-888-914-9661 (PIN: 773 067)
Online: Web Form (opens new window)