NA-BIS Афиша: Privacy Policy
1. Scope and Responsible Entity
This Privacy Policy describes how ATLRC LLC ("ATLRC," "we," "us," or "our") collects, uses, discloses, retains, and protects personal information in connection with the NA-BIS Афиша mobile application for iOS and Android (the "App"), the website na-bis.com (the "Website"), and communications with us about them (collectively, the "Services").
ATLRC LLC is a Georgia limited liability company located at 3510 Winterwood Court, Marietta, GA 30062, USA. You may contact us about this Policy or our privacy practices at info@na-bis.com.
The App provides information about concerts and cultural events in the United States, including events organized by ATLRC. The App does not provide user accounts, sell tickets, or process payments. Ticket purchases take place through external ticketing services.
Installing the App, visiting the Website, or allowing App notifications does not constitute consent to receive marketing text messages.
2. Personal Information We Collect
For purposes of this Policy, "personal information" includes information that identifies, relates to, or can reasonably be associated with a person or device where it is treated as personal information under applicable law. An identifier may be personal information even if it does not reveal a person's name.
2.1 Installation Identifier
The App generates a random identifier and stores it on your device (the "Installation Identifier"). We also receive and store this identifier with the interaction records described in Section 2.2. It allows us to associate those records with the same identifier over time.
The Installation Identifier is not derived from your name, email address, telephone number, or advertising identifier. It is not an account login or a password.
Depending on your device and backup settings, the identifier may be included in a device backup and restored after reinstallation or transfer to another device. It therefore does not necessarily identify one unique person or remain limited to one physical device.
2.2 Interaction Records
Subject to the choices described below, the App sends information to our database when you use the following features:
mark or unmark an event as "I'm going";
select "Buy tickets";
add an event to your device calendar through the App (a record is created only after the event has been added successfully);
select a promotional video link; or
vote for an artist, change your vote, or withdraw it.
These are the App interactions we record in our database.
When you choose to vote, the App sends the information described below to record your vote. Artist voting is separate from the optional usage-statistics setting described in Section 8.1. We record the other interactions listed above only if you opt in to optional usage statistics and while that setting remains on. Before transmitting those interactions for the first time, the App asks for your consent. If you decline or later turn the setting off, the App does not transmit those optional interaction records.
The information submitted includes the Installation Identifier, the type and identifier of the relevant event or artist, the action, and a cancellation indicator where relevant. Stored records also include a creation timestamp.
The database maintains interaction state rather than a complete chronological record of every tap. For most features, it maintains one record for each combination of Installation Identifier, target, and action. For artist voting, it maintains the latest recorded voting state for each Installation Identifier and artist. Repeated use of a feature may update an existing record rather than create a separate record for each interaction.
If you vote while the device is offline, the App stores the pending vote locally and may submit it when the App starts or returns to the foreground and a connection is available.
A ticket-link selection does not establish that you purchased a ticket, and a video-link selection does not establish that you watched a video. We do not receive payment information through these interaction records.
Opening or scrolling through the schedule does not itself create an interaction record of the types described above. The App nevertheless makes requests to retrieve event information and images and to check for updates, as described in Section 2.4.
2.3 Notifications
The App uses locally scheduled reminders for events you have marked. Your device schedules and displays these reminders.
The release covered by this Policy does not obtain, store, or transmit push notification tokens and does not send remote push notifications. Notification permission is requested for the local reminders described in Section 4.
Before we begin collecting push notification tokens or using remote notifications, we will update this Policy and the applicable store disclosures, provide required notices, and obtain required consent. If we introduce promotional push notifications, we will provide an explicit in-app opt-in and an in-app method to opt out.
2.4 Technical Information and Website Technologies
Providers that support the Services process technical information when your device communicates with their infrastructure. Depending on the service, this includes IP addresses, request timestamps, browser or platform information, operating system information, and App runtime or update information.
Supabase provides the App's database and image-storage infrastructure. The App retrieves event and artist information from Supabase and loads images from Supabase Storage; some event posters may also be loaded from the Website.
Expo provides EAS Update, which the App contacts at a cold start to check for software updates. EAS Update uses its own randomly generated installation identifier, separate from the Installation Identifier described in Section 2.1. The requests also include technical information used to select and deliver compatible updates. We do not add our Installation Identifier or App interaction records to those update requests. Further information is available in Expo's privacy explanation (https://expo.dev/privacy-explained).
We do not include IP addresses in the App interaction records described in Section 2.2. Infrastructure providers may retain IP addresses and other request information in operational or security logs.
The Website consists of static pages hosted on GitHub Pages. GitHub states that it logs and stores visitors' IP addresses for security purposes, whether or not the visitor is signed in to GitHub. See GitHub's information about GitHub Pages (https://docs.github.com/en/pages/getting-started-with-github-pages/about-github-pages).
The Website's home page includes embedded YouTube players, which load automatically when the page is opened. Loading the page therefore causes your browser to communicate with Google before you select Play, disclosing technical information such as your IP address and browser information. Depending on the player configuration and your settings, Google may use cookies or similar technologies and may associate information with a Google account. Google's processing is described in the Google Privacy Policy (https://policies.google.com/privacy).
Other than the embedded YouTube players described above, we do not use separate website analytics services, advertising pixels, or tag managers. The Website does not include data-entry forms, and ATLRC does not directly set first-party cookies on the Website. Google may use cookies or similar technologies through its players as described above, and may collect information about your online activities over time and across different websites through the embedded YouTube players. The Website does not change its data practices in response to browser Do Not Track signals.
2.5 Communications
If you email us, we receive your email address, the content of your message, attachments, and other information you choose to provide. This may include your name or Installation Identifier.
The App does not require your name, email address, telephone number, mailing address, or payment information to use its features. You may nevertheless provide such information voluntarily when communicating with us.
2.6 Permissions and Third-Party Software
The App does not request permission to access your device's location, contacts, photo library, camera, or microphone.
When you use the calendar feature, the App requests calendar access. On supported iOS versions, its current implementation requests full access to calendar events; on Android, it uses calendar read and write permissions. These permissions may allow broader access than the App actually uses.
The App uses calendar access to identify an appropriate calendar, create an event at your request, and check whether an event it previously created still exists. It does not read the contents of other calendar events or transmit information read from your device calendar to our servers. The interaction record described in Section 2.2 records use of the feature, not the contents of your calendar.
The App displays sponsor branding and links to sponsor websites. It does not include third-party advertising, analytics, or crash-reporting SDKs. We nevertheless collect our own App interaction records and use infrastructure services as described above. Website YouTube players are separate from the App's SDK configuration.
3. Purposes of Processing
We use the information described in this Policy for the following purposes:
to provide, operate, and maintain the Services and deliver event information and images;
to maintain interaction state and artist votes;
to understand use of App features and evaluate interest in events and artists through statistical reports;
to deliver App updates and maintain compatibility and functionality;
to respond to inquiries and manage privacy requests;
to maintain security and investigate misuse or technical problems; and
to comply with applicable legal obligations and establish, exercise, or defend legal claims.
The Website's embedded YouTube players enable visitors to view videos. Google may also process information for its own purposes under its privacy policy, as described in Sections 2.4 and 5.1.
We may associate an Installation Identifier with an email address when reasonably necessary to verify or fulfill a request submitted by email. We do not use that association to create advertising profiles.
We do not use App interaction records to make solely automated decisions that produce legal or similarly significant effects concerning individuals.
4. Notifications and Calendar Access
When you first select "I'm going," the App requests notification permission if required by your operating system and current permission settings. It schedules local reminders approximately 24 hours and three hours before the event, subject to permission, the time of your selection, and device settings.
Declining notification permission does not prevent use of the App. Notification permission controls reminders, not the separate transmission of interaction information described in Section 2.2.
Removing your "I'm going" selection cancels the corresponding local reminders. When the App next successfully refreshes the event schedule, it cancels or reschedules reminders for events that have been removed or rescheduled. A device that has not received updated event information may still have reminders based on earlier information.
You may disable App notifications through your device settings. Doing so does not by itself delete existing server records.
The App requests calendar permission when you use the calendar feature. Its current permission scope and the limited purposes for which it uses that access are described in Section 2.6. If you remove an event from your calendar, that does not automatically remove the server record of your use of the calendar feature. Your calendar service may separately synchronize calendar events according to your device and calendar-account settings.
5. Disclosure of Personal Information
5.1 Providers Supporting the Services
We use providers to support database hosting, image storage, App updates, Website hosting, and email communications. These include Supabase for the database and image storage, Expo for App updates, GitHub for Website hosting, and email providers, including Microsoft Outlook.com, for correspondence.
Where providers process personal information on our behalf, their processing is subject to the applicable service agreements and data-processing terms. We require third parties with whom the App shares user data to provide the same or an equivalent level of protection as described in this Policy and required by applicable platform rules.
Some providers also process information for purposes they determine. For example, Expo's terms describe its processing of aggregated or de-identified user data for purposes including improving or developing its services, including where such information remains personal data under applicable law. See Expo's terms (https://expo.dev/terms).
Google processes information received through the Website's embedded YouTube players under its own privacy terms. The fact that a service is embedded in the Website does not mean that it acts solely on our instructions. See the Google Privacy Policy (https://policies.google.com/privacy).
5.2 Statistical Reports
We use statistical summaries to evaluate interest in events and artists and may provide summary figures to event partners.
Our monthly summaries contain target type, target identifier, action, month, and a count. The month is the month in which the source interaction records were created. The summaries do not contain Installation Identifiers or email addresses. The counts reflect interaction-state records included in the retention process, not a complete count of all taps in a calendar month.
For these monthly summaries, the reporting view used for external disclosure excludes counts below five. Partners receive reports from ATLRC rather than direct access to individual App interaction records.
Artist voting results are part of the voting feature. For each artist, the App retrieves the current numbers of votes for and against. These counts do not include voter identifiers or individual voting timestamps. They report aggregate totals rather than individual voting records. The App displays results only after at least ten votes have been cast; the counts themselves, however, can be retrieved through the App's data service at any number of votes.
Removing identifiers or applying a minimum count does not by itself establish that every summary is anonymous. Where information remains reasonably linkable to a person or device, we treat it as personal information under this Policy and applicable law. We do not use the summaries to attempt to identify individual users.
5.3 Legal Disclosures
We may disclose personal information where reasonably necessary to comply with applicable law or valid legal process, protect our rights or property or the rights or safety of others, investigate suspected unlawful activity, or establish, exercise, or defend legal claims.
5.4 Business Transactions
We may disclose or transfer personal information in connection with a proposed or completed merger, acquisition, reorganization, sale of assets, or similar business transaction, subject to applicable confidentiality and data-protection requirements.
Any materially different use of the information is subject to notice and consent requirements under applicable law and applicable platform requirements.
5.5 Sale, Targeted Advertising, and Embedded Services
We do not sell App interaction records or disclose those records to advertising networks for targeted advertising. We do not use the App's Installation Identifier to create advertising profiles.
The Website's embedded YouTube players involve separate processing by Google as described in Sections 2.4 and 5.1. Statements about our App interaction records should not be understood to mean that third parties receive no information when you visit the Website.
6. External Links and Sponsorship
The App links to external ticketing services, video services, artist pages, and sponsor websites. It opens web destinations through system-provided browser components, rather than an App-controlled checkout or a webview whose page content we control. The App does not read the external page's content, cookies, or information you enter there.
The App does not append its Installation Identifier or interaction records to external links. Some ticket links contain promoter-attribution parameters identifying the referral source rather than your App installation.
External operators may collect information such as IP addresses and browser information and may use cookies or information associated with an account you hold with them. Their independent processing is governed by their terms and privacy policies. This does not exclude our own processing described in this Policy.
Opening directions or an email link hands the request to a compatible maps or email application. Those applications process information under their own terms and settings.
Displaying sponsor branding or a sponsor link does not itself give the sponsor access to our App interaction records. Website embeds, including YouTube players that communicate with Google when the page loads, are separately described in Section 2.4.
7. Retention and Deletion
7.1 Interaction Records and Statistical Summaries
An automated deletion process runs daily. During each run, it removes from the active database interaction-state records, including artist votes, whose stored creation timestamp is more than 12 months old. The creation timestamp is set when a record is first created; it does not change when the record is later updated, when a selection is cancelled or made again, or when a vote is changed. Later use of a feature therefore does not extend the retention period of an existing record.
During the retention process, deleted records are used to produce monthly statistical summaries without Installation Identifiers. The source-record deletion and summary update are performed together. The meaning of those counts and limitations on anonymity are described in Section 5.2. The same daily process deletes monthly summaries from the active database once the month they describe is more than 36 months in the past.
These ordinary retention periods do not prevent earlier deletion in response to a verified request, subject to applicable exceptions. If particular information must be retained to meet a legal obligation or is necessary to establish, exercise, or defend a legal claim, we retain only what is needed for that purpose and restrict its use accordingly.
7.2 Correspondence, Technical Logs, and Database Backups
We retain correspondence for as long as reasonably necessary to address the inquiry, document our response, and meet applicable legal obligations. Relevant factors include the nature of the inquiry, whether further action is needed, and legal or dispute-related requirements.
Infrastructure providers maintain technical logs under the arrangements applicable to the services we use; the retention periods for those logs are set by those providers. The 12-month interaction-record period does not establish the retention period for those logs.
Our current database plan does not include automatic backups. We make occasional manual database exports for recovery purposes. We keep no more than the two most recent exports, and we delete each export no later than 90 days after it is created, even if no newer export has been made. Access to exports is restricted, and they are used only to restore the database. Because exports are separate from the active database, they may contain records that have since been deleted from it. We keep a record of deletion requests in our correspondence. If we restore data from an export, then before the restored data returns to ordinary use, we reapply the deletion requests received since the export was made and the applicable retention limits described in Section 7.1.
7.3 Information Stored on Your Device
The App stores the Installation Identifier, event selections, reminder settings, identifiers of calendar events it creates, pending offline votes, and cached content on your device. Depending on device and platform settings, some of this information may be included in device backups.
Uninstalling the App does not delete information in our database or manual exports and may not remove information retained in device backups. Restoring a backup may restore the same Installation Identifier.
8. Your Choices and Privacy Rights
8.1 Device and Data-Collection Controls
You may manage App notifications and calendar permissions through your device settings. Changing these permissions does not by itself delete information previously transmitted to our database.
The first time you use one of the features listed in Section 2.2 other than artist voting, the App asks whether you agree to send optional interaction records to ATLRC for usage statistics. You can change your choice at any time with the "Share usage statistics" («Отправлять статистику») switch on the App's "About" («О нас») screen. When the switch is off, the App does not send those interactions. The setting does not disable the technical requests described in Section 2.4. Turning the switch off does not delete records already sent; you may request deletion as described in Section 8.2.
The usage-statistics setting does not control artist voting. When you choose to vote, the App sends the information needed to record your vote, as described in Section 2.2. A pending offline vote may be sent when the App starts or returns to the foreground and a connection is available, as described in Section 2.2. Browsing the schedule does not create interaction records.
The Website has no settings of its own. Your browser and Google account may offer controls over cookies and some Google processing. These controls do not necessarily prevent the initial technical requests made when embedded players load.
8.2 Submitting a Request
You may submit a privacy request concerning the Services by emailing info@na-bis.com.
For requests about App interaction records, open the App's "About" («О нас») screen, copy the Installation Identifier displayed at the bottom, and include it in your request.
If you expect to uninstall the App and may later wish to submit a request, save a copy of your Installation Identifier first. We store it with your interaction records, but without that identifier or other information reasonably available to us, we may be unable to determine which records relate to your installation.
You may still provide a saved identifier after uninstalling the App. For requests about correspondence or Website information, describe the relevant interaction and provide information reasonably sufficient to help us locate the records; an Installation Identifier is not required for unrelated requests.
If the information reasonably available to you and to us does not enable us to locate relevant records, we will explain that limitation.
8.3 Verification and Response
We take reasonable and proportionate steps to verify a requester's identity or authority and to prevent unauthorized disclosure or deletion. We request only information reasonably necessary for those purposes.
Because the App does not have user accounts, possession of an Installation Identifier alone may not be sufficient to verify a request. A request to disclose particular records may require additional verification appropriate to the sensitivity of the information and the risk of disclosure. If we cannot reasonably verify a request or locate the relevant information, we will explain the limitation and any available next steps, as required by applicable law.
We respond within the time required by applicable law. If an extension, exception, or refusal applies, we provide the explanation and other information required by law.
Deleting existing server records does not erase pending information on your device. A pending offline vote, a new vote you choose to submit, or use of another feature while usage statistics are enabled may generate new interaction records. To stop future collection of optional interaction records, turn off the usage-statistics setting described in Section 8.1.
8.4 Rights Under Applicable Law
Depending on your jurisdiction and whether relevant privacy laws apply to our processing, you may have rights to access, obtain a copy of, correct, or delete personal information and other rights concerning its processing. Where applicable, these may include restricting or objecting to processing, withdrawing consent, and opting out of certain uses or disclosures.
Where provided by applicable law, you may use an authorized agent, appeal a decision about a request, or complain to a competent authority. To submit an appeal, email info@na-bis.com and identify the request and the decision you wish to appeal.
We will not unlawfully discriminate against you for exercising privacy rights. Nothing in this Policy limits rights or remedies available under applicable law.
9. Security and Processing Locations
Our primary App database is hosted in Northern Virginia, United States. Our providers and personnel may process information in other locations in connection with their services or authorized operations.
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or loss. These include HTTPS transmission and access controls. No storage system or method of transmission can be guaranteed to be completely secure.
The Services are intended for the United States market. If you access them from another country, information may be processed in the United States or other locations where our providers operate. Data-protection laws may differ from those in your country. This statement does not exclude protections required by applicable law and is not a substitute for any required transfer safeguards.
10. Children's Privacy
The Services are intended for adults seeking information about events, including parents and guardians selecting events for children. They are not directed to children under 13.
We do not knowingly collect personal information from children under 13. If you believe such information has been collected through the Services, contact info@na-bis.com. If we learn that personal information has been collected from a child under 13 in violation of applicable law, we will take steps to delete it and address any ongoing collection.
11. Changes to This Policy
We may update this Policy to reflect changes in the Services, our processing practices, or applicable law. We will publish the revised Policy at na-bis.com/privacy/ and update the "Last updated" date.
Where required by applicable law or platform requirements, we will provide additional notice and obtain required consent before implementing the relevant changes. Continued use of the Services does not substitute for consent where consent is required.
12. Contact Information
ATLRC LLC
Attn: Privacy
3510 Winterwood Court
Marietta, GA 30062, USA
Email: info@na-bis.com
You are not required to contact us before exercising a right to complain to a regulator or seek another remedy available under applicable law.