Legal document
Privacy Notice
Aetheria Media Holdings S.r.l. · Version 1.0
Privacy Notice
This Privacy Notice explains how Aetheria Media Holdings S.r.l. ("we", "us", "our"), as data controller, collects, uses, and protects personal data in connection with the "England vs Norway" conditional promotional giveaway. We are committed to privacy by design and to collecting only the data we genuinely need.
1. Data Controller
Aetheria Media Holdings S.r.l., Via S. Raffaele 1, 20121 Milano (MI), Italy. Contact details for privacy matters are on the Contact & Complaints page.
2. Personal Data We Collect
2.1. At entry: full legal name, date of birth, country of residence, email address, optional social-media handle, and your consent selections (age confirmation, acceptance of the Official Rules, acknowledgement of this Notice, and optional marketing consent).
2.2. Technical and fraud-prevention data: IP address, approximate location derived from IP, device and browser signals, timestamps, and entry reference. These are used cautiously for security, deduplication, and fraud detection.
2.3. From verified provisional winners only, and only later in the process: identity-verification information and a cryptocurrency wallet address for prize payment. We never collect or store private keys or seed phrases.
3. Purposes and Legal Bases
3.1. To administer the Promotion, verify eligibility, prevent fraud, select and verify winners, and pay prizes — on the basis of taking steps at your request and performance of the Promotion, and our legitimate interests in running a fair, secure Promotion.
3.2. To comply with legal obligations, including sanctions screening, anti-money-laundering, and tax reporting — on the basis of legal obligation.
3.3. To send marketing communications — only where you have given separate, opt-in consent, which you may withdraw at any time.
4. Cookies and Similar Technologies
4.1. We use strictly necessary cookies for session security and cross-site-request-forgery protection. Non-essential cookies are set only with your consent where required. See the Cookie Notice and Cookie Preferences.
5. Sharing of Data
5.1. We share personal data only with service providers acting on our behalf (for example, email delivery and bot-protection providers) under appropriate contracts, and with authorities where required by law. We do not sell your personal data.
6. International Transfers
6.1. Where personal data is transferred across borders, we apply appropriate safeguards recognised under applicable data-protection law.
7. Retention
7.1. We retain entry-administration data only for the configured retention period necessary for the Promotion and to resolve disputes. Winner and transaction records are retained only where and for as long as required by law (for example, tax and anti-money-laundering rules). Marketing data is deleted upon withdrawal of consent. See the Data Retention & Deletion notice.
8. Your Rights
8.1. Subject to applicable law, you may request access to, rectification of, erasure of, or restriction of your personal data; object to processing; request portability; and withdraw consent. Submit requests via the data-request page. You may also complain to your local data-protection authority.
9. Security
9.1. We apply technical and organisational measures including encryption in transit, hashed administrator passwords, access controls, audit logging, and least-privilege access. No system is perfectly secure, but we work to protect your data.
10. Children
10.1. The Promotion is not open to persons under 18 (or the higher local age of majority). We do not knowingly process the data of minors and will delete such data if identified.
11. Changes
11.1. We may update this Notice; the version and date indicate the current version. Consent versions and timestamps are recorded where consent is relied upon.