Privacy Notice

This Privacy Notice explains how Aetheria Media Holdings S.r.l. ("we", "us", "our"), as data controller, collects, uses, shares, and protects personal data in connection with the "England vs Argentina" conditional promotional giveaway (the "Promotion"). We are committed to privacy by design, transparency, and to collecting only the data we genuinely need.

1. Data Controller and Contact

1.1. The data controller is Aetheria Media Holdings S.r.l., Via S. Raffaele 1, 20121 Milano (MI), Italy.

1.2. For privacy-related questions, data-subject requests, or complaints, please contact us through the Contact & Complaints page or the data-request facility on this website.

1.3. We have appointed appropriate administrative and technical personnel to oversee our data-protection obligations and respond to requests.

2. Scope of This Notice

2.1. This Notice applies to personal data collected through the Promotion website, entry forms, verification workflows, correspondence, and related service providers.

2.2. This Notice does not apply to third-party websites or services that may be linked from the Site. Those services have their own privacy policies.

2.3. This Notice should be read together with the Cookie Notice, Data Retention & Deletion notice, and the Official Rules.

3. Personal Data We Collect

3.1. Entry data: At the time of entry, we collect your full legal name, date of birth, country of residence, email address, optional social-media handle (if you choose to provide it), and your consent selections (age confirmation, acceptance of the Official Rules, acknowledgement of this Privacy Notice, and optional marketing consent).

3.2. Technical and fraud-prevention data: We collect your IP address, approximate location derived from IP, device type and browser signals, operating system, timestamps, referral information, entry reference, and similar technical data. These are used cautiously for security, deduplication, fraud detection, and abuse prevention.

3.3. Verification data: From verified Provisional Winners only, and only later in the process, we may collect identity-verification information such as a government-issued identification document, proof of address, and any additional information required for sanctions, anti-money-laundering, or tax compliance.

3.4. Payment data: From verified Provisional Winners only, we collect a cryptocurrency wallet address for prize payment. We never collect, store, or request private keys, seed phrases, or recovery phrases. We also record the selected blockchain network, transaction amount, timestamp, and transaction hash for audit and compliance purposes.

3.5. Communications data: We retain records of correspondence, complaints, and support requests for as long as necessary to resolve the matter and meet legal obligations.

3.6. Marketing preferences: We record whether you have opted in or out of marketing communications, together with the date, time, and version of the consent collected.

3.7. We do not collect special-category personal data (such as health, racial or ethnic origin, genetic or biometric data, or data concerning sex life or sexual orientation) unless strictly required by law or for sanctions and anti-money-laundering verification, and then only with a lawful basis and appropriate safeguards.

4. Purposes and Legal Bases for Processing

4.1. Performance of the Promotion and taking steps at your request: We process entry data to administer the Promotion, verify eligibility, prevent fraud, deduplicate entries, select and verify winners, communicate with entrants, and pay prizes. This processing is necessary to perform the Promotion and to take steps at your request before entering into the prize process.

4.2. Legal obligation: We process personal data to comply with legal obligations, including sanctions screening, anti-money-laundering checks, tax reporting, information requests from competent authorities, and record-keeping requirements.

4.3. Legitimate interests: We process technical and fraud-prevention data, and we may process limited personal data for security, abuse prevention, and the defence of legal claims, based on our legitimate interests in operating a fair and secure Promotion. We balance these interests against your rights and provide opt-outs where appropriate.

4.4. Consent: We send marketing communications only where you have given separate, explicit, opt-in consent. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or your ability to enter the Promotion.

4.5. Vital interests and public task: To the extent required by law, we may process personal data to protect vital interests or to perform a task carried out in the public interest.

5. Cookies and Similar Technologies

5.1. We use strictly necessary cookies to maintain secure sessions, to protect against cross-site request forgery, and to remember your cookie preferences. These cookies are always active because the Site cannot function securely without them, and they do not require consent under applicable law.

5.2. Non-essential cookies (such as analytics or preference cookies) are set only after you have given consent where consent is legally required. We do not enable non-essential analytics before consent where consent is required.

5.3. For more information, including how to manage your choices, please see the Cookie Notice and the Cookie Preferences page.

6. Sharing of Data

6.1. Service providers: We share personal data only with service providers acting on our behalf (for example, secure hosting, email delivery, bot protection, identity verification, and analytics providers) under appropriate contracts that require them to process data only for our purposes and to maintain appropriate security measures.

6.2. Legal and regulatory disclosures: We may disclose personal data if required by a court order, regulatory request, lawful process, or applicable law, or to protect our rights, property, or safety, or the rights, property, or safety of others.

6.3. Professional advisers: We may share personal data with professional advisers, such as legal, accounting, and insurance advisers, to the extent necessary for them to provide services to us and subject to confidentiality obligations.

6.4. We do not sell personal data: We do not sell, rent, or trade personal data to third parties for their own marketing purposes.

6.5. Business transfers: If we are involved in a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate safeguards and notice requirements.

7. International Transfers

7.1. Some of the service providers we use may process personal data in countries other than the one in which you reside. Where personal data is transferred across borders, we apply appropriate safeguards recognised under applicable data-protection law, such as standard contractual clauses, adequacy decisions, binding corporate rules, or other lawful transfer mechanisms.

7.2. We take reasonable steps to ensure that any international transfers are subject to appropriate contractual, technical, and organisational protections.

8. Data Retention

8.1. We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Specific retention periods are set out in the Data Retention & Deletion notice.

8.2. In summary:

- entry-administration data is retained for the period necessary to run the Promotion, select and verify winners, and resolve disputes;

- winner and transaction records are retained where and for as long as required by law, including tax and anti-money-laundering obligations;

- marketing data is retained until you withdraw consent, after which it is deleted from active marketing use; and

- fraud and security signals are retained for a limited period appropriate to detect and prevent abuse.

8.3. When a retention period expires, we securely delete or anonymise personal data, subject to any legal requirement to retain it.

9. Your Rights

9.1. Subject to applicable law, you may have the following rights in relation to your personal data:

- Access: Request confirmation of whether we process your personal data and obtain a copy of it.

- Rectification: Request correction of inaccurate or incomplete personal data.

- Erasure: Request deletion of your personal data in certain circumstances.

- Restriction: Request restriction of processing in certain circumstances.

- Objection: Object to processing based on legitimate interests or for direct marketing.

- Portability: Request a copy of your data in a structured, commonly used, machine-readable format, where technically feasible.

- Withdraw consent: Withdraw consent at any time for processing based on consent.

- Complaint: Complain to your local data-protection authority.

9.2. To exercise your rights, please use the data-request page on this website. We may need to verify your identity before processing your request.

9.3. We will respond to valid requests within the timeframe required by applicable law and will explain any legal basis for refusing or limiting a request.

9.4. Exercising your rights is free of charge, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act.

10. Security

10.1. We apply technical and organisational measures appropriate to the risk, including encryption in transit, hashed administrator credentials, access controls, audit logging, least-privilege access, and regular security reviews.

10.2. No system is perfectly secure. We continually work to protect your data against unauthorised access, loss, alteration, or misuse, but we cannot guarantee absolute security.

10.3. In the event of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable law.

11. Children

11.1. The Promotion is not open to persons under 18 (or the higher local age of majority). We do not knowingly collect or process the personal data of minors in connection with the Promotion.

11.2. If we become aware that we have collected personal data from a person below the applicable minimum age, we will delete that data promptly and disqualify any associated entry.

11.3. Parents, guardians, or responsible adults who believe a minor has provided personal data to us should contact us via the Contact & Complaints page so that we can take appropriate action.

12. Automated Decision-Making and Profiling

12.1. We do not make decisions based solely on automated processing that produce legal or similarly significant effects on individuals, except to the extent necessary for security checks (such as bot detection, duplicate-entry detection, or sanctions-list screening) where permitted by law and subject to appropriate safeguards.

12.2. Where such automated processing occurs, individuals have the right to obtain human intervention, express their point of view, and contest the decision, as required by applicable law.

13. Changes to This Notice

13.1. We may update this Notice from time to time to reflect changes in our practices, technology, or law. The version and date shown at the top of this document indicate the current version.

13.2. Material changes will be posted on the Site and, where required by law, notified to entrants. Consent versions and timestamps are recorded where consent is relied upon.

13.3. Continued participation in the Promotion after the effective date of changes constitutes acceptance of the updated Notice. If you do not accept the updated Notice, you should not enter or should withdraw your entry.