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Data Protection Notice

Privacy Policy — itsnotover.app

The protection of your personal data is important to us. This Privacy Notice (the “Notice”) is intended to inform you about the terms and conditions concerning the collection, storage, and use of your personal information when you use our online Platform It’s Not Over, by visiting the website itsnotover.app or by downloading the It’s Not Over application, to your smartphone, tablet, or desktop computer, provided that you are a natural person.

1. Controller

Softhood G.P. (hereinunder “Softhood”), a company functioning under the Laws of Greece acts as the Data Controller of any personal data entered in or collected through our website and Platform.

Our Company is Based in Varympompi, Athens, Greece, at Iolis Str. No 40 (P.C. 13672). It possesses VAT Number 802630775 and has been registered with Business Registry number 179887903000.

If you wish to contact us, for any issue related to the processing of your Personal Data and the exercise of your rights, you can use the following contact details.
Email address: support@itsnotover.com

2. A few words about our Platform

“It’s Not Over” is a competitive puzzle Platform (hereinunder “Platform”), where users/players purchase tickets to access mystery puzzles. Each puzzle has a cash prize that grows with every ticket sold. The first player to correctly solve the puzzle wins the relevant prize pool.

The personal data that you provide to us while browsing in or registering as a user in our Platform, are subject to processing and will be kept on file under the responsibility of our Company, according to the conditions contained in this Notice.

3. What is Personal Data?

The term “personal data”, as used in this Notice, refers to any information relating to you as a natural person, either as an individual or as a professional, that can be linked to you and/or can identify you, directly or indirectly, such as, for example: full name, email address, contact telephone number, details about your subscription, etc. (hereinafter referred to as “Personal Data or Data”)

4. What is the Processing of Personal Data?

Processing of Personal Data refers to any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organizing, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

5. Which types of Data are we collecting about you, and how?

5.1. As a rule, we only collect the personal data that you choose to provide to us directly when you browse or interact with our website/Platform. This may take place:

A) When you register as a member/create an account on our Platform
Indicative categories of collected data: email, birth date, log in credentials (username/password), phone number.

B) When you participate in the puzzle game
Indicative categories of collected data: submitted answers, solution attempt timestamps, ticket purchases, win/loss records.

C) When you communicate with the support team
Indicative categories of collected data: name, email, the context of your message.

D) When you have solved the puzzle and you decide to share your experience with our community by participating in an interview and/or by providing audiovisual material to Platform’s social media accounts.
Indicative categories of collected data: name, user’s image/video, and voice data.

5.2. In addition to the abovementioned cases, the following personal data are also collected for the purposes of the Platform:

A) Metadata of security logs related with your use of the Platform.

B) Website usage data and metadata are collected through the use of cookies. For more information about the collection and use of this data, please read our Website’s Cookies Policy.

C) Confirmation of the success or failure of transactions, made with a debit/credit card or with an online payment method, to pay for the ticket purchase. This confirmation is automatically provided to us by the online payment service providers, with whom we cooperate, whose secure systems are used to carry out your online transactions with the Platform. Please note that the Platform does not, in any case, have knowledge of your card details or retain such data, and that the competent online payment service providers act as independent controllers for your personal data processed by them when you use their payment services, which operate under their sole responsibility.

D) Confirmation on successful authentication from Google, which is collected by the aforementioned Company if you choose to use the respective log-in method, using your Google account, to gain access to our Platform.

6. Are we processing personal data belonging to minors?

In general, we do not process data concerning children under the age of 18, as the services of our Platform are addressed to persons over the age of 18 who have legal capacity to perform a purchase contract (see also our Platform’s Terms & Conditions). If we discover that we have collected Data of a minor under 18 years of age, without a legal basis for this, we will proceed to the immediate deletion of the data, except if their retention is required by law or to pursue our company’s legal rights/claims. In any case, the provisions of chapters 7 and 8 of this policy shall also apply to minors.

7. For what purposes are your data processed?

We collect your Data exclusively for purposes related to the provision and promotion of our services, and to maintaining the efficient day-to-day operation of our Platform.

More specifically, your data is processed for the following purposes:

8. What is the legal basis for the processing of your Data by our Platform?

According to the applicable data protection legislation (GDPR, Law 4624/2019), the processing of your personal data, for any intent and purpose, must be based on specific legal grounds.

The processing of website users’ data for the abovementioned purposes (chapter 7 of this Notice) is carried out under the following legal bases:

A) For the purposes of providing you with our Platform’s services (purpose “a”) and communicating with the users to notify them regarding their participation in the puzzle games (purpose “c”), the processing is carried out because it is necessary for the performance of a contract between us, and specifically for the provision of our services based on the Terms & Conditions for the use of the Platform.

B) Where data is processed to provide our users with user/customer support (purpose “b”), and to ensure the information security of our Platform (purpose “g”), the legal basis for the processing is the pursuit of the legitimate interests of our Platform and our users.

C) For the purpose of recording and processing audiovisual material for promotional and communication purposes (purpose “d”), the processing is carried out exclusively on the basis of user’s freely given, specific, informed, and explicit consent. This processing is not necessary for the provision of the Platform’s services and participation is entirely voluntary.

D) For the purpose of Analytics and Statistics related to the use of the Platform (purpose “e”), processing is carried out, depending on your relationship with the Platform, on two distinct legal bases:

i. If you are a registered user or a subscriber of our Platform, the legal basis for the processing is the pursuit of the legitimate interests of our Platform and our users.

ii. If you are not a registered user, the processing of your data for this purpose only takes place through the use of cookies and similar technologies. In this case, the legal basis for the processing of your data is your explicit consent which you provide to us by enabling the “statistical/analytics” cookies category in our cookie banner. For more information on how we use cookies and how you can configure their usage, please refer to our platform’s Cookie Policy.

E) For the purpose of disseminating our Platform’s promotional material (purpose “f”), we only process data belonging to registered users and/or subscribers, the processing based on our legitimate interest as recognized by article 11 paragraph 3 of Greek Law 3471/2006, unless you have declared your opposition to receiving the relevant messages.

F) In general, with regard to the use of cookies on our website, to the extent that the cookies used are not necessary for the functioning and the smooth and secure operation of our website, the lawfulness of their processing relies on your consent, which you may choose to provide to us through the options of our website’s “cookie banner”. For more information on this issue, please see our Cookies Policy.

9. Who are the recipients of your Data/Where is your data transferred?

As a rule, your data is only being processed by the competent, in each case, personnel of our Platform, who have been duly informed about the secure processing of your personal data.

Additionally, your data may also be transferred, where applicable and necessary, to:

10. How do we ensure that our Processors respect your Personal Data?

The Processors, who process your data on our behalf, have agreed and contractually bound themselves to:

11. Is your data being processed outside the European Union?

As a rule, we try not to transfer your Data outside the EU, if such a transfer is not necessary to ensure the provision of our services to you.

As regards the use of partners and features provided by non-EU providers (such as social media or US-based tech firms), we have ensured that, where such options are available to us, your data is stored within EU-based servers. Where this possibility does not exist, we ensure that any such third-party transfers are covered by at least one of the legal bases and safeguards of Chapter V GDPR (such as the signing of SCCs or the existence of an active adequacy decision).

12. For how long is your data stored and when do we delete them?

As a general rule, we delete your data as soon as the processing is no longer necessary to achieve the purpose for which the data was collected or for us to comply with our legal obligations. In any case, your data will not be kept for more than 20 years.

Your user account data are deleted upon the deletion of your account, as per your request. They are also deleted following your last log-in after an extended period of inactivity.

Security logs for information security purposes (i.e. IP address) are retained for a limited period of time in accordance with our data retention policies.

User logs and metadata relating to successful/unsuccessful attempts to resolve the puzzles will be retained for as long as necessary to protect the Platform legally.

Audiovisual material collected for promotional and communication purposes is retained for as long as your consent remains valid and the material continues to be used for such purposes.

We delete the Data collected by Cookies in accordance with our Cookies Policy.

Once the abovementioned time periods expire, your data will be irreversibly deleted.

13. Is your data safe?

We are committed to safeguarding your Personal Data. We have taken appropriate organizational and technical measures to ensure the security and protection of your Data from any form of accidental or unlawful processing.

These measures are reviewed and modified at regular intervals and also on an ad-hoc basis when necessary.

14. Which rights do you possess in regard to your personal data?

You have the right to access your personal data.
This means that you have the right to be informed by us on whether we are processing your Data. If we are processing your Data, you can request to be informed about the purpose of the processing, the type of your Data we hold, who we give it to, how long we store it for, whether automated decision-making is taking place, and on how to exercise your remaining data protection rights.

You have the right to rectify inaccurate personal data.
If you find that there is an error in your Data, you may submit a request for us to correct it.

You have the right to ask for the deletion of your personal data/right to be forgotten.
You may ask us to delete your Data if it is no longer necessary for the processing purposes listed above or if you wish to withdraw your consent.

You have the right to restrict the processing.
You may ask us to restrict the processing of your Data for as long as your objections to the processing are pending.

You have the right to object to the processing of your Data.
You may object to the processing of your Data where it is carried out in the pursuit of our legitimate interests.

You have the right to portability of your Data.
You may request to receive the Data you have provided to us in a readable form or request us to transfer it to another controller directly.

You have the right to withdraw your consent.
In cases where the processing of your data is based solely on your prior consent, you have the right to withdraw your consent at any time.

15. How can you exercise your rights?

To exercise your rights, you may send us a request to our e-mail address (support@itsnotover.com) with the title “Exercise of the right of access/ correction/ deletion/ portability/ restriction/ objection/ consent withdrawal” and the description of your request.

16. When will you receive a response to your request?

We will respond to your Requests free of charge and without delay. We aim to always respond to your requests within one (1) month of receiving them. However, if your Request is complex or there is a large number of pending Requests, we will let you know within the first month if we need an extension of two (2) additional months within which to respond to you.

17. Right to lodge a complaint

If you believe that your request has not been adequately fulfilled or your personal data protection rights are being violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority-HDPA (postal address: 1-3 Kifisias Ave, P.C. 115 23, Athens, website: https://www.dpa.gr/, tel: 210 6475600, e-mail: contact@dpa.gr) or the competent data protection authority of your country of residence (within the EU).

18. How will you be informed about potential updates to this Data Protection Notice?

We will update this Data Protection Notice whenever necessary. If there are significant changes to this Notice or to the way we use your Personal Data, we will notify you either by posting an announcement in a prominent place within our website before the changes take effect or by any other appropriate means. We encourage you to periodically read this Notice to keep updated on how your Data is being protected.

Effective Date

This Data Protection Notice is effective as of its publication date on the Platform. The currently applicable version was last updated on March 2026.

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