[Last Updated: March 13, 2025]

1. (1) INTRODUCTION & SCOPE

This Privacy Policy (“Privacy Policy”) describes how GMTicketing OU (“Company”, “we” or “our”) collects, uses, and discloses Personal Data (as defined below), in connection with:

• Visitor of our website available at https://www.footballticketnet.com/and other digital pages we own and operate that directs to our website, and any content, features or services included therein (“website” and “Visitors”, respectively);
• Individuals who have placed an order to purchase tickets, tours or other products offers through our website (“Consumers” and “Product” respectively) through our website.

Visitors and Consumers shall be further referred to herein as “you” and “your”. The website and any services provided therein including order placement shall be further referred to herein as “Services”.

This Privacy Policy further explains how we safeguard your Personal Data, how such data may be used or shared with others, and how you may exercise your rights related to your Personal Data, as required under applicable data protection laws.

This Privacy Policy is an integral part of our Terms and Conditions (collectively the “Terms”). Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms and Conditions

The types of Personal Data we receive and collect depend on which Services you use and how you use them. Any Personal Data you provide is made at your free will and consent (where required under applicable data protection legislation), and you acknowledge that you are not under any statutory obligation to provide us with Personal Data. However, we must collect or receive some Personal Data to provide the Service, and if you will not provide us with such Personal Data, we will not be able to fulfill certain purposes, for example, provide certain Services - all as described under Section 4 below - “Data We Collect & Purpose of Collection and Use“ which details the purposes for which each Personal Data set is collected.

This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others:

If you are a California resident – please review our CCPA Privacy Notice, which serves as a Notice at Collection as required under the California Privacy Rights Act (“CCPA”) and further details the categories of information collected and additional information regarding our privacy practices, including your rights.

2. (2) POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Updated” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

3. (3) CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

GMTicketing OU, is the “data controller” (as such term is defined under privacy legislation) of the Personal Data collected by us, as detailed under this Privacy Policy.

For any question, inquiry or concern related to this Privacy Policy or the collection and use of your Personal Data, you may contact our privacy team as detailed in the Contact Us webpage HERE.

4. (4) THE DATA WE COLLECT & PURPOSE OF COLLECTION AND USE

Depending on your interaction with us and our Services, we may collect certain information related to such interaction and use, as follows:

“Non-Personal Data” – meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. Non-Personal Data includes technical information regarding your device or browser, type of operating system, scope, frequency, interactions with the website, and other technical information regarding the device used – all when collected on an aggregate basis, or otherwise not combined with any identifiers. We may further process and anonymize Personal Data in a manner that the data will be Non-Personal Data. Non-Personal Data may be used by us without limitation and for any purpose. Some of this information may be considered “de-identified” under U.S. privacy laws and when we rely on data that has been “de-identified”, we will take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device and not attempt to re-identify it.

“Personal Data” – meaning information that identifies an individual or may with reasonable effort or by reasonable means identify an individual. This may include online identifiers such as IP address, name, emails, etc., and other information that is associated with you. If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

Under the table below we detail the types of Personal Data we collect and how and for which purposes we use your Personal Data.

Please note that, in addition to the purposes set forth above, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce our Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. We will not collect additional categories of Personal Data or use the Personal Data for any purpose that is materially different, unrelated, or incompatible purpose without obtaining your consent unless we are required or permitted by applicable law.

5. (5) HOW WE COLLECT YOUR DATA

Depending on the nature of your interaction with us and our websites and Services, we may collect Personal Data as follows:

• Automatically– we may use cookies or similar tracking technologies to gather some information automatically when you interact with our websites and Services (see Section 6 of this Privacy Policy “Cookies and Similar Tracking Technologies We Use”.
• Provided directly by you– we will collect information if and when you choose to provide us with the information, such as where you create an Account, place and order, contact us, etc.

6. (6) COOKIES AND SIMILAR TRACKING TECHNOLOGIES WE USE

We use “cookies” (or similar tracking technologies such as tags, pixels, etc.) when you access to, interact with, or use our websites and Services. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your device or browser while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, enable automatic activation of certain features (e.g., shopping cart), for statistical purposes, as well as for advertising purposes.

The information generally collected and stored by cookies includes Online Identifiers (such as cookie ID, IP address, etc.) and Usage Data (such as actions made, click stream, time and date stamp, content viewed, directing URLs, etc.) – both as defined under this Privacy Policy preferences and technical information related to your device or browser (such as type of device, operating system, etc.). 

Cookies can be either placed by us, or by third parties such as analytic providers, marketing partners, social media, etc. In addition, the duration of such cookies (meaning the period until such are deleted) can be either “session” – meaning deleted when you close your browser, or “persistent” – meaning longer periods according to their purpose and settings, provided however that you can delete or block cookies through your browser or device settings or as further explained below.

Please see our cookies list page: HERE which details the cookies we use on are website. You to change your cookies settings and preferences ant any time (include accept cookies, reject cookies, and opt-out) by using the cookie setting tool available on our website.  

Also note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to the setting or the support page of your browser to learn more about how you can adjust your privacy and security settings.

Please note that once you choose to opt out or disable cookies, some features of our website and Services may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.

Where we use third-party advertising cookies, such third-party may independently collect Personal Data, through the use of such tracking technologies, and may combine such information with other information they have independently collected relating to your online activities across the Internet, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of advertising campaigns you interacted with. These third parties collect and use this information under their own privacy policies and are responsible for their practices.

7. (7) SHARING PERSONAL DATA WITH THIRD PARTIES

We share your Personal Data with third parties, including our affiliated companies, partners or service providers that help us provide operate and manage our websites, business operation, marketing operations and our Services. The categories of such third-party recipients, the type of Personal Data we will share and the purposes for which we will share the Personal Data are as follows:

• Our Service Providers and Agents - we share Personal Data with our agents and service providers to perform requested services on our behalf. These third parties may include counsels and advisors, technology and hosting providers (such as analytic tools, management or security tools, communications tools, processing payments, shipping and delivery services, etc.(. These providers are prohibited from using Personal Data we share with them for any purposes other than providing us with the requested functions and services. The type of Personal Data that will be shared can be any data processed by us, as needed for the provisions of the specific services.
• Marketing Partners – we may share Personal Data with marketing partners we engage with or use their tools and services to market and promote our website and Services, for example, for our marketing campaigns and targeted online advertising. These partners may include social media platforms or other marketing services operators. The Personal Data shared may include Online Identifiers and Usage Data. These partners may combine your Personal Data with other data they collect independently from your visits and interactions across the web. We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
• Our Company Group & Corporate Transactions - we share Personal Data, internally within our company group to fulfil certain purposes for which Personal Data is collected and retained, or in the event of a corporate transaction (for example, sale of a substantial part of business, merger, consolidation, etc.). The types of Personal Data that will be shared can be any data processed by us, as needed, however our affiliated companies or acquiring company will assume the rights and obligations as described under this Privacy Policy.
• Enforcement of our Rights, Security and Fraud Prevention & Law Enforcement - we may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties as needed to comply with applicable laws or in response to a verified order. We may further Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or third parties to legal liability, and solely to the extent required. The types of Personal Data that will be shared are as needed to fulfil the purpose set forth above, for example, subject to law enforcement authority request.

For avoidance of doubt, we may further transfer and disclose or otherwise use Non-Personal Data or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at our discretion and without limitations.

8. (8) YOUR RIGHTS RELATED TO YOUR PERSONAL DATA

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include: 

Note that, not all those rights apply in every jurisdiction. 

For California Residents, please further review our CCPA Privacy Notice.

You may submit a request to exercise most of your rights, by submitting a claim through the designated webpage available here

When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Certain rights can be easily executed independently by you without the need to fill out the DSR form, and for example:

• If you are our Consumer, you can correct certain data provided under your Account (such as contact information);
• You can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
• You can use the cookie settings tool on our website to change your preferences and opt-out of cookies including opt-out of “sale” of Personal Data.

In the event you are a Consumer – note that closing your Account does not automatically resolved in deletion of data. If you wish to delete your Personal Data, please ensure to contact us with such request.

9. (9) DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:

• Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;
• Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., Product adverse event); or
• If we reasonably believe there is a prospect of litigation relating to your Personal Data.

Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

10. (10) DATA SECURITY

Securing your Personal Data is of high priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as encryption, access restrictions and permissions, etc.

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party\'s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

11. (11) INTERNATIONAL DATA TRANSFER

Due to our global business operation, we may store or process your Personal Data in several territories. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the EEA is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA is transferred, in all cases pursuant to standard contractual clauses approved by the European Union ("SCCs"). Additionally, following the withdrawal of the United Kingdom (“UK”) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission)..

12. (12) PROTECTING CHILDREN

Our Services and Products are not intended for any individual under the age of 18, and we do not knowingly collect or maintain information about anyone under the age of 18. Please contact us if you have reason to believe that a child has shared any information with us.

13. (13) ADDITIONAL NOTICE TO US RESIDENTS:

Residents of certain U.S. states (depending on the applicable state law, acting as an individual or in the household context only and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context or as representative of a business), may have additional rights under applicable privacy laws and be entitled to additional disclosures.

“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope.

“Sensitive Data” includes data revealing racial, ethnic or national origin; religious beliefs; information regarding an individual’s medical history, mental or physical health condition, diagnosis or medical treatment; neural data; status as transgender or non-binary; sex life or sexual orientation; status as a victim of a crime; citizenship or immigration status;  genetic or biometric data; Personal Data collected from a known child; and precise geolocation data. We will obtain your consent before collecting Sensitive Data, such as the biometric identifiers described above, even if they are not used to identify you.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, including any Sensitive Data, the purpose of processing, the categories of Personal Data shared with third parties, the categories of third parties with whom Personal Data is shared, the categories of Personal Data that is sold or used for targeted advertising, if any, the categories of third parties to whom the Personal Data is sold, if any, a list of your data rights and instructions for exercising those rights and appealing decisions, and out contact information. This information is detailed under this Privacy Policy and further below.

Categories of Personal Data & Categories of Third Parties with Whom Personal Data is Shared:

Under this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent, unless we are otherwise entitled, required or permitted under applicable laws.

Additionally, under Section 7 of the Privacy Policy we detail and disclose the categories of third parties we share Personal Data with for a business purposes.

“Sale” of Personal Data:

Under US privacy laws, in principle, the term “sale” refers to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as this term is commonly understood, meaning - we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term “sale” under applicable US privacy laws, our practice of using “cookies or other third-party advertising services and sharing Personal Data for such purpose to third party advertising and marketing providers (e.g., providers of marketing tools and analytic tools, advertising networks, social media networks, media buying, search platforms) is considered a “sale”.

Such practice includes the following Personal Data categories shared with these third parties:

Identifiers – online identifiers such as IP and Cookie ID;

Internet and electronic network activity information – such as your engagement with our website and ads.

Geolocation data – derived from IP.

Consumer Rights Related to Their Personal Data:

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

Access – the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.

List of Third Parties – the right to receive a list of the specific third parties to which we have disclosed either your Personal Data or any Personal Data.

Delete – the right to request us to delete their Personal Data provided to or obtained by us.

Correct – the right to request us to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.

Opt-Out – the right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for profiling in furtherance of making decisions that produce legal or similarly significant effects. However, as noted above, we do not engage in profiling in furtherance of legal or similarly significant decisions.

Appeal – the right to appeal if we decline to take action in response to your exercise of a privacy right.

Non-Discrimination – the right to not be discriminated against for exercising your privacy rights.

Section 8 under this Privacy Policy provides additional information regarding your principal rights.

Exercising Consumer Privacy Rights:

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by submitting a Submit a claim form available here.

For certain rights, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual, provided that they provide proof of their authorization, and we may also require that the individual directly verify his/her identity and the authority of the authorized agent.

We will respond to your request within the timeframe required under applicable law, and we reserve the right to extend the response time subject to applicable law requirements. If we refuse to take action on a request, we will notify you and our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.