Terms & conditions - Venga Challenges

The Challenges Program is an in-app reward system where users can earn fixed rewards by successfully completing specified actions or milestones ("Challenge Requirements") within the Venga application.

1. Nature of the Program
   1. Fixed Rewards: Rewards are fixed for each completed Challenge and depend solely on the user successfully meeting the defined Challenge Requirements.
   2. No Chance: This is explicitly not a lottery, not a game of chance, and not a draw. Rewards are not based on luck, probability, random selection, or any element of chance among participants.
2. Challenge Availability and Activation
   1. One-Time Offer: Each individual Challenge may be completed and the reward claimed by a user only once. A Challenge, once completed, claimed, or dismissed, will not be re-presented to that user.
   2. Activation Requirement: A user must activate a specific Challenge within the Venga app interface to become eligible to claim the corresponding reward.
   3. Partial Progress Tracking: Progress made towards meeting the Challenge Requirements before activation will be tracked and count toward completion, provided that:
      1. The Challenge Requirements were not fully completed prior to the point of activation.
      2. If the Challenge Requirements are fully met before a user activates the Challenge, that specific Challenge will become unavailable to the user.
   4. Modification Rights: Individual Challenges may be added, removed, or modified at any time without prior notice, provided that any user who has activated a Challenge will be subject to the T&Cs active at the time of their activation.

Participants are required to conduct themselves in a professional, respectful, and safe manner at all times, in compliance with these T&Cs and all applicable laws and regulations.

Participants must act fairly and are prohibited from employing any means intended to manipulate or gain an unfair advantage in the Event. Specifically, Participants are forbidden from using bots, scripts, automation tools, emulators, or modified software, attempting to defraud or exploit the Event mechanics, or creating multiple accounts or fake identities. Violations of these rules will result in disqualification and forfeiture of any Digital Reward.

Participants must act fairly and are prohibited from employing any means intended to manipulate or gain an unfair advantage in the Event.

Venga reserves the right to disqualify any Participant who engages in unsafe, disrespectful, unlawful, or disruptive conduct, interferes with other Participants or the orderly conduct of the Program, or attempts to manipulate, cheat, or compromise the integrity of the Program. Disqualified Participants will forfeit all rights to the Digital Reward and any associated rewards and may lead to the suspension or permanent closure of the user's Venga account and prosecution under applicable law.

Venga reserves the right, at its sole discretion and without prior notification, to terminate, suspend, or modify the Program as a whole or any individual Challenge under the following circumstances:

• Technical or security issues: If any malfunction, vulnerability, or security breach arises that could compromise the proper functioning of the system or the fairness of the Program.
• Fraud, misuse, or widespread abuse of the Challenge mechanics is detected.

Legal or regulatory requirements: If Spanish law, EU law, or any other applicable legislation or regulatory authority requires the Program or any Challenge to be altered, paused, or discontinued.

Force majeure: If circumstances beyond Venga’s reasonable control (including but not limited to natural disasters, power outages, or widespread service interruptions) make it impossible or impractical to continue operating the Program or a specific Challenge.

Any significant change to these T&Cs will be communicated through the Venga app or the official website.

The Reward is stated in gross amounts, without any deductions or withholdings. Participants are solely responsible for any taxes, duties, or other fiscal obligations that may arise in connection with receiving the Digital Reward under applicable law.

Venga may provide documentation required by law to assist Participants with their tax compliance but shall not be held responsible for any individual tax liabilities or obligations of the Participants.

The data controller for the personal data of the Participants is Venga Europe S.L., with registered office at Passeig del Mare Nostrum, Norrsken House, nº 15, 08039, Barcelona (Spain), and Tax ID number (CIF) B-56395585.

During the participation process in the Program, the following categories of data may be processed:

1. Identification data: first name, surname(s), identification document (DNI/NIE/passport), image, voice.
2. Contact data associated with the Venga account.
3. Data derived from eligibility verification (KYC, identity).
4. Data derived from prize delivery (bank details or Venga account details necessary to make the payment).

Personal data will be processed for the following purposes:

1. Management of participation in the Program, including requirements control, identity verification and communication with Participants.
2. Determination and validation of the winner, as well as prize delivery.
3. Compliance with legal obligations, including those relating to fraud prevention, if applicable, identity verification, tax obligations or requests from competent authorities.
4. Ensuring the safety of the Program, operational control and incident management.

The processing is based on the following legal grounds:

1. Performance of the legal relationship arising from participation in the Event (Art. 6.1(b) GDPR).
2. Compliance with applicable legal obligations (Art. 6.1(c) GDPR).
3. Venga’s legitimate interest in ensuring the safe conduct of the Program and disseminating general content relating to it (Art. 6.1(f) GDPR).
4. Explicit consent for recordings or individualized appearances as provided in Annex I (Art. 6.1(a) GDPR).

Data may be disclosed to public authorities and bodies where legally required, service providers to Venga (audiovisual production, technological support, identity verification, communications), acting as data processors, and digital platforms and social networks located outside the EEA (for example, the United States), exclusively in cases where the Participant has specifically consented to their direct appearance in Venga content.

In the event of international data transfers, these will be carried out in accordance with the safeguards set out in Chapter V of the GDPR (e.g. Standard Contractual Clauses).

Personal data will be retained for the time necessary for:

1. Management of the Program and validation of the winner.
2. Compliance with applicable legal obligations.
3. In the case of incidental images and general promotional material, for the period necessary for the purposes of dissemination and legitimate promotion of the activity.

Participants may, at any time, exercise their rights of access, rectification, erasure, objection, restriction of processing, data portability and withdrawal of consent (where applicable). Requests may be sent to: [email protected], together with a copy of a valid identity document. Participants are also entitled to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

Venga implements appropriate technical and organizational measures to ensure the security, integrity and confidentiality of personal data, in accordance the GDPR.

In the event of force majeure, technical issues, security incidents, fraud, misuse, or any other circumstances beyond Venga’s reasonable control, Venga reserves the right to modify, delay, suspend or cancel the Challenge. Venga may also alter or cancel the Challenge if required by law or regulatory authorities. Any such changes will be communicated to Participants through the Venga app or official website.

Venga shall not be held liable for any losses, damages, or harm arising from technical failures, device issues, connectivity problems, performance issues caused by third-party providers, user errors, or misuse of the application.

Participants acknowledge that they are solely responsible for their use of the Venga app and agree to release Venga from any claims arising therefrom.