Great Freedom Fest (UK)

(Last updated on August 15, 2026)

Great Freedom Fest, Remittance Prize Draw Campaign — terms and conditions of participation

United Kingdom, Version 1.0. Effective 14 August 2026

Important, please read before entering

This is a promotional prize draw run alongside our ordinary remittance service. Entering costs you nothing beyond the transfer you were already making. It is not a lottery, wager, bet or game of chance for consideration.

You are not required to pay any entry fee, buy a ticket, or pay any additional or increased fee, charge, commission or foreign exchange margin in order to enter.
Every remittance you make during the Campaign is charged at Aspora’s standard published tariff, exactly as it would be if this Campaign did not exist.
Prizes are funded entirely from Aspora’s marketing budget and are not funded from customer payments. Because of this, the Campaign is not a lottery.
The Grand Cash Prize is a single-winner draw. Please read clause 5 for details.

If you win, we will ask you for your consent to publish your name, photograph and county, so that everyone who took part can see that a valid award was made. We do not ask for that consent, or for a photograph, when you enter — only if you are selected as the Winner. You do not have to give that consent, and taking part is entirely your choice, but if you decline it, or withdraw it before the Prize is paid, you will not receive the Prize and it will be awarded to the next eligible participant drawn.

Aspora will never ask you to pay a fee, share a one-time passcode (OTP), PIN, password, card number or account credential in order to claim a prize. Any message, call or person asking you to do so is attempting to defraud you. Report it immediately to help@aspora.com or through the in-app Help centre.

1. The Promoter, the Campaign and these Terms

1.1 The promoter of this Campaign is Real Transfer Limited (trading as “Aspora”), a company registered in the United Kingdom with company number NI065249, with its registered office at Office 8, Merrion Business Centre, 58 Howard Street, Belfast, Northern Ireland, BT1 6PJ (the “Promoter” or “Aspora”).

1.2 No permit or licence is required for this Campaign. There is no promotional permit regime in the United Kingdom equivalent to that operated in other jurisdictions in which Aspora runs promotions. Because no participant pays anything for the chance to win, and because the price of the underlying remittance service includes no element that reflects the opportunity to participate, the Campaign is not a lottery within the meaning of the Gambling Act 2005 and does not require an operating licence from the Gambling Commission. Where any provision of these Terms conflicts with a requirement of applicable law, applicable law prevails.

1.3 These terms and conditions (the “Terms”) govern the “Great Freedom Fest” promotional campaign (the “Campaign”) operated by the Promoter through the Aspora mobile application (the “App”) during the Campaign Period.

1.4 The Campaign Period starts at 00:01 (UK time) on 14 August 2026 and ends at 23:59 (UK time) on 31 August 2026 (the “Campaign Period”). Entries received outside the Campaign Period will not be counted, irrespective of the reason.

1.5 By completing a Qualifying Transaction during the Campaign Period you confirm that you have read, understood and agree to be bound by these Terms, and that you satisfy the eligibility criteria in clause 3. If you do not agree to these Terms, do not enter.

1.6 These Terms are supplemental to, and do not replace, the Aspora Terms of Service and the Aspora Privacy Policy applicable to your use of the App, which continue to apply in full. In the event of a conflict, these Terms prevail in respect of the Campaign only.

1.7 These Terms are published in English only.

2. Definitions

In these Terms, capitalised terms have the following meanings:

Term	Meaning
Draw	The random selection of the Winner.
Eligible Participant	A person who qualifies under clause 3.1.
Entry	One chance to be selected in the Draw.
Grand Cash Prize	The single cash prize of £40,000.
Prize	The Grand Cash Prize.
Publicity Consent	The consent given by the Winner under clause 10 and the Publicity Consent Note, which is requested only after the Draw.
Qualifying Transaction	An outward remittance of not less than £10, initiated by an Eligible Participant through the App during the Campaign Period at the Promoter’s standard published tariff and successfully settled to the beneficiary.
Sanctioned Person	A person who is the target of, or owned or controlled by a person who is the target of, financial sanctions administered by the United Kingdom, the United Nations Security Council, the United States or the European Union.
Winner	A Grand Cash Prize winner, being an Eligible Participant (under clause 3.1) who has made a Qualifying Transaction, is selected at random in the Draw, and gives the Publicity Consent when asked to do so after the Draw.

3. Eligibility

3.1 To be eligible to enter, you must, at the time of entry and at all times until any Prize is delivered to you:

(a) be a natural person aged eighteen (18) years or over;

(b) be lawfully resident in England, Wales or Scotland. The Campaign is not open to residents of Northern Ireland, where prize promotion and gambling law is separate from that of Great Britain;

(c) hold a registered personal Aspora App account in your own name in respect of which all customer due diligence, identification and verification requirements have been fully completed and accepted by the Promoter before the relevant Qualifying Transaction;

(d) hold an account which is in good standing and which is not suspended, restricted, dormant, frozen, subject to a lien, or the subject of any fraud, chargeback, dispute or financial crime investigation;

(e) not be a Sanctioned Person, and not be resident or located in a jurisdiction subject to comprehensive sanctions; and

(f) be capable of receiving the relevant Prize lawfully in the United Kingdom.

3.2 The following persons are not eligible to enter and their Entries will be void:

(a) employees, officers, directors, secondees, contractors, consultants and agents of the Promoter and of any company in the Promoter’s group, and members of their immediate families (spouse or partner, parent, child or sibling) and persons living in the same household;

(b) employees, officers and agents of any supplier of a Prize, of any advertising, media, creative or fulfilment agency engaged in connection with the Campaign, and members of their immediate families;

(c) officials and employees of any governmental or regulatory authority involved in the supervision of the Promoter or of the Campaign; and

(d) any person whose participation would place the Promoter in breach of any applicable law, licence condition or regulatory requirement.

3.3 Entry is limited to one natural person per Aspora account, and to one Aspora account per natural person. Where the Promoter reasonably determines that a person has entered using more than one App account, or the identity or documents of another person, all Entries associated with that person will be void and the Promoter may close the relevant accounts.

3.4 Corporate, business, merchant and joint accounts are not eligible.

3.5 The Promoter will screen each Winner against applicable sanctions, politically exposed persons and adverse media lists before releasing any Prize. The Promoter may withhold or cancel a Prize where release would, in the Promoter’s reasonable opinion, breach applicable law or its financial crime obligations. Where the Promoter is permitted to explain its reasons, it will do so.

4. How to enter, and the fact that entry is free

4.1 Entry is free. No payment, ticket purchase, subscription, entry fee or additional charge of any kind is required to enter the Campaign or to be selected in the Draw. No fee, charge, commission, spread or foreign exchange margin applied to any transaction is increased, varied or added by reason of the Campaign. All transactions are priced at the Promoter’s standard published tariff, which is available in the App. The Promoter will not increase its transfer fees or widen its foreign exchange margin by reason of the Campaign at any time during the Campaign Period.

4.2 To enter, you must complete at least one (1) Qualifying Transaction, being an outward remittance of not less than £10 through the App which is successfully settled to the beneficiary.

4.3 Subject to completing a Qualifying Transaction, you will be allocated only one (1) Entry for the whole Campaign Period. Making further or larger transfers does not increase your chance of selection. An Entry cannot be bought, sold, transferred, assigned, gifted or exchanged and has no monetary value.

4.4 Excluded Transactions. The following do not count as Qualifying Transactions and any Entry generated by them will be cancelled:

(a) transactions which are cancelled, failed, rejected, refunded, recalled, reversed, charged back or not settled to the beneficiary, whether before or after the Draw;

(b) transactions funded wholly by promotional credit, refunds or referral rewards;

(c) transactions which the Promoter reasonably suspects to be connected with fraud, money laundering, terrorist financing, sanctions evasion or any other unlawful purpose; and

(d) transactions made in breach of the Aspora Terms of Service.

4.5 The Promoter’s records of transactions, Entries and consents shall be the primary evidence of those matters in the absence of manifest error. This does not affect your right to question a decision, to complain under clause 15, or to exercise any right available to you in law.

4.6 Entry does not increase, and must not be understood as increasing, the likelihood of any customer receiving any other benefit, pricing advantage or service from the Promoter. Entry does not constitute consent to receive marketing from the Promoter, and your marketing preferences remain separate and may be changed at any time in the App.

5. Prize

5.1 The Grand Cash Prize. There is one (1) Grand Cash Prize of £40,000 in the entire Campaign. It is awarded to one (1) Eligible Participant selected at random. Your chance of winning depends on the total number of valid Entries received, which is not known in advance.

5.2 Where any element becomes impossible to provide for reasons beyond the Promoter’s reasonable control, the Promoter may substitute a benefit of equal or greater value, and will notify affected participants through the App.

5.3 Except as expressly stated in these Terms, and save for rights which cannot be excluded under applicable law, the Promoter gives no warranty, representation or guarantee in respect of any Prize.

6. The Grand Cash Prize, additional conditions

6.1 The Grand Cash Prize of £40,000 will be paid exclusively by electronic bank transfer, in pounds sterling, to an account held with a bank or building society in the United Kingdom in the sole name of the Winner. The Promoter will not pay the Grand Cash Prize in physical cash, will not pay it to a joint account, a third party, a business account, a money services account or an account outside the United Kingdom, and will not split it between accounts or persons.

6.2 Before the Grand Cash Prize is paid, the Winner must:

(a) complete the verification steps in clause 8.4 and satisfy the enhanced screening in clause 6.3;

(b) confirm their identity through the authenticated in-App channel and, if requested, produce a valid passport, UK photocard driving licence or other identity document acceptable to the Promoter;

(c) provide evidence issued by the bank confirming that the account is held in the Winner’s sole name, together with the sort code and account number;

(d) sign the Promoter’s Prize Acceptance and Release Form; and

(e) provide such further information or documentation as the Promoter reasonably requires to discharge its legal and regulatory obligations.

Nothing in clause 6.2 requires the Winner to make any payment or transfer. There is no fee, deposit, administration charge or release charge, and no further remittance is required in order to receive the Grand Cash Prize.

6.3 Because of the amount involved, the Grand Cash Prize is subject to enhanced due diligence, including screening against sanctions, politically exposed person and adverse media sources, and internal financial crime approval. The Promoter may withhold or cancel the Grand Cash Prize where payment would, in the Promoter’s reasonable opinion, breach applicable law, a sanctions restriction or the Promoter’s financial crime obligations.

6.4 Fraud control on bank details. The Promoter will collect the Winner’s bank details only through the authenticated in-App channel, and will independently verify them with the Winner using a call-back to the telephone number registered on the Winner’s account. The Promoter will not accept bank details, or a change of bank details, sent by email, SMS, social media or messaging application. Any request purporting to come from the Promoter that asks you to send bank details by those means, or that asks you to pay anything in order to receive the Grand Cash Prize, is fraudulent.

6.5 Payment will be initiated within 30 (thirty) days of the Winner satisfying clauses 6.2 and 6.3. Settlement timing thereafter depends on the receiving bank and is outside the Promoter’s control.

6.6 The Grand Cash Prize is paid gross, subject only to any deduction or withholding required by applicable tax laws. The Promoter will not gross up any such deduction.

6.7 The Winner is solely responsible for any bank charge, transfer charge or currency conversion cost applied by the receiving bank, and for any cost of subsequently transferring or remitting the Grand Cash Prize to any other person, account or jurisdiction, together with any tax or regulatory consequence of doing so.

7. The Draw

7.1 The Draw will be conducted on 15 September 2026.

7.2 The Winner of the Grand Cash Prize will be selected at random using a computer process that produces verifiably random results, in a manner that gives every valid Entry an equal chance of selection. The algorithm, the seed, the list of Entries submitted to the process and the output are logged and retained so that the result can be verified afterwards. No individual at the Promoter selects, influences or is able to override the outcome of the Draw.

7.3 The Draw will be conducted in the presence of a representative of the Promoter’s internal audit or compliance function. The Draw record will be retained as per applicable laws and will be made available to a competent authority on request.

7.4 A reserve Winner will be drawn for the Grand Cash Prize, and will be called upon if the Winner is disqualified, cannot be verified, does not claim within the period in clause 8.3, or forfeits the Prize.

7.5 The result of the Draw is final. Save in the case of manifest error or as required by applicable law, the Promoter will not enter into correspondence regarding the outcome of the Draw. This does not affect your right to complain.

8. Notification, verification and claiming

8.1 The result will be communicated to you whether or not you make any further transaction, and no payment of any kind is required in order to discover whether you have won. The Winner will be notified within five (5) business days of the Draw by in-App notification and by email and SMS to the contact details registered on the Winner’s Aspora account. It is your responsibility to keep those details current.

8.2 Fraud warning. Aspora will never contact you to request payment of a fee, tax, deposit, courier charge, processing charge or release charge in order to give you a Prize, and will never ask you for a one-time passcode (OTP), PIN, password, full card number, security code or account credentials. Aspora will never ask you to make a transfer in order to receive a Prize, and will never ask you to send your bank details by email, SMS, social media or a messaging application. Aspora will confirm your bank details with you by telephoning the number registered on your account. Any request that does not follow that process is a fraud attempt. Do not comply. Report it to help@aspora.com.

8.3 A Winner must respond to the notification and complete the verification steps within twenty-one (21) days of the date the notification is first sent. A Winner who fails to do so forfeits the Prize, and a reserve Winner will be substituted. Where a Winner contacts the Promoter within that period and is having difficulty completing a step, the Promoter will work with the Winner rather than treat the Prize as forfeited, and will make reasonable adjustments where these are needed.

8.4 Before any Prize is released, the Winner must: (a) confirm acceptance of the Prize; (b) confirm their identity through the authenticated in-App channel and produce identity documentation for verification if requested; (c) sign the Prize Acceptance and Release Form; (d) give the Publicity Consent under clause 10 for the use of their photograph and name on the App, the Aspora website and the channels described in clause 10.4; and (e) satisfy the screening in clause 3.5.

8.5 At the point of notification the Promoter will invite you to supply a photograph for publication under clause 10. Uploading a photograph, and consenting to its publication, is a condition of receiving the Prize. A Winner who does not upload a photograph, or who asks the Promoter not to publish one, will forfeit the Prize, and the Prize will be awarded to the next eligible participant drawn in accordance with clause 7.4.

8.6 The Promoter may require a Winner to complete a video verification call, or to attend in person at a location in Great Britain agreed with the Winner, for the purposes of verification. The Promoter will not require attendance in person where verification can reasonably be completed remotely, and will meet any reasonable travel cost it asks the Winner to incur.

9. Taxes, duties and levies, your responsibility

9.1 You are responsible for all taxes, duties, levies, charges, withholdings, filings, declarations and reporting obligations of any nature which arise, in any jurisdiction, in connection with your participation in the Campaign or your receipt, ownership, use or disposal of any Prize.

9.2 This includes any liability arising in your country of tax residence, your country of citizenship, or any jurisdiction in which you are otherwise subject to tax, whether or not that jurisdiction is the United Kingdom. If you are or may be tax resident outside the United Kingdom, a Prize may be taxable income in that jurisdiction, may be taxable at a special or higher rate applicable to winnings, and may be taxable without the benefit of any personal allowance, exemption or deduction.

9.3 The Grand Cash Prize is a material sum and the tax consequences of receiving it can be significant. The Promoter therefore recommends that the Winner obtains independent professional tax advice in every jurisdiction in which the Winner may be taxable before accepting it, and in any event before remitting or transferring it to another jurisdiction. Remitting the Grand Cash Prize to another country may itself carry tax, exchange control and reporting consequences for which you alone are responsible.

9.4 The Promoter does not provide tax advice and makes no representation, warranty or statement as to the tax treatment of any Prize in any jurisdiction.

9.5 The Promoter may deduct or withhold from any Prize any amount which it is required by applicable law to deduct or withhold, and shall have no obligation to gross up or compensate you for that deduction.

9.6 The Promoter may, as a condition of releasing a Prize, require you to provide: (a) a tax residency declaration and any taxpayer identification number; and (b) satisfactory evidence that any applicable tax has been paid or provided for.

9.7 You shall reimburse the Promoter for any tax, penalty or interest which the Promoter incurs as a direct result of any incorrect or incomplete declaration. This clause does not apply where the Promoter has contributed to the error.

9.8 The Grand Cash Prize is a payment of money and is not a supply for value added tax purposes. Any value added tax for which the Promoter is accountable in connection with the Campaign is borne by the Promoter and does not increase or reduce the Prize.

10. Publicity, use of your name and photograph

10.1 It is a condition of receiving the Prize, and not a condition of entering the Campaign, that you give the Publicity Consent set out in the separate Aspora Prize Draw Publicity Consent Note, which forms part of these Terms and which is presented to you in the App only if you are selected as the Winner. If you do not give that consent, you will not receive the Prize and the Prize will be awarded to the next eligible participant drawn in accordance with clause 7.4.

10.2 What the Promoter will ordinarily publish. So that participants can see that a valid award has been made, the Promoter will publish, or make available on request, information indicating that a valid award took place, ordinarily the name and county of the Winner.

10.3 Your right to object. The Promoter will inform you of its intention to publish or make available that information at or before the time of entry, and you may object to it being published or made available, or ask that less information is published, either when you enter or at any time before publication, using the in-App option or by writing to help@aspora.com. If you withdraw it before the Draw, your Entry will be withdrawn and you will no longer participate. If you withdraw it after the Draw has taken place, the Prize will be awarded to the next eligible participant drawn.

10.4 A photograph will be published only where you have supplied one, and only where you have given your consent. The Promoter will invite you to supply a photograph only if you are notified as the Winner. No photograph is requested from any participant who is not selected in the Draw. The Promoter will never use your identification document photograph, your customer due diligence image or any image held for verification purposes. If you do not supply a photograph, or you decline or withdraw consent to its publication, you will not receive the Prize and it will be awarded to the next eligible participant drawn in accordance with clause 7.4. This does not affect the services offered to you by Aspora in the ordinary course of business.

10.5 Publication on any other channel, including social media, paid advertising, press releases and media interviews, requires a further consent, which is also required in order to receive the Prize and which is requested as part of the Publicity Consent Note only if you are selected as the Winner. If you do not give that consent, or if you withdraw it, clause 10.6 applies.

10.6 You may withdraw the Publicity Consent at any time, at no cost, through the App or by contacting help@aspora.com. If you withdraw it after publication, the Promoter will remove the relevant material as soon as reasonably practicable. Withdrawing the Publicity Consent will withdraw your Entry from the lucky draw. If you withdraw it after the Draw has taken place, the Prize will be awarded to the next eligible participant.

10.7 The Promoter will not publish the amount or value of any Prize alongside your name and photograph, and will not publish your full residential address, contact details, account details or transaction history.

11. Your personal data

11.1 The Promoter is the data controller in respect of personal data processed for the Campaign. Personal data is processed in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, the Aspora Privacy Policy available at https://www.aspora.com/privacy-policy, and these Terms.

11.2 The Promoter processes: your identification and contact details; your identity verification data; transaction data used to determine eligibility and allocate Entries; consent and objection records; any photograph you supply for publication, which is stored separately from your identity verification records; and, if you win, your name and county. The purposes are administering the Campaign, verifying eligibility, conducting the Draw, awarding and delivering the Prize, publishing the result, complying with legal, tax, regulatory and financial crime obligations, and handling complaints and disputes.

11.3 The legal bases are: performance of the contract constituted by these Terms; compliance with the Promoter’s legal and regulatory obligations, including under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; the Promoter’s legitimate interests in the integrity of the Draw and the prevention of fraud; and, in respect of the publication of your photograph and any wider publicity, your consent.

11.4 Personal data may be disclosed to: competent authorities, including the Financial Conduct Authority, the National Crime Agency, HM Revenue and Customs, the Information Commissioner’s Office and the Advertising Standards Authority; the Promoter’s group companies; the bank through which the Grand Cash Prize is paid; the Promoter’s sanctions, politically exposed person and adverse media screening providers; the licensed financial institutions through which remittances are executed; and the Promoter’s auditors, professional advisers and technology service providers. Personal data may be transferred outside the United Kingdom, including to India, the United States and the United Arab Emirates, subject to an international data transfer agreement or another safeguard permitted by UK data protection law.

11.5 Campaign records, including consent and objection records, will be retained as per applicable laws from the end of the Campaign Period in order to evidence that the Campaign was conducted fairly and in compliance with applicable law, and for longer where required by law.

11.6 You have the rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent, as set out in the Aspora Privacy Policy. To exercise them, or to contact the Data Protection Officer, write to dpo@aspora.com. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk.

12. Financial crime, fraud and abuse

12.1 The Promoter may, at any time and in its reasonable discretion, disqualify a participant, cancel Entries, withhold a Prize or require the return of a Prize where it reasonably suspects: fraud, deception or impersonation; manipulation of the Campaign or the Draw; use of automated means, bots, scripts, emulators or multiple accounts; collusion; breach of these Terms or of the Aspora Terms of Service; or any connection with money laundering, terrorist financing, sanctions evasion or other unlawful activity.

12.2 The Promoter may report any such matter to the police, the National Crime Agency, the Financial Conduct Authority or any other competent authority, and may suspend or close the relevant Aspora account. There are circumstances in which the law prevents the Promoter from telling you that it has done so, or the reasons for it.

12.3 Where a Prize has already been delivered and clause 12.1 applies, the Promoter may recover the Prize.

13. Changes to the Campaign

13.1 The Promoter may amend these Terms, or suspend, shorten, extend, modify or cancel the Campaign, only where it is necessary to do so:

(a) to comply with applicable law or a direction of a competent authority;

(b) because of an event beyond the Promoter’s reasonable control which prevents the Campaign being run as planned; or

(c) because fraud, technical failure or manipulation has affected or would affect the integrity or fairness of the Campaign.

13.2 Any such change will be notified through the App and on the Aspora website as soon as reasonably practicable, together with the reason for it.

13.3 No amendment, suspension or cancellation will deprive a person of a Prize to which they have already become entitled, or already credited. The Promoter will not make retrospective changes to eligibility or to the Prize allocation in clause 5 once the Campaign Period has begun.

14. Liability

14.1 Nothing in these Terms excludes or limits the Promoter’s liability for: (a) fraud or fraudulent misrepresentation; (b) death or personal injury caused by the Promoter’s negligence; or (c) any other liability which cannot lawfully be excluded or limited. Nothing in these Terms affects your statutory rights, including your rights under the Consumer Rights Act 2015.

14.2 Subject to clause 14.1, the Promoter is not liable for:

(a) any loss which was not reasonably foreseeable at the time you entered;

(b) any act or omission of a bank, correspondent bank, fulfilment provider or licensed financial institution, including any delay, charge, deduction or refusal by a receiving bank in relation to the Grand Cash Prize;

(c) any tax consequence of a Prize;

(d) any failure, interruption, delay or error in any telecommunications network, internet connection, device, app store or payment system which prevents or delays an Entry, a notification or a Prize claim, except to the extent caused by the Promoter; or

(e) any loss suffered as a result of a participant’s failure to keep their contact details up to date or to respond within the periods in clause 8.3.

14.3 Subject to clause 14.1, the Promoter’s total aggregate liability to any participant in connection with the Campaign shall not exceed the value of the Prize which that participant won, or would have won but for the Promoter’s breach.

15. Complaints

15.1 Please come to us first. If you are dissatisfied with any aspect of the Campaign, raise your complaint through the in-App Help centre or by writing to help@aspora.com. We will acknowledge your complaint promptly and provide a final response within the timescales set out in the Aspora complaints policy. For most complaints that is within eight weeks. Where your complaint concerns a payment service, we will respond within fifteen business days, or within thirty-five business days in exceptional circumstances, and we will tell you if that applies.

15.2 Complaints about how this promotion was advertised or run. The Advertising Standards Authority is the independent body that administers the UK Advertising Codes, which govern sales promotions of this kind. If your complaint is about the way the Campaign has been advertised, described or conducted, including the fairness of the Draw, the clarity of these Terms or the way winners are selected and notified, you may complain to the Advertising Standards Authority. Its service is free.

Online: asa.org.uk
Post: Advertising Standards Authority, Castle House, 37 to 45 Paul Street, London EC2A 4LS
Telephone: 020 7492 2222

15.3 Complaints about a payment service. Where your complaint concerns a regulated payment service provided to you by the Promoter, and you are an eligible complainant, you may be able to refer it to the Financial Ombudsman Service once you have received our final response, or if we have not responded within the applicable time limit in clause 15.1. Our final response will tell you whether your complaint is one the Financial Ombudsman Service can consider. Its service is free. You must refer your complaint within six months of the date of our final response.

Online: financial-ombudsman.org.uk
Email: complaint.info@financial-ombudsman.org.uk
Post: Financial Ombudsman Service, Exchange Tower, London E14 9SR
Telephone: 0800 023 4567 or 0300 123 9 123
From outside the United Kingdom: +44 20 7964 0500
Relay UK: (18002) 020 7964 1000

15.4 Complaints about your personal data. If your complaint concerns how we have collected, used, published or retained your personal data, including anything in clause 10, clause 11 or the Publicity Consent Note, you may complain to the Information Commissioner’s Office. Its service is free.

Online: ico.org.uk
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113

15.5 Complaining costs you nothing. Raising a complaint with us, or with any of the bodies above, is free, does not affect your Entry, does not affect any Prize you have won, and does not affect your Aspora account, your pricing or the service you receive. Nothing in this clause 15 limits your statutory rights or your right to take legal action.

16. General

16.1 Not a lottery or gambling activity. The Campaign is a promotional marketing activity conducted alongside the Promoter’s ordinary remittance service. It is not a lottery, raffle for consideration, wager, bet or commercial gaming activity, no consideration is given by any participant for the chance to win, and no participant is required to pay in order to discover whether they have won or to take possession of a Prize. The Campaign does not require a licence under the Gambling Act 2005.

16.2 No person other than a participant and the Promoter has any right to enforce these Terms.

16.3 If any provision of these Terms is or becomes invalid, illegal or unenforceable, it shall be severed and the remaining provisions shall continue in full force.

16.4 A failure or delay by the Promoter in exercising any right under these Terms is not a waiver of that right.

16.5 The Promoter may assign or transfer its rights and obligations under these Terms to any company in its group or to a successor in business, provided that this does not adversely affect a participant’s entitlement to a Prize.

16.6 Governing law and jurisdiction. These Terms and any dispute arising out of or in connection with them are governed by the law of England and Wales, and the courts of England and Wales shall have jurisdiction. If you are resident in Scotland you may also bring proceedings in the Scottish courts and you retain the benefit of any mandatory protection available to you under Scots law. Nothing in this clause limits any right you may have to complain to a regulator or ombudsman.

16.7 Contact. Questions about the Campaign should be addressed to help@aspora.com, or through the in-App Help centre.

A. In short

The consents in this Note are required in order to receive the Grand Cash Prize. We only ask for them if you win — not when you enter, and not from anyone who is not selected in the draw. If you decline, you will not receive the Prize and it will be awarded to the next eligible participant. Entering costs you nothing beyond the transfer you were already making, and choosing not to give a consent changes nothing about your Aspora account, your pricing or the service you receive.

If you win, we will publish, or make available on request, your name and the county you live in, so that everyone who took part can see that a valid award was made. We will tell you before you enter that we intend to do this, and you can object. If you object we will respect that, and we will still be able to confirm the result confidentially to the Advertising Standards Authority if we are challenged.

We can only publish a photograph if you give us one and you agree to it. We will ask you to supply a photograph only if you win. We will never use the photograph from your identity documents or from anything you gave us for identity checks. If you do not supply a photograph, or you change your mind before the prize is paid, you will not receive the Prize and it will be awarded to the next eligible participant.

You can change your mind at any time. If you withdraw your consent before the draw, your entry is withdrawn. If you withdraw it after the draw, the prize will be awarded to the next eligible participant.

B. Who is asking, and about what

B.1 The controller of your personal data for this purpose is Real Transfer Limited (trading as “Aspora”), a company registered in the United Kingdom with company number NI065249, authorised by the Financial Conduct Authority as an authorised payment institution (firm reference number 535949), with its registered office at Office 8, Merrion Business Centre, 58 Howard Street, Belfast, Northern Ireland, BT1 6PJ (“we”, “us”, “our”).

B.2 This consent relates to the “Great Freedom Fest” promotional campaign (the “Campaign”). It should be read together with the Campaign Terms and Conditions and the Aspora Privacy Policy.

B.3 This consent applies if you are selected as the Winner of the Grand Cash Prize. If you are not selected as the Winner, nothing will be published about you and this consent lapses without any action on your part.

If you win and you agree, we will publish the following on the Aspora app and on the Aspora website only:

What	Detail
Your name	Your name only.
Your photograph	One still photograph of you, supplied by you when you are notified as the Winner. We will never use your identity document photograph or any image held for identity verification purposes. If you supply no photograph, you will not receive the Prize, as explained in clause 10.4 of the Terms.
Your county	Your county of residence only, for example “West Sussex”. We will not publish your address, postcode or neighbourhood.
That you are the Winner	That you are the Winner of the Campaign. We will not publish the amount you received alongside your photograph.
Where	The Aspora mobile application and the Aspora website at www.aspora.com. Nowhere else under this Consent 1.
For how long	For up to 1 month from first publication, after which it is removed.
Who else sees it	Our hosting, content delivery and app store providers process the content in order to display it. We do not sell your data and we do not give it to advertisers.

We will not publish: your passport or driving licence number, your date of birth, your residential address or postcode, your telephone number, your email address, your account number, your transaction history, or any information about the people you send money to.

D.1 This consent is also required in order to receive the Prize. In addition to Consent 1, we may use your full name, your photograph, the fact that you won and a short quotation or winner story provided by you:

(a) in a press release issued by Aspora, and in resulting coverage by newspapers, magazines, online publications, radio and television in the United Kingdom, India and elsewhere;

(b) on Aspora’s own social media channels, and in paid social media advertising; and

(c) in Aspora’s own marketing materials, including in-app and email marketing to other customers.

D.2 Coverage published by a third party such as a newspaper or broadcaster is outside our control once it is published. We cannot require a third party to remove or amend material it has published, although we will pass on any request you make.

D.3 Material published on our own channels under Consent 2 will remain in place for no longer than 1 month from first publication, after which it will be removed.

D.4 You may withdraw this consent at any time, at no cost, through the App or by writing to help@aspora.com.

D.5 An important practical point about press and social media. Once a photograph and name have been issued to the media or posted on a social platform, they can be copied, shared, screenshotted, re-posted and indexed by search engines by people we have no control over. If you later withdraw this consent, we will stop using the material and will remove it from our own channels and ask the platforms and publications to do the same, but we cannot guarantee that every third-party copy will be removed. Please take this into account before agreeing.

E.1 You may change either choice, Consent 1 or Consent 2, at any time in the App, or by writing to help@aspora.com.

E.2 If you withdraw the consent at any time, your entry into the Campaign is withdrawn. In the event the draw has already taken place the prize will be awarded to the next eligible participant following the similar process.

E.3 Withdrawing a consent does not affect the lawfulness of anything we did while the consent was in place.

E.4 If you have any question about this Note, or wish to contact our Data Protection Officer, write to dpo@aspora.com.

E.5 We will keep a record of this consent and of any withdrawal for five years in order to demonstrate to the competent authority that the Campaign was run lawfully. That retention is required by law and does not depend on your consent.