We handle club correspondence and campaign telemetry under verified Texas privacy standards.

Effective Date and Revision Marker

This privacy notice is formally in force as of October 16, 2026 (2026-10-16). It governs all digital touchpoints on penalnaro.com, including direct match fixture inquiries, support chat threads, and paid campaign landing destinations.

Data Controller and Business Identification

The data controller responsible for the intake, processing, and storage of personal records collected through this website is Penalnaro, trading at penalnaro.com.

Full Postal Address: 701 West Riverside Drive, Austin, Texas 78704, Austin, Texas, United States.
Direct Phone: +1 (562) 555-8793
Editorial Dispatch Email: [email protected]

Penalnaro is a registered business entity in the State of Texas, operating an independent soccer and sports editorial desk and visual production studio under the direction of sports editor Elena Petrova since 2021.

Legal Bases for Processing

We process personal information under defined legal bases in accordance with applicable data privacy statutes:

Categories of Data Collected

We record only the technical and operational details necessary to coordinate soccer coverage, book production sessions, and measure web traffic:

• Inquiry Form Dispatches (pifuada.php): Representative name, telephone number, email address, physical club or venue address, production scope selection, requested fixture specifications, free-text operational notes, and explicit consent check.
• Automatic Technical Envelope: Client IP address, browser user-agent string, referring URL, timestamp of initial page render, and timestamp of form transmission.
• Support Chat Interface (kane100.php): Conversation message transcripts and a local session token persisted inside the client browser.
• Consent Decisions: The visitor's accepted or declined cookie preference stored locally under site_consent_v2.
• Paid Campaign Attribution: URL click identifiers appended to inbound links from active marketing campaigns (gclid, msclkid, fbclid).

We do not create visitor accounts, we do not require passwords, and we do not process payment card details on this website. Our catalog operates on an inquiry basis with fixed hourly ($150–$300/hr) and session ($500–$555) rates billed through direct club invoices.

Operational Purposes of Processing

Collected data is used strictly for legitimate commercial and editorial functions:

• Scheduling Austin-based camera operators and sideline telephoto glass for match fixtures.
• Drafting and issuing formal editorial retainer agreements ($3,000–$7,500/month) with assigned monthly production credits (8–18 credits).
• Transmitting emergency weather delay notices and fixture rescheduling dispatches.
• Evaluating advertising reach across regional soccer clubs, adult leagues, and youth academies.
• Diagnosing server transmission faults and defending our publishing infrastructure against malicious botnets.

Active Advertising Platforms & Click Identifiers

This website is an active landing destination for paid digital advertising. Commercial ad traffic runs to our desk via google ads, microsoft advertising, and Meta Ads. We monitor campaign performance through specific click identifiers appended to destination links: gclid from Google Ads, msclkid from Microsoft Advertising, and fbclid from Meta Ads.

Consent Mode v2 Architecture & Parameters

To respect user autonomy and meet current platform standards, penalnaro.com implements Google Consent Mode v2. Under this consent mode framework, before a visitor interacts with our cookie banner, or whenever a visitor chooses to decline non-essential cookies, the following four tracking parameters are held in a denied state:

• ad_storage: denied (Disables storage of marketing cookies in the user's browser).
• ad_user_data: denied (Prevents transmission of user-specific data to Google for advertising purposes).
• ad_personalization: denied (Blocks remarketing and personalized advertising profiling).
• analytics_storage: denied (Restricts telemetry storage to cookieless, non-persistent pings).

Only when the visitor clicks "Accept All" are these parameters updated to granted. If the visitor subsequently opens preferences and declines, or if the browser broadcasts a Global Privacy Control signal, all four parameters are immediately reset to denied.

Data Processors and Technical Recipients

Penalnaro shares operational data only with contracted service providers essential to our editorial workflow:

• Google LLC / Google Ireland Ltd: Advertising measurement and analytics infrastructure subject to Consent Mode v2.
• Microsoft Ireland Operations Ltd: Microsoft Advertising network attribution. For further details on Microsoft data governance, review their privacy statement at privacy.microsoft.com.
• Meta Platforms Ireland Ltd: Social ad delivery and pixel telemetry when marketing tags are consented to.
• Web Infrastructure & Server Hosting Provider: Dedicated US-based secure server facility hosting penalnaro.com and processing pifuada.php inquiries.
• Mail Routing Provider: Encrypted SMTP relay delivering matchday booking notices directly to Elena Petrova's editorial desk.

International Data Transfers

Penalnaro operates from Austin, Texas, United States. Data submitted by visitors outside the United States is transferred to and processed within the United States. For visitors accessing our services from the European Economic Area or the United Kingdom, transfers to US service providers are safeguarded using Standard Contractual Clauses (SCCs) adopted by the European Commission, or recognized adequacy frameworks such as the EU-U.S. Data Privacy Framework.

European Privacy Rights (GDPR)

For visitors protected by the General Data Protection Regulation (gdpr), you possess specific statutory rights concerning your personal data:

• Right of Access: The right to obtain confirmation as to whether your matchday inquiries or chat logs are being processed and receive a full copy.
• Right to Rectification: The right to correct inaccurate squad rosters, manager contact details, or billing coordinates.
• Right to Erasure (Right to be Forgotten): The right to demand deletion of your inquiry records when retention is no longer justified.
• Right to Restriction: The right to suspend processing while data accuracy or objection claims are verified.
• Right to Data Portability: The right to receive your structured correspondence in a machine-readable format.
• Right to Object: The right to object at any time to processing grounded in legitimate interests or direct marketing.
• Right to Withdraw Consent: The right to revoke advertising cookie permissions at any time via our footer consent controls.

United States State Privacy Rights (CCPA / Texas TDPSA)

Residents of California under the California Consumer Privacy Act (CCPA) as amended by the CPRA, residents of Texas under the Texas Data Privacy and Security Act (TDPSA), and residents of Virginia, Colorado, Connecticut, and Utah hold distinct statutory rights:

• Notice of Collection: The right to know the categories of personal data collected, commercial purposes, and categories of third-party recipients prior to collection.
• Right to Know and Access: The right to request disclosure of specific pieces of personal information collected over the preceding 12 months.
• Right to Delete: The right to request the deletion of personal information maintained by our editorial desk.
• Right to Correct: The right to update inaccurate personal information.
• Opt-Out of Sale or Sharing: Penalnaro does not sell personal records for monetary consideration. However, using third-party advertising cookies (Google Ads, Meta Ads, Microsoft Advertising) may be classified as "sharing" for cross-context behavioral advertising. You hold the absolute right to opt out by declining cookies or enabling browser privacy signals.
• Non-Discrimination: We will never deny services, charge differing hourly rates, or alter video reel turnarounds if you exercise your statutory rights.

Global Privacy Control (GPC) Compliance

Penalnaro explicitly respects and honors the global privacy control (GPC) browser signal. If your browser broadcasts a valid Sec-GPC header, our website automatically suppresses all non-essential advertising tags, prevents pixel firing for Google Ads, Microsoft Advertising, and Meta Ads, and maintains Consent Mode v2 variables in their denied state without requiring manual banner interaction.

Regulatory Complaints and Supervisory Authorities

If you believe our data handling practices violate applicable privacy laws, you possess the right to lodge a formal complaint with relevant regulatory bodies:

In Texas, inquiries and consumer complaints may be filed with the Office of the Attorney General of Texas.
In California, complaints may be submitted to the California Privacy Protection Agency (CPPA) or the California Attorney General.
In the European Union, you may contact the Data Protection Authority (DPA) in the member state of your habitual residence or place of work.

Data Retention Schedules

We maintain rigid, finite retention windows for every data category. We never retain personal records indefinitely:

Technical & Operational Security Measures

We enforce strict technical controls to protect matchday rosters, fixture schedules, and contact records:

• Active Transport Layer Security (TLS 1.3 / SSL) with forced HTTPS redirection across all site domains.
• Honeypot form verification fields (agency and domain) to trap automated exploitation scripts.
• Strict server access controls restricting raw inquiry databases to authorized editorial personnel.
• Routine security patches applied to the server environment hosting our static assets and PHP backend.

Children's Privacy Protection

Our services are directed exclusively at soccer club directors, academy managers, athletic coordinators, tournament organizers, and adult athletes. We do not knowingly solicit, collect, or process personal information from children under 13 years of age (or under 16 years of age in applicable jurisdictions) without verified parental or legal guardian consent. If we discover that personal data of a minor has been submitted through our inquiry desk without parental authorization, we purge the record immediately.

Exercising Subject Access Requests (DSAR)

To exercise your right to access, review, correct, or delete personal records held by Penalnaro, you may submit a formal Data Subject Access Request.

Direct Request Email: [email protected] with the subject line "Data Subject Request - Editorial Desk".
Postal Request: Penalnaro Desk, 701 West Riverside Drive, Austin, Texas 78704, Austin, Texas, United States.
DSAR Portal: Submit via our dedicated Data Subject Request Page.

Response SLA: We formally acknowledge and answer all verified data subject requests within 5 days, well within statutory maximums.

Notification of Policy Updates

We reserve the right to revise this Privacy Policy to reflect changes in advertising rules, state privacy legislation, or studio operations. When material updates occur, we revise the effective date displayed at the head of this document and publish a prominent notice on our primary newsroom feed for a minimum of 30 days.

Direct Privacy Contact

For any questions regarding this policy or our data management protocols, contact our lead editorial desk directly: