Spark Sports Privacy Notice

1. Introduction

This Privacy Notice, together with our Terms and Conditions and any other documents referred to in it, explains how Sports Initiative Ltd, trading as Spark Sports (“Spark Sports”, “we”, “us” or “our”), collects, uses and protects the personal data we collect from you, or that you provide to us, when you use our website and any other Spark Sports services, whether now or in the future (the “Services”).

Spark Sports is a community ticketing and fundraising platform. We help local sports clubs make selected fixtures available for community promotion, allow schools, charities and other partners to share ticket links and earn a fair share of tracked sales, and let families buy tickets online, including our “child goes free” and match-day experiences for younger supporters.

For the purposes of the UK Data Protection Act 2018 and the UK General Data Protection Regulation (“UK GDPR”), Sports Initiative Ltd is the Data Controller for the personal data described in this notice. We are registered in England and Wales under company number 16012549, with our registered office at 15 Old Chatham Road, Blue Bell Hill, Aylesford, England, ME20 7EZ.

Sports Initiative Ltd is registered with the Information Commissioner’s Office under registration number ZC208051.

We have appointed a person responsible for overseeing questions about this Privacy Notice. If you have any questions, or wish to exercise any of your legal rights, please use our contact form or write to us at the registered address above.

2. The information we collect about you

“Personal data” means any information about an individual from which that person can be identified. We may collect, use and store the following categories of personal data about you:

• Identity Data: first name, last name, username or similar identifier, title, date of birth where required to confirm eligibility for age-related tickets, and gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: payment card and bank account details. These are collected and processed directly by our payment provider as explained below.
• Transaction Data: details of the tickets and services you buy or sell through the platform, and payments to and from you.
• Technical Data: internet protocol address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website.
• Profile Data: your username and password, purchases and orders, interests, preferences, feedback and survey responses.
• Usage Data: information about how you use our website and Services.
• Partner and Attribution Data: for clubs, schools, charities and other partners, contact and organisation details, the ticket allocations you promote, and data linking sales back to the partner that introduced the supporter for fundraising and revenue-share purposes.
• Marketing and Communications Data: your preferences for receiving marketing from us and your communication preferences.

Payments and card details. When you make or receive payments through Spark Sports, Stripe processes all payment information directly, including card details and any identity-verification data. Sports Initiative Ltd does not store or have access to your full payment card details. Stripe processes this information in accordance with its own privacy policy and acts as a separate data controller for those activities.

Special category and children’s data. We do not seek to collect special category data, such as health information or racial or ethnic origin. Because our platform is designed around family access, we collect limited data relating to children as explained in section 6.

If you fail to provide personal data. Where we need personal data to fulfil a contract with you, for example to process a ticket order, and you do not provide it, we may not be able to provide the Service you have requested.

3. How we use your information

We will only use your personal data when the law allows us to. Most commonly, we use it where we need to perform a contract with you, where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, where we need to comply with a legal obligation, or where you have given consent.

Where we rely on legitimate interests, you have the right to object as explained in section 9. Where we rely on consent, for example for certain marketing, you can withdraw it at any time.

4. Cookies and similar technologies

We use cookies and similar technologies when you visit the website to keep you signed in, remember your preferences, keep the platform secure, and understand how the website is used so we can improve it. Some cookies also help us measure the effectiveness of our marketing.

You can control non-essential cookies through our cookie banner and through your browser settings. Turning off some cookies may affect how the website works. For full details, please read our Cookie Policy.

5. Sharing your information

Your name and, where you provide one, your profile photo may be visible to other users while your account is active. Except as described below, we will not share your personal data with third parties. We may share your information:

• with clubs whose fixtures you buy tickets for, so they can administer entry, manage attendance and understand the performance of their fixtures;
• with schools, charities and other partners, so that sales introduced by them can be tracked for fundraising and revenue-share purposes. Partners receive attribution and sales data, but not your full financial details;
• with other users where you enter into a transaction through our platform;
• with Stripe and other service providers that provide hosting, IT, email, analytics and customer-support services on our behalf and may only use your data on our instructions;
• with any group companies of Sports Initiative Ltd where relevant to providing the Services;
• where required by law or regulation, or to protect the rights, property or safety of Spark Sports, our users or others, including for fraud prevention, credit-risk reduction and safeguarding;
• with a prospective buyer or seller if we are involved in a merger, acquisition or sale of all or part of our business or assets. We will notify you of any change of ownership affecting your personal data; and
• with any other third party where you have given your prior consent.

We will never pass your information to a third party for them to use in their own direct marketing without your express consent.

6. Children and young people

Spark Sports is built around family access, so children attend matches through our platform, including “child goes free” places and match-day experiences for younger supporters that may involve meeting players and having photographs taken. We take the protection of children’s data seriously.

• Accounts and purchases are for adults. Our website and Services are not intended for children to register or buy tickets independently. Tickets, including free child places, must be bought and managed by a parent, guardian or responsible adult.
• Data about children. Where an adult books a child place, we may hold limited information about the child, for example that a child place is attached to a booking and the age band where relevant to eligibility. This data is provided by the responsible adult and used only to administer attendance and the match-day experience.
• Photographs and match-day moments. Where match-day experiences involve photographs of children, these are arranged by the participating club. The club is responsible for obtaining any consents required for taking and using those images. We recommend checking the arrangements and consents with the relevant club.
• We do not knowingly collect personal data directly from a child. If we become aware that we have collected personal data from a child other than through a responsible adult, we will delete it.

If you believe a child’s personal data has been provided to us and should be removed, please use our contact form and we will act promptly.

7. How long we keep your information

We keep your personal data only for as long as necessary to fulfil the purposes we collected it for, including to satisfy legal, accounting, tax or reporting requirements, and to resolve disputes and enforce our agreements.

For example, we generally keep transaction and financial records for at least six years to meet UK tax and accounting obligations. Where you close your account or ask us to delete your data, we may retain certain information where we have an ongoing legitimate business need or legal obligation to do so, such as preventing fraud or complying with legal, reporting or auditing requirements. Where information is no longer required, we will securely delete or anonymise it.

8. International transfers

Some of our service providers are based outside the UK, so their processing of your personal data may involve a transfer outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection by relying on at least one of the following safeguards:

• transferring to countries that the UK Government has deemed to provide an adequate level of protection for personal data;
• using specific contracts, such as the ICO’s International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, that give personal data the same protection it has in the UK; or
• where providers are based in the US, relying on the UK–US Data Bridge or another approved adequacy mechanism.

Stripe may also transfer data outside the UK where necessary to process transactions, protected by approved mechanisms. Please contact us if you would like more detail about the safeguards we use.

9. Your rights

Under UK data protection law, you have a number of rights in relation to your personal data. You have the right to:

• request access to your personal data, sometimes called a data subject access request;
• request correction of inaccurate or incomplete data;
• request erasure of your personal data where there is no good reason for us to keep it;
• object to processing where we rely on legitimate interests, and object to direct marketing at any time;
• request restriction of processing in certain circumstances;
• request the transfer of your personal data to you or a third party; and
• withdraw consent at any time where we rely on consent to process your data.

You can manage, change or delete much of your information through your Spark Sports account settings. To exercise any of these rights, use our contact form. You will not usually have to pay a fee, and we will respond within one month. We will let you know if we need longer and may need to verify your identity before acting on a request.

10. Security

The security of your personal data is important to us. We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All information you provide is stored on secure servers, and payment transactions are handled directly by Stripe using industry-standard encryption. Sports Initiative Ltd does not store or process your payment card information.

No method of transmission over the internet is completely secure, so we cannot guarantee the security of data sent to us. We have procedures to deal with any suspected personal data breach and will notify you and the ICO where we are legally required to do so.

11. Marketing communications

We may contact you with information about Spark Sports, including our events and services and those of selected partners that may be of interest to you, in line with your marketing preferences. All such marketing will come from Spark Sports.

You can ask us to stop sending marketing at any time by using the unsubscribe link in our messages, updating your account settings, or using our contact form. We may still send service-related messages while you hold an account with us, such as ticket purchase confirmations.

12. Clubs, partners and public listings

If you are a club, school, charity or other partner using Spark Sports to promote fixtures or fundraise, some information you provide, such as your organisation’s name and the fixtures or campaigns you promote, may be displayed publicly or shared with supporters and other participants so the platform can work. Please make sure you have the right to share any information you upload and that you handle any personal data you receive through the platform in line with your own data-protection obligations.

13. Third-party links

The website may include links to third-party websites, plug-ins and applications that are not operated by us. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

14. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our practices or for legal reasons. We will post changes on this page and, where changes are material, notify you by email or through a prominent notice on the website before they take effect. We encourage you to review this notice periodically.