London Spirit (The Hundred) Limited (**we, us, our**) takes your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about what to expect when we collect personal information about you, including how we will use your personal information and the steps that we take to ensure that it is kept secure. We are responsible as ‘controller’ of personal information for the purposes of those laws. We collect and process your personal data when you visit our website at [**www.londonspirit.com**](http://www.londonspirit.com) or our retail store at [**store.londonspirit.com**](http://store.londonspirit.com) (**Platforms**) or when you buy tickets from our Ticket Shop at [**https://tickets.londonspirit.com**](https://tickets.londonspirit.com/) (**Ticket Shop**) or provide the information requested on a form, including via our social media platforms, or sign up for a newsletter or enter a competition or request more information about or purchase of a product or service. We operate two types of user accounts when you create an account with us on our Platform/s: Junior Accounts (for users under 13, requiring verified parental or guardian consent) and Full Accounts (for users aged 13 or over). This Privacy Notice explains how we collect and use personal data for each account type. Personal data means any information that identifies you or could reasonably be used to identify you, either alone or in combination with other information. This Privacy Notice is intended for those aged 13 years and older. For anyone under the age of 13, it is intended that parents and/or guardians read and explain it to their children. ### **Who are we?** We are a professional cricket franchise competing in *The Hundred*, England’s 100-ball cricket competition. Established in 2019, our home ground is Lord’s Ground. We field both men’s and women’s teams and are committed to delivering exciting sporting experiences while respecting and protecting your privacy. ### **What data do we collect about you?** We may collect, use, store and transfer different kinds of personal data about you as follows: **Identity Data** first name, last name, any previous names, username or similar identifier, marital status, title, date of birth (which we use to determine whether you require a Junior Account or a Full Account) and gender. **Contact Data** billing address, delivery address, email address and telephone numbers. **Financial Data** bank account and payment card details. **Transaction Data** details about payments to and from you and other details of products and services you have purchased from us. **Technical Data** internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our Platform(s). **Profile Data** your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. **Usage Data** information about how you interact with and use our Platform(s), products and services; and **Marketing and Communications Data** your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect aggregated, anonymised data for analytics purposes. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific platform feature in order to analyse general trends in how users are interacting with our platform to help improve the Platform and our service offering. ### **How is your personal data collected?** We use different methods to collect data from and about you including through: **Your interactions with us** you may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, via our social media or otherwise. This includes personal data you provide when you: (a) apply for/request/purchase our products or services; (b) create an account on our Platform(s); (c) subscribe to our services or publications; (d) request marketing to be sent to you; (e) enter a competition, promotion or survey; or (f) give us feedback or contact us. **Automated technologies or interactions** As you interact with our Platform(s), we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our [**Cookie Policy**](https://www.londonspirit.com/cookie-policy-london-spirit) for further details. **Third parties or publicly available sources** We will receive personal data about you from various third parties such as analytics providers (e.g. google), payment processors, and publicly available sources e.g. Companies House and the Electoral Register. Marketing and Communications Data is collected from the ECB with your consent. This may include marketing preferences you provide when registering for an ECB Single Sign‑On account via [The Hundred](https://www.thehundred.com/) website **Children** We appreciate that many children are cricket fans and we are committed to protecting their privacy and compliance with applicable data protection laws. ***Junior Accounts (under 13)*** Children under the age of 13 may only access our Platform(s) through a Junior Account, which requires: (a) the child's date of birth; and (b) the contact details of their parent or legal guardian that we can obtain and verify consent before activating the account. We will not activate a Junior Account until parental or guardian consent has been verified. Parents or legal guardians must supervise children under 13 when they are online. We may contact parents or guardians: (a) to verify consent; (b) to respond to requests relating to the child's data; and (c) if we have concerns about a child's safety or privacy. Parents or guardians may request access to, correction of, or deletion of their child's personal data at any time. We do not: (a) send direct marketing to children under 13; and (b) share children's personal data with third parties for marketing purposes; and (c) use children's data for profiling or behavioural advertising. ### **How we use your personal data** **Legal basis** The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases: **Performance of a contract with you** Where we need to perform the contract we are about to enter into or have entered into with you. **Legitimate interests** We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). **Legal obligation** We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis. **Consent** We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. ### **Purposes for which we will use your personal data** We will only use your personal data for the purpose for which we collected it which includes the following: ##### **1. To register you as a new fan or customer** **Type of data** (a) Identity (b) Contact **Legal basis** Performance of a contract with you ##### **2. To process and deliver your order including:** (a) Manage payments, fees and charges (b) Collect and recover money owed to us **Type of data** (a) Identity (b) Contact (c) Financial (d) Transaction **Legal basis** (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) ##### **3. To manage our relationship with you which will include:** (a) Notifying you about changes to our terms or privacy notice (b) Dealing with your requests, complaints and queries **Type of data**
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications **Legal basis** (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) (d) Consent ##### **4. To enable you to partake in a prize draw, competition or complete a survey** **Type of data** (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications **Legal basis** (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Consent ##### **5. To administer and protect our business and our Platform(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)** **Type of data** (a) Identity (b) Contact (c) Technical **Legal basis** (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation ##### **6. To deliver relevant Platform content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you** **Type of data** (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical **Legal basis** (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent ##### **7. To use data analytics to improve our Platform(s), products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing** **Type of data** (a) Technical (b) Usage **Legal basis** Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform(s) updated and relevant, to develop our business and to inform our marketing strategy) ##### **8. To send you relevant marketing communications** **Type of data** (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications **Legal basis** (a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) (b) Consent, having obtained your prior consent to receiving direct marketing communications ##### **9. To carry out market research through your voluntary participation in surveys** **Legal basis** Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). ##### **10. To determine whether a Junior Account or Full Account is required and to manage parental or guardian consent** (a) Identity (b) Contact (c) Technical **Legal basis** (a) Necessary to comply with a legal obligation (b) Consent (for Junior Accounts) (c) Necessary for our legitimate interests (to ensure age-appropriate access and comply with child-protection requirements) ### **Direct marketing** During the registration process on our Platform(s) when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email, SMS, telephone or post or you will receive marketing communications from us if you have requested information from us or purchased goods or services from us, including via our Ticket Shop, and you have not opted out of receiving the marketing. We do not send direct marketing communications to users with Junior Accounts. You may also receive marketing communications from us if you have given your explicit consent to a third party - such as the ECB or MCC - to share your personal data with us for direct marketing purposes. ### **Third-party marketing** We will get your express consent before we share your personal data with any third party for their own direct marketing purposes e.g. ECB or MCC. ### **Opting out of marketing** If you would rather not receive marketing information from us or any other third party to whom we may disclose your personal information, please contact us (see the section **How to contact us below**) or modify your preferences via the preference centre within your account or unsubscribe. If you agree to us providing you with marketing information or news, you can always unsubscribe at a later date. You are in control of what you receive. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product or service, updates to our Terms and Conditions, or checking that your contact details are correct. ### **Cookies** We use cookies for analytics, personalisation, and advertising. See our [**Cookie Policy**](https://www.londonspirit.com/cookie-policy-london-spirit) for details and to manage your preferences. ### **Automated Decision Making** **We only use automated decision making in limited cases:** **Competitions:** entrants’ details may be stored and a winner chosen automatically at random. We do not carry out profiling or other automated decisions that have a significant effect on you. ### **How we share your personal data** We share your data only for specific purposes and with appropriate safeguards. **With your marketing consent** (a) with selected partners whose offers may interest you (b) with the ECB (c) with MCC Those parties may contact you directly if you have opted in. **To deliver our services** (d) We use third‑party suppliers (including but not limited Platform hosting, providers who support our ticketing, payment and customer service systems, mailing and analytics) who process data only on our instruction (e) We contractually require these suppliers to protect your data and use it only to provide services to you or us **For legal, regulatory or governance reasons** (f) We may disclose data to comply with legal obligations, to our professional advisers, auditors, insurers, government bodies, law enforcement, or sport governing bodies when necessary ### **International transfers** We may transfer data outside the UK when needed to provide services (e.g., supplier location, your location, or cross‑border services). In such circumstances, we put appropriate protections in place to keep your data secure and compliant with data protection law. ### **How do we protect information?** We use technical and organisational measures to protect your data and restrict access to those who need it. We have procedures to detect and respond to data breaches and will notify you and regulators when required by law. ### **Data retention** We keep personal data only as long as needed for the purpose collected, including to meet legal, compliance or reporting obligations. We may keep data longer where there is an active complaint or potential litigation. We may anonymise data for research or statistical use and keep anonymised data indefinitely. ### **Your rights** As a data subject, you have a number of rights:

RIGHT	DESCRIPTION
Right of access	the right to see what information we hold about you i.e. a Data Subject Access Request;
Right to be informed	the right to know how your information is being collected and used for example, in this Privacy Notice;
Right to data portability	you can ask to receive your information in a format that lets you move it to another organisation;
Right to erasure / right to be forgotten	in some cases, you can ask us to delete your information, for example, if you withdraw your consent or we no longer need it;
Right to object	you have the right to object to the processing of your information in certain circumstances, for example, for direct marketing;
Right to rectification	if your information is wrong or incomplete, you can ask us to correct or update it;
Right to restrict processing	you can ask us to limit how we use your information, for example, while we are checking if it is accurate; and
Rights related to automated decision-making including profiling	you have rights if decisions are being made about you automatically (without human involvement), especially if it affects you significantly.

**(a)** **No fee usually required** We usually do not charge for requests. We may charge or refuse requests that are manifestly unfounded, repetitive or excessive. **(b)** **What we may need from you** We may ask for proof of identity and additional information to process your request. **(c)** **Time limit to respond** We aim to respond within one month and will tell you if we need more time. **(d) Junior Accounts** For Junior Accounts, parents or legal guardians may exercise data protection rights on behalf of their child. ### **How to contact us** If you would like to exercise any of your rights, please contact [compliance@londonspirit.com](mailto:compliance@londonspirit.com). However, please be aware that these rights are not absolute and may be subject to lawful exceptions and limitations. If you believe that we have not complied with your data protection rights or if you have a complaint, please contact [compliance@londonspirit.com](mailto:compliance@londonspirit.com). We hope they can resolve any query or concern you raise about our use of your information. If not, please contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint. ### **Third-party links** Our Platform(s) may include links to third‑party sites. We are not responsible for their privacy practices therefore we recommend that read their privacy notices. ### **Review** We keep our Privacy Notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address. **Updated as at 26 January 2026.**

Privacy Notice

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