SPS Sportsoft
a leading B2B technology company

Introduction

This privacy policy (“Privacy Policy”) describes the way in which SPS Sportsoft Limited collects and processes your personal information data which you provide to us to enable us to manage your relationship with SPS Sportsoft Limited.

This Privacy Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. By accepting this Privacy Policy you agree that you understand and accept the use of your personal information as set out in this Privacy Policy. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Who We are

References in this Privacy Policy to “we”, “us” or “our” relate to SPS Sportsoft Limited, a company registered in England and Wales with (company number 10688793 whose registered office is at 9^th Floor, The Royal Liver Building, Pier Head, Liverpool, L3 1HU. We control the way your personal data is collected and the purposes for which your personal data is used by us, actin as the “data controller” for the purposes of applicable data protection legislation. The website www.spssportsoft.com (“Our Site”) is owned and operated by SPS Sportsoft Limited.

2. Contacting Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your data protection rights, please contact data.protection@sportpesa.com. You may also use this address at any time to withdraw consent to marketing, opt out of SMS marketing or update your marketing preferences. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Scope – what this Privacy Policy covers

This Privacy Policy applies only to your use of our site and SP Score. It does not extend to any websites that are linked to from our site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site.

4. Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: IP address; location; web browser type and version; operating system; a list of URLs starting with a referring site, your activity on our site, and the site you exit to.

SP Score mobile number collection. Where you choose to provide it within SP Score or related services, we collect your mobile number. We collect this when you enter it in SP Score, via in-app forms or settings, through customer support interactions, or when you provide it for participation in loyalty, bonus or mission schemes. Your mobile number is used as a unique identifier to link your SP Score activity with your SportPesa account for the purposes described in this Privacy Policy. Mobile number – where you choose to provide it within SP Score or related services. Your mobile number is used as a unique identifier to link your SP Score activity with your SportPesa account for the purposes described in this Privacy Policy

5. How We use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes: providing and managing your access to our site; personalising and tailoring your experience on our site; supplying our products and services to you; personalising and tailoring our products and services for you; responding to communications from you; market research; analysing your use of our site and gathering feedback to enable us to improve our site and your user experience; ensuring the legality of supplying our services from your location; and where we need to comply with a legal obligation.

Email communications. Where you have subscribed, we may supply you with emails such as newsletters and alerts. You may unsubscribe or opt out at any time by contacting data.protection@sportpesa.com. Supplying you with emails e.g. newsletters, alerts etc. that you have subscribed to by ticking the appropriate box (you may unsubscribe or opt-out at any time by contacting care@sportpesa.com).

Marketing. With your permission and where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on our products. We will not send you unsolicited marketing or spam and will take all reasonable steps to protect your rights and comply with our obligations under applicable legislation. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email; telephone; text message and/or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam.

Use of mobile numbers. We use your mobile number for the following purposes:

1. a) Unique identifier and cross-platform service features (legitimate interests). We use your mobile number as a unique identifier to operate SP Score features that link activity in SP Score with your SportPesa account, including identity matching across platforms to determine whether an SP Score user is also a SportPesa This enables us to provide non‑marketing features such as content, recommendations and service continuity across platforms, fraud prevention, and to support customer service. This processing is carried out on the basis of our legitimate interests in operating and improving our services.
2. b) Personalised marketing by SMS and in‑app (consent). Where you have explicitly opted in, we use your mobile number to send marketing communications by SMS and to deliver personalised campaigns via our marketing personalisation provider. We may create a profile of your interactions across SP Score and SportPesa to tailor marketing content to you. You can withdraw your consent at any time as set out in section 6.
3. c) Loyalty, bonus and mission schemes (legitimate interests). Where you choose to participate in missions, challenges, promotions, loyalty or reward schemes made available through SP Score or related services, we may use your mobile phone number as a unique identifier to link your participation and activity across our services, verify completion of specific actions and allocate rewards. This processing is based on our legitimate interests in operating and fulfilling voluntary reward programmes, preventing misuse and administering rewards.
4. Marketing preferences and opting out

SMS marketing and consent. We will only send you marketing communications by text message where you have explicitly opted in to receive them. You can withdraw your consent and opt out of SMS marketing at any time by replying STOP to an SMS from us or by emailing office@spssportsoft.com. We will action your request promptly. We will only send you marketing communications by text message where you have explicitly opted in to receive them. You may withdraw your consent at any time by contacting office@spssportsoft.com.

Profiling for personalisation. Where you have provided consent to marketing, we may use your mobile number and information about your interactions across SP Score and SportPesa to create a profile and tailor marketing content to you. You may withdraw consent at any time and we will stop such processing for marketing. Where you have provided consent, we may use your mobile number to create a profile of your interactions across SP Score and SportPesa in order to tailor marketing content to you. You may withdraw consent at any time.

7. Disclosure of your personal data

We may share your personal data within our group of companies where this is necessary to provide our Services, support internal administration, compliance and reporting, and improve and secure our systems.

We may also share your personal data with trusted third‑party service providers who act on our documented instructions to help us operate, secure and improve our Services. These service providers act as our processors and are not permitted to use your personal data for their own purposes.

These service providers may include:

• marketing and communications providers (including providers of SMS delivery and marketing personalisation tools);
• analytics and measurement providers;
• customer support and communications providers;
• rewards, loyalty, promotions and gamification providers (including providers used to operate missions, challenges and reward schemes and to verify completion of eligible actions and allocate rewards);
• IT, hosting, security and infrastructure providers.

We may also disclose your personal data where required by law or regulation, to enforce our terms, to protect our rights or the rights of other users, or in connection with a merger, acquisition or restructuring.

8. International transfers

Some of our group companies and service providers may be located outside the UK or may process personal data in countries outside the UK. Where personal data is transferred outside the UK, we ensure a similar level of protection by implementing appropriate safeguards in accordance with UK data protection law, which may include the International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, and supplementary measures where required.

Further details of the safeguards in place are available on request by contacting us using the details in section 2.

9. Data Security

We have implemented appropriate technical and organisational measures designed to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. Measures include access controls based on role and necessity, encryption in transit and at rest where appropriate, secure development and testing practices, network security, and staff training and confidentiality obligations.

Access to your personal data is limited to personnel and providers who have a business need to know and who are subject to duties of confidentiality and instructions. We maintain procedures to detect, investigate and respond to personal data breaches. Where required by law, we will notify you and the applicable regulator without undue delay.

10. Data retention

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to provide our Services, maintain business records, comply with legal, accounting and reporting obligations, and resolve disputes.

In addition to the general criteria above, the following apply to mobile numbers collected in connection with SP Score:

• Marketing and personalisation: we retain your mobile number for marketing only while your consent remains active. If you withdraw consent, we will stop marketing and may retain limited information (for example, on a suppression list) to ensure your preference is respected.
• Rewards, loyalty, bonus and mission schemes: we retain your mobile number for no longer than necessary to verify completion of relevant actions, allocate rewards, address queries or disputes, and meet related legal or audit requirements.
• Cross‑service matching and unique identifier: where your mobile number is used as a unique identifier to operate non‑marketing service features and support fraud prevention or customer service, we retain it for as long as needed to provide those features and then delete it or irreversibly pseudonymise it where feasible.

11. Your legal rights

You have the right to request access to your personal data; request correction of inaccurate or incomplete personal data; request erasure of your personal data where there is no good reason for us to continue processing it; object to processing based on our legitimate interests, including a specific right to object at any time to processing of your personal data for direct marketing (including profiling related to direct marketing); request restriction of processing in certain circumstances; request the transfer of your personal data to you or to another controller in a structured, commonly used and machine-readable format where technically feasible; and withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

These rights may be subject to limitations or restrictions arising from our own legal or regulatory obligations. To exercise any of your rights or to update your marketing preferences, including opting out of SMS marketing, please contact data.protection@sportpesa.com. You can also opt out of SMS marketing at any time by replying STOP to a message from us.

You will not normally have to pay a fee to exercise your rights. We may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded, repetitive or excessive. We may ask you for information to confirm your identity and to help us locate your data. We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made multiple requests, we may take longer and will keep you updated.

12. Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on Our Site, and the updated version will take effect on posting. Your continued use of Our Site or SP Score after the updated Privacy Policy is posted will constitute acceptance of the changes. We encourage you to check this page regularly to stay informed of any updates.

For any questions about this Privacy Policy or our privacy practices, or to exercise your rights, please contact data.protection@sportpesa.com. Our postal address is 9th Floor, The Royal Liver Building, Pier Head, Liverpool, L3 1HU.