PITCHSIDE HOSPITALITY LIIMITED PRIVACY POLICY

1. Introduction

At Pitchside Hospitality Limited (“PITCHSIDE”), we take your privacy seriously. PITCHSIDE is committed to protecting the privacy of: our clients, users of our website and individuals who attend PITCHSIDE’s sporting or corporate events, fundraising auctions, golf days, gala dinners, attend or participate in experiences and any other individuals we interact with from time to time.

This Privacy Policy states our policy and practices regarding the collection and use of personal data, including helping ensure that we provide a safe and secure user experience on our websites. We will ensure that the information you submit to us, or which we collect, via various channels (including our websites, through written correspondence (including e-mail), or through any of our offline locations), is only used for the purposes set out in this Privacy Policy.

Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the personal data is handled. We also aim to satisfy our obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and the national laws implementing GDPR.

For the purpose of this Privacy Policy the controller of personal data is PITCHSIDE and our contact details are set out in the ‘Contact Us’ section at the end of this Privacy Policy. When we refer to PITCHSIDE, "we", "us" or "our" we are referring to PITCHSIDE Group Limited and the other companies in our group. Currently, the companies in our group of companies are located in the United Kingdom and includes PITCHSIDE Partners Limited and Pitch International LLP.

2. The Information we collect

In general, you can visit the PITCHSIDE website without identifying yourself or revealing any personal information. However, you may choose to provide us with personal data (e.g. via our Contact Us page, or when you opt-in to receive our marketing communications or take part in an auction). Personal data is information that can be used to identify you, such as your name, title, email address, telephone number, industry and company details or similar information.

When you register for or attend our events or participate in our auctions or experiences, PITCHSIDE will ask you to provide: basic contact information and information on your participation in the events. PITCHSIDE may also ask you to provide billing information or a photograph or identification if you require accreditation to enter specific venues.

In addition to the above, if we are booking any travel and/or accommodation for you, PITCHSIDE may ask you to provide identification documentation (usually your passport) and airmiles or hotel loyalty scheme details.

3. How we use your Personal Data

You can be assured that any personal data you provide voluntarily will only be used in connection with your business relationship with PITCHSIDE. We will hold, use and disclose your personal data for our legitimate business purposesincluding:

· to provide the services we perform for you;

· to better understand your needs and to provide better service;

· to answer your questions and deal with your requests;

· to plan, organise and host sporting and corporate events and experiences;

· from time to time, we may also, with your consent, use your information to contact you for market research or to provide you with marketing information we think would be of particular interest. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact. You can do this by following the unsubscribe links on any marketing message sent to you or by contacting us at any time (via the contact details set out in the ‘Contact Us’ section at the end of this Privacy Policy).

PITCHSIDE uses credit card numbers only for payment processing and are not retained for other purposes. PITCHSIDE uses passport information only for booking travel and/or accommodation and is not retained for other purposes.

PITCHSIDE may receive information about you from other third parties and combine this information with information we already have about you. This helps us to better understand your needs and to provide a better service.

We will not use or share the personal data provided to us in ways unrelated to the uses described in this statement. More information about how we may share your information can be found at section 5.

4. The Legal Basis for Processing your Personal Information

Under GDPR, the main grounds that we rely upon in order to process your personal data are the following:

(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;

(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

(c) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website, our market research, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner; and

(d) Consent– in some circumstances, we may ask for your consent to process your personal data in a particular way.

5. How we share your Personal Information

We may disclose your personal data with other parties. Details of those parties are set out below along with the reasons for sharing it.

i. Other Companies within our Group within the EEA

When you disclose your personal data to us we may share it with other companies in our Group of companies in the European Economic Area ("EEA"). We apply equal rigour to the security of data held and processed across the Group and the whole of our network.

We will share your personal information as above for any or all of the following purposes:

• To work with other PITCHSIDE partners and affiliates within our Group of companies
• Customer support
• Marketing
• Technical operations
• Account management purposes

ii. Third Parties

We will share your personal data with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:

· Enhancing business contact information

· Managing our IT operations

· Facilitating joint-marketing efforts

· Organising any corporate or sporting event you attend

· Arranging your travel, accommodation and/or hospitality

· Arranging accreditation at certain venues

Such third parties as referenced in paragraph ii. may include:

· Providers of IT infrastructure, digital support and data centre management to help us to protect the security of your information, ensure our online services remain fit for purpose and perform systems testing;

· Telephone services providers for communication;

· External auditors to independently assess us;

· Offsite data storage facilities, for efficient data management and security; and

· Travel agencies, hotels, venues and sports organisations (or their third-party suppliers) for the purpose of arranging your travel, accommodation and attendance at certain events.

We may pass aggregated information to third parties about how our users use our services but this will not include information which could be used by them to identify you. For further information see Section 8 below.

We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal data is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, including entering into the Standard Contractual Clauses as approved by the European Commission.

We will not share your sensitive personal information with any third parties without your consent.

iii. Regulatory and Law Enforcement Agencies

We may disclose your personal data if required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal data to such bodies or agencies. This may include fraud prevention agencies to help us to prevent and detect financial crime and fraud.

iv. New business owners

If we or our business merges with or is acquired by, or acquires another business or company, we may share your personal data with the (new) owners of the business or company and their advisors.

6. How long we will hold your information

We will retain your personal data for the time necessary to provide the services we perform for you or stated by the purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal data. The next section sets out more information on your rights.

7. Your rights in relation to the information we hold about you

You have certain rights in relation to the personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request. If you wish to exercise any of these rights, please contact us using the contact details below.

Right of Access

You have the right at any time to ask us for a copy of the personal data that we hold about you. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal data, or certain elements of the request.

Right of Correction or Completion

If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.

Right of Erasure

In certain circumstances, you have the right to request that personal data we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal data. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes.

You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.

The above right exists only in respect of personal data that:

· you have provided to us previously; and

· is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

Consent

To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

You can exercise any of the above rights by contacting us at privacy@pitchinternational.com.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

8. Aggregate Information about PITCHSIDE online visitors

We gather information and statistics collectively about all visitors to our website, for example:

· which area users access most frequently

· the type of operating system and browser software

· the geographical location of browsers

· broad demographic information.

We only use such data in the aggregate form and our analytical services do not record any personal data. The information and statistics we collect helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users. Such data may be shared with third parties, such as advertisers, however the underlying data is not shared with anybody else.

9. Use of Cookies

We use “cookies” and other similar technologies to help provide you with a better, more personalised user experience. A cookie is a string of information that a website stores on a visitor’s device or computer, and that the visitor’s browser provides to the website each time the visitor returns. We use these technologies to help us understand and improve how visitors use our website. The two types of cookies we use are known as "session" cookies and "persistent" cookies. These may be cookies which we use and/or a third party uses.

Session cookie: A session cookie would include, for example, session ID, user browser/platform and support service contact time. A session cookie is used each time you visit our website to give you a session ID. We use this type of cookie to link your actions on our website and each session cookie will only last for a browser session, at the end of which it will expire. Each browser session will start when you open your browser window and finish when you close your browser window. After your visit all session cookies are deleted. Each time you visit our website you will have a different session ID.

Persistent cookie: A persistent cookie allows the preferences or actions of the user across a website (or across different websites) to be remembered (such as for example your language preferences). It has a longer lifetime than a session cookie and lasts for the period of time specified in the cookie (this will vary from cookie to cookie). This type of cookie will not be deleted when you close your browser window and will be stored on your device. It will be activated every time you visit the website or application which created that particular persistent cookie.

The cookies we use fall into the following categories:

Strictly necessary cookie: These cookies are essential to our online services in order to enable you to move around our website and applications and to use features, such as remembering information you have entered on forms when you move to other pages within a browser session. Without strictly necessary cookies, certain services which you have asked for will not be made possible and our online services will not perform as smoothly as we think you would expect. Accepting strictly necessary cookies is a condition of using our online services. If you reject these cookies, then we cannot predict how our service will perform when you visit it nor guarantee your security.

Performance cookie: Performance cookies collect information about your use of our website and enable us to improve the way they work. For example, performance cookies will show us which are the most frequently visited pages on our website, help us record any difficulties you have and show us whether our advertising is effective or not (but note that performance cookies do not collect information to display targeted advertising on other websites). Performance cookies do not collect information that identifies you personally and all information that is collected by these cookies is aggregated and anonymous. In some cases, we may use third parties to manage our performance cookies, but we do not allow any third party to use these cookies other than for the types of purpose listed in this paragraph. For example, they do not remember information about you for the purposes of targeting adverts at you on other websites.

Accepting performance cookies is a condition of using our online services. If you reject these cookies, then we cannot predict how our service will perform when you visit it nor guarantee your security.

Functionality cookie: Functionality cookies allow us to remember the choices you make on our website and to provide enhanced and more personal features. We also use functionality cookies to remember changes you have made, such as customising a certain webpage, remembering if we have asked you to participate in a promotion and for other services you request such as watching a video or commenting on a blog. All of these features help us to improve your visit to our online services. Our functionality cookies will not track your activity on other websites. In some cases, we may use third parties to manage our functionality cookies, but we do not allow any third party to use these cookies other than for the types of purposes listed in this paragraph. For example, they do not remember information about you for the purposes of targeting adverts at you on other websites.

You can control our use of functionality cookies. If you prevent the use of functionality cookies then this may mean that we cannot offer some services and may interrupt your enjoyment of it (for example, we may not be able to record your request not to offer you a particular type of service). This may also mean we are limited in the scope of support we can offer you.

Third party cookies: Third party advertisers and other organisations (including social media services) may use their own cookies or other technologies to collect information about the content of our online services and/or the advertisements you have clicked on. Third party advertisers may also use this information to measure the effectiveness of their advertisements. We would not have access or control over the cookies placed by third parties and use of their cookies is subject to their own privacy policies. We recommend that you review the privacy policies of any third parties that have a presence on our website.

Cookies placed by third parties may serve different purposes. They may be strictly necessary, performance, functionality, targeting or advertising cookies. To disable or reject third party cookies you must go to the relevant third party’s website.

Managing cookies

By law the default setting on your web browser is to prohibit cookies, but you may have changed this during the installation process. If you are unsure of your cookie settings, we recommend visiting the website www.aboutcookies.org. This site gives detailed guidance on how to control and delete cookies. Most browsers will allow you to opt-in to different categories of cookie. In particular, the Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable or delete cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer.

10. Complaints

If you are unhappy about our use of your personal data, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with your local supervisory authority.

11. Security

We have put in place measures to ensure the security of the information we collect and store about you and will use our reasonable endeavours to protect your personal data from unauthorised disclosure and/or access including through the use of network and database security measures, but these cannot guarantee the security of any data which is collected and stored. We use encryption when collecting or transferring sensitive data, such as credit card information.

12. Other websites

Please note that clicking on links on our websites may result in your browser accessing a third-party website, where data privacy practices are different to that of PITCHSIDE. We are not responsible for, and have no control over, information that is submitted to or collected by these third parties and you should consult their privacy policies.

13. Internet based transfers

Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

14. Changes to our Privacy Policy

Our Privacy Policy is subject to change from time to time and, if we update it, we will post these changes on this page so that you will be aware of how we use your personal data.

15. Contact Us

If you have any enquires or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact: Kirsty Stewart (also referred to as the GDPR Lead)

Email: kirsty.stewart@pitchsidehospitality.com