WHO ARE WE?
Two Circles is a sports marketing agency registered in the UK as Two Circles Limited (registered number 07753583, of Suite 1, 3rd Floor 11-12 St. James’s Square, London, United Kingdom, SW1Y 4LB).
THE PURPOSES OF PROCESSING
Two Circles processes the following categories of personal data for the purposes defined in the table:
| Purpose | Category | Lawful Bases | Retention |
| Capturing contact details for emailing survey | Email address, Name | Consent | Three (3) Months following emailing of the survey |
| Capturing and hosting survey responses | Email address, Name, Purchase history, IP address, Sex, Health, Economic Status | Consent | Three (3) Months following emailing of the survey |
| Aggregating and anonymising survey responses | Email address, Name, Purchase history, IP address, Sex, Health, Economic Status | Legitimate Interest | N/A |
| Administering prize draw | Email address, Name | Consent | Twenty-eight (28) days following the conclusion of the prize draw |
| Retention of the prize draw winner’s details & announcing or otherwise sharing the prize draw winner’s details | Email Address, Name, County of residence | Consent, Legal Obligation | Twelve (12) months following the conclusion of the prize draw |
THE LEGITIMATE INTEREST FOR PROCESSING
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or those of a third party, for the following purposes:
- To carry out analytics for the purpose of informing our marketing and consultancy strategy
- To share personal data with other Two Circles’ companies to support our legitimate interests (strictly not for resale or marketing purposes)
RECIPIENTS OF THE PERSONAL DATA
| Recipient | Service | Location of Processing | Transfer Mechanism |
| Alchemer | Survey Tool | USA | Standard Contractual Clauses and UK Addendum |
| Microsoft | Office applications, document storage and internal communications | UK | N/A |
| Promo-Staff Group | Onsite staff | Canada | Adequacy Decision |
| Other Two Circles entities | Administrative Support | UK, EEA, USA & Australia | Standard Contractual Clauses and UK Addendum |
THIRD COUNTRY TRANSFERS
We may share your personal data within the Two Circles group of companies and with our processors. This will involve transferring your data outside of the UK. Where third country transfers take place, we ensure an appropriate transfer mechanism is used to legitimise those transfers in accordance with the UK GDPR.
DATA PROTECTION RIGHTS
You have various rights under the UK GDPR which entitle you, in certain circumstances and depending on the Privacy Laws which apply to you and us, to:
- ask us for a copy of the personal data we hold about you;
- correct or update your personal data, which you can do yourself by logging into your account (if relevant) or if you would prefer, please contact us and we can assist;
- request that we delete your personal data;
- object to the handling of your personal data where we are relying on a legitimate interest (as set out in the above table);
- restrict the processing of your personal data;
- request the transfer of your personal data (or some of it) to a third-party service provider; or
- where you have provided your consent for something, in certain circumstances, you may withdraw this consent (but note that we may continue to use your personal data if we have legal grounds for doing so).
Please contact us using the details set out below if you would like to exercise your rights. You can find out more about your rights on the ICO website.
RIGHT TO LODGE COMPLAINT WITH THE DATA PROTECTION AUTHORITY
If you are concerned about the way we are handling your personal information you may also contact your local data protection authority (for example, if you are based in the UK, this is the Information Commissioner’s Office, but if you are based in the EEA please refer to the European Data Protection Board website for details of your local authority). However, where possible, we would really appreciate the opportunity to help with your concern in the first instance.
CONTACT US
If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at the following address: Data Protection Officer, Two Circles, Suite 1, 7th Floor 50 Broadway, London, United Kingdom, SW1H 0BL, or by email at dpo@twocircles.com.
GET IN Touch
