PRIVACY POLICY
Effective: July 1st, 2025
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 CATEGORIES OF PERSONAL INFORMATION WE COLLECT, THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION, AND HOW LONG WE RETAIN IT
Two Circles collects the following categories of personal data for the purposes defined in the table:
| Purpose | Category | Retention |
| Capturing contact details for emailing survey | Email address, Name | Three (3) Months following emailing of the survey |
| Capturing and hosting survey responses | Email address, Name, IP address, Sex, Age, Economic Status, Nationality | Three (3) Months following emailing of the survey |
| Aggregating and anonymising survey responses | Email address, Name, Sex, Age, Economic Status, Nationality | N/A |
| Administering prize draw | Email address, Name | 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 | Twelve (12) months following the conclusion of the prize draw |
We also 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)
SHARING OR DISCLOSURE OF PERSONAL INFORMATION
| Recipient | Service | Location of Processing | |
| Alchemer | Survey Tool | USA | |
| Microsoft | Office applications, document storage and internal communications | UK | |
| Other Two Circles entities | Administrative Support | UK, EEA, USA & Australia |
We also may disclose information collected from and about you as follows: (1) with vendors, consultants, contractors and other service providers who carry out work on our behalf and improve the products and services they provide to us; (2) as necessary if we believe that there has been a violation of our rights or the rights of any third party; (3) to respond to legal process (such as a search warrant, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; (4) in the event that our business or substantially all of its assets are acquired, your personal information may be one of the transferred assets; and (5) with your consent or at your direction.
CHILDREN
The survey is not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.
TENNESSEE PRIVACY RIGHTS
If you are a Tennessee resident, Tennessee law provides you with the following rights with respect to your personal information:
- The right to know what personal information we are processing about you and the right to access that personal information.
- The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing.
- The right to request that we delete any personal information we have collected about you.
- The right to opt out of the selling of your personal information.
- The right to opt out of targeted advertising or profiling.
- The right to appeal if we decline to act regarding your privacy request. To do so, please follow the instructions for exercising your privacy rights below, or use the contact information provided in this Policy. We will respond to appeals from Tennessee residents within 60 days.
To submit any of the above requests, you may contact us at dpo@twocircles.com. You may also designate an authorized agent to make a request your behalf. When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide your email address. We may also use a third party verification provider to verify your identity. We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under the Tennessee Information Protection Act. Please note that we are only required to honor requests to know twice in a 12-month period.
We do not discriminate against Tennessee residents who exercise any of their rights described in our privacy policy. The fact that you have elected to exercise these rights will have no adverse effect on the price and quality of our products or services.
In addition, in the last 12 months, we have not sold any personal information about you or processed any personal information about your for targeted advertising.
CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Site. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.
CONTACT US
If you have any questions about this Privacy Policy, 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.
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