Privacy Policy

This privacy notice aims to give you information on how Halfspace Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or request more information. It also explains how we’ll store and handle that data and keep it safe. We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how we use your data.

This website is not intended for children, and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

Halfspace Limited is the controller and responsible for your personal data (collectively referred to as “Halfspace”, “we”, “us” or “our” in this privacy notice).

Halfspace is a full-service growth marketing agency for the sports, entertainment and leisure industries fuelled by best-in-class audience data solutions that can be activated throughout the marketing funnel. Halfspace delivers a data driven end-to-end full service model to provide clients with long-term revenue driving growth solutions implemented by our specialist digital marketing teams. Through our work for our clients and customers we process personal data on their behalf. With respect to such personal data, Halfspace is a “data processor” (“Data Processor”) under the EU General Data Protection Regulation (“GDPR”) and a “service provider” under the California Consumer Privacy Act (“CCPA”). For more information about how we act as a processor on behalf of our clients and customers please see the Halfspace Processor Privacy Notice.

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Halfspace Ltd, a company registered in England and Wales with company number 11272188

Email address: privacy@halfspace.co.uk

Postal address: 1st Floor, 11 Gough Square, London, EC4A 3DE

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.

This Privacy Notice is effective from 22 September 2021. It is reviewed frequently, and historic versions can be obtained by contacting us.

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 (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, last name, username or similar identifiers.
• Contact Data including address, email address and telephone numbers.
• Technical Data including 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, and other technology on the devices you use to access this website.
• Usage Data including information about how you use our website.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Enquire about or apply for our products or services;
  • Contact us via our website;
  • Subscribe to our publications;
  • Request marketing materials to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other technologies. Please see the section “Cookies” in “How and why do we use your personal data” for further information.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from analytics providers such as Google and WordPress based outside the UK.

We will collect, use, store and transfer store your personal data:

• To respond to queries you may submit through the website e.g., when you get in touch for more information or when you sign up for an event.
• To carry out data analytics so that we can better understand your interests and preferences, and so that we can improve our products and services.
• If you fail to provide data when requested, we may not be able to perform our services (or may perform them, but less effectively).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You have the right to opt out of receiving marketing communications from us at any time (see ‘Your data protection rights’ below).

Cookies are small text files that are stored on your computer or other devices when websites are loaded into a browser. They are commonly used to remember you and your preferences, to ensure a consistent browsing experience for visitors and to perform essential functions such as allowing users to remain logged in.

Cookies set by the website owner are called “first party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies are used to provide third-party features or functionality such as videos, social media links or website analytics.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about cookies, please visit https://www.allaboutcookies.org/. If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Explaining the legal bases we rely on

Data protection law sets out a number of different reasons for which a company may collect and process your personal data. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we require consent to process it, for example when processing cookies via this website.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo register you as a new customer

(a) Identity
(b) Contact Performance of a contract with you to manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications(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 to study how customers use our services)To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical(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 To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)To make suggestions and recommendations to you about services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and CommunicationsNecessary for our legitimate interests (to develop our products/services and grow our business)

We sometimes share your personal data with trusted third parties. These are companies that are processing the data collected on our behalf and therefore have to adhere to the same strict guidelines and rules in relation to your personal data. We work closely with them to ensure that your privacy is respected and protected at all times.

These third parties include:

• Social media sites including LinkedIn
• Website feature and functionality providers Video players including YouTube
• Customer relationship platforms including ESB Connect
• Website analytics and hosting including WordPress https://en-gb.wordpress.org/about/privacy/ and Colibri https://colibriwp.com/privacy-policy/

At the time of writing, the only platform which may place cookies on your device is WordPress.

If you are a customer of ours we may share your Identity and Contact Data with:

• Our business partners:
  • Lotame https://www.lotame.com/about-lotame/privacy/
    • Lotame provides data enrichment and management solutions via its platforms and technologies. We use Lotame to commercialise our customers first-party data on their behalf via Lotame’s data management platform and marketplace.
  • ESB Connect http://www.esbconnect.com/business-data-privacy-policy/
    • ESB Connect enables our customers to commercialise their CRM data.
  • Tradespotting https://tradespotting.com/en/946-2/
    • Tradespotting uses various AdTech platforms such as SSP (supply-side platforms), DSP (demand-side platforms) and social media platforms to buy advertising on behalf of Halfspace clients.
• Where legally required we may share your personal data with:
• Our professional advisers, such as lawyers and accountants
• Government, police forces and/or regulatory authorities
• As part of actual or potential business sale of Halfspace or its assets, to prevent suspected fraud, to respond to claims asserted against us or to comply with legal processes such as court order

Sometimes we will need to share your personal data with third-party data processors and parties outside the UK and European Economic Area (EEA). Where your data is processed outside the UK or EEA, we will ensure that appropriate data transfer mechanisms are in place to protect that transfer.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You have the right to:

• Be clearly informed about how we use your personal data (the right to be informed)
• Ask for a copy of personal data that we hold about you (the right of access)
• Ask us to update and amend any incorrect, out-of-date or incomplete personal data that we hold about you (the right of rectification)
• Request, in certain circumstances, that we delete personal data held on you (the right of erasure or to be forgotten)
• Ask us to ‘restrict processing of data’, in certain circumstances (the right to restrict processing)
• Ask us to supply you with the personal data we hold about you in a structured machine-readable format (where technically possible) and/or to provide a copy of the data in such a format to another organisation (the right to data portability)
• Opt out of any marketing communications, withdraw your consent to us collecting and processing your data and object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object)

If you wish to exercise any of the above rights, please contact us using our contact details below.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the United Kingdom using their website https://ico.org.uk/.

The customers and clients which Halfspace works with may use your data to tailor advertising. This process is also known as personalised or interest-based advertising.

You can opt out of this type of advertising by:

• Controlling cookies via the CMP (consent management platform) of a site or app you use.
• Altering settings in your browser so that you don’t accept cookies.
• You can find out more at www.youronlinechoices.com/uk/your-ad-choices and www.allaboutcookies.org.
• There are also advertising alliances that enable you to opt-out of the collection of data for interest-based advertising and other purposes: for companies participating in the Digital Advertising Alliance Consumer Choice Page at www.aboutads.info/choices and for members of the Network Advertising Initiative via www.networkadvertising.org/choices

Further if you wish to opt-out of our partners processing your data you can contact them via these links:

• Lotame https://www.lotame.com/about-lotame/privacy/privacy-manager-opt-out/
• ESB Connect http://www.opt-me-in.com/privacy-policy/
• Tradespotting hello@tradespotting.com (by email)

We hope this Privacy Notice has been helpful in clarifying the way we handle your personal data and your rights to control it. However, we realise that it is a lot of information to digest.

If you have any questions, please contact us at privacy@Halfspace.co.uk

This Privacy Notice was last updated on 07 January 2023