WHO ARE WE?
Two Circles (Two Circles Limited) is a sports marketing agency and is a part of the WPP group within GroupM. In all territories excluding North America, the legal entity responsible for data is Two Circles Limited. In North America, the responsible local entity is Two Circles Incorporated.
This notice outlines how and why Two Circles collects and uses personal data specifically from visits to the twocircles.com and insidetwocircles.com websites and explains your rights in relation to this data.
WHAT INFORMATION IS COLLECTED AND USED BY TWO CIRCLES?
We collect information that enables us to identify your browser and device and tell us which pages within our Website you visit and on which pages you spend the most time. We do this by using the following:
“Cookie” is a small alphanumeric text file that we automatically assign to visitors to our website. It is stored in your browser and allows us to identify you.
Sometimes a cookie resides on your device for just the single time you’re visiting our Website; this is called a session cookie. Sometimes a cookie remains on your device until you delete it or it expires automatically; this is called a persistent cookie. Both types of cookies are used on our Website.
“IP address” means Internet protocol address
“Pixel” is a line of code that sits within our webpages and which we use to record that you have visited a particular page within our website.
We use some, or all, of this information to improve your website experience by delivering content that you are likely to prefer on future visits. Our lawful basis for this type of processing is that we have a legitimate interest in understanding and improving your experience of our Website.
If you don’t agree to us using cookies and the above information, you may prevent their use through your browser settings. By choosing not to accept cookies, certain Website features may not work as we have intended.
SPECIFIC COOKIE TYPES USED BY TWO CIRCLES
Google Analytics (persistent)
Google Analytics (session)
This cookie may appear as has_js. We do not retain this data as it is deleted upon closing of your browser, and therefore we cannot share it with any third parties.
COLLECTION AND USE OF CONTACT INFORMATION
There are a few instances where we may collect your name and contact details (such as e-mail address, telephone number and postal address). But, we won’t collect this information without consent (including by submitting such information to Two Circles via the contact us page on our website) and never use it in online advertising placement. Examples where you might voluntarily provide your name and contact details include:
Responding to requests: we keep a record of information, including email address and other contact information, solely for responding to a user’s request. For example:
– If you click on the “contact us” link and submit a question or comment, we will collect your name, e-mail address, and phone number to send you a reply.
– If you voluntarily ask to be added to our newsletter list, we will collect your e-mail address to send you our email newsletter.
By entering your contact information as noted above you are consenting to Two Circles using that information to contact you regarding your request. This consent is our legal basis for using the information in this way.
If at any time you decide to withdraw your consent and like would us to remove you from our marketing e-mails or newsletters, or to unsubscribe from our database, you can contact us using the details provided at the bottom of this Privacy Notice. You must include your name, e-mail address, and clear instructions regarding changes you are requesting. You may also unsubscribe from e-mail newsletters by clicking on the “unsubscribe” link found at the bottom of the e-mail.
Two Circles is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you visit our Website or provide us with contact information.
Does Two Circles share any information with other vendors or partners? We may provide access to information we collect to our vendors and contractors (also known as third parties) who are performing services on our behalf to enable the uses of your information that we have described above. These vendors are not permitted to use this information for any other purpose. Additionally, we must disclose information when we believe we’re legally obliged to, or in order to investigate, prevent, or take action regarding prohibited activities, such as incidents of hacking, misuse, or other prohibited activities. Any links to third party websites (including social sites) will transfer users to these third party sites where separate privacy policies apply to the collect and use of personal data and users should always review these separately.
Does Two Circles transfer your Personal Data outside the European Union? If you provide us with personal data, we may transfer that personal data to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world to enable us to use that personal data as described above. Our standard practice is to use European Union model clauses for the transfer of data from the EEA & Switzerland to other non-EEA countries.
Data retention and storage: We will keep your information that we collect on the Website for a reasonable period for the purposes set out above. We follow generally accepted industry standards to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use.
CHANGES TO THIS PRIVACY NOTICE
Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).
HOW TO 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: Two Circles, 15 St John Street, London EC1M 4AA, United Kingdom, or by email at firstname.lastname@example.org.