INTRODUCTION

Genius Sports Group is committed to protecting your privacy. This privacy policy explains how Genius Sports Limited and the companies in its corporate group (“Genius Sports”, “we”, “us” or “our”) use your personal data (or personally identifiable information) when you visit our website (www.genius sports.com) and any of its sub-domains (investors.geniussports.com and news.geniussports.com). It also advises you of your rights as a data subject and how those rights may be exercised. We will ensure that any information that we collect or that you submit to us through the website will be used only for the purposes set out in this policy.

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

We keep our privacy practices under review and may amend this policy from time to time. This version is dated March 2022.

ABOUT US

Genius Sports provides data, technology and media services for the sports, betting and entertainment industries. This privacy policy is issued on behalf of the Genius Sports group of companies. When we mention “Genius Sports”, “we”, “us” or “our” in this policy, we are referring to the company in the Genius Sports Group that is relevant for processing your personal data.

Genius Sports Group Limited is the data controller responsible for this website and for processing personal data collected via the website. It is a company registered with Companies House in England and Wales under company number 09706742 and with the Information Commissioner’s Office under registration number ZA198905.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, then please contact the DPO using the contact details given at the end of this policy.

PERSONAL DATA WE COLLECT

Broadly speaking, your personal data is any information about you from which you may be directly or indirectly identified. The personal data we collect about you via our website will depend on the nature of your interaction(s) with us. However, we will only collect personal data that is reasonably necessary to fulfil the purpose for which it’s being collected (for example, to respond to your enquiry or to allow you to apply for a job with us). 

If you are …

We might collect …

A subscriber to our marketing list

 

 

·       Contact details, including full name, company name, email address and telephone number.

·       Information that enables us to provide you with relevant content. This might include your job title, business region and marketing preferences.

An enquirer via our “contact us” form

·       Contact details, including full name, company name, email address, telephone number and location.

·       Details of enquiry.

A job applicant

·       Contact details, including full name, gender, email address and telephone number.

·       Professional background information, including CV/resume, cover letter and employment history.

·       Details related to the role on offer, including salary expectations availability to start/notice period, distance from work location, authority to work and visa/sponsorship requirements.

 

There are certain types of personal data (referred to as “special category data”) that are afforded a higher level of protection under applicable data protection law because they are more sensitive. Special category data include personal data relating to a person’s racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life or sexual orientation. We do not request any special category data via our website.

COOKIES AND AUTOMATED TECHNOLOGIES

Our website uses cookies to distinguish you from other users.

You may set your browser to refuse all or some browser cookies, or to alert you when websites access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our [Cookie Policy – insert link].

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your personal data in the following ways:

Directly from you

We may collect personal data from you via our website where you choose to provide it to us in the following scenarios:

  • where you make a general request or enquiry using the “contact us” form on our website
  • where you use the “request a demo” feature on our website to request a demonstration of one of our products or services
  • where you subscribe to our marketing list
  • where you subscribe for tailored email alerts on the Investor Relations section of our website
  • where you request a copy of our e-book for digital publishers
  • where you apply for a role via our website

Automated technologies

  • As you interact with our website, we automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our [Cookie Policy – insert link] for further details.]
  • As mentioned above, if you subscribe to our marketing list, we use a third-party provider, Salesforce, to gather statistics on link clicking.

Third parties

We use the following third parties to collect personal data as a result of interactions via our website:

  • Salesforce. We use third party provider, Salesforce, to deliver our marketing updates. Salesforce gathers statistics on engagement with our marketing communications (email opening and link clicks) but does not use any technology that stores or accesses data on the device of the recipient of the marketing communication. Salesforce’s privacy policy is available here: Privacy Policy – Salesforce.com.
  • Greenhouse. We use third party provider, Greenhouse, to deliver our recruitment platform and store the personal data we collect relating to prospective candidates. Greenhouse’s privacy policy is available here: Greenhouse privacy policy | Greenhouse.   

Publicly available sources

After you have submitted personal data to us via our website, we may sometimes use publicly available sources in order to obtain further information about you. For example, if you subscribe to receive marketing from us, then we may review your profile on LinkedIn in order to understand your business area better so that we can ensure we send you content that is relevant to you. If you apply for a job with us, then we may use LinkedIn to obtain further detail on your professional background and experience.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data where this is permitted by law. We have set out below an explanation of the way in which we use your personal data and which of the lawful bases we rely on to do so.

Purposes for using personal data

Personal data processed

Lawful basis for processing

To provide you with marketing, including Genius Sports updates, news and product information

Contact details and marketing preferences

 

Consent (you may withdraw your consent at any time by using the unsubscribe link provided on the page of our website where you subscribed, by following the instructions for unsubscribing in our marketing emails or by contacting us using the details in the “Contact and DPO” section below)

To send you a copy of our e-book on digital publishing upon request

Contact details

Necessary for our legitimate interests (to provide you with the requested product so that we may develop and grow our business)

To respond to an enquiry made by you

 

Contact details and details of enquiry

Necessary for our legitimate interests (to answer your enquiry so that we may develop and grow our business)

To monitor link tracking in our marketing communications in order to help us provide more engaging and relevant content

Statistics on link clicks including email open rate and clicks in our email communications

Necessary for our legitimate interests (to enable us to monitor and improve the quality and relevance of our marketing communications)

To apply for a job with us

Contact details, gender, LinkedIn profile, professional/educational background information and details related to the role on offer (including salary expectations, motivation for the role, authorisation to work, distance from work and availability to work).

Necessary for our legitimate interests (to enable us to hire the people we need to develop and grow our business) – for further detail on how we process applicant personal data, please see our separate [Recruitment Policy – insert link]

If you apply for a job with us, you may voluntarily submit personal data for the purposes of our monitoring of our equality and diversity composition

Gender, race, ethnic origin

Consent (you may withdraw your consent at any time by contacting us using the details in the “Contact and DPO” section below)

 

We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will contact you and explain the legal basis which allows us to do so.

HOW WE SHARE YOUR PERSONAL INFORMATION

We will not sell your personal data to other parties. However, we may share your personal data with the following third parties either because they process personal data on our behalf or because we are required to do so by law:

  • Companies within the Genius Sports group of companies. We share your personal data with other companies within the Genius Sports group, including our companies located outside of the United Kingdom (“UK”) and the United States (“US”) (please see the “Cross-Border Transfers” section below for further information).
  • Organisations that provide services to us. We work with a number of trusted third parties to provide our website and associated services. In particular:
    • our website is hosted by Pagely (please see Pagely’s privacy policy here: Privacy Policy – Pagely®);
    • our sales teams use Microsoft Dynamics and Office 365 to store and process details submitted through our “contact us” enquiry forms (please see Microsoft’s privacy policy here: Privacy – Microsoft privacy);
    • our sales and marketing teams use Salesforce Pardot to store and process customer contact details and to deliver marketing updates (please see Microsoft’s privacy policy here: Privacy – Microsoft privacy);
    • we use Amazon Web Services EU to provide cloud storage (please see AWS’ privacy policy here: AWS Privacy (amazon.com));
    • our Talent Acquisition Team use a number of third party suppliers to deliver our recruitment platform and associated services (please see our Recruitment Privacy Policy [insert link] for further detail).
  • Our professional advisers. We share personal data with our professional advisers only where it is required in order for them to provide their advice.
  • Potential buyers. In the event of a prospective sale of all any part of our business, we may provide access to personal data to a potential buyer, provided that we inform the buyer that your personal data may only be used for the purposes outlined in this privacy policy.
  • Governments or our regulators. We may share personal data with governmental bodies or regulators where required to do so by law.
  • Police, law enforcement and security services: We may share personal data with enforcement bodies to help them with any investigation, prevention of crime or matter of national security.

In each case, we will only share your personal data where it is necessary to do so. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

CROSS-BORDER TRANSFERS

Regardless of where in the world you are based, we share your personal data with the Genius Sports Group. This will involve transferring your personal data outside of your country, including in particular to locations in which we have offices, namely Australia, Bulgaria, Colombia, Estonia, Latvia, Lithuania, Switzerland, the UK and the US.

This means that your personal data will be shared outside of the UK and European Economic Area (“EEA”), where the standard of protection of personal data may be lower than it is in the UK and EEA.

In addition, many of our third-party suppliers are based outside of the UK and EEA so their processing of your personal data will also involve a transfer outside of the UK or EEA or your originating country.

Whenever we transfer your personal data internationally, we ensure that a similar degree of protection is afforded to is as in the UK or EEA by implementing one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed by the UK or EEA to provide an adequate level of protection for personal data; or
  • We will use standard contractual clauses that have been approved for use in the UK or EEA (as appropriate), together with any supplementary measures required.

Where we use standard contractual clauses and supplementary measures as the relevant safeguard, we will also conduct a transfer impact assessment to ensure adequate protection of your personal data.  

Please contact us using the details in the “Contact and DPO” section below if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

DATA SECURITY

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

RETENTION OF YOUR INFORMATION

We will retain your personal information only for the time necessary to fulfil the purposes for which it was collected or as required by 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 that there is a prospect of litigation in respect of our relationship with you.

We will store the following categories of your personal information for the time periods indicated:

Category of personal data

Storage time period

Contact details and email history for enquiries

 

Two years after last contact

Contact details and preferences for marketing purposes

 

Until you unsubscribe

Job applications and candidate contact details

If candidate is successful, seven years after the date on which employment ceases.

If candidate is unsuccessful, four months after the date on which candidate is advised that their application will not be progressed unless it is considered that it would be worthwhile retaining the candidate details for potential future opportunities beyond that period, in which case the candidate will be asked if they consent to a further retention period.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the rights to:

  • request access to your personal data;
  • request rectification of any mistakes in your personal data;
  • request erasure of your personal data;
  • object to our processing of your personal data;
  • request restriction of processing of your personal data;
  • request transfer of your personal data (data portability);
  • withdraw your consent to our use of your personal data (only where we rely on consent as the lawful basis for processing).

We may need to ask for information from you to help us confirm your identity and ensure your right to exercise your data privacy rights before we are able to act on your request. We reserve the right to refuse to comply with a request if it is unfounded, repetitive or excessive. Otherwise, we aim to respond to all complete and legitimate requests within one month. Occasionally, it could take us longer to respond if we require further information from you, the subject matter is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.  

Further information on each of your legal rights and how to exercise them is set out below. It should be noted that the rights are not absolute but are subject to certain limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

  • Right of access: You have the right to ask us for a copy of the personal data we hold about you at any time.
  • Right of rectification: If the personal data we hold about you is not accurate or is incomplete, you have the right to have the data rectified, updated or completed.
  • Right of erasure: In certain circumstances, you have the right to request that personal information we hold about you is erased – for example, if the information is no longer necessary for the purposes for which it was collected or processed, or if our processing of the information was based on your consent and there is no other legal basis on which we may process the information.
  • Right to object: In certain circumstances, you have the right to object to our processing of your personal data – for example, you may object to the use of your personal data for direct marketing purposes, or you may object to processing based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
  • Right to restrict processing: In certain circumstances, you have the right to restrict our use of your personal information – for example, where you have challenged the accuracy of the information during the period where we are verifying its accuracy.
  • Right to data portability: In certain circumstances, you have the right to receive the personal data that we hold about you in a structured, commonly used and machine-readable format. This right only applies in relation to personal data that you have provided to us and which is processed by us using automated means. Where the right applies, you may ask us to send the data directly to you or to a third party. However, we are not able to guarantee technical compatibility of the data we provide with a third party’s systems.

COMPLAINTS

If you are unhappy about our use of your personal information, you may contact us using the details in the “Contact and DPO” section below. We will investigate your complaint and notify you in writing of the outcome as soon as possible and in any event within 30 days of receiving the complaint.

If you are unsatisfied with our response to your complaint, you may refer your concerns to the relevant supervisory authority in your country. In the United Kingdom, we are regulated by the Information Commissioner’s Office (“ICO”). You may make a complaint to the ICO using any of the following contact methods:


Telephone:
+44 (0) 303 123 1113

Website:
https://ico.org.uk/make-a-complaint/

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

CONTACT AND DPO

If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact our DPO, Maria Hernandes, by one of the methods listed below. When you contact us, we will ask you to verify your identity.

Telephone:     
+44 (0) 20 7851 4060

Email
privacy@geniussports.com

Post:
Data Protection Officer
9th Floor
10 Bloomsbury Way
Holborn
London
England
WC1A 2SL