Halfspace Processor Privacy Policy

Introduction

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.

This privacy notice aims to give you information on how Halfspace Limited processes personal data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various data products and services through which our customers: (i) manage their audience data via the DMP (data management platform) provided by Halfspace; (ii) commercialise their DMP and CRM (customer relationship management; i.e. customer database) data; (iii) activate their data; or (iv) otherwise collect, use, share or process personal data via our products and services.

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 detailed privacy information related to a Halfspace customer, please contact our customer directly who is the controller. Whilst we conduct due diligence in our agreements with our customers, our customers are responsible for their own compliance with data protection regulations.

Our products and services are not intended for children and we do not knowingly process data relating to children.
For the data processing detailed in this privacy notice Halfspace Limited is the processor of your personal data (collectively referred to as “Halfspace”, “we”, “us” or “our” in this privacy notice).

How to contact us

If you have any questions about this privacy notice 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: C/O 6th Floor, 25 Farringdon Street, London, EC4A 4AB

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 18 September 2021. It is reviewed frequently and historic versions can be obtained by contacting us.

What personal data is processed under this privacy notice?

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).

Halfspace acts as a data processor with respect to any personal data included in the Customer Data. By “Customer Data” we mean the content or information which individuals authorized by a customer submit to Halfspace.

Who do we share this personal data with?

Halfspace does not disclose this personal data to third parties except where permitted or requested by our applicable customer, or where required by law.

To perform the services requested by our customers Halfspace shares this personal data with:

  • Lotame https://www.lotame.com/about-lotame/privacy/
    • Lotame provides data enrichment and management solutions via its platforms and technologies. We use Lotame to derive audience insights and commercial benefit for our customers, including by collecting first-party data on their behalf via Lotame’s DMP and selling it via Lotame’s marketplace.
  • ESB Connect http://www.esbconnect.com/business-data-privacy-policy/
    • ESB Connect enables our customers to collect, manage and commercialise their CRM data.
  • Tradespotting https://tradespotting.com/en/946-2/
    • Tradespotting uses various ad tech platforms such as SSP (supply-side platforms), DSP (demand-side platforms) and social media platforms to buy advertising on behalf of Halfspace clients.

Halfspace will, to the extent required by law and the applicable customer contract, obtain assurances before disclosing personal data to another processor or sub-processor that the recipient will: (a) use the personal data only to assist Halfspace in providing, maintaining or improving the Halfspace Service, (b) provide at least the same level of protection for personal data as is required of Halfspace, and (c) notify Halfspace if the recipient is no longer able to provide the required protections. Upon notice, Halfspace will act promptly to endeavour to stop and remediate any unauthorised processing of personal data by the recipient.

Where your personal data may be processed?

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.

How do we protect your personal data?

As specified in the data processing agreement with the applicable controller, 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.

How long will we keep your personal data?

Storage periods depend on the data processing terms with our customers and their choices, type of personal data, purposes of its collection and processing, and applicable law.

However, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes of our clients.

What are my rights?

Data subjects in the EU and United Kingdom have certain rights regarding the processing of their personal data. You can obtain information about the applicable rights and how to exercise them from the relevant customer that is the

Data Controller of your personal data. Halfspace will work with its customers to enable your rights.

Under the GDPR, 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 the relevant data controller.

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.

What are my online choices?

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:

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

Contacting Halfspace

We hope this Privacy Notice has been helpful in clarifying the way we work with our customers to process 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 18 September 2021.