PRIVACY POLICY

INTRODUCTION

Welcome to Genius Sport's privacy policy.

Genius Sports Limited and Betgenius Limited (“we” or “our” or “us”) want to make sure all the personal information we have collected about you is safe and secure whether we collect it from you via electronic means (such as email or social media platforms), when you visit one of our global offices or in-person at a conference. This notice sets out our commitments to you, in compliance with the General Data Protection Regulation (commonly known as the “GDPR”) and explains how we collect, store and use your personal information.

Third-party links. Our websites (www.geniussports.com, www.betgenius.com, www.geniussportsmedia.com) may include links to third-party websites, plug-ins and applications – for example, third party links to news stories about us. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.



COLLECTING YOUR INFORMATION

Website users

All of our pages on our website can be accessed without giving us your personal information (unless you click on a third party link (see Third-party links above)). We only use essential cookies (see the Cookies section below).

Direct Interactions

You may give us your name and contact information by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you give us feedback or contact us.

Customers or prospective customers

If you are an individual that works for one of our customers (or prospective customers), you generally share with us (or we ask you for) your name, job title, address, email address and telephone number. We may also keep records of your interactions with us, which may include an audio recording (where you have provided your consent for us to record).

Suppliers or prospective suppliers

If you are an individual that works at one of our suppliers (or prospective suppliers), we’ll ask you for your name, job title, email address and telephone number. We may also keep records of your interactions with us, which may include an audio recording (where you have provided your consent for us to record).

Visitors

If you visit any of our offices, we’ll ask you for your name and signature and you may also choose to provide us with your email address and photograph. We also have CCTV in operation in reception in every office.



HOW WE USE YOUR INFORMATION

PurposePersonal information usedOur lawful basis
DIRECT INTERACTIONS
To help you if you have a question or to send you information which you have asked us to send to youName and email address (and any other relevant information which you may have provided)We have a legitimate interest to properly manage and administer our relationship with you and provide answers to any queries you have. Where you have told us you want to receive certain information.
CUSTOMERS (OR PROSPECTIVE CUSTOMERS)
To enter into and perform contracts where we areproviding services to you (or your employer)Your name, job title, email address, address and telephone number Records of your interactions with usThis is necessary to enable us to properly administer and perform any contract for the provision of any services and products you provide to us.
To let you know what sport content is available to bookYour name and email addressWe undertake this processing because it is necessary in order to perform our contract with you. We have a legitimate interest to communicate regularly and efficiently with you to keep you updated on content availability
It is difficult to get the right people in the right place at the right time for a meeting and, therefore, we may record a telephone meeting (via Zoom, for example) to share with absent colleagues for knowledge sharing purposes.Your name and audio recordingWhere you have given us your consent to do so.
SUPPLIERS (OR PROSPECTIVE SUPPLIERS)
To enter into and perform contracts where you (or your employer) are supplying products/services to usYour name, job title, email address and telephone number Records of your interactions with usThis is necessary to enable us to properly administer and perform any contract for the provision of any services and products you provide to us.
It is difficult to get the right people in the right place at the right time for a meeting and, therefore, we may record a telephone meeting (via Zoom, for example) to share with absentYour name and audio recordingWhere you have given us your consent to do so.
colleagues for knowledge sharing purposes. If you (or another provider) are providing training to our employees, we may record the session for training purposes (so that we can give the opportunity to a wider pool of employees to strengthen their skills and knowledge).
VISITORS
To administer your arrival and to keep a register of individuals onsiteYour nameWe have a legitimate interest to ensure our personnel and property are secure.
To enable us to identify you whilst you are on the premisesYour photographWhere you have given us your consent to do so.
To enable us to contact you after your visit for security reasonsYour email addressWhere you have given us your consent to do so.
To comply with health and safety requirementsCCTV footageWe have a legal obligation and a legitimate interest to maintain the security of our premises and to assist in preventing and investigating crime


WHO ELSE RECEIVES YOUR PERSONAL DATA?

We may send your details to others to help run our organisation.

These are:

• Anyone you have said you are happy for us to send your details to.

Organisations that provide services to us: such as the building management companies for each building together with a visitor management software system, IT service providers (like our cloud storage services, enterprise resource system, customer relationship management platform, collaboration tools, internal messaging platforms and web/video conference facility), our contract management platform and our CCTV software provider.

Our group companies.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

The Government or our regulators: where the law tells us to do so or to help then with investigations or initiatives.

Police, law enforcement and security services: to help them with any investigation, prevention of crime or matter of national security.

We may share your personal information with third parties where required by law, where it is necessary for our working relationship or where we have another legitimate interest in doing so.

Those third parties may be located in third countries outside of the EU (see section below). By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this notice.



TRANSFERRING YOUR DATA OUTSIDE THE EEA

By using our third party providers we may transfer the personal information we collect about you to the USA, if this is necessary, in order to perform our contract with you, or in accordance with any legitimate interests of Genius Sports. Our third party providers including Workday Inc., Salesforce, Slack Technologies and Atlassian Inc. are registered with the US Privacy Shield. This means that those organisations within the USA have been deemed by the European Commission to provide an adequate level of protection for your personal information.

We may also transfer your personal data to our employees in Medellin (Colombia). There is not an adequacy decision by the European Commission in respect of that country. This means that Colombia is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place approved standard contractual clauses between us and our Colombian entity as an appropriate measure to ensure that your personal information is treated by our employees in Colombia in a way that is consistent with and which respects the EU and UK laws on data protection.



HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR?

We collect personal data from you for different reasons and so we might keep it for different lengths of time. For:

• Individuals making direct interactions, it will generally be a period of 2 years after we were last in contact with you.

• Individual contacts at suppliers, this will be for as long as we continue to have a relationship with that supplier and then for a period of 6 years afterwards.

• Individual employees for our customers, this will be for as long as we continue to have a relationship with that customer and then for a period of 6 years afterwards.

• Visitors, it will generally be a period of 12 months after you last visited the office, except for CCTV footage which is automatically removed after 30 days (unless we need to retain the footage for investigation purposes).



YOUR RIGHTS TO YOUR PERSONAL DATA AND COMPLAINTS

You’re entitled to know what personal information we hold about you and how that information is processed, which means you can ask us to do any of the following things:

• to provide access to your data;

• to rectify any mistakes relating to your data;

• to erase your data;

• to stop processing your data;

• to receive an electronic copy of your data;

• to object to our processing of your data; and

• to object to any automated decision making that we may do using your personal data;

Just let us know (see Contact section below) if you’d like to exercise any of your rights. Please note that there are circumstances where your rights (as set out above) cannot be exercised for regulatory purposes.

If you’re unhappy with how any access request has been dealt with, you have the right to complain to the Information Commissioner by calling their helpline: 0303 123 1113 or starting a live chat at https://ico.org.uk/concerns/.



COOKIES

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 the cookies we use, please refer to our cookie policy.



CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the top of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.



CONTACT

We welcome any queries or enquiries or requests in respect of this notice, you can contact us by sending us an email at: privacy@geniussports.com.

Our company registration details are as follows:

Genius Sport Limited (company no: 10197219, ICO registration no: ZA198905)

Betgenius Limited (company no: 04062777, ICO registration no: Z5201353)

Address (for both entities): 9th Floor, 10 Bloomsbury Way, Holborn, London, England, WC1A 2SL



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GENIUS SPORTS MEDIA - PRIVACY NOTICE



INTRODUCTION

Betgenius Limited, also known as Genius Sports Media, (“we”, “us” or “our”) supports advertisers and digital publishers (“Clients”) by offering a suite of products, technologies, and content (“Betgenius Technologies”) to enable Clients to reach their target audience, promote their offerings, or drive incremental traffic.

This privacy policy is intended to inform consumers about how the Betgenius Technologies collects and uses data as a data controller. It will also outline how to exercise your rights to opt-out of data collection by us.

Betgenius collects only Device-Identified Information (“DII”) where our Clients deploy the Betgenius Technologies on the websites you visit. When we refer to DII in this policy, we mean information that is linked to a browser, device, group of devices, but is not used or intended to be used to directly identify you (or any particular individual). We use DII browser session cookies and persistent cookies in our products and technology to provide, monitor, analyze, and improve our services.

For more information about cookies please visit allaboutcookies.org.


HOW DO WE COLLECT YOUR INFORMATION?

We use the Betgenius Technologies to collect information. The Betgenius Technologies consist of cookies, pixels, tags and other non-cookie technologies to collect and store data about devices, apps and web browsers (see “What information do we collect?” section for more information on the types of data we collect).

The Betgenius Technologies are embedded into digital advertisements, or otherwise deployed onto websites, which you have viewed or visited. For example, where you have visited our Client’s website, or a publisher’s website promoting our Client, the Betgenius Technologies will automatically collect your information (unless you have opted-out (see the “Opting Out” section below)).



WHAT INFORMATION DO WE COLLECT?

We may process the following information when you visit a website which uses Betgenius Technologies:

Internet Connection Data

• Your IP address (in full) that your device uses to connect to the internet

Browsing Data

• The domain name of the website you are visiting

• The type of page you visit

• The date and time of your visit to the website

Online Identifiers

• Cookie ID

• The location (country) of your device

Device / Thecnical Data

• Device, operating system (e.g. Windows or Macintosh) and browser details (e.g. Internet Explorer or Chrome)

• IDs assigned to your device by our technology partners (see Trusted Third Parties below)

• Technical details of the request, such as HTTP protocol elements, HTTP request method and databytes in response

Betting Activity

• The ID associated with your betting account

• Deposit amount, currency, time of deposit, details of the device used and your location (non-precise)

• Details of the event upon which you are betting

• Details of the bet you are placing, including the odds and the outcome you have backed



OPTING OUT

Betgenius utilizes persistent cookies to manage your opt-out status. You may visit https://ssl.connextra.com/optoutstatus to opt-out of data collection. The cookie will apply to the specific browser you are using; if you wish to opt-out for other browsers or computers that you use, you must repeat the process using those browsers or computers.

Opting out does not mean that you will no longer receive online advertising. It does mean that Betgenius will no longer collect any data associated with your activities.



HOW WE USE YOUR INFORMATION



PurposePersonal information usedOur lawful basis
To allow us to display personalised advertisements to you.All dataConsent
To allow us to identify the services that interest you.Browsing DataConsent
To allow us to optimize the display of the advertisement on the device you are using.Device/Technical DataConsent
To allow us to derive non-precise information about your geographical location (country, region or city) in order to display advertisements for products available in your geographical area. To check that the services we are advertising are legal in your region.Internet Connection DataConsent
To allow us to detect what service or market is of interest to you within our ad.Betting Activity Browsing DataConsent
To allow us to avoid displaying the same ads too often and to detect what product is of interest to you within our ad.Online IdentifiersConsent
To allow us to record advert serving impressions, record advert clicks, to analyse effectiveness of a campaign and to report ad-serving activity and results to our Advertisers.All dataConsent
To monitor, analyse and improve our servicesConsent
To enable us to identify you whilst you are on the premisesYour photographWhere you have given us your consent to do so.

Some of our partners or vendors (for example, Google Analytics) or Clients may set or use their own cookies through the Betgenius technologies we provide. However, we have no access to or control the use of these cookies.

If you tell us we can use your information in a certain way, you can tell us to stop using it at any time (see Contact section below).

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by using the details in the Contact section below or by contacting the Advertiser to whom you have given consent.



WHO ELSE RECEIVES YOUR PERSONAL DATA?

We may send your details to others to help run our organisation. These are:

Anyone you have said you are happy for us to send your details to.

Organisations that provide services to us: such as IT service providers (like our cloud storage services, content delivery networks, programmatic services and our trusted third

party demand side platforms).

Our Advertisers. Whose adverts you may have seen or interacted with.

Our subsidiaries and affiliates.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

The Government or our regulators: where the law tells us to do so or to help then with investigations or initiatives.

Police, law enforcement and security services: to help them with any investigation, prevention of crime or matter of national security.

We may share your personal information with third parties where required by law, where it is necessary for our working relationship or where we have another legitimate interest in doing so.



TRANSFERRING YOUR DATA OUTSIDE THE EEA

By using our third party providers we may transfer the personal information we collect about you to the USA, if this is necessary, in order to perform our contract with you, or in accordance with any legitimate interests of Betgenius. Our third party providers, including MediaMath, Beeswax, Akamai Technologies and AppNexus, and our US entity (Genius Sports Media Inc) are registered with the US Privacy Shield (www.privacyshield.gov). This means that those organisations within the USA have been deemed by the European Commission to provide an adequate level of protection for your personal information.

We may also transfer your personal data to our employees in Medellin (Colombia). There is not an adequacy decision by the European Commission in respect of that country. This means that Colombia is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place approved standard contractual clauses between us and our Colombian entity as an appropriate measure to ensure that your personal information is treated by our employees in Colombia in a way that is consistent with and which respects the EU and UK laws on data protection.



HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR?

All personal data collected by Betgenius Technologies will be deleted, aggregated or anonymised no more than 13 months after collection.



YOUR RIGHTS TO YOUR PERSONAL DATA AND COMPLAINTS

You’re entitled to know what personal information we hold about you and how that information is processed, which means you can ask us to do any of the following things:

• to provide access to your data;

• to rectify any mistakes relating to your data;

• to erase your data;

• to stop processing your data;

• to receive an electronic copy of your data;

• to object to our processing of your data; and

• to object to any automated decision making that we may do using your personal data;

Just let us know (see Contact section below) if you’d like to exercise any of your rights. Please note that there are circumstances where your rights (as set out above) cannot be exercised for regulatory purposes.

If you’re unhappy with how any access request has been dealt with, you have the right to complain to the Information Commissioner by calling their helpline: 0303 123 1113 or starting a live chat at https://ico.org.uk/concerns/.



CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the top of this page. Where required by law we will seek your consent to changes in the way we use your personal information.



CONTACT

We welcome any queries or enquiries or requests in respect of this notice, you can contact us by sending us an email at: privacy@geniussports.com.

Our company details are as follows:

Genius Sports Media, Inc. (US Privacy Shield participant, here )

11601 Wilshire Blvd.

Ste. 2300-A

Los Angeles

California 90025



Betgenius Limited (company no: 04062777, ICO registration no: Z5201353)

9th Floor

10 Bloomsbury Way

Holborn

London

England

WC1A 2SL