Privacy Policy

SPHERE PRIVACY NOTICE

 

1. WHO WE ARE

Sphere Innovations Limited (referred to as “Sphere”, “we” or “us”) is a company based in the UK.  Our company registration number is 11996985 and our registered address is  86-90 Paul Street, London, England, EC2A 4NE.

Under the Data Protection law in the UK and EU Sphere is the “Data Controller” in relation to the personal information that you share with us (referred to as “Personal Data”), and we have certain obligations under this law to protect your Personal Data, and enable you to exercise your legal rights in relation to it. This Privacy Notice sets out how we use, share and look after your Personal Data, and what your rights are.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the information set out below:

Sphere Innovations Limited

Name of responsible internal team: Data Protection and Privacy Team

Email address: dataprotection@sphere.buzz

Postal address: 86-90 Paul Street, London, England, EC2A 4NE.

Our website is not intended for use by children and Sphere does not knowingly collect Personal Data from anyone under the age of 18.

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

“Personal Data” means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name, customer code or identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data includes purchases or orders made by you, the nature of your business, your business interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use the Website, products and services.
• KYC Data includes information about the source of funds you may use to purchase products or services from us, credit scores, reputation in the market, and other Personal Data we require in order to verify your suitability as a client or supplier for us, and in deciding whether we may need some additional safeguards when doing business with you.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical Data includes 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, device ID and other technology on the devices you use to access this website.

We also collect, use and share Anonymised Aggregated Data such as statistical or demographic data for any purpose. Anonymised Aggregated Data  is not considered Personal Data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate and anonymise your Usage Data to calculate the percentage of users accessing a specific website feature or perhaps buying a certain type of product.

3. HOW YOUR PERSONAL DATA IS COLLECTED 

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post,  phone, email or otherwise. This includes Personal Data you provide when you:
• apply for or use our products or services;
• meet with us either at our offices, your premises, or in other locations, and express an interest in our products or services;
• create an account with us;
• subscribe to or use any of our services or publications;
• request marketing to be sent to you;
• complete a survey; or
• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://onsphere.com/privacy-policy/ for further details.
• Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:

1. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
2. Identity and Contact Data from Data brokers or aggregators including business directories.
3. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

The law requires us to have a legal basis for collecting and using your Personal Data.  We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

The table below sets out how we will use your Personal Data, and for what purpose as well as our lawful basis for doing so:

5. MARKETING

We  provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have provided us with consent for us to do so, requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by using the unsubscribe link provided in any marketing communication that is sent to you, or by contacting us at any time here.

Where you opt out of receiving these marketing messages, , you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, appointment reminders, updates to our Terms and Conditions, and/or checking that your contact details are correct.

6. COOKIES

For more information about the cookies we use and how to change your cookies preferences please  our cookie policy available here.

7. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data with third parties for the purposes set out in the table  above. These include:

• third party providers of Personal Data and other services to us, such as credit agencies, and third party archival, cloud and backup providers.
• third party providers of professional services, such as accountants, bankers, insurers and lawyers.
• HM Revenue and Customs, and other regulatory authorities.
• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.

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 our 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.

8. INTERNATIONAL TRANSFERS

We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data.

Whenever we transfer your Personal Data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the ICO and/or the European Commission.
• Where we use certain service providers located outside of the UK/EEA, we use specific contracts approved by the ICO/ European Commission which give Personal Data the same protection it has in the UK and EU..

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK and/or EEA.

9. DATA SECURITY

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.

10. DATA RETENTION

How long will we use your Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, KYC, Financial and Transaction Data) for six years after they cease being customers for tax and accounting purposes.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS

You have the right to:

Be informed of how your Personal Data is being utilised by us, as set out in this Privacy Notice.

Request access to your Personal Data (commonly known as a “Data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Data’s accuracy; (b) where our use of the Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. we will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

12. REQUESTS

What we may need from you

Following any request made by you we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. COMPLAINTS

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.

14. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

We keep our Privacy Notice under regular review. This version was last updated on 13 March 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

15. CONTACT DETAILS

Sphere Innovations Limited

Name of responsible internal team: Data Protection and Privacy Team

Email address: dataprotection@sphere.buzz

Postal address: 86-90 Paul Street, London, England, EC2A 4NE.

Telephone number: 020 8126 4620

16. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.