Last Updated: 26 June 2024
1. Who we are and what we do
Who we are
Starting 11 is owned and operated by Sport Insights Media Ltd. Our address is 167-169 Great Portland Street, 5th Floor, London, W1W 5PF and we are registered in England and Wales under Company number 12708129.
We are also registered with the Information Commissioner's Office ("ICO") in relation to our processing of Personal Data under registration number ZB024334.
What we do
Sport Insights Media specialises in crafting captivating and interactive games designed to elevate user engagement and provide valuable data-driven insights for brands. As a new-age digital customer intelligence company, we are revolutionising the way brands get to know their audience with the power of gamification.
Controller
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
2. Purpose of this privacy notice
This privacy notice covers the personal data we obtain from you when you participate in one of our Starting 11 quizzes and also the personal data we obtain from you when you visit the starting11.co.uk website.
The purpose of the notice is to explain what Personal Data we collect and how we process it. It also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the 'How to contact us' section.
3. Who this privacy notice applies to
This privacy notice will apply to you if:
- You register with us to receive hints when participating in one of our quizzes
- You visit the starting11.co.uk website
- You contact us via the [email protected] email address
4. What Personal Data is
'Personal Data' means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
5. Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled 'Purposes, lawful bases and retention periods'.
6. How we collect your Personal Data
We collect most of the Personal Data we hold directly from you via website forms and emails.
7. Purposes, lawful bases and retention periods
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
| Categories of individuals | Categories of Personal Data | Purpose of Processing | Lawful Basis | Retention Period |
|---|---|---|---|---|
| Quiz players | First name, Last Name, Password, Email Address | To register you on Starting 11 so you can be notified about any new quizzes and competitions and receive hints to help you to complete our quizzes | Consent | Your details will be kept until you cancel your registration |
| Quiz players | Email address | Where you have ticked the box to receive updates about our features and offers we will use your email address to send you information about our latest quizzes and competitions plus promotions for Starting 11 and our selected partners. | Consent | Your details will be kept until you cancel your registration |
| Quiz players | If you request a hint during the quiz then we may ask you to tell us about something about your interests, likes and purchasing habits. This could, for example, be questions about your favourite sports, your preferred food and drink brands, which social media sites you like to follow, the team you support, your opinions about your team and on football in general, how often you attend matches, whether you buy your club's merchandise etc. | So we can send you offers for products and services from our selected partners that we think are likely to be of interest to you (if you ticked the opt in box on the registration form) | Consent | Your details will be kept until you cancel your registration |
| Website visitors | Email address | To respond to your queries where you have contacted us via the [email protected] email address. | Legitimate interest - it is within our legitimate interests to assist you with queries about our services and products | 3 Years from the date you contacted us |
| Website visitors | Browser type, date and time of access, the web page from which the user accessed the site and the operating system used. | This information helps ensure the functionality of our websites. The data is also used to optimize the website and to ensure the security of our IT systems. | Legitimate Interests - it is within our legitimate interests to ensure that our website remains functional and is kept secure. | Starting11.co.uk uses a third party provider (Google Analytics) to collect this information. For further details about how long they retain this data, please see their Privacy Notice. Further information may also be found on Google's Technologies page. |
8. Sharing your Personal Data
Your personal data will be stored on servers operated by Amazon Web Services and Google.
9. International Transfers
Your Personal Data may be processed outside of the UK. This is because some of the organisations we use to provide our service to you are based overseas.
We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in this country. These are as follows:
- Where required we have entered into International Data Transfer Agreements ("IDTA") with the receiving organisations and adopted supplementary measures, where necessary. (A copy of a the template IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).
- In the case of transfers to the US, we will ensure that the recipient companies have signed up to the UK-US Data Privacy Framework.
10. Your rights and how to complain
You have certain rights in relation to the processing of your Personal Data, including to:
-
Right to be informed
You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this. -
Right of access (commonly known as a "Subject Access Request")
You have the right to receive a copy of the Personal Data we hold about you. -
Right to rectification
You have the right to have any incomplete or inaccurate information we hold about you corrected. -
Right to erasure (commonly known as the right to be forgotten)
You have the right to ask us to delete your Personal Data. -
Right to object to processing
You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material. -
Right to restrict processing
You have the right to restrict our use of your Personal Data. -
Right to portability
You have the right to ask us to transfer your Personal Data to another party. -
Automated decision-making
You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making. -
Right to withdraw consent
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so. -
Right to lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner's Office who can be contacted at:
ICO
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
and also online at:
Contact us | ICO
or by telephone on 0303 123 1113
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called 'How to contact us and our Data Protection Officer'. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
11. Children's Privacy
Starting 11 takes its obligations to protect Children's Privacy very seriously and we are therefore very mindful of the need to ensure that the marketing we send to quiz participants is age appropriate.
In order to facilitate this, we ask all players who register with us to provide us with their date of birth. This allows us to filter our advertising so that any children who have signed up with us receive carefully selected age restricted content. By this means we prevent those children from being exposed to:
- marketing for child inappropriate products such as alcohol or betting sites.
- advertising that might encourage unhealthy lifestyle choices such as for fast food, sweets or sugary drinks.
- promotions for expensive or luxury products that the child has no use for or would be unable to afford.
If the date of birth given at registration indicates that the child is below 18 then no advertising material at all will be sent to that child's email address.
Finally, all our marketing emails contain an unsubscribe option which allows the child to opt out of receiving further advertising from us should they wish to.
12. How to contact us and our Data Protection Officer
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
Sport Insights Media, 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
[email protected]
+44 203 137 2894
We have also appointed a Data protection Officer ("DPO"). Our DPO is Evalian and can be contacted as follows:
Evalian, West Lodge, Leylands Business Park, Colden Common, Hampshire, SO21 1TH
[email protected]
Please mark your communications FAO the 'Data Protection Officer'.
13. Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.
Last modified 26/06/2024