🔐Privacy Policy

Welcome to the Sphere Research Ltd (hereinafter, “Sphere,” “Company,” “us,” “our,” or “we”) Privacy Policy (the “Policy”).

This Policy governs our information-handling practices as applicable to residents in the United Kingdom ("UK"), European Union (“EU”), European Economic Area (“EEA”), and Switzerland (collectively, the “Data Subjects”) that are visiting our website, www.sphere.co.uk, and the other websites under the sphere.co.uk domain (collectively, the “Sites”), or are customers who use our web design software, tools, and related services (together with the Sites, the “Service”).

This Policy explains how we collect, use, disclose, and protect Data Subjects’ information as part of the Service in accordance with data-protection laws in the UK, EU, EEA, and Switzerland (collectively the “Data Protection Laws”). Any discussion of your use of the Service in this Policy is meant to include your visits and other interactions with the Sites and Services, whether or not you are a user of Sphere’s technology products.

Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service.

By accessing and using the Service, you signify your acceptance to the terms of this Policy. If you do not agree with or you are not comfortable with any aspect of this Policy, or the Terms of Service, you should immediately discontinue access or use of our Services.

1. Our relationship to you

In order for you to understand Sphere’s data protection obligations and your rights to your Personal Information under this Policy, it is important that you identify which relationship(s) you have with Sphere.

• A “Customer” is a specific type of User that has engaged us to act as an agent (or, as a “Data Processor”) by obtaining our Services. Sphere is in a “data processor” relationship with Customers.

• A “User” is an individual providing personal data to us via our website or other services, products or platforms, such as using our contact form, or signing up for our marketing emails or creating an account. Sphere Research Ltd is in a “data controller” relationship with Users.

• Sphere does not have a direct relationship with Customers’ End Users. A “Customer End User” is an individual that provides their Personal Information to our Customers. We do not control the purposes nor the means by which this Personal Information is collected, and we are not in a direct relationship with Customer End Users. For details about how Personal Information about Customer End Users is handled, please review our Customers’ privacy policies instead of this one, and contact them for further information.

Hereinafter we may refer to Customers and Users collectively as “you.”

2. Notice

Sphere provides notice to you through privacy policies on our site, and we may provide additional disclosures about the data collection, use, and sharing practices of specific Services. This Policy describes how we process Personal Information.

As a data processor, Sphere is not able to provide notice to or obtain consent from Customer End Users. To the extent required by law, Sphere supports Customers’ data-protection compliance efforts, but it is up to the Customer to ensure the appropriate data protection safeguards are in place before processing Personal Information from Customer End Users.

3. Collection of Personal Information

Sphere collects various types of Personal Information about you while you are using the Services. Information that is anonymized or aggregated is not “Personal Information.”

In general, we collect the following types of Personal Information:

• Registration data: full name, email address, and optional social media account information (e.g., if logging in through your Google account).

• Interaction data: authentication data, ID, and other data collected via cookies and similar technologies. Please read our Cookie Policy for more information.

4. Purposes of processing

Under the Data Protection Laws, we are required to notify you about our purposes of processing your Personal Information, as well as the legal basis for such processing.

Unless otherwise permitted by law, we may process your Personal Information:

• If you consent to the processing

• To satisfy our legal obligations

• If it is necessary to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you

• In the public interest

• In your vital interests, or

• For our legitimate interests, such as to protect our property, rights, or the safety of Sphere, our customers, or others

Purpose of processing	Legal basis
‍We process your Personal Information to: Enhance the security of our Services Combat spam or other malware or security risks Monitor and verify identity or service access To comply with applicable security laws and regulations Investigate, prevent and mitigate any potentially prohibited or illegal activities Collect fees based on your use of our Services	Processing is necessary for compliance with a legal obligation.
To enforce Sphere’s terms and agreements.
We have Terms of Service and other policies that define how you can use our Services. To ensure that you and others are using our Services in accordance with such terms and policies, we may process your Personal Information to: Investigate, prevent and mitigate any potentially prohibited or illicit activities Enforce our agreements with third parties, and/or We collect information about your account usage and monitor your interactions with our Services. We may use any of your Personal Information collected on our Services for these purposes. The consequences of not processing your Personal Information for such purposes is the termination of your account, as we cannot perform our Services in accordance with our terms.	Processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract.

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To provide Service communications.
We may contact you to send you administrative or account-related information to keep you updated about our Services, alert you of relevant security issues or updates, or provide other transaction-related information to you.	Processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract.

‍To provide customer service.
When you contact our customer service team, we process your Personal Information to respond to your questions, disputes, feedback, or issues with our Services. We may process your Personal Information in response to another customer’s request, as relevant. Without processing your Personal Information for such purposes, we cannot respond to your requests.	Processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract.

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To facilitate acquisitions, mergers, or other business transactions.
We may process any of your Personal Information as is necessary in the context of acquisitions, mergers, or other business transactions. We will try to notify you in advance if we intend to process your Personal Information for this purpose. You will have the option of terminating your account if you do not wish to have your Personal Information processed for such purposes.	Processing is necessary for the purposes of the legitimate interests pursued by Sphere.

‍We will only use your Personal Information for the purposes above or for compatible purposes.

If we wish to share your Personal Information with third parties that are not described in this Policy, we may request your permission as required by Data Protection Law. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. However, if you limit the way we use your Personal Information, certain features or Services may not be available to you.

5. Third party recipients

Sphere conducts the majority of data processing activities required to provide you with the Services. However, we do engage third-party service providers to assist with supporting our Services, including vendors in the following areas:

• Marketing or analytics tools

• Cloud storage providers

• Customer support tools

• IT and security service providers, and

• Product development tools

Each service provider is vetted and bound by contractual obligations that are equivalent to the provision of this Policy or more stringent.

6. Retention

We are committed to keeping your Personal Information secure on our Services. We limit our storage of your Personal Information to the amount of time necessary to fulfil the purposes for which we collected the Personal Information, including for the purposes of satisfying any legal, accounting, or reporting obligations, or to resolve disputes. Although retention laws and requirements vary by jurisdiction, we have some standard retention periods for parts of your Personal Information which are described below:

• Contact information, such as your name and email address, is retained on an ongoing basis until you unsubscribe from our marketing communications.

• Browser interaction data, such as cookies, is kept for a period of up to one year from expiry of the cookie or date of collection.

• Product analytics data is kept for up to 5 years, and automatically deleted on an ongoing basis.

If you have questions about retention periods that apply to any other data, please contact us at [e-mail]

07. Security

We are committed to protecting the security of your Personal Information by using reasonable and appropriate physical, electronic, and administrative safeguards.

08. Direct marketing

Direct marketing includes any communications to you that are only based on advertising or promoting products and services. Transactional communications about your account or our Services are not considered “direct marketing” communications.

We will only contact Customers by electronic means (including email) based on our legitimate interests or the Customer’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you do not want us to use your Personal Information in this way, please go to the email settings for your account to opt out, click an unsubscribe link in your emails, or contact us at [e-mail].

09. Your rights

You have the rights to your Personal Information that are described below. You can exercise your rights by contacting us at [e-mail] so that we may consider your request under applicable law. When we receive an individual rights request via email, we may take steps to verify your identity before complying with the request to protect your privacy and security.

• Right to withdraw consent. When we rely on your consent for processing of your Personal Information, you have the right to withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of Sphere’s processing based on consent before your withdrawal.

• Right to erasure. You have the right to request erasure of your Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented to, but no longer consent to; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. Your right to erasure is subject to limitations by relevant Data Protection Laws.

• Right to restriction of processing. You have the right to restrict our processing of your Personal Information where one of the following applies:

1. The processing is unlawful and you oppose the erasure of your Personal Information and request the restriction of its use instead.

2. We no longer need your Personal Information for the purposes of the processing, but it is required by you to establish, exercise, or defend legal claims.

• You have objected to processing, pending the verification of whether the legitimate grounds of Sphere’s processing override your rights. Right to object to processing. Where the processing of your Personal Information is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We can continue to process your Personal Information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

10. Limitations to your rights

Your rights to your Personal Information are not without limits. Access may be denied when:

• Denial of access is required or authorised by law

• Granting access would have a negative impact on other's privacy

• Doing so protects our rights and properties, or

• Where the request is frivolous or vexatious

11. Recourse, enforcement, & liability

We will investigate and work expeditiously to resolve any complaints or disputes in accordance with this Policy. If you have an inquiry or complaint regarding our privacy policies or practices, please contact us first at [e-mail]

You have also a right to lodge a complaint with a competent supervisory authority.

12. Children's data

We recognise that some Data Protection Laws vary based on the age of consent. Depending on the jurisdiction, the age of consent can be between 13 to 16 years old. We do not knowingly request to collect Personal Information from any Data Subject under the age of consent as defined by the jurisdiction in which the Data Subject resides. If we are aware of or suspect that a Data Subject is under the age of consent, we will require the Data Subject to terminate their account. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of consent using our Services.

13. Changes to this Policy

We may change this Policy at any time and the changes will apply to any Personal Information we already hold and to any new Personal Information collected after the change occurs. If we make any material changes to this Policy, we will endeavour to notify you by email or by posting a prominent notice on our sites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our Services after the effective date of this Policy constitutes an acceptance of the amended terms. You may refer to the “Last Updated” date of this Policy to determine if the Policy has changed since the date of your last visit.

14. Contact us

If you have any questions regarding this Policy or about the privacy practices of Sphere, please contact us by email at [e-mail].

Policy was last updated on 29th October 2022