Effective Date : August, 2023

Player and Connected Persons Privacy Notice


This privacy notice provides information on how Second Spectrum UK Limited and its affiliated companies ("Second Spectrum”, “we”, “our” or “us”) collects, processes and shares personal data relating to players in sporting events and other “connected persons” associated with those events, in particular referees/judges, club owners, managers, directors or any other relevant participant or person involved within a given sport (references to "you” and “your” in this policy are to players and connected persons).

It also explains your rights as a data subject and how those rights may be exercised.

We keep our privacy practices under review and may amend this policy from time to time. This version is dated August 2023.


Second Spectrum, a part of the Genius Sports family provides an unparalleled machine understanding of every game.

In providing our services, we process certain personal data about sports players and connected persons both as a “processor” and a “controller” of that information. 

This means that where we provide services to our customers, such as professional clubs and leagues, we are a processor of your personal data, meaning that we process it exclusively on behalf of and pursuant to the instructions of our customers.

In the limited instance where we use the data for software algorithm improvement purposes, we are a controller of your personal data. For more information on the purpose for processing your personal data as a controller and the lawful basis we rely on to do so, please read the section below.


We will only use your personal data as a controller for the purpose set out below:

Purpose Personal data usedData source

Lawful basis for processing

The data is used for research and development purposes to continue to train our models and improve our techniques and services.

When the data is used for these purposes, it will not be used to make decisions about individual players.

Publicly available personal data:
  • Team affiliation
  • Position/role
  • Jersey number
  • Superficial physical features
Observed data:
  • In-context movement information, such as speed, location and position

We film directly at the sports stadia where the commissioning club or league is playing.

Dedicated cameras around the playing area capture and track identifiers during matches.

We also receive pre-recorded videos from commissioning clubs or leagues.

Our player tracking system applies state-of-the-art machine learning and computer vision techniques to produce fast and accurate location data.

In compliance with our data accuracy related obligations under the applicable data protection laws, Second Spectrum uses the data collected to train and improve the accuracy of our algorithm. 

Player position is a vital component of the services we offer. In order to determine player position and movement throughout the match, our systems need to be able to accurately and quickly identify individual players.

We process your personal data because it is necessary for our (and that of our customers’s) legitimate interests to ensure that the software algorithm tracking and reporting functionality is as accurate and precise as possible.

To the extent that any data points generated in the course of our services is considered to be special category data (e.g., biometric data) under the applicable data protection laws and it is used for algorithm improvement purposes, Second Spectrum relies on the following lawful basis: applied sports scientific research pursuant to Article 9(2)(j) UK General Data Protection Regulation, Article 89(1) UK General Data Protection Regulation, and Section 19 of the Data Protection Act 2018.

Where we say that it is in our legitimate interests to use your personal data in the ways described above, our “legitimate interests” (or another’s legitimate interests) means the interest of our business (or another’s) to conduct itself so as to provide the best services and products.

Before using your personal data for our or another party’s legitimate interests, we make sure that we take into account any potential impact that such use may have on you and your rights.

We do not use your personal data for activities where our (or another’s) interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law).


Under certain circumstances, you have rights under the data protection laws in relation to your personal data, including the rights to:

  • access to your personal data
  • rectification of any mistakes in your personal data
  • erasure of your personal data
  • data portability
  • restriction of processing of your personal data
  • object to our processing of your personal data
  • withdraw your consent to our use of your personal data (only where we rely on consent as the lawful basis for processing)

If you wish to exercise any of these rights, then please contact us using the details in the “Contact and DPO” section below. Please note that there may be legal or regulatory reasons why the above rights cannot be exercised; if this is the case, we’ll tell you why.


  • We might share your personal data with the following categories of recipients:
  • our service providers (e.g., cloud storage services)
  • our professional advisers
  • our affiliated companies

In each case, we will only share your personal data where it is necessary to do so.


We generally keep personal data for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal data for longer periods of time if necessary to comply with legal, tax or accounting requirements, or if we are required to do so by a court, regulator or other applicable legal or governmental body with authority to make the request.

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 the data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax and other requirements.


We are a global business and therefore it may be necessary to transfer your personal data outside of the country in which it was collected, including to our affiliated companies and service providers based in other locations.

Second Spectrum has offices in the UK, the United States, Switzerland, and China where personal data is routinely processed.

Where a transfer is made to a country outside of the UK or European Economic Area (EEA), the standard of protection for personal data may be lower than it is in the UK or EEA.

Whenever we transfer your personal data outside of the UK or EEA, we take steps to ensure that it is afforded a similar level of protection as within the UK or EEA, by making use of one of the specific safeguards approved by the UK Information Commissioner or European Commission, as appropriate, including carrying out transfer impact assessments and entering into international data transfer agreements, such as the UK’s international data transfers agreement and the EU’s standard contractual clauses.

You may obtain more details of the protection given to your information when it is transferred cross-border by contacting us using the details in the “Contact and DPO” section below.


If you have a complaint about the handling of your personal information, please contact us using the details in the “Contact and DPO” section below. We’ll investigate your complaint and notify you in writing of the outcome as soon as possible and in any event within 30 days of receiving the complaint.

If you're not happy with the response to your complaint, you can refer your complaint to the relevant supervisory authority in your country. In the United Kingdom, we are regulated by the Information Commissioner’s Office (“ICO”). You may make a complaint to the ICO by calling their helpline on 0303 123 1113 (local rate), by starting a live chat athttps://ico.org.uk/make-a-complaint/ or by writing to them at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.


Second Spectrum UK Limited (company no: 11611829, ICO registration no:ZA937925)

Address: 1st Floor 27 Soho Square, London, England, W1D 3QR

Our Data Protection Officer is Maria Hernandes. You may contact Maria and our privacy team by email to:privacy@geniussports.com