Privacy policy
Privacy policy
Introduction
Introduction
Two Degrees Below Ltd. (including www.twodegreesbelow.com) is committed to protecting your privacy and maintaining the security of personal information we receive or collect.
We process personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
The purpose of this privacy notice is to explain what personal information Two Degrees Below and/or its affiliates (“Two Degrees”, “we”, “us” or “our”) collect, how and why we use it, how we protect it, and your rights in relation to the processing of your personal data.
Two Degrees Below Ltd. (including www.twodegreesbelow.com) is committed to protecting your privacy and maintaining the security of personal information we receive or collect.
We process personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
The purpose of this privacy notice is to explain what personal information Two Degrees Below and/or its affiliates (“Two Degrees”, “we”, “us” or “our”) collect, how and why we use it, how we protect it, and your rights in relation to the processing of your personal data.
Changes to the privacy statement and your duty to inform
us of changes
Changes to the privacy statement and your duty to inform us of changes
We may update this privacy notice from time to time to reflect changes in the way we process personal data, the systems we use or applicable law. The latest version will always be available on our website.
You can exercise your privacy rights by contacting us at hello@twodegreesbelow.com or by submitting a request through our online data privacy request form. You do not have to use the online form to exercise your rights. We will consider your request in relation to the personal data we hold about you across our relevant systems and records.
We may update this privacy notice from time to time to reflect changes in the way we process personal data, the systems we use or applicable law. The latest version will always be available on our website.
You can exercise your privacy rights by contacting us at hello@twodegreesbelow.com or by submitting a request through our online data privacy request form. You do not have to use the online form to exercise your rights. We will consider your request in relation to the personal data we hold about you across our relevant systems and records.
The data we collect about you and how we collect it
The data we collect about you and how we collect it
Personal data, or personal information, means any information relating to an identified or identifiable individual. It does not include information where an individual can no longer be identified.
We may collect, use, store and transfer the following categories of personal data:
• Identity and professional data: including your name, job title, employer, professional role and other information relevant to our business relationship with you.
• Contact data: including your email address, postal address and telephone number where appropriate.
• Business relationship and CRM data: including how we became aware of you or your organisation, enquiries, meeting history, communications with Two Degrees Below, relevant areas of interest, relationship history and information relating to prospective or existing business opportunities.
• Marketing and communications data: including your communication preferences and information about how you interact with communications we send, such as emails, invitations, content or forms.
• Technical and website usage data: including IP address, browser and device information, website activity, pages viewed, source or campaign information and cookie or similar identifiers, where permitted by your cookie preferences.
We collect personal data in a number of ways, including:
• Direct interactions: when you contact us, meet with us, register for an event, complete a form, request information, book a meeting, become a client or supplier, submit a job application, or otherwise communicate with Two Degrees Below.
• Business development sources: we may obtain professional contact information from publicly available sources, corporate websites, professional networking platforms, referrals and third-party business information providers in order to identify organisations and individuals who may have a professional interest in our services.
• Our website and communications: subject to your cookie choices and applicable law, we may collect information about how you interact with our website and communications in order to understand engagement and improve our marketing.
• Our business systems: we use customer relationship management and marketing technology, including HubSpot, to manage business contacts, enquiries, meetings, communications, marketing preferences, prospective opportunities and client relationships.
For business development purposes, the information we process is generally limited to professional information such as name, job title, employer, business contact details, professional profile information, industry and relevant organisational information. We do not intentionally collect special category personal data.
Personal data, or personal information, means any information relating to an identified or identifiable individual. It does not include information where an individual can no longer be identified.
We may collect, use, store and transfer the following categories of personal data:
• Identity and professional data: including your name, job title, employer, professional role and other information relevant to our business relationship with you.
• Contact data: including your email address, postal address and telephone number where appropriate.
• Business relationship and CRM data: including how we became aware of you or your organisation, enquiries, meeting history, communications with Two Degrees Below, relevant areas of interest, relationship history and information relating to prospective or existing business opportunities.
• Marketing and communications data: including your communication preferences and information about how you interact with communications we send, such as emails, invitations, content or forms.
• Technical and website usage data: including IP address, browser and device information, website activity, pages viewed, source or campaign information and cookie or similar identifiers, where permitted by your cookie preferences.
We collect personal data in a number of ways, including:
• Direct interactions: when you contact us, meet with us, register for an event, complete a form, request information, book a meeting, become a client or supplier, submit a job application, or otherwise communicate with Two Degrees Below.
• Business development sources: we may obtain professional contact information from publicly available sources, corporate websites, professional networking platforms, referrals and third-party business information providers in order to identify organisations and individuals who may have a professional interest in our services.
• Our website and communications: subject to your cookie choices and applicable law, we may collect information about how you interact with our website and communications in order to understand engagement and improve our marketing.
• Our business systems: we use customer relationship management and marketing technology, including HubSpot, to manage business contacts, enquiries, meetings, communications, marketing preferences, prospective opportunities and client relationships.
For business development purposes, the information we process is generally limited to professional information such as name, job title, employer, business contact details, professional profile information, industry and relevant organisational information. We do not intentionally collect special category personal data.
How we use your personal data
How we use your personal data
We may use personal data to:
• respond to enquiries, meeting requests and requests for information;
• manage prospective and existing client, partner and supplier relationships;
• identify organisations and professional contacts for whom our services may be relevant;
• send relevant B2B communications about our services, thinking, events and other business activity where we have an appropriate lawful basis;
• manage event registrations, invitations and follow-up communications;
• record and manage communication preferences and opt-outs;
• segment our audiences and tailor communications according to professional role, organisation, interests or previous interactions;
• understand engagement with our website and communications and assess the effectiveness of our marketing and business development activity;
• maintain our CRM, sales pipeline, commercial reporting and relationship history;
• comply with our legal and regulatory obligations; and
• establish, exercise or defend legal claims where necessary.
Depending on the circumstances, we process personal data on one or more of the following lawful bases:
• Legitimate interests, including developing our business, identifying prospective corporate clients, maintaining professional relationships, communicating relevant information about our services and operating our business effectively, where those interests are not overridden by your rights and interests.
• Performance of a contract or steps prior to entering into a contract, for example where you request a proposal, engage us to provide services or we need to administer an existing commercial relationship.
• Consent, where applicable, including certain marketing communications and the use of non-essential cookies or similar technologies.
• Legal obligations, where processing is necessary for us to comply with the law.
Where we rely on legitimate interests for direct marketing, we aim to ensure that our communications are relevant and proportionate to your professional role and reasonable expectations. You have the right to object to direct marketing at any time.
We may use automation within our CRM and marketing systems to organise contacts, segment audiences, manage workflows or trigger relevant communications. We do not use this activity to make solely automated decisions about individuals that produce legal or similarly significant effects.
We do not sell, rent or exchange your personal information with third parties for their own commercial purposes.
We may use personal data to:
• respond to enquiries, meeting requests and requests for information;
• manage prospective and existing client, partner and supplier relationships;
• identify organisations and professional contacts for whom our services may be relevant;
• send relevant B2B communications about our services, thinking, events and other business activity where we have an appropriate lawful basis;
• manage event registrations, invitations and follow-up communications;
• record and manage communication preferences and opt-outs;
• segment our audiences and tailor communications according to professional role, organisation, interests or previous interactions;
• understand engagement with our website and communications and assess the effectiveness of our marketing and business development activity;
• maintain our CRM, sales pipeline, commercial reporting and relationship history;
• comply with our legal and regulatory obligations; and
• establish, exercise or defend legal claims where necessary.
Depending on the circumstances, we process personal data on one or more of the following lawful bases:
• Legitimate interests, including developing our business, identifying prospective corporate clients, maintaining professional relationships, communicating relevant information about our services and operating our business effectively, where those interests are not overridden by your rights and interests.
• Performance of a contract or steps prior to entering into a contract, for example where you request a proposal, engage us to provide services or we need to administer an existing commercial relationship.
• Consent, where applicable, including certain marketing communications and the use of non-essential cookies or similar technologies.
• Legal obligations, where processing is necessary for us to comply with the law.
Where we rely on legitimate interests for direct marketing, we aim to ensure that our communications are relevant and proportionate to your professional role and reasonable expectations. You have the right to object to direct marketing at any time.
We may use automation within our CRM and marketing systems to organise contacts, segment audiences, manage workflows or trigger relevant communications. We do not use this activity to make solely automated decisions about individuals that produce legal or similarly significant effects.
We do not sell, rent or exchange your personal information with third parties for their own commercial purposes.
Marketing communications
Marketing communications
Where permitted by law, we may contact professional contacts at corporate organisations about Two Degrees Below services, ideas, events or opportunities that we reasonably believe are relevant to their role.
Where consent is required, we will obtain it before sending the relevant marketing communication.
Every marketing communication will provide an appropriate way to unsubscribe or object. Where you opt out, we may retain limited information on a suppression list so that we can ensure your preference continues to be respected.
Where permitted by law, we may contact professional contacts at corporate organisations about Two Degrees Below services, ideas, events or opportunities that we reasonably believe are relevant to their role.
Where consent is required, we will obtain it before sending the relevant marketing communication.
Every marketing communication will provide an appropriate way to unsubscribe or object. Where you opt out, we may retain limited information on a suppression list so that we can ensure your preference continues to be respected.
Cookies and website tracking
Cookies and website tracking
We use cookies and similar technologies on our website, including technologies that may allow us to understand website usage and, where applicable, associate website interactions with existing business contacts.
Non-essential cookies and similar tracking technologies are used in accordance with your choices through our cookie consent mechanism. You can change your cookie preferences at any time through the cookie settings available on our website.
Further information about the cookies and similar technologies we use is available in our Cookie Policy.
We use cookies and similar technologies on our website, including technologies that may allow us to understand website usage and, where applicable, associate website interactions with existing business contacts.
Non-essential cookies and similar tracking technologies are used in accordance with your choices through our cookie consent mechanism. You can change your cookie preferences at any time through the cookie settings available on our website.
Further information about the cookies and similar technologies we use is available in our Cookie Policy.
Service providers and sharing of personal data
Service providers and sharing of personal data
We use selected third-party service providers to support the operation of our business. These may include providers of CRM and marketing technology, website hosting, email, analytics, IT, professional services and other business systems.
In particular, we use HubSpot as our customer relationship management and marketing platform. HubSpot may process personal data on our behalf to provide CRM, marketing, communications, forms, meeting scheduling, reporting and related functionality.
We require service providers processing personal data on our behalf to handle that information appropriately and in accordance with applicable data protection law and our contractual arrangements with them.
We do not sell or rent your personal information to third parties.
We use selected third-party service providers to support the operation of our business. These may include providers of CRM and marketing technology, website hosting, email, analytics, IT, professional services and other business systems.
In particular, we use HubSpot as our customer relationship management and marketing platform. HubSpot may process personal data on our behalf to provide CRM, marketing, communications, forms, meeting scheduling, reporting and related functionality.
We require service providers processing personal data on our behalf to handle that information appropriately and in accordance with applicable data protection law and our contractual arrangements with them.
We do not sell or rent your personal information to third parties.
Data security
Data security
We have put in place appropriate security measures designed to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We limit access to personal data to employees, agents, contractors and other third parties who have a legitimate business need to access it. Where they process personal data on our behalf, they are required to do so appropriately and subject to relevant confidentiality and data protection obligations.
We have procedures in place to deal with suspected personal data breaches and will notify affected individuals and any applicable regulator where we are legally required to do so.
We have put in place appropriate security measures designed to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We limit access to personal data to employees, agents, contractors and other third parties who have a legitimate business need to access it. Where they process personal data on our behalf, they are required to do so appropriately and subject to relevant confidentiality and data protection obligations.
We have procedures in place to deal with suspected personal data breaches and will notify affected individuals and any applicable regulator where we are legally required to do so.
Data retention
Data retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting requirements.
When determining an appropriate retention period, we consider the amount, nature and sensitivity of the data, the purposes for which it is processed, the potential risk from unauthorised use or disclosure, whether those purposes can be achieved through other means, and applicable legal requirements.
Business development and prospect records are reviewed periodically and deleted when they are no longer required for business development purposes.
We may retain limited suppression records where necessary to ensure that individuals who have opted out of marketing communications are not contacted again.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting requirements.
When determining an appropriate retention period, we consider the amount, nature and sensitivity of the data, the purposes for which it is processed, the potential risk from unauthorised use or disclosure, whether those purposes can be achieved through other means, and applicable legal requirements.
Business development and prospect records are reviewed periodically and deleted when they are no longer required for business development purposes.
We may retain limited suppression records where necessary to ensure that individuals who have opted out of marketing communications are not contacted again.
International transfers
International transfers
Some of our suppliers and technology providers may store or process personal data outside the United Kingdom or allow access to it from other countries.
Where personal data is transferred internationally, we take appropriate steps to ensure that it remains protected in accordance with applicable data protection law. These safeguards may include transfers to countries recognised as providing an adequate level of protection or the use of approved contractual safeguards, such as the UK International Data Transfer Addendum or other legally recognised transfer mechanisms.
Some of our suppliers and technology providers may store or process personal data outside the United Kingdom or allow access to it from other countries.
Where personal data is transferred internationally, we take appropriate steps to ensure that it remains protected in accordance with applicable data protection law. These safeguards may include transfers to countries recognised as providing an adequate level of protection or the use of approved contractual safeguards, such as the UK International Data Transfer Addendum or other legally recognised transfer mechanisms.
Your legal rights
Your legal rights
Under data protection law, you may have rights in relation to your personal data, including the right to:
• Request access to your personal data, enabling you to receive a copy of the personal data we hold about you and check that we are processing it lawfully.
• Request correction of incomplete or inaccurate personal data we hold about you.
• Request erasure of your personal data where there is no lawful reason for us to continue processing it, subject to applicable legal exceptions.
• Object to processing of your personal data where we rely on legitimate interests.
• Request restriction of processing of your personal data in certain circumstances.
• Request transfer of personal data to you or, where applicable, another organisation.
• Object to direct marketing at any time. Where you object, we will stop using your personal data for direct marketing purposes.
• Withdraw consent at any time where we rely on consent as the lawful basis for processing. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
You can exercise these rights by contacting us at hello@twodegreesbelow.com.
Under certain circumstances, by law, you have the following rights in relation to your personal data:
Request access to your personal data (commonly known as “data subject access request”): this enables you to receive a copy of your personal data and to check that we are lawfully processing it;
Request a rectification to your personal data: this entitles you to have any incomplete or inaccurate personal data corrected;
Request the erasure of your personal data (often referred to as the “right to be forgotten”): this entitles you to request your personal data be deleted 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 information where you have exercised your right to object to processing (below);
Object to the processing of your personal data: this entitles you to request that we no longer process your personal data;
Request the restriction of the processing of your personal data: this entitles you to request that we suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interest but we need to hold some of it for the purpose of legal proceedings;
Request transfer of your personal data: this entitles you to receive a copy of your personal data, or request we transmit such personal data to another party; and
• Withdraw your consent at any time: where we are relying on consent to process your personal data you may withdraw this consent at any time by contacting us at
hello@twodegreesbelow.com.
Use of AI in recruitment
Use of AI in recruitment
Where you apply for a role with us, we may process the information you provide as part of your application, including your CV, covering letter, portfolio, application answers, interview notes and any recruitment task materials.
We may use approved AI tools to help summarise application materials, compare relevant experience against role requirements and support interview preparation.
AI is used as a support tool only. We do not reject, shortlist or hire candidates solely on the basis of an AI-generated recommendation.
All recruitment decisions are reviewed and made by people, who are expected to consider the original application materials and apply their own judgement.
To support fairness and consistency, we aim to assess candidates against job-related criteria and use consistent prompts or assessment approaches for candidates applying for the same role.
We do not use AI tools to assess, infer or make decisions based on protected characteristics or other sensitive personal information.
Candidate information is only processed using approved company systems and approved AI tools and must not be entered into personal accounts or unapproved public AI tools.
Recruitment information, including CVs, interview notes, candidate tasks and related AI-supported outputs, will only be retained for as long as necessary for recruitment purposes and will then be securely deleted in line with our data retention approach.
If you have questions about how AI has been used in relation to your application, or believe your information has been misunderstood, you can contact us and ask for this to be reviewed by a person.
Please do not hesitate to contact us, using the details below, if you:
• have any questions about privacy or this particular statement
• wish to exercise your rights in relation to your personal data rights
• wish to make a complaint about our use of your data.
Email address:
hello@twodegreesbelow.com
Postal address: Two Degrees Below Ltd., 1 Brackenwood Road, Wakefield, West Yorkshire, WF1 3TH, UK
If, despite our commitment and efforts to safeguard your personal data, you have any concerns or complaints about our privacy activities, you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.
Contact us
Contact us
Please contact us if you:
• have any questions about privacy or this notice;
• wish to exercise any of your rights in relation to your personal data; or
• wish to make a complaint about our use of your personal data.
Email: hello@twodegreesbelow.com
Online privacy requests can be submitted via this form.
Postal address: Two Degrees Below Ltd., 1 Brackenwood Road, Wakefield, West Yorkshire, WF1 3TH, UK
If you have concerns or complaints about our handling of your personal data, you also have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would appreciate the opportunity to address your concerns first, so please contact us in the first instance.
Version: 4
Date: September 2026
Owner: Clare Taylor
Next Review: September 2027
Next date for annual issue: September 2027
Please do not hesitate to contact us, using the details below, if you:
• have any questions about privacy or this particular statement
• wish to exercise your rights in relation to your personal data rights
• wish to make a complaint about our use of your data.
Email address:
hello@twodegreesbelow.com
Postal address: Two Degrees Below Ltd., 1 Brackenwood Road, Wakefield, West Yorkshire, WF1 3TH, UK
If, despite our commitment and efforts to safeguard your personal data, you have any concerns or complaints about our privacy activities, you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.
