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 any personal information received from you. We strictly adhere to the requirements of the applicable data protection laws, including the General Data Protection Regulation and the UK Data Protection Act 2018, as well as our data privacy policies.
The purpose of this notice is to explain to you what personal information Two Degrees and/or its affiliates (“Two Degrees”, “we”, “us” or “our”) collect, how we may use it and will look after it, as well as tell you about your privacy 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 any personal information received from you. We strictly adhere to the requirements of the applicable data protection laws, including the General Data Protection Regulation and the UK Data Protection Act 2018, as well as our data privacy policies.
The purpose of this notice is to explain to you what personal information Two Degrees and/or its affiliates (“Two Degrees”, “we”, “us” or “our”) collect, how we may use it and will look after it, as well as tell you about your privacy 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
This privacy notice is effective as of December 2023 and will be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws. Any updates will be posted on our website so that you are aware of the information we collect and how we use it at all times. Continued use of the website and communication with us will constitute your agreement to any such changes.
It is important that the personal data we hold about you is accurate and current. Please therefore keep us informed if your personal data changes (or if you wish to verify or remove your personal details) during your relationship with us by contacting us at hello@twodegreesbelow.com.
This privacy notice is effective as of December 2023 and will be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws. Any updates will be posted on our website so that you are aware of the information we collect and how we use it at all times. Continued use of the website and communication with us will constitute your agreement to any such changes.
It is important that the personal data we hold about you is accurate and current. Please therefore keep us informed if your personal data changes (or if you wish to verify or remove your personal details) during your relationship with us by contacting us at hello@twodegreesbelow.com.
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 about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following types of personal data
• Identity data: including first name, last name, marital status, title, date of birth and gender;
• Contact data: including residential address, email address and telephone number;
• Technical data: including IP address used to connect your computer or mobile device to the internet, browser type and version, operating system and platform and other technologies on the devices you use to access this Website.
We use different methods to collect personal data from you, including through
• Direct interactions. For example, when we interact with you for business purposes or contact you with business related information that we consider may be of interest to you. Also, if you make an enquiry or submit a job application you will be asked to provide certain information including name, email address and telephone number.
• Automated technologies or interactions. When you interact with our Website, we may automatically collect information about your equipment, browsing action and patterns. This information is collected through cookies. A cookie is an element of data that our Website sends to your browser which is then stored on your system. You can set your browser to prevent this happening. Any information collected in this way can be used to identify you unless you change your browser settings.
• We may obtain professional contact information about individuals from third-party business information providers, publicly available sources, professional networking platforms, referrals and corporate websites for the purpose of identifying organisations and individuals who may be interested in our services.
• For business development purposes, we may process: name, job title, employer, business email address, business telephone number, professional social media profile information, industry and organisational information
We do not collect sensitive data about you without your express consent and would only do so in accordance with data privacy laws and our cookie policy.
“Sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment. Such categories included racial or ethnic origin, political opinions, biometric and genetic data, criminal records, religious beliefs and physical and mental health.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following types of personal data
• Identity data: including first name, last name, marital status, title, date of birth and gender;
• Contact data: including residential address, email address and telephone number;
• Technical data: including IP address used to connect your computer or mobile device to the internet, browser type and version, operating system and platform and other technologies on the devices you use to access this Website.
We use different methods to collect personal data from you, including through
• Direct interactions. For example, when we interact with you for business purposes or contact you with business related information that we consider may be of interest to you. Also, if you make an enquiry or submit a job application you will be asked to provide certain information including name, email address and telephone number.
• Automated technologies or interactions. When you interact with our Website, we may automatically collect information about your equipment, browsing action and patterns. This information is collected through cookies. A cookie is an element of data that our Website sends to your browser which is then stored on your system. You can set your browser to prevent this happening. Any information collected in this way can be used to identify you unless you change your browser settings.
• We may obtain professional contact information about individuals from third-party business information providers, publicly available sources, professional networking platforms, referrals and corporate websites for the purpose of identifying organisations and individuals who may be interested in our services.
• For business development purposes, we may process: name, job title, employer, business email address, business telephone number, professional social media profile information, industry and organisational information
We do not collect sensitive data about you without your express consent and would only do so in accordance with data privacy laws and our cookie policy.
“Sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment. Such categories included racial or ethnic origin, political opinions, biometric and genetic data, criminal records, religious beliefs and physical and mental health.
How we use your personal data
How we use your personal data
We only use your personal data where required for specific purposes. Most commonly, we will use your personal data in the following circumstances:
• We may process business contact information to identify and contact individuals with responsibility for areas relevant to our services, including leadership, employee engagement, organisational culture, learning and development and people strategy
• Our legitimate interests include identifying prospective business clients, building commercial relationships and providing relevant information about our services to professional contacts where this is proportionate and consistent with their reasonable expectations
• Where we need to comply with a legal or regulatory obligation
Unless we consider we have a legitimate business reason for contacting you, we will only contact you with your consent, and you have the right to withdraw your consent at any time.
We do not sell, rent or exchange your personal information with any third party for commercial reasons.
We only use your personal data where required for specific purposes. Most commonly, we will use your personal data in the following circumstances:
• We may process business contact information to identify and contact individuals with responsibility for areas relevant to our services, including leadership, employee engagement, organisational culture, learning and development and people strategy
• Our legitimate interests include identifying prospective business clients, building commercial relationships and providing relevant information about our services to professional contacts where this is proportionate and consistent with their reasonable expectations
• Where we need to comply with a legal or regulatory obligation
Unless we consider we have a legitimate business reason for contacting you, we will only contact you with your consent, and you have the right to withdraw your consent at any time.
We do not sell, rent or exchange your personal information with any third party for commercial reasons.
Data security
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.
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.
Data retention
Data retention
We maintain a specific data retention policy to ensure that we only retain your personal data for as long as necessary to fulfil the purpose 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 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 through other means, and the applicable legal requirements.
Business development and prospect records will be reviewed periodically and deleted when they are no longer required for business development purposes. We may retain limited suppression records where necessary to ensure individuals who have opted out are not contacted again.
We maintain a specific data retention policy to ensure that we only retain your personal data for as long as necessary to fulfil the purpose 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 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 through other means, and the applicable legal requirements.
Business development and prospect records will be reviewed periodically and deleted when they are no longer required for business development purposes. We may retain limited suppression records where necessary to ensure individuals who have opted out are not contacted again.
International transfers
International transfers
We may from time to time wish to transfer personal data to our other group entities or third parties supporting the operation of our business which may involve transferring data outside the European Economic Area (EEA).
Prior to making any such transfer of personal data, we will take the necessary steps to ensure that a similar degree of protection is afforded to your personal data in accordance with the applicable data privacy laws.
We may from time to time wish to transfer personal data to our other group entities or third parties supporting the operation of our business which may involve transferring data outside the European Economic Area (EEA).
Prior to making any such transfer of personal data, we will take the necessary steps to ensure that a similar degree of protection is afforded to your personal data in accordance with the applicable data privacy laws.
Your legal rights
Your legal rights
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
• Where we process your personal data for direct marketing purposes, you have an absolute right to object at any time. If you opt out, we will stop sending marketing communications and retain limited information where necessary to ensure your preference is respected
• 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
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, and 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 public AI tools
• Recruitment information, including CVs, interview notes, candidate tasks and related AI-supported outputs, will only be kept 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 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.
Version: 3
Date: July 2026
Owner: Clare Taylor
Next Review: July 2027
Next date for annual issue: August 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.
