PRIVACY NOTICE

Welcome to our privacy notice. Two One Vows is committed to protecting and respecting your privacy. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you access it from) and will explain your privacy rights and how the law protects you.

This notice explains how we collect and process your personal data through your use of our website, including any data you may provide directly through our site.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

For the purposes of the Data Protection Act 2018 (the Act), Two One Vows is the data controller. Our Data Protection Officer is Tafadzwa Murdock. He can be contacted at accounts@twoonevows.com. Our registered address is Capital Office, 124 City Road, London, EC1V 2NX. Our ICO registration number is 14496859.

You may contact us to find out more about how we use personal data via email at accounts@twoonevows.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the opportunity to deal with your concerns directly before you approach the ICO, so please contact us in the first instance.

IF YOU DO NOT PROVIDE PERSONAL DATA

If we need to process the data you provide in order to fulfil our services, and you fail to provide that data when requested, we may not be able to perform the service. In such cases, we may have to cancel a service you have booked with us, and we will notify you if this becomes necessary.

WHAT INFORMATION DO WE USE?

We will collect and process the following information about you:

1. Information You Give Us:
You provide this information by filling in forms on our website (www.twoonevows.com) or by corresponding with us via email. This may include your full name, email address, physical address, and phone number—basic personal data required for communication, service use, entering competitions, or reporting problems.

2. Information We Collect About You:
Each time you visit our website, we automatically collect technical and usage data such as:

  • Content statistics (e.g., your input on the website)
  • Technical information (e.g., device identifiers, device type, geo-location data, connection details, IP address, browser type and version, operating system, and time zone)
  • Activity information (e.g., clickstream data, page response times, length of visits, interactions like scrolling or clicking, and any phone number used to call our customer service)

3. Information We Receive From Other Sources:
This includes data we receive about you if you use any of our other websites or services. We work closely with third parties (e.g., business partners, sub-contractors for technical, payment, and delivery services) and will notify you when we receive personal data about you from these sources, along with the purposes for which we intend to use that information.

COOKIES

Our website uses cookies to distinguish you from other users. This helps us provide you with a better browsing experience and allows us to improve our site. By visiting our website for the first time, you agree to our cookie control system. For detailed information on the cookies we use and their purposes, please see our Cookie Policy.

HOW DO WE USE YOUR INFORMATION?

We will only use personal data where the law allows us to. You will not be subject to decisions based solely on automated data processing without your prior consent. Common purposes include:

  • Contract Performance: Using your personal data to perform the contract we are about to enter or have entered into with you.
  • Communication: Providing email notifications, newsletters, and marketing communications either at your request or with your consent.
  • Legitimate Interests: Processing data where it is necessary for our legitimate interests, provided that your interests and fundamental rights do not override these interests.
  • Service Delivery: Ensuring our service is delivered efficiently, such as notifying you of changes, generating relevant content, tailoring the website to your interests, and improving our visibility to potential collaborators.
  • Customer Service: Managing inquiries, complaints, and service updates.
  • Internal Administration: Supporting and improving our services, record keeping, and marketing or demographic studies.
  • Security: Protecting our website and services.
  • Legal Obligations: Complying with any legal or regulatory requirements.
  • Breach Investigation: Investigating potential breaches of our Terms and Conditions.

We will ask for your consent before using your information for any purpose other than those stated in this privacy notice.

AUTOMATED DECISION MAKING

We may use automated decision making in processing your personal information for some services and products. If you are unhappy with an automated decision, you can request a manual review of its accuracy.

MARKETING

We strive to provide you with choices regarding the use of your personal data for marketing and advertising. We may use your contact details and technical data (such as your IP address and browsing habits) to determine which products, services, or offers may be relevant to you. You will receive marketing communications from us if you have requested information, purchased goods or services, entered a competition, or registered for a promotion, unless you have opted out.

You can ask us to stop sending you marketing messages at any time by using the opt-out links provided in our communications or by contacting us at accounts@twoonevows.com.

THIRD-PARTY MARKETING

We will obtain your express opt-in consent before sharing your personal data with any external company for marketing purposes.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which it was originally collected, unless we reasonably believe that we need to use it for another purpose that is compatible with the original one. If you wish to know how a new purpose is compatible with the original, please email us at accounts@twoonevows.com. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis for doing so.

Please note that we may process your personal data without your explicit knowledge or consent, as permitted by law.

HOW DO WE SHARE YOUR INFORMATION?

You acknowledge that we may share your personal information with:

  • Our Group: This includes our subsidiaries, our ultimate holding company, and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006).
  • Selected Third Parties: This may include:
    • Google LLC for document storage on Google Drive, email communication via Gmail, and contact management via Google Contacts.
    • Xero Limited for invoicing services.
    • Squarespace Inc. for hosting services.
    • Zapier Inc. for application integration.
    • Airtable Inc. for spreadsheet and database services.
    • Paragon Internet Group Limited (Tsohost) for additional hosting services.
    • Freshworks Inc. for customer relationship management.
    • And select business partners, suppliers, and sub-contractors necessary to perform our contractual obligations with you.

Except as set out in this Privacy Notice or as required by law, we will not share, sell, or distribute your information without your consent.

We may also disclose your personal information:

  • To any third party necessary to fulfil your orders or provide you with a service.
  • Where required by law or court order.
  • To enforce our rights under this Privacy Notice or our Terms and Conditions.
  • In connection with a business transaction, such as a merger or sale of assets, where your personal data may be transferred to the relevant third party.
  • If we are required to disclose or share your data to comply with any legal obligation or to protect the rights, property, or safety of Two One Vows, our customers, or others.

WHERE DO WE STORE YOUR INFORMATION?

All personal data we process is managed by our staff in the UK. For IT hosting and maintenance, this information may be stored on servers outside the European Economic Area (EEA).

Our external service providers—Google, Squarespace, Zapier, Airtable, Tsohost, Freshworks—are based outside the EEA, and their processing of your personal data will involve transfers outside the EEA. In such cases, we ensure that appropriate safeguards are in place:

  • We may use specific contracts approved by the European Commission to provide the same protection as within Europe.
  • For providers in the US, we may rely on the Privacy Shield or other equivalent safeguards.

Appropriate security measures will be in place to protect your information from unauthorized access, unlawful processing, accidental loss, destruction, or damage. However, please note that transmission of information via the internet is not completely secure. Although we work hard to protect your personal data, we cannot guarantee the security of your data during transmission—it is at your own risk.

HOW LONG DO WE KEEP YOUR DATA?

We will retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including to meet legal, accounting, or reporting requirements. Generally, we retain your data for 6 months.

When determining the appropriate retention period, we consider:

  • The amount, nature, and sensitivity of the data.
  • The potential risk of harm from unauthorized use or disclosure.
  • The purposes for which the data is processed.
  • Whether the purpose can be achieved by other means.
  • Applicable legal requirements.

Under UK tax law, we are required to keep basic personal data (name, address, contact details) for a minimum of six (6) years, after which it will be destroyed. In some cases, we may anonymise your data for research or statistical purposes, in which case it may be used indefinitely without further notice.

You can ask us to delete your data under certain circumstances. Please see below for more information.

WHAT ARE YOUR RIGHTS?

Under data protection laws, you have rights regarding your personal data, including the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to the processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Withdraw your consent.

EXERCISING YOUR RIGHTS

If you wish to exercise any of your rights, please email us at accounts@twoonevows.com. We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made several requests, it may take longer, and we will notify you accordingly.

There is no fee to access your personal data or exercise your rights, though we may charge a reasonable fee for clearly unfounded, repetitive, or excessive requests. Alternatively, we may refuse to comply with such requests in these circumstances.

THIRD-PARTY LINKS

Our website may contain links to other websites, plug-ins, and applications. We do not control and are not responsible for the privacy practices of these third-party websites. This Privacy Notice does not apply to their practices. Please consult their privacy policies for information on how they collect and use your personal data.

SOCIAL MEDIA PLATFORMS

Any communications or interactions on third-party social media platforms will be subject to the terms and conditions and privacy policies of those platforms. Please note that Two One Vows will never ask for your personal or sensitive information via social media. We advise that you discuss sensitive information only through email.

This website may also use social sharing buttons to allow you to share content on social media platforms. Use these buttons at your discretion, as the third-party platform may track and store your data.

CHANGES TO OUR PRIVACY NOTICE

Any future changes to our privacy notice will be posted on this page and, where appropriate, communicated to you by email. By continuing to use our website, you agree to the current privacy notice and any updates made in the future.

Please contact us at accounts@twoonevows.com if you have any questions or need further information regarding this Privacy Notice.