Two Dot Technologies Ltd Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information. It explains our identity, what data we collect, why and how we process it, your rights, and how we protect your information.

Table of Contents

• Who we are
• What data we collect
• Why we collect it (lawful basis)
• How we use it
• Data retention
• Third parties and data transfers
• User rights
• Security measures
• Cookies
• How to complain

What Data We Collect

We may collect the following types of information:

• Name
• Contact details (such as email address, phone number)
• Account information
• Viewing history
• Account history
• IP address
• Device information
• Browser information
• Website analytics data
• App analytics data
• Marketing preferences
• Consent records
• Financial information (if required for payments)
• Transaction information (if required for payments)
• Information submitted via contact forms
• Information submitted via correspondence
• Meeting transcription data
• Anonymised meeting audio
• Email addresses
• Communication Metadata - we explicitly DO NOT store the content of any communications on our, or any other 3rd party's, servers.
• Cookie data (see Cookies section below)
• Tracking data (see Cookies section below)

Additionally, we process customer relationship management (CRM) data, but we DO NOT store it.

How We Use Your Data

We use your personal data for purposes including:

• Providing and improving our services
• Administering your account
• Communicating with you and responding to queries
• Sending marketing, promotions, or service updates (with your consent if required)
• Monitoring usage and statistics for analytics
• Security, fraud prevention, and legal compliance
• Improving our website, user experience and services
• Providing the functionality of our software

To Provide Services (including Delivery)

• Names and contact details
• Purchase or account history
• Account information
• Website user information (including user journeys and cookie tracking)
• Information relating to compliments or complaints

For the Operation of Customer Accounts and Guarantees

• Names and contact details
• Purchase history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences

For Service Updates or Marketing Purposes

• Names and contact details
• Account information
• Call recordings
• Relevant information from previous investigations
• Customer or client accounts and records
• Financial transaction information
• Correspondence

For Dealing with Queries, Complaints, or Claims

• Names and contact details
• Account information
• Call recordings
• Relevant information from previous investigations
• Customer or client accounts and records
• Financial transaction information
• Correspondence

Lawful Bases and Data Protection Rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Your Data Protection Rights

• Right of access: You have the right to ask us for copies of your personal information.
• Right to rectification: You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Right to erasure: You have the right to ask us to delete your personal information.
• Right to restriction of processing: You have the right to ask us to limit how we can use your personal information.
• Right to object to processing: You have the right to object to the processing of your personal data.
• Right to data portability: You have the right to ask that we transfer your personal information to another organisation, or to you.
• Right to withdraw consent: When we use consent as our lawful basis, you have the right to withdraw your consent at any time.

You can exercise your rights at any time by contacting us at info@twodot.co. If you make a request, we must respond to you without undue delay and in any event within one month.

Our Lawful Bases for the Collection and Use of Your Data

To Provide Services and Goods

• Consent: We have permission from you after we gave you all the relevant information.
• Legitimate Interests: We're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone.

For the Operation of Customer Accounts and Guarantees

• Consent: We have permission from you after we gave you all the relevant information.
• Legitimate Interests: We're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone.

For Service Updates or Marketing Purposes

• Consent: We have permission from you after we gave you all the relevant information.
• Legitimate Interests: We're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone.

For Dealing with Queries, Complaints, or Claims

• Consent: We have permission from you after we gave you all the relevant information.
• Legitimate Interests: We're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone.

Where We Get Personal Information From

• Directly from you
• Publicly available sources

Data Retention

We only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for legal, regulatory, tax, or reporting requirements. When your information is no longer needed, it will be securely deleted or anonymised. For details, see our retention schedule:https://twodot.co/data-retention

Who We Share Information With

We may share your information with trusted third parties for the purposes outlined above. They are:

• Service providers assisting with data hosting (Google Cloud), analytics (Google Analytics), marketing, or communication
• Regulatory bodies and legal authorities if required by law or to protect our rights

No other third parties have access to your data.

Some service providers may store or process data outside the United Kingdom or European Economic Area (EEA). Where this occurs, we ensure that appropriate safeguards are in place (such as Standard Contractual Clauses or adequacy decisions).

Security Measures

We take the security of your information seriously. We use safeguards such as encryption, access controls, secure servers, and (where appropriate) pseudonymisation to protect your data from loss, unauthorised access, or misuse.

• We retrieves the least possible amount of data that we need and only store it if absolutely necessary. This means senitive CRM data, for example, is NOT stored on our systems and by disconnecting your CRM from Two Dot, we immediately lose access to this data.
• We encrypt all customer data during both transmission and storage to prevent malicious access
• Additionally, we encrypt all API access keys that our software uses to connect to your infrastructure. This prevents our team or any external malicious actor from having unauthorised access into your data.

Additionally, our software license agreement contains a NDA to prevent us sharing sensititve informtion.

Cookies

Our website uses cookies and similar technologies to improve your experience, for analytics, and for marketing purposes. For more detail about the types of cookies, what they do, and how you can manage preferences, please see our Cookie Policy.

How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

Last updated: 2025_11_16