Privacy policy

Welcome to Two AS’s (trading as Two: “Two”, “we”, “us”, “our”) privacy policy. This privacy policy applies to Two and its subsidiaries, including Two B2B Ltd (UK) and Two Bcommerce AB (Sweden).

We at Two take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and, how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Controller

Two is the data controller and is responsible for certain personal data about you that we collect and use to supply you with our payment solution services (“the Services”) as a representative of a business customer (including sole traders), or where you use or browse our website.

Contact us

If you have any questions about this policy or about how we handle your data, please contact our data privacy team as follows:

Email: privacy@two.inc

Address: 4 Crown Place, EC2A 4BT

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 27 February 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.‍

1. The data we collect about you

1. 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).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:‍

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‍Representatives of business customers including marketplace customers or e-commerce merchants, representatives of third party providers and strategic partners‍

1. • Identity Data: includes name, job title, company name
   • Contact Data: includes company email address and telephone number job title and company details where applicable.  
   • Marketing Data: includes your preferences in receiving marketing communications from us or third parties.  
   • Profile Data: includes your username, for the buyer or merchant portal, feedback including in relation to ‘KYC Questions’, invoices, your contact history.
   • Usage Data: information about how you use our website, IT, communication and other systems.
   • Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.

Sole traders

1. • Identity Data: includes name, social security number (Sweden only).
   • Contact Data: includes address, billing address and delivery address (if different), email address and telephone numbers.
   • Marketing Data: includes your preferences in receiving marketing communications from us or third parties.  
   • Profile Data: includes your username, feedback, invoices, your contact history
   • Credit Check Data: consumer credit file including credit and repayment history and credit score, and ID verification documents, where appropriate details about payments to and from the bank account you provide during the credit application process, which we collect via our Open Banking providers. Separately, we collect and store information about your transactions with Us..
   • Transaction Data: includes details about payments to and from Us and other details of the Services and Goods you have purchased via us.
   • Usage Data: includes information about how you use our website, and the Services.
   • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. ‍

Website users

1. • Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
   • Usage Data: information about how you use our website, IT, communication and other systems
     

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Third-party links

Our website (two.inc) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Third-party apps, websites and services

If you use any third party apps, websites or services to access our services, your usage is subject to the relevant third party's terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform. ‍

If you fail to provide personal data‍

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a service you have purchased from us but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

1. • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise for example if you contact our customer services team. This includes personal data you provide when you:
   • apply for the Services including via our platforms, such as the Two Buyer Portal, and the Two Merchant Portal;
   • sign up for a demo on our website;
   • create an account
   • request marketing to be sent to you; or
   • give us feedback or contact us.
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   • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy www.two.inc/cookie-policy for further details.
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   • Third parties. We will receive personal data about you from various third parties such as:
   • analytics providers such as Google;
   • providers of services such as: some text
     1. credit checking services;
     2. payment services;
     3. ID verification services; and
     4. Open Banking enabled underwriting services.

For further information regarding specific providers, please contact Us.  ‍

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3. How we use your personal data‍

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. • Where we need to perform the contract we are about to enter into or have entered into with you.
   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   • Where we need to comply with a legal obligation.
   • In limited circumstances where you have given your consent.  

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

1. Purpose/Activity

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

If you are a sole trader, you may receive marketing communications from us if you have consented for us to send you this information or if you have requested information from us or purchased the Services from us and you have not opted out of receiving that marketing.

Opting out and objecting

You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in Two’s emails or by emailing hello@two.inc directly.  

You can object to us carrying out automated decision making by emailing hello@two.inc  however, this may mean that we are unable to provide you with our Services.  

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.two.inc/cookie-policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

1. • External Third Partiessome text
     • Service providers acting as processors who provide services such as credit checking, ID verification, payment processing services and IT and system administration services and email segmentation.  
     • Our debt collection service providers.
     • Financing partners – we sometimes provide information o our financing partners, which include banks ,insurance companies and non-bank lenders, in order to facilitate the provision of our Services.
     • Marketing Companies and Online Advertising – Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, Companies that provide marketing and advertising assistance such as [insert name if relevant] (including management of email marketing operations, mobile messaging services such as SMS, and services that deploy advertising on the internet or social media platforms, such as insert name if relevant) as well as analysis of the effectiveness of our advertising and communications campaigns.
     • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
     • HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
   • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We may share your personal data with external third parties based outside the UK or the European Economic Area (EEA).  

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK/EEA.

Please contact us if you require further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

6. 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.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 your personal 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, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available from us by contacting us.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your Legal Rights) to find out more about these rights.

If you wish to exercise any of these rights please contact our privacy team.  

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.

1. Where our use of the data is unlawful but you do not want us to erase it.
2. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
3. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

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