Privacy Policy

Twospouts is “a controller” under the General Data Protection Regulation and the Data Protection Act 2018.

Twospouts – “we”, “us”, “our” – recognises the importance of your privacy and is committed to protecting any personal information we collect about you.

FOR THE PURPOSES OF THIS PRIVACY PROMISE, THE WORD “YOU” INCLUDES WEBSITE VISITORS, TWOSPOUTS’S REGISTERED USERS AND PURCHASERS OF TWOSPOUTS’S PRODUCTS AND SERVICES.

THE PURPOSE OF THIS PRIVACY PROMISE IS TO INFORM YOU ABOUT:

• What personal information about you is collected by Twospouts.
• How the information is used.
• With whom the information may be shared.
• How you can access and change any personal information Twospouts holds about you.
• What security procedures are in place to protect the loss, misuse or alteration of your personal information by Twospouts.
• How to contact Twospouts.

THIS PRIVACY PROMISE APPLIES TO ANY PERSONAL INFORMATION YOU PROVIDE US:

• When visiting Twospouts’s website.
• When using the Twospouts online services.
• When entering into an agreement with Twospouts and/or another third party.
• When you Twospouts, or communicate with Twospouts over the telephone or in any other manner including by letter, facsimile or email.
• In addition to collecting personal information directly from you, we may also obtain personal information about you from third party sources such as our training providers and other third party service providers Failure by you to provide personal information when requested by Twospouts may mean that we are unable to provide certain services and products to you.

WHAT TYPES OF INFORMATION DO WE COLLECT?

Twospouts gathers three types of information about you, namely:

1. Aggregated information generated by our systems – or third party systems – to track our website traffic but that which does not identify you personally; and

2. Personal information about you such as your name, contact information, including email address, and in some cases, your billing details and general financial information

3. Other information relevant to customer surveys and/or offers

The type of information that Twospouts collects about you is dependent on how you use the services offered on our website and the products you are interested in purchasing through Twospouts

Generally, Twospouts does not collect ‘sensitive information’ about you.

Sensitive information includes – but is not limited to – information about your race or ethnic origin, your religion and your sexual preferences.

Twospouts will only collect sensitive information about you in the event that it is necessary for the purpose of providing you with a product or service.

In such circumstances, Twospouts will only collect sensitive information with your consent unless we are required by law to collect such information from you.

COLLECTION OF AGGREGATE DATA

Twospouts also collects non personal information in aggregate form to track data such as the total number of visits to our website, the number of visits to specific areas of our website and the domain names of our website visitors’ internet service providers.

We use this information, which remains in aggregate form, to understand how our website visitors use our website so that we can constantly improve and enhance our services. We may also share this information with our training providers for the purpose of providing you with optimal online career management services.

YOUR INTERNET PROVIDER – IP – ADDRESS

Twospouts’s web servers provide us with your IP address – this assists us in the diagnosis of problems and or support issues with our services

COOKIES AND APPLETS

Twospouts uses ‘cookies’ and ‘applets’ in its website systems. These enable you to use services such as free demonstrations of our training courses. You are able to disable cookies and applets via your computer’s web browser however this will restrict access to some web pages and services within the Twospouts website.

HOW WE COLLECT INFORMATION

Twospouts may collect personal information about you directly from you and when you visit our website and you elect to use our services when submitting your details.

Twospouts may also collect personal information about you from our training providers and other third party service providers.

HOW WE USE YOUR PERSONAL INFORMATION

Twospouts may use your personal information for one or more of the following purposes:

• to communicate with you, including via email newsletters.
• to facilitate and process contracts between yourself and Twospouts and/or third parties.
• to identify the number of people using Twospouts website services and establish the nature of their interests.
• to facilitate Twospouts registration.
• to conduct Twospouts marketing activities.
• to provide you with information about Twospouts and its services and products.
• to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

Twospouts may disclose your personal information to our training providers in order to facilitate your enrolment in a selected training course.

Twospouts will only pass on this information where you have expressly consented to allow Twospouts to do so on your behalf.

Twospouts may also disclose your personal information to third party contractors who perform services for us including the management and maintenance of our information systems.

Where your personal information is passed on to third party contractors, Twospouts takes reasonable steps to ensure that these individuals and/or organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

Other than as outlined above, Twospouts will not disclose your personal information without your consent unless disclosure is necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.

ACCESS TO AND CORRECTION OF INFORMATION WE HOLD ABOUT YOU

Upon your request, Twospouts will provide you with access to your personal information unless there is an exception which applies under the General Data Protection Regulation, Data Protection Act 2018 and The Privacy and Electronic Communications – EC Directive – Regulations 2003. If we deny such access, we will tell you why.

Twospouts may recover any reasonable costs incurred in providing you access to the requested information.

To request access to your personal information, please contact Twospouts using one of the contact options provided in our Privacy Promise.

KEEPING INFORMATION UP TO DATE

Twospouts strives to ensure that the information we hold about you is accurate, complete and up to date at all times.

If the personal information we hold about you is inaccurate, incomplete, or no longer up to date, or you wish for your details to be removed from the website, please contact us at michael@twospouts.com so that we may take reasonable steps to address this and/or discuss alternative options with you.

STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

Twospouts takes reasonable steps to protect the security of your personal information in accordance with this Privacy Promise.

Twospouts regularly reviews and implements new security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

Whilst Twospouts strives to protect such information, we cannot ensure or warrant the security of any information you transmit to us or obtain from our online products or services.

Accordingly, use is at your own risk.

Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.

In the event of a personal breach we have in place procedures to ensure that the effects of such breach are minimised and shall liaise with the ICO and with you as appropriate.

More information is available from the data protection officer.

LINKS TO OTHER WEBSITES

Twospouts website contains links to other websites.

Please note that these links are intended for your convenience only.

Links to third party websites do not constitute endorsement, sponsorship or approval by Twospouts of the content, policies or practices of those third party websites.

If you have any concerns regarding your privacy when visiting a linked third party, you should ensure that you check the privacy statement/policies of those websites.

DESTRUCTION OF YOUR PERSONAL INFORMATION

Twospouts will take reasonable steps to destroy or de-identify any personal information about you once the information is no longer required for the purposes for which it was collected or as authorised or required by law.

CHANGES TO TWOSPOUTS PRIVACY PROMISE

From time to time, Twospouts may make changes to this Privacy Promise. Accordingly, we encourage you to periodically review this promise to remain informed about how we collect and protect your personal information. Your continued use of Twospouts website constitutes your acceptance of the collection, use and disclosure of your personal information to the extent outlined in this Privacy Promise as amended from time to time. For further information about the protection of your privacy, please visit the Information Commissioner’s Office website at www.twospouts.com

FEEDBACK AND QUESTIONS ABOUT PRIVACY AND TWOSPOUTS WEBSITE

Twospouts welcomes ideas and feedback about all aspects of our website. This feedback may be used to administer and refine the services we provide and may be shared with Twospouts partners either in aggregate form or with specific
identifying characteristics removed.

If you have any questions regarding this Privacy Promise, practices of Twospouts website or your dealings with Twospouts, you can contact us in the following ways:

Email: michael@twospouts.com, Head of Compliance

Phone: +44 (0) 2086386442

London Address:

Office 7,

35-37 Ludgate Hill,

London EC4M

michael@twospouts