Last update: 6 November 2022
Two Dudes UK cares about privacy and protecting all Personal Data handled by us.
This policy describes how and why we use your Personal Data, the lawful basis on which we use your Personal Data and what measures we take to protect it. It also provides information on how to exercise your rights in connection with our Processing of Personal Data.
Two Dudes Reg. No. (12480474) (Two Dudes UK, we, us, our) is the Controller of all Personal Data listed in this Privacy Policy (the Policy).
This Policy provides information on how we handle Personal Data when you communicate with us, use the Services or visit our website, http://twodudes.uk (together the Functions).
Users of the Services
Employees of potential customers
Employees of existing customers
Visitors to our website
Applicable Law refers to the legislation applicable to the Processing of Personal Data, including the UK GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by the Commissioner or other relevant regulatory authority.
Commissioner means the Information Commissioner’s Office (the UK regulator for data protection issues).
Controller is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
Data Subject is the living, natural person whose Personal Data is being processed.
Personal Data is all information relating, directly or indirectly, to an identifiable natural person.
Processing means any operation or set of operations which is performed on Personal data, such as storage, modification, reading, handover and similar.
Processor is the company/organisation that processes Personal Data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
The Services We provide social media marketing, influencer marketing, content creation, web design, web maintenance and paid Ads.
UK GDPR means the retained EU law version of the General Data Protection Regulation ((EU) 2016/679).
The definitions above shall apply in the Policy regardless of whether they are capitalised or not.
The information in this Policy covers Personal Data Processing for which Two Dudes UK is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of (“the why”) and the means of the Processing (what methods, what Personal Data and how long the Personal Data is stored). The Policy does not describe how we Process Personal Data in the role of a Processor (i.e. when we process Personal Data on behalf of our customers).
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we Process your Personal Data. This section aims to give you an understanding of what type of Personal Data we Process and the lawful basis on which we Process that Personal Data.
In order for us to be able to process your Personal Data, it is required that we have so-called legal basis for each process. In our business, we process your personal data mainly on the following grounds:
Consent – Two Dudes UK may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract – The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
We will keep your Personal Data no longer than is necessary for the purpose for which it was collected. Depending on the lawful basis on which we justify the Processing, this may: a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) be based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, how long the Personal Data will be stored and the criteria used to determine the storage period.
We never store your Personal Data longer than necessary and delete Personal Data regularly. Two Dudes UK also takes reasonable actions to keep the Personal Data up-to-date and to delete outdated and otherwise incorrect or redundant Personal Data.
The main purpose of the Processing undertaken by us is to provide, carry out and improve our services to you. There are several different reasons why we may need to collect, manage and save your data.
We mainly Process the following types of Personal Data:
Contact details to be able to confirm your identity, to verify your personal and contact details and to be able to communicate with you
Information on your usage of the service or product to improve our services provided to you
IP-address to perform customer analysis and for content on our site to be presented effectively to you and the device you use
Payment information to be able to offer (for example direct debit and other payment options)
We collect your Personal Data in a number of different ways. We mainly collect your Personal Data:
By you providing your Personal Data to us when you use the Functions
By your employer providing your Personal Data to us
By social media such as Facebook or Instagram
Through third-party analysis technology such as cookies
Through information created from data analysis
Through generated information that has been obtained internally
You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access (art 15) – You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification (art 16 GDPR) – If you think that any of your Personal Data that we process is incorrect, let us know and we will fix it!
Erasure (art 17 GDPR) – Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections (art 21 GDPR) – Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry – in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction (art 18 GDPR) – You can also ask us to restrict our Processing of your Personal Data:
Whilst we are Processing a request from you for any of your other rights;
If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability (art 20 GDPR) – We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent (art 7 GDPR) – If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.
If you wish to exercise any of the rights set out above, please hello@twodudes.uk.
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the UK, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by ensuring that one of the following requirements is fulfilled:
it has been determined that the level of protection is adequate in the third country where the data is processed;
the Processor has signed up to the EU Commission’s standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPAs) with all our Processors. Each DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Two Dudes UK does not sell your Personal Data to third parties and of course we do not share your Personal Data with just anyone. However, in some cases we may need to share your Personal Data with selected third parties. If so, we make sure that the transfer happens in a secure way that protects your privacy. To follow are categories of recipients with whom we may share your data.
Advertising agencies and suppliers of print and advertising.
IT suppliers for cloud storage, business systems and case/project management. In order to be able to carry out our assignments and services, we store your Personal Data in our business systems (a system that administers our customers and contacts).
Statistics to contribute to industry statistics and to improve the customer experience.
Two Dudes UK has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access. Organisational measures are measures that are implemented in work methods and routines within our organisation. Technical measures are measures implemented through technical solutions.
Organisational security measures:
Login and password management
Technical security measures:
Encryption
Access control levels
Access logs
Two-step verification
Two Dudes UK uses cookies and similar tracking techniques to analyse the use of the Functions so that we can give you the best user experience. For more information on how we use cookies, see our Cookie Policy (https://twodudes.uk/privacy-policy/).
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Commissioner. You can contact the Commissioner on 03031231113 or via email https://ico.org.uk/global/contact-us/email/.
More information about our obligations and your rights can be found at https://www.gov.uk/government/publications/data-protection-rights-for-data-subjects/data-protection-rights-for-data-subjects
We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
We have appointed a Data Protection Officer who can answer questions about your rights and other questions about how we process your personal information.
Name: RIshi Shah
Email: rishi@twodudes.uk
Why and who?
Two DudesLtd. Reg. No. 12480474 (“Two Dudes“, “we“, “us“, “our“) uses cookies and other tracking technologies (“Cookies“) in order to improve your user experience.
This Cookie Policy describes Two Dudes’s use of Cookies by explaining what Cookies are, why we use them and how you can control the use of Cookies when you use our site (https://twodudes.uk/) (the “Webpage“). This policy does not include information about the use of Cookies that are essential in order to provide the Webpage to you (these are known as strictly necessary cookies).
For more information about how we process your personal data in relation to Cookies, see our Privacy Policy, which is available here: https://twodudes.uk/privacy-policy/.
What are Cookies?
A Cookie is a text file that is sent from the Webpage and stored on your computer, cell phone or any other device that you use to visit the Webpage.
Cookies allow us to, amongst other things, recognise the device you use next time you visit the Webpage, provide certain essential functions and to monitor user behaviour on the Webpage.
How long is the Cookie stored?
There are two types of Cookies – session cookies and permanent cookies.
Session cookies are deleted when you close the browser (e.g. Internet explorer, Safari or Google Chrome).
Permanent cookies remain on your device after you have closed the browser. The Cookie will be stored for as long for the period of time indicated in the Cookie table or until you remove it.
Two Dudes’s use of Cookies
We use the following types of Cookies:
Preference
These Cookies remember your choices on the Webpage (e.g. username, language etc.) and tell us how you have interacted with the Webpage so that we can personalise our service.
Performance
These Cookies analyse how you use the Webpage and monitor the Webpage’s performance. This helps us identify and manage problems. A performance Cookie can keep track of the traffic on different pages as well as the performance of the Webpage and give us information on how long it takes for a page to load.
Operation and optimisation
These Cookies help us ensure that the Webpage is working as it should. They also give us information which allows us to test new ideas and improve the Webpage.
Other tracking technologies
These techniques will help us understand how you use the Webpage. This can, for example, be a small, transparent picture that is embedded in a Webpage or in an e-mail which collects data such as your IP-address, information about your device and your location.
First- and third-party Cookies
First-party Cookies are set by the Webpage on your device and therefore only we can see the data that the Cookie retrieves.
Third party Cookies are set by party other than us when you visit the Webpage. Two Dudes only uses reliable third-parties. Third-party cookies can, amongst other functions, help us understand the needs of our users and give us information on how effective our marketing is. Third-party cookies may in some cases be used on websites other than the Webpage. Information collected by these third-parties cannot identify your name, contact information or other personal information unless you choose to provide it.
Cookies
Our cookie tables (available here: https://twodudes.uk/privacy-policy/) list the Cookies that are used as part of our services. Please note that the names of Cookies may change over time.
Name:
Provider:
Type:
Purpose:
Duration:
Managing Cookies
When you visit the Webpage for the first time, we ask for your consent to use non-necessary cookies. You can withdraw your consent at any time. If you no longer wish to store the Cookies you have accepted, you can go to your web-browser settings and accept, deny or remove Cookies (usually under “Help”, “Settings” or “Edit”). Please note that if you limit the ability of Two Dudes to set Cookies, you may worsen your overall user experience on the Webpage, since it may no longer be personalized to you. It may also mean that you are not able to benefit from the full functionality of our Webpage.
Changes to this Policy
We reserve the right to make changes to this Policy. If a change affects our obligations or your rights, we will inform you about the changes in advance in order to give you the chance to accept the updated policy.
Contact
We have assigned Rishi Shah as our data protection officer. Rishi Shah will be able to answer your questions regarding Cookies and how we process your personal data. You can contact Two Dudes’s data protection officer by emailing rishi@twodudes.uk.
Two Dudes UK’s Privacy Policy
Why and who?
Two Dudes UK cares about privacy and protecting all Personal Data handled by us.
This policy describes how and why we use your Personal Data, the lawful basis on which we use your Personal Data and what measures we take to protect it. It also provides information on how to exercise your rights in connection with our Processing of Personal Data.
Two Dudes Reg. No. (12480474) (Two Dudes UK, we, us, our) is the Controller of all Personal Data listed in this Privacy Policy (the Policy).
This Policy provides information on how we handle Personal Data when you communicate with us, use the Services or visit our website, http://twodudes.uk (together the Functions).
The intended recipients of the information provided in this Policy are:
Users of the Services
Employees of potential customers
Employees of existing customers
Visitors to our website
Definitions
Applicable Law refers to the legislation applicable to the Processing of Personal Data, including the UK GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by the Commissioner or other relevant regulatory authority.
Commissioner means the Information Commissioner’s Office (the UK regulator for data protection issues).
Controller is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
Data Subject is the living, natural person whose Personal Data is being processed.
Personal Data is all information relating, directly or indirectly, to an identifiable natural person.
Processing means any operation or set of operations which is performed on Personal data, such as storage, modification, reading, handover and similar.
Processor is the company/organisation that processes Personal Data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
The Services We provide social media marketing, influencer marketing, content creation, web design, web maintenance and paid Ads.
UK GDPR means the retained EU law version of the General Data Protection Regulation ((EU) 2016/679).
The definitions above shall apply in the Policy regardless of whether they are capitalised or not.
Two Dudes UK’s role as a Controller
The information in this Policy covers Personal Data Processing for which Two Dudes UK is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of (“the why”) and the means of the Processing (what methods, what Personal Data and how long the Personal Data is stored). The Policy does not describe how we Process Personal Data in the role of a Processor (i.e. when we process Personal Data on behalf of our customers).
Two Dudes UK’s Processing of Personal Data
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we Process your Personal Data. This section aims to give you an understanding of what type of Personal Data we Process and the lawful basis on which we Process that Personal Data.
Legal basis
In order for us to be able to process your Personal Data, it is required that we have so-called legal basis for each process. In our business, we process your personal data mainly on the following grounds:
Consent – Two Dudes UK may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract – The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
How long do we store your Personal Data for?
We will keep your Personal Data no longer than is necessary for the purpose for which it was collected. Depending on the lawful basis on which we justify the Processing, this may: a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) be based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, how long the Personal Data will be stored and the criteria used to determine the storage period.
We never store your Personal Data longer than necessary and delete Personal Data regularly. Two Dudes UK also takes reasonable actions to keep the Personal Data up-to-date and to delete outdated and otherwise incorrect or redundant Personal Data.
Processing
The main purpose of the Processing undertaken by us is to provide, carry out and improve our services to you. There are several different reasons why we may need to collect, manage and save your data.
We mainly Process the following types of Personal Data:
Contact details to be able to confirm your identity, to verify your personal and contact details and to be able to communicate with you
Information on your usage of the service or product to improve our services provided to you
IP-address to perform customer analysis and for content on our site to be presented effectively to you and the device you use
Payment information to be able to offer (for example direct debit and other payment options)
How do we collect your Personal Data?
We collect your Personal Data in a number of different ways. We mainly collect your Personal Data:
By you providing your Personal Data to us when you use the Functions
By your employer providing your Personal Data to us
By social media such as Facebook or Instagram
Through third-party analysis technology such as cookies
Through information created from data analysis
Through generated information that has been obtained internally
Your rights
You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access (art 15) – You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification (art 16 GDPR) – If you think that any of your Personal Data that we process is incorrect, let us know and we will fix it!
Erasure (art 17 GDPR) – Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections (art 21 GDPR) – Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry – in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction (art 18 GDPR) – You can also ask us to restrict our Processing of your Personal Data:
Whilst we are Processing a request from you for any of your other rights;
If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability (art 20 GDPR) – We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent (art 7 GDPR) – If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.
If you wish to exercise any of the rights set out above, please hello@twodudes.uk.
Transfer of personal data
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the UK, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by ensuring that one of the following requirements is fulfilled:
it has been determined that the level of protection is adequate in the third country where the data is processed;
the Processor has signed up to the EU Commission’s standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPAs) with all our Processors. Each DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Our processors
Two Dudes UK does not sell your Personal Data to third parties and of course we do not share your Personal Data with just anyone. However, in some cases we may need to share your Personal Data with selected third parties. If so, we make sure that the transfer happens in a secure way that protects your privacy. To follow are categories of recipients with whom we may share your data.
Advertising agencies and suppliers of print and advertising.
IT suppliers for cloud storage, business systems and case/project management. In order to be able to carry out our assignments and services, we store your Personal Data in our business systems (a system that administers our customers and contacts).
Statistics to contribute to industry statistics and to improve the customer experience.
Security measures
Two Dudes UK has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access. Organisational measures are measures that are implemented in work methods and routines within our organisation. Technical measures are measures implemented through technical solutions.
Organisational security measures:
Login and password management
Technical security measures:
Encryption
Access control levels
Access logs
Two-step verification
Cookies
Two Dudes UK uses cookies and similar tracking techniques to analyse the use of the Functions so that we can give you the best user experience. For more information on how we use cookies, see our Cookie Policy (https://twodudes.uk/privacy-policy/).
If we don’t keep our promise
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Commissioner. You can contact the Commissioner on 03031231113 or via email https://ico.org.uk/global/contact-us/email/.
More information about our obligations and your rights can be found at https://www.gov.uk/government/publications/data-protection-rights-for-data-subjects/data-protection-rights-for-data-subjects
Changes to this policy
We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
Contact
We have appointed a Data Protection Officer who can answer questions about your rights and other questions about how we process your personal information.
Contact information for Two Dudes UK data protection representative:
Name: RIshi Shah
Email: rishi@twodudes.uk
