Privacy Notice

Welcome to the 2Heads Privacy Notice. We blend the discipline of strategy, the spark of creativity and the power of technology & innovation to create meaningful experiences that bring brands and people together. With our offering, we naturally collect information on individuals and have written this Privacy Notice to provide clear insights into the specifics of whose information we collect, how we collect it as well as why we collect it.

As the data privacy universe has a lot of technical legal words and phrases, we’ve created a Glossary at the end of this Privacy Notice to explain these terms and phrases. For any words and phrases in this Privacy Notice that start with a capital letter, take a look at the Glossary.

This Privacy Notice was last updated in January 2024 by our Data Protection Team and it’s regularly kept under review and updated as and when necessary. If you have any questions about it, please do reach out to our Data Protection Team on privacy@2heads.com.

1. Key information about our business 

Our business consists of the following legal entities:

• 2 Heads Design Inc. (entity incorporated in the United States of America).

• 2 Heads Global Design Limited (entity incorporated in England & Wales with the company registration number of02004364).

• 2 Heads Globally Holdings Limited (entity incorporated in England & Wales with the company registration number of 07097156).

• 2 Heads Employee Benefit Trust Limited (entity incorporated in England & Wales with the company registration number of 10421374).

• 2 Heads Digital Solutions Limited (entity incorporated in England & Wales with the company registration number of 06947571).

• Gther Ltd (entity incorporated in England & Wales with the company registration number of 13266788).

This Privacy Notice is issued on behalf of our business as a whole. When we mention “2Heads”, “we”, “us” or “our”, we are referring to the relevant entity responsible for collecting or Processing your Personal Data.

Data Protection Laws have created the concepts of a Data Controller and a Data Processor. 2Heads’ status is that of a Data Controller. We are supervised by the Information Commissioner’s Office (“ICO”) which is the data protection supervisory authority in the United Kingdom (“UK”). Our registration identification with the ICO for 2 Heads Global Design Limited is ZB643281.

2. Our data protection compliance program

We’re strong believers in protecting the confidentiality and integrity of Personal Data and our Data Protection Team have built a data protection compliance program for 2Heads. This program includes a governance framework, notices, policies, procedures and technical security controls.

At 2Heads, we diligently adhere to the following data protection principles:

• Personal Data must be Processed lawfully, fairly and in a transparent manner.

• Personal Data must be collected only for specified, explicit and legitimate purposes.

• Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

• Personal Data is accurate and where necessary, kept up to date.

• Personal Data should not be kept in a form which permits identification of individuals for longer than is necessary for the purposes for which the Personal Data is Processed.

• Personal Data must be Processed in a manner that ensures its security using appropriate technical and organisational measures to protect it against unauthorised or unlawful Processing and against accidental loss, destruction or damage.

We are serious about looking after your Personal Data. You have trusted us and we won’t let you down.

3. The type of Personal Data that we Process

We collect, use, store and transfer different kinds of Personal Data depending on our relationship with you. In general, we collect the following types:

• Identity Data (e.g., first name, maidan name, last name and title).

• Contact Data (e.g., phone number, email address, business address and billing address).

• Communications & Marketing Data (e.g., your preferences in respect of cookies and marketing).

• Financial Data (e.g., bank account details and value added tax numbers).

• Profile Data (e.g., information about your professional background/organisation and agreements you have entered into with us such as our terms and conditions).

• Transaction Data (e.g., invoices and payment details).

• Technical & Usage Data (e.g., internet protocol addresses, browser type and version, time zone settings, location and information about how you use our website).

• Special Category Data (e.g., information about your health).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your Personal Data but is not considered Personal Data under Data Protection Laws as this data will not directly or indirectly reveal your identity.

4. The lawful bases that we rely upon to Process Personal Data

In order to process your personal data, we are required to have a valid lawful basis under Data Protection Laws. While there are six lawful bases under Data Protection Laws, we primarily rely on one or more of the following (depending on your situation):

• Consent: when an individual gives us their clear consent to Process their Personal Data for a specific purpose.

• Contract: when Processing the Personal Data is necessary to enter into a contract or fulfil our obligations under a contract.

• Legal obligation: when Processing the Personal Data is necessary for us to comply with the law.

• Legitimate Interests: when Processing the Personal Data is necessary for our Legitimate Interests or the Legitimate Interests of a third party, unless there is a good reason to protect the individual’s Personal Data which overrides those Legitimate Interests.
  
  5. The categories of individuals whose Personal Data that we Process

We are grateful to all the individuals that have connected with us at 2Heads. We appreciate everyone that helps us to deliver our offering, uses our services and enjoys the output of our work. The categories of individuals whose Personal Data that we collect are as follows:

• Website users.

• Job candidates.

• Staff working in our prospective and existing clients.

• Staff working in our prospective and existing third-party suppliers.

We have provided further information below on what Personal Data we Process, how we Process it and why we Process it.

Website users

What? We collect your Technical & Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data and Communications & Marketing Data (if you decide to get in touch with us).

How? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies. We also collect this Personal Data through our direct interactions with you such as when you contact us through our website.

Why? One or more of the following lawful bases apply:

• Consent (i.e., in that you are choosing to provide us with your details so that we can contact you).
• Legitimate Interests (i.e., it’s necessary for our Legitimate Interests in running and developing our business).
• Legal obligation (i.e., it’s necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes). 

Job candidates

What? We collect your Technical & Usage Data (for tracking purposes). We collect your Communications & Marketing Data. We also collect your Identity Data, Contact Data and Profile Data (for when you submit your application to join us). We collect some Special Category Personal Data about you (such as information about your health where we are required to put in place reasonable adjustment for your interview). We only collect this type of Personal Data when we have a legal basis to do so and have satisfied one of the conditions required under Data Protection Laws.

How? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies. We also collect this Personal Data through our direct interactions with you and third parties (i.e., contacting the referees that you have provided).

Why? One or more of the following lawful bases apply:

• Consent (i.e., in that you are choosing to provide us with your details so that we can contact you about a job).
• Contract (i.e., in that we need this information to potentially enter into an employment contract with you).

Prospective and existing clients

What? We collect your Technical & Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Communications & Marketing Data (for when you entered into our terms and conditions).

How? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies. We also collect this Personal Data through our direct interactions with you such as when you engage with us.

Why? One or more of the following lawful bases apply:

• Contract (i.e., in that you have agreed to our terms and conditions).
• Legitimate Interests (i.e., it’s necessary for our Legitimate Interests such as in developing our business strategy).
• Legal obligation (i.e., it’s necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs). 

Prospective and existing third-party suppliers

What? We collect your Technical & Usage Data (for tracking purposes). We also collect your Identity Data, Contact Data, Financial Data, Transaction Data and Profile Data (for when we are engaging you for your services and expertise).

How? As you interact with our website, we automatically collect this Personal Data about you by using cookies and similar technologies. We collect this Personal Data through our direct interactions with you (i.e., we will hold Personal Data on your staff that have engaged with us) and through third party suppliers (i.e., we run credit checks against our third party suppliers before engaging with them and such a check may include Personal Data if the name of a director is listed).

 
Why? One or more of the following lawful bases apply:

• Contract (i.e., in that we need this information perform a contract with you).
• Legitimate Interests (i.e., it’s necessary for our Legitimate Interests such as in developing our business strategy).
• Legal obligation (i.e., it’s necessary for us to comply with a legal obligation such as in relation to our financial, tax and legal affairs). 
  
  6. The categories of organisations with whom we share Personal Data

We will only share your Personal Data when necessary and have outlined examples of the types of organisations with whom we would share it with:

• Technology companies that provide us with support, hardware and software products (such as Microsoft, Google, Slack and HubSpot) – for us to conduct our business operations.

• Professional advisers such as banks, payment providers and accountancy firms (such as Haines Watts, Worldpay and Aria Grace Law) – which we need to engage with for the purposes of our business and may need to provide data.

• Regulators and other governmental authorities (such as the UK Companies House, UK HM Revenue & Customs and Dubai Police Force) – which we need to engage with for the purposes of our business and may need to provide data.

• Third parties to whom we may be in contact with to sell, transfer or merge parts of our business or assets, or to attempt to acquire or merge with other companies.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with Data Protection Laws. We enter into contractual agreements with all of our third parties (with the exception of regulators and governmental authorities) which include the appropriate data protection clauses.

7. Transferring Personal Data across borders

We ensure that Personal Data is transferred safely and securely at all times. Whenever your Personal Data travels outside of the UK and/or the EEA, we ensure that it’s protected by putting in one of the following safeguards: 

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data as endorsed by the ICO and identified and determined by the European Commission.

• We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

If you want to find out the specific mechanism used when transferring your Personal Data out of the UK and/or the EEA, please reach out to our Data Protection Team on privacy@2heads.com.

8, Our methodology to retaining Personal Data  

We will only keep 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.

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.

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 of our relationship with you.

9. Your legal rights pertaining to your Personal Data  

Under certain circumstances, you have specific rights in respect of the Personal Data that we Process about you. Your rights include:

• Right of access to information and copies of the Personal Data that we hold about you.

• Right to rectify (i.e., correct) your Personal Data where it is inaccurate or incomplete.

• Right to delete your Personal Data, but only in specific circumstances, for example where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected or Processed. It may not therefore always be possible for us to delete all of the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.

• Right to restrict Processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid. 

• Right to object to Processing in cases where Processing is based upon our Legitimate Interests or where Processing is for direct marketing purposes (including profiling).

• Right to data portability which means the right to receive, move, copy or transfer your Personal Data to another Data Controller. You have the right to this when we are Processing your Personal Data based on Consent or on a contract and the Processing is carried out by automated means.

If you wish to exercise any of the rights set out above, please contact our Data Protection Team on privacy@2heads.com. You won’t 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.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest 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.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will certainly notify you and keep you updated.

We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint to the ICO which can be contacted on www.ico.org.uk. We would appreciate, however, if you would contact us in the first instance so that we can address your concerns.

10. Links and features on our website

Our website 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 Personal Data about you. We want to let you know that we do not control these third-party websites and are not responsible for their privacy statements and notices. When you leave our website, we really do encourage you to read the privacy documentation of the website you visit.

11. Our approach to direct marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical & Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in Consent before we share your Personal Data with any third-party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us and withdrawing your Consent. Where you opt-out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g., as we may be required to contact you in order to perform the contract).

12. Glossary

Consent refers to when an individual gives agreement which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the Processing of any Personal Data relating to them.

Data Controller refers to an organisation that determines when, why and how to Process Personal Data. It is responsible for establishing policies and procedures in line with Data Protection Laws.

Data Processor refers to an organisation that Processes Personal Data on behalf of a Data Controller. It is responsible for establishing policies and procedures in line with Data Protection Laws and also its contractual obligations with Data Controllers.

Data Protection Laws refers to the UK GDPR, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable European Union legislation (such as the General Data Protection Regulation 2016/679) relating to Personal Data. The “UK GDPR” is the retained version of the General Data Protection Regulation 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419). The UK GDPR sits alongside the Data Protection Act 2018.

European Economic Area (“EEA”) refers to the 27 countries in the European Union (“EU”), Iceland, Liechtenstein and Norway.

Legitimate Interest refers to when an organisation’s interests are legitimate (as they need to do something to operate) and these interests do not override an individual’s interests or fundamental rights and freedoms.

Personal Data refers to any information identifying an individual or information relating to an individual that an organisation can identify (directly or indirectly) from that data alone or in combination with other identifiers that it Processes. Personal Data includes Special Category Personal Data, Criminal Convictions Data and pseudonymised Personal Data. Further examples of Personal Data are included in section 3 of this Privacy Notice. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

Process or Processing refers to any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Category Personal Data refers to information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data of an individual.

If there is anything at all that you don’t understand in this glossary, you can reach out to our Data Protection Team on privacy@2heads.com.