Global Privacy Notice

After a long day, stepping into your bedroom should feel like a retreat from the world. However, it’s easy for this space to get cluttered by dirty clothes, laundry that needs folding or even work papers.

Overview

Two Prime Inc., and each of its affiliates (collectively, “Two Prime,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us.

This Privacy Notice explains our practices with respect to the personal data we collect and process about you. This includes information we collect through, or in association with, our website located at https://www.twoprime.com/, our related social media sites, and our tools, products and services that we may offer via our website (the website, social media pages, tools, products and services, collectively, the “Services”).

Two Prime’s United Kingdom (“UK”) representative and European Union (“EU”) representative is DataRep. To contact DataRep, please visit: https://www.datarep.com/data-request/. This Privacy Notice further explains the manner in which Two Prime collects, uses, and maintains Personal Data of individuals based in the UK and the EU, as required under the General Data Protection Regulation 2016/679 ("GDPR") or the GDPR and the Data Protection Act 2018, as applicable.

Please review the following to understand how we process and safeguard personal data about you.

By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed

Personal data we collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

A. Categories of personal data we collect

The types of personal data we collect about you depend on your interactions with us and your use of the Services. We collect the below categories of personal data from our users:

Your rights regarding personal data

You have certain rights regarding the collection and processing of personal data. These rights may include the right to access, correct, delete, restrict, object to processing, or lodge a complaint with a supervisory authority.

A. Accessing, modifying, rectifying, and correcting collected personal data

We strive to maintain the accuracy of any personal data collected from you. You are responsible for ensuring the information you provide is complete, accurate, and up to date.

Your choices

You may opt out of marketing communications, manage location data, and control cookies through browser or device settings.

Protecting personal data

We use reasonable physical, technical, and organizational safeguards to protect personal data. However, no system is completely secure.

Retention of personal data

We retain personal data as long as necessary for business and legal purposes. Inactive contacts are deleted after five (5) years.

Other important information about personal data and the Services

We retain personal data as long as necessary for business and legal purposes. Inactive contacts are deleted after five (5) years.

A. Collection of personal data from children

The Services are not intended for individuals under 18.

B. Third-party websites and services

Modifications and updates to this Privacy Notice

Updates are effective upon posting. Continued use constitutes acceptance.

Applicability of this Privacy Notice

This Privacy Notice applies regardless of access method and is subject to governing agreements.

Additional information and assistance

Two Prime Inc.

Attn: Chief Compliance Officer / Data Privacy
Email: info@twoprime.com

Identifier data, such as a real name, alias, online identifier, internet protocol address, email address, job titles, the company you work for or other similar identifiers.
Internet or other electronic network usage activity information, including, but not limited to, browsing history, search history, operating system, pages viewed, and the dates/times of your visits.
Marketing and communications data, including, but not limited to, your preferences in receiving marketing from us and your communication preferences.

We will not collect additional categories of personal data other than those categories listed above. If we intend to collect additional categories of personal data, an updated website privacy notice will be made available at or before the time of collection.

B. How we use your personal data

We collect and process your personal data for the following business and commercial purposes:

To provide and maintain our website and Services.
To provide information or respond to any requests or inquiries, or to provide customer service in connection with our website or our Services.
To provide marketing communications by email, including emails, newsletters, analyses and reports.
To identify any security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity.
To debug, identify and repair errors that impair the provision of our Services.
To comply with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

C. How we obtain your personal data

We collect your personal data from the following categories of sources:

Directly from you. When you provide it to us directly, whether online or by email.
Automatically or indirectly from you. For example, through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Services.
From third parties. For example, ad networks to serve advertisements across the Internet. These advertisers use cookies, pixel tags, and other tracking technologies to collect information about your online activity and provide online advertising targeted to you and your interests.

D. Legal bases for processing

We process personal data for, or based on, one or more of the following legal bases:

Your consent.
Performance of a contract.
Legitimate interests.
Compliance with legal obligations and protection of individuals.

E. To whom we disclose your personal data

We disclose your personal data to the following categories of third parties:

Our service providers so we can provide our Services to you.
Our affiliated entities, including Two Prime Lending Ltd.
Government agencies or regulators when required to do so by law; to protect confidentiality or security; or to prevent fraud or unauthorized activity.

B. Your California privacy rights

California residents have rights under the CCPA, including the right to know, delete, access, opt out of sale, and non-discrimination. We do not sell personal data. Requests must be verifiable and may be submitted using the contact information below.

C. Your Nevada privacy rights

Nevada law permits residents to request that personal data not be sold, even if such data is not currently sold.

D. Your other U.S. state privacy rights

Residents of certain U.S. states may have rights including access, correction, deletion, opt-out of targeted advertising, profiling, and automated decision-making.

E. Your European Union and United Kingdom privacy rights

EU and UK residents have enhanced rights under GDPR, including rights to erasure, restriction, portability, objection, and to lodge complaints with supervisory authorities.

We are not responsible for third-party privacy practices.

C. Business transfer

Personal data may be transferred in the event of a merger, acquisition, or sale.

We do not respond to browser “Do Not Track” signals.

E. International use

Personal data is processed and stored in the United States.