Privacy Policy

1About this privacy policy

The Engine Room is a membership community for second-in-commands and operational leaders working in founder-led businesses. We provide membership services, training, events, peer support, resources, coaching and related business-development activities.

The Engine Room is operated by COO Accelerator Ltd trading as The Engine Room ("The Engine Room", "we", "us" or "our").

Our registered address is:

Blake House, 18 Blake Street, York, YO1 8QG

Our website is:

www.ittakes2.global

For the purposes of UK data-protection law, COO Accelerator Ltd is the data controller responsible for the personal information described in this privacy policy.

This policy explains how we collect, use, store and protect personal information when you:

• visit our website;
• enquire about The Engine Room;
• apply for or purchase membership;
• participate in our membership community;
• attend one of our online or in-person events;
• access our training, coaching or resources;
• join our mailing list;
• complete a survey, assessment or form;
• communicate or work with us; or
• otherwise interact with The Engine Room.

This policy applies to members, prospective members, founders, business owners, event attendees, speakers, partners, suppliers and website visitors.

2How to contact us

Questions about this privacy policy or the way we use your personal information can be sent to:

Email: Julie.phillips@ittakes2.global Post: Blake House, 18 Blake Street, York, YO1 8QG

3Personal information we collect

You can visit most areas of our website without giving us personal information.

However, when you enquire about, join or interact with The Engine Room, we may collect the following information.

Identity and contact information

This may include:

• your name;
• job title or professional role;
• email address;
• telephone number;
• postal or business address;
• employer or business name; and
• social-media profile details where you choose to connect with us through those platforms.

Membership and business information

This may include:

• your membership application and membership status;
• information about your role as a second-in-command, operator or business owner;
• information about your employer or business;
• the size, structure, sector and stage of your business;
• your professional challenges, objectives and development needs;
• your interests and preferences;
• records of training, events, coaching or community activities in which you participate;
• your responses to assessments, questionnaires, surveys and feedback forms; and
• information you voluntarily share during membership calls, workshops, events, coaching sessions or community discussions.

Transaction and payment information

This may include:

• the products, services or memberships you purchase;
• payment status and transaction records;
• billing information;
• invoices and payment history; and
• information needed to administer refunds, renewals or cancellations.

Payments may be processed by third-party payment providers. We do not normally collect or store your complete debit-card or credit-card details ourselves.

Communications

We may keep records of communications between you and The Engine Room, including:

• emails;
• telephone calls;
• meeting notes;
• membership enquiries;
• customer-service requests;
• feedback;
• comments or direct messages sent through social media; and
• records of your marketing and communication preferences.

Event information

When you register for or attend an event, we may collect:

• registration and ticket information;
• dietary requirements;
• accessibility requirements;
• emergency contact information where appropriate;
• attendance records;
• photographs, video or audio recordings from the event; and
• feedback about the event.

We will tell you when photography or recording is taking place and provide appropriate opportunities to raise concerns or opt out where reasonably possible.

Website and technical information

When you use our website or digital services, we may automatically collect information such as:

• your IP address;
• browser type and version;
• device type;
• operating system;
• time zone and general location;
• pages viewed;
• links clicked;
• the website from which you arrived;
• the date, time and duration of your visit; and
• information collected through cookies and similar technologies.

Further information is provided in the cookies section below and in our separate cookie policy, where applicable.

Information received from other sources

We may receive personal information about you from:

• your employer, founder or another representative of your business;
• a colleague who recommends or registers you;
• event organisers or partners;
• referral partners;
• professional networking platforms;
• publicly available business sources;
• payment and membership-platform providers; and
• other organisations where you have agreed that they may share your information with us.

When a founder or employer purchases membership for a second-in-command, we may receive basic contact and employment information from that founder or employer. We will provide the member with relevant privacy information when we first contact them.

4Special-category information

Certain types of personal information are considered particularly sensitive under data-protection law. These include information about health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade-union membership, genetic or biometric information, and a person's sex life or sexual orientation.

We do not routinely ask for this information.

We may occasionally need limited health, dietary or accessibility information so that we can support your participation in an event or activity safely and appropriately.

Where we collect special-category information, we will:

• collect only what is reasonably necessary;
• explain why it is needed;
• identify an appropriate lawful basis and special-category condition;
• restrict access to the information; and
• delete or anonymise it when it is no longer required.

Please avoid sharing sensitive personal information in community groups or sessions unless it is relevant and you are comfortable doing so.

5How we use personal information

We may use your personal information to:

Provide and administer our services

This includes:

• responding to enquiries;
• processing membership applications;
• setting up and managing membership accounts;
• delivering training, coaching, events and community activities;
• providing access to resources, recordings, templates and membership platforms;
• facilitating introductions and peer-to-peer interaction;
• communicating important membership information;
• processing purchases, invoices, renewals and cancellations;
• providing customer service and technical support; and
• fulfilling our contractual commitments.

Personalise and improve The Engine Room

This includes:

• understanding members' needs and professional challenges;
• tailoring training, events, resources and communications;
• monitoring engagement with membership services;
• requesting feedback;
• carrying out research and surveys;
• reviewing the effectiveness of our programmes;
• developing new products, services and events; and
• improving the experience of our website and digital platforms.

Operate and protect our business

This includes:

• keeping appropriate financial and business records;
• managing our relationships with suppliers, partners and speakers;
• protecting our website, membership platforms and systems;
• preventing fraud, misuse or unlawful activity;
• enforcing our membership terms, community standards and other agreements;
• managing complaints and disputes;
• obtaining professional or legal advice; and
• complying with our legal, regulatory, tax and accounting obligations.

Communicate and market our services

Subject to applicable law and your communication preferences, we may:

• send newsletters, insights and business-development content;
• tell you about membership opportunities;
• invite you to events, webinars, workshops and training;
• share information about relevant products and services;
• follow up on an enquiry or event registration; and
• tell you about services offered by It Takes Two or other closely related brands operated by COO Accelerator Ltd

You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email or contacting us at Julie.phillips@ittakes2.global

Service communications relating to an active membership, booking, purchase or event registration are not marketing messages and may still be sent where necessary to provide the service.

6Our lawful bases

Data-protection law requires us to have a lawful basis for using personal information.

Depending on the circumstances, we may rely on the following lawful bases.

Contract

We may process your information because it is necessary to:

• respond to steps you take before entering into a contract;
• process your membership or booking;
• provide services you or your organisation have purchased; or
• fulfil our obligations under a membership agreement or other contract.

Legitimate interests

We may process your information where it is necessary for our legitimate business interests, provided that those interests are not overridden by your rights and interests.

These interests may include:

• operating and developing The Engine Room;
• supporting members and customers;
• improving our services;
• managing business relationships;
• keeping appropriate records;
• protecting our organisation and systems;
• understanding how our website and services are used;
• promoting relevant business-to-business services; and
• communicating with existing members, customers, contacts and professional partners.

Where required, we consider and balance our interests against the potential effect on you.

Consent

We may rely on your consent where:

• you have actively chosen to receive certain marketing communications;
• you provide optional sensitive information;
• you agree to a particular use of photographs, recordings or testimonials; or
• consent is otherwise required by law.

You may withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before it was withdrawn.

Legal obligation

We may process personal information where necessary to comply with legal, regulatory, tax, accounting or reporting obligations.

Vital interests

In an emergency, we may use personal information where it is necessary to protect someone's life or physical safety.

7Marketing communications

We may send marketing communications to:

• people who have asked to receive them;
• existing or previous customers and members where permitted by law;
• business contacts where we have a lawful basis to do so; and
• people who have expressed an interest in The Engine Room, It Takes Two, our events or our services.

Marketing communications may be sent by email, telephone, post or social media, depending on the information available and your preferences.

Every marketing email will include a way to unsubscribe.

You can ask us to stop using your information for direct marketing at any time by:

• selecting the unsubscribe link in an email;
• emailing Julie.phillips@ittakes2.global or
• contacting us using the details in this policy.

When you unsubscribe, we may retain limited information on a suppression list to ensure that we respect your request and do not add you back to marketing communications accidentally.

8Community participation and information shared with other members

The Engine Room is designed to encourage peer support, discussion and professional connections.

Depending on how the community operates, other members may be able to see information such as your:

• name;
• profile photograph;
• job title;
• organisation;
• biography;
• areas of expertise;
• posts, comments and contributions; and
• information you choose to share during community discussions or events.

Please consider carefully what information you disclose in a group, forum, chat, virtual session or event.

We ask members to treat information shared by others respectfully and confidentially. However, we cannot guarantee that another participant will not record, copy, repeat or otherwise use information you voluntarily disclose.

You should not share another person's personal or confidential information through The Engine Room unless you have their permission and an appropriate reason to do so.

9Coaching, workshops and recorded sessions

Some training calls, webinars, workshops or membership sessions may be recorded.

Where a session will be recorded, we will normally tell participants before recording begins.

Recordings may be used to:

• make sessions available to members who could not attend;
• provide a membership or training resource;
• support internal training and quality improvement; or
• create marketing content where appropriate permission has been obtained.

Recordings may capture your name, image, voice, comments or questions.

Where practical, you may participate without activating your camera or may submit questions privately. Please contact us before a session if you have concerns about recording.

We will not use a personal coaching conversation, testimonial or case study for marketing without an appropriate lawful basis and, where required, your permission.

10Photographs, videos and testimonials

We may take photographs or video recordings at our events.

General event photography may be used to document and promote The Engine Room, our events and our community. We will provide appropriate notices at events and will consider reasonable requests not to be photographed or filmed.

Where we wish to feature you prominently, use a testimonial, publish a case study or disclose information about your business results, we will normally seek your specific agreement.

You may withdraw consent for future use of consent-based material by contacting us. This will not necessarily require us to withdraw or destroy materials that have already been printed, published or distributed where doing so would be impossible or disproportionate.

11Who we share personal information with

We do not sell your personal information.

We may share information with carefully selected third parties where necessary to operate The Engine Room, including:

• website-hosting and IT providers;
• membership and community-platform providers;
• customer-relationship-management systems;
• email and marketing-platform providers;
• video-conferencing and webinar providers;
• event venues and event-management suppliers;
• trainers, coaches, facilitators and speakers;
• payment processors and accounting providers;
• professional advisers, including accountants, insurers and lawyers;
• analytics and website-performance providers;
• photographers, videographers and production providers;
• referral or delivery partners involved in a service you have requested; and
• regulators, courts, law-enforcement bodies or public authorities where required by law.

We require service providers acting on our behalf to use personal information only for the agreed purpose and to protect it appropriately.

Where an event, programme or service is delivered jointly with another organisation, we will explain where relevant how personal information will be shared and used.

We may also disclose information as part of a business sale, restructuring, merger or transfer, subject to appropriate confidentiality and data-protection safeguards.

12International transfers

Some of the technology and service providers we use may store or process personal information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate safeguard is in place. This may include:

• transferring information to a country recognised as providing an adequate level of protection;
• using approved contractual safeguards;
• relying on another legally recognised transfer mechanism; or
• obtaining explicit consent where appropriate.

You can contact us for further information about the safeguards used for international transfers relevant to your personal information.

13Payment information

Payments for memberships, events or services may be processed by Stripe

The payment provider may collect and process payment-card and transaction information under its own privacy policy and terms.

We do not normally receive or retain your complete payment-card details. We may receive information confirming:

• your identity;
• the amount paid;
• the date of payment;
• the payment status;
• the payment method used; and
• limited card information, such as the card type and final digits.

Please review the payment provider's privacy notice for further information about how it processes your payment data.

14How long we keep personal information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, accounting, reporting and contractual requirements.

Retention periods may vary depending on the type of information and our relationship with you.

As a general guide:

• membership and customer records may be retained for the duration of the relationship and for an appropriate period afterwards;
• contracts, invoices and financial transaction records will normally be retained for at least six years after the end of the relevant financial year, where required for tax and accounting purposes;
• enquiry records may be retained for a reasonable period so that we can respond and follow up;
• event and attendance records may be retained for administration, reporting and future event planning;
• coaching and training notes will be retained only for as long as needed to provide the relevant service and manage our professional relationship;
• marketing information will be retained until you unsubscribe, object or we determine that it is no longer appropriate to keep it;
• information on suppression lists may be kept for longer so that we can respect your request not to receive marketing;
• unsuccessful applications may be retained for a limited period; and
• technical and website analytics information will be retained according to the settings of the relevant platform.

When personal information is no longer required, we will securely delete it, anonymise it or place it beyond normal operational use.

15Security

We take reasonable technical and organisational measures to protect personal information from:

• unauthorised access;
• unlawful use or disclosure;
• accidental loss;
• alteration;
• destruction; and
• damage.

These measures may include access controls, secure passwords, multifactor authentication, encryption, staff procedures, supplier checks, secure data storage and appropriate backup arrangements.

Access to personal information is restricted to people who have a genuine business need to use it.

Although we work to protect your information, no internet transmission or electronic storage system can be guaranteed to be completely secure.

16Cookies and similar technologies

Cookies are small files placed on your device when you visit a website. They can help a website function, remember preferences and provide information about how visitors use the site.

We may use:

• essential cookies, which are needed for the website to operate;
• functionality cookies, which remember choices or preferences;
• analytics cookies, which help us understand website traffic and usage; and
• marketing cookies, which may be used to measure campaigns or provide relevant advertising.

Where required, non-essential cookies will not be placed unless you have given permission through our cookie banner or consent-management tool.

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17Links to other websites

Our website, membership platform, emails or community content may include links to websites operated by other organisations.

We do not control those websites and are not responsible for their content, security or privacy practices.

When you follow a link to another website, you should read that organisation's privacy policy before providing personal information.

18Social media

We use social-media platforms to communicate, publish content and engage with our community.

When you interact with us through a social-media platform, the platform may collect and use your personal information under its own privacy policy. Depending on the activity, we and the platform may each be responsible for different aspects of the processing.

Please review the privacy settings and policies of the social-media services you use.

19Children's information

The Engine Room is intended for business owners, employees and adult professionals. It is not directed at children, and we do not knowingly collect personal information from anyone under the age of 18.

Please contact us if you believe that a child has provided personal information to us.

20Your data-protection rights

Depending on the circumstances, you may have the following rights:

The right to be informed

You have the right to receive clear information about how we collect and use your personal information.

The right of access

You may ask us for a copy of the personal information we hold about you and for further information about how it is used.

The right to rectification

You may ask us to correct personal information that is inaccurate or to complete information that is incomplete.

The right to erasure

You may ask us to delete your personal information in certain circumstances. This right is not absolute, and we may need to retain information where we have a legal or legitimate reason to do so.

The right to restrict processing

You may ask us to restrict the way we use your personal information in certain circumstances.

The right to data portability

Where applicable, you may ask to receive certain personal information in a structured, commonly used and machine-readable format or ask us to transfer it to another organisation.

The right to object

You may object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to your personal information being used for direct marketing.

Rights relating to automated decision-making

You may have rights relating to decisions made solely by automated means that have a legal or similarly significant effect on you.

The Engine Room does not currently make significant decisions about individuals solely through automated processing.

The right to withdraw consent

Where we rely on consent, you may withdraw it at any time.

You will not normally have to pay a fee to exercise your rights. We may ask for information to confirm your identity before responding.

We will respond within the time required by applicable data-protection law.

To exercise a right, contact:

Julie.phillips@ittakes2.global

21Complaints

Please contact us first if you have concerns about how we use your personal information. We will take your concern seriously and try to resolve it.

You also have the right to complain to the Information Commissioner's Office, the UK regulator for data protection.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can find further information through the Information Commissioner's Office website.

If you are based outside the United Kingdom, you may also have the right to contact the data-protection regulator in the country where you live or work.

22Changes to this policy

We may update this privacy policy periodically to reflect changes in:

• our services;
• our business;
• the technology we use;
• our suppliers; or
• applicable law and regulatory guidance.

The latest version will be published on our website. Where a change is significant, we may also notify members or other affected individuals directly.

This policy was last updated on 20th July 2026