Legal
Privacy Policy
Last updated: 16 August 2026
1. Who we are
This website, 2n2offshore.com, and the 2N2 brand are operated by Graftr Systems Ltd ("we", "us", "our").
2N2 is a trading name of Graftr Systems Ltd. Graftr Systems Ltd is the data controller responsible for the processing of personal information described in this policy.
Graftr Systems LtdRegistered in England and Wales, company no. 16960119
46 Priorwood Gardens,
Ingleby Barwick,
Stockton-on-Tees,
TS17 0XH,
United Kingdom
Email: martin@2n2offshore.com
2. What this policy covers
This policy relates to the 2N2 informational website. That is the only thing we currently operate publicly.
The 2N2 mobile application has not launched. It does not currently collect information, track users, process payments, access location, store certificates, or carry out any other processing, because it is not yet available to anyone.
Before the application becomes publicly available, this policy will be reviewed and updated — or a separate application privacy policy published — to describe accurately what the app does. See section 16.
3. Information we may receive
The website has no accounts, no sign-up, no forms and no mailing list. There are only two ways we may receive information about you.
If you contact us
If you email martin@2n2offshore.com, we may process:
- your name;
- your email address;
- the contents of your message;
- any other information you choose to provide.
We use this to respond to your enquiry and to manage ordinary business correspondence.
Technical information generated when you visit
Like effectively all websites, this site is delivered by hosting infrastructure that automatically records limited technical information with each request. This typically includes:
- IP address;
- browser and device information;
- details of the page or file requested, and the date and time;
- security and error logs.
This is generated by the infrastructure itself as a necessary part of delivering and securing the website. We do not use it to profile, track or identify individual visitors, and we do not combine it with anything else.
4. What we do not do
This website does not:
- use analytics or website measurement tools;
- use advertising, marketing or behavioural tracking;
- set advertising, marketing or analytics cookies;
- offer accounts, logins or authentication;
- collect email addresses or operate a mailing list;
- process payments;
- sell or rent personal information.
We have deliberately not added third-party analytics or tracking tools to this site.
5. Cookies
This website sets no cookies — none for advertising, none for analytics, and none that are technically necessary. Because no cookies requiring consent are used, no cookie banner is shown.
If this ever changes, this policy will be updated and — where the law requires it — your consent will be sought before any such technology is enabled.
6. How we use information
Where we do hold personal information, we may use it to:
- respond to enquiries and communicate with people who contact us;
- operate, maintain and secure the website;
- keep proper business records;
- comply with our legal obligations;
- establish, exercise or defend legal rights, where necessary.
7. Lawful bases under UK GDPR
We rely on the following lawful bases, depending on the circumstances:
- Legitimate interests (Article 6(1)(f)) — responding to enquiries about our business and products, operating and securing the website, and keeping business records. Our interest is in running and protecting a legitimate business; we consider this does not override your rights, given how little information is involved.
- Steps taken at your request before entering into a contract (Article 6(1)(b)) — where your enquiry concerns a possible working relationship or agreement.
- Compliance with a legal obligation (Article 6(1)(c)) — where the law requires us to retain or disclose information.
We do not currently rely on consent, because we do not operate any consent-based processing such as marketing emails or analytics cookies. If that changes, we will ask for consent properly and you will be able to withdraw it.
8. Sharing information
We do not sell personal information.
Information may be handled by trusted providers and advisers where necessary to operate our website and business, namely:
- website hosting and infrastructure providers;
- domain registration and DNS providers;
- business email providers;
- professional advisers, such as legal or accounting advisers, where genuinely required;
- public authorities, where disclosure is required by law.
Providers acting on our behalf do so under contract and are not permitted to use the information for their own purposes. If you would like to know which specific providers we use, email us and we will tell you.
9. International processing
Some of our service providers operate infrastructure outside the United Kingdom. Where personal information is transferred outside the UK, we rely on a safeguard recognised under UK data protection law — such as UK adequacy regulations, or the International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses.
In practice the volume of personal information involved in this website is very small: correspondence you send us, and routine server logs.
10. Data retention
We keep personal information only for as long as reasonably necessary for the purpose it was provided, including any legal, accounting or record-keeping requirements that apply.
Email correspondence is kept for as long as needed to deal with the matter it concerns and to maintain proper business records, then deleted. Technical server logs are retained only for the limited period applied by our hosting provider for security and diagnostic purposes.
11. Security
We use reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse or alteration. The website is served only over HTTPS, and access to our business email is protected by appropriate account security.
No website, system or method of transmission is completely secure, and we cannot guarantee absolute security. We do not claim otherwise.
12. Your rights
Under UK data protection law you have rights in relation to your personal information, including the right to:
- request access to the information we hold about you;
- have inaccurate information corrected;
- request erasure of your information;
- request that we restrict how we use it;
- object to processing carried out on the basis of legitimate interests;
- request portability of information you provided to us;
- rights in relation to automated decision-making and profiling.
These rights do not all apply in every situation — they depend on the circumstances and on the lawful basis we are relying on. We do not carry out automated decision-making or profiling.
To exercise any of these rights, email martin@2n2offshore.com. We will respond within the time limits set by law.
13. Complaints
If you are unhappy with how we have handled your personal information, please contact us first so we can try to put it right.
You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk.
14. Children
This website, and the offshore contractor service we are building, are aimed at working professionals and businesses in the offshore sector. They are not directed at children, and we do not knowingly seek or collect personal information relating to children through this website.
15. Links to other websites
This website may contain links to third-party websites. We do not control those websites and are not responsible for their content or their privacy practices. Their own privacy policies govern any information you provide to them, and we would encourage you to read them.
16. The 2N2 mobile application
2N2 is currently under development and is not publicly available.
The planned application may eventually provide features involving contractor profiles, rotations and calendars, certificates, projects, files, invoices and earnings, travel information, job opportunities and other offshore contractor tools.
None of those features currently process any personal information, because the application has not launched. Nothing in this section should be read as describing processing that is happening today.
Before the application becomes publicly available, this policy will be reviewed and updated — or a dedicated application privacy policy published — to set out:
- exactly what information the app collects;
- why it is collected;
- the lawful bases relied on;
- where it is stored, and for how long;
- any third-party processors involved;
- any device permissions used, such as camera or location;
- how to delete an account and the data associated with it;
- the privacy controls available to users;
- any recruitment-related processing;
- any financial, invoicing or referral-related processing.
This matters: the privacy disclosures we publish on the App Store and Google Play must accurately match what the application actually does. We would rather leave this section explicitly incomplete than describe processing that does not yet exist.
17. Changes to this policy
We may update this policy as 2N2 develops, or as legal or technical requirements change — in particular when the mobile application launches. The "last updated" date at the top of this page shows when it was last revised.
18. Contact
For any question about this policy, or about how we handle personal information:
Graftr Systems Ltd46 Priorwood Gardens,
Ingleby Barwick,
Stockton-on-Tees,
TS17 0XH,
United Kingdom