Privacy Policy

Data Controller

REFY BEAUTY LTD (CRN: 12522650) (REFY Beauty) is the data controller (i.e. the company who collects your data) and we control how it is and will be used.

We are responsible for holding your data is securely & ensuring that your rights as a user are respected. We are committed to protecting the personal data of our visitors.

We do not market our products, nor do we aim an individual product, at anyone who is under 18. We cannot identify individuals who are 18 or under within our database.

 

Effective Data 

This privacy policy is effective from 01/09/2020.

 

What Is Privacy Policy

This privacy policy gives you information on how REFY BEAUTY collects personal data through your use of our website, including any data you may provide through this website when you purchase a product, sign up to receive marketing information from us, take part in a competition, use an application or submit an event enquiry form.

The data we collect is used to receive your order, process your payment and send your purchase to you. We may also deliver marketing communications, personalise your visit to our site and provide assistance via our support teams.

If you have any queries on this privacy policy or any questions about exercising your rights in respect of your personal data we hold or handle then please contact us on support@refybeauty.com

We must have a valid cause to use your data. There are four primary reasons for use of your data: contractual, legal obligation, consent which you provide to us & our legitimate business interests.

If you feel we’ve not done something right then you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do get in touch with us first at support@refybeauty.com

 

Changes to Your Circumstances

It is very important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes.

 

How Long Do We Hold Your Data

We keep your personal data for a limited period of time. The specifics of these retentions and the retention length will vary by customer. After this period, your data will be permanently erased or otherwise rendered anonymous. This action cannot be undone.

 

Data Types & How It Is Used

See below a summary of the personal data we collect, why we collect it and how we use it. This should make sense, but if it is not clear please do drop us an email and we can clarify.

ID Data, Order Data and PR Data (contact details)

Why and what we do with it

Your full name, address, email address, phone number and date of birth (should you choose to provide it) when you register for an account with REFY Beauty.

We register your account with us and store your details so that you can login when you visit again. We also check whether you’re old enough to use our website. We use these details to process your order. If we don’t have your address then unfortunately, we cannot perform our contract with you and send you our products. We may send you status updates in relation to your order –we believe communication is key to customer service. We may send you information about our amazing products and offers - if you opt in to receive updates then we’ll let you know all about these – you can opt out at any time.

 

Contract Data and Trans Data (contact history)	Why and what we do with it
We keep records of what you’ve said to us whether it be over the phone, by email or on instant chat (and even on social media from time to time) as well as your ID Data and Contract Data.	This allows us to provide better customer support. We need this so that we can deal with any comments or questions you may have and so that we can contact you in response. We also need to understand what we are and aren’t doing well, so we can train our staff, improve our website and make our products the best they can be!

 

Unique Data (our purchase history and saved items)	Why and what we do with it
We like to keep an eye on details of your previous orders, your browsing history on our website and products you had or have in your basket.	To provide customer support and handle returns/refunds. To figure out what products/offers you might be interested in and send you information on these.  So that we can display relevant adverts when you’re browsing third party websites and social media.

 

Informational Data (information about your phone or laptop, and how you use our website)	Why and what we do with it
Information about your computer, tablet, phone (including IP address, browser type, operating system software type and device type).	To figure out what products/offers you might be interested in and send you information on these.  To enable you to store your preferences on your devices, so you can login easily. To make improvements to our website and ensure we provide a unique and tailored experience for our customers.

 

PR Data and ID Data (your responses to surveys, competitions and promotions)	Why and what we do with it
Your name, email address and any other information you provide to us when you take part in competitions or events we operate on our website, in store or via any other media (including through our social media channels).	If we can’t use your details when you enter our competitions, then we can’t complete our contract with you and you won’t be able to win our great prizes! We will use the data from the surveys you complete to improve our website and products. If you submit an event enquiry, then we will need to contact you to discuss it.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

You don’t have to give us any of this personal information but if you don’t, you may not be able to purchase our products via the website, and you are unlikely to be able to receive the customer service that we aim to provide.

We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our website, and developing new products. We also share this information with third parties.

We will only use your personal data when the law allows us to.

 

Data Sharing

We do not, and will not, sell any of your personal data to any third party. We may from time to time share your data with the following categories of companies as an essential part of being able to provide our services to  you:

 

• Companies that help us complete your order, such as payment service providers, warehouses, and delivery companies; and
• Professional service providers, such as marketing agencies, advertising partners (namely Rakuten Advertising) and website hosts, who help us deliver REFY BEAUTY LTD to you.
• Legal advisers, bankers, auditors and insurers and our regulators, including HM Revenue & Customs and with any third parties to who we choose to sell or transfer any part of our business or assets.

 

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on REFY Beauty’s instructions and they are subject to a duty of confidentiality.

We have put in place appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data Rights

Under law, you are entitled to the following rights:

• The right to withdraw consent to marketing.
• The right to object to our processing of your personal data versus our interests.
• The right to data portability to transfer your data to another party.
• The right to request the deletion of your personal data in some cases.
• The right to request a copy of the personal data that we hold regarding your person.
• The right related to decision making and how bespoke suggestions are made to you. We use your data to make tailored recommendations to you. We do not use automated decision-making that would have a potentially damaging effect on you.
• You may at any time withdraw consent where we are relying on consent to process your personal data. If you wish to exercise any of the rights set out above, please Contact Us by using the details provided in this policy.

CCPA Compliance

Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

Privacy Policy : https://rakutenadvertising.com/legal-notices/services-privacy-policy/
Your Rights/Opt Out : https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

Klarna

To offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

 

Mobile Terms of Service

The REFY mobile message service (the "Service") is operated by REFY (“REFY”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.

By consenting to REFY’s SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of REFY through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).

You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with REFY. Your participation in this program is completely voluntary.

We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.

You may opt-out of the Service at any time. Text the single keyword command STOP to REFY or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other REFY mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.

For Service support or assistance, text HELP to REFY or email support@refybeauty.com.

We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.

The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.

To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.

We respect your right to privacy. To see how we collect and use your personal information, please see our Privacy Notice.

 

Changes To Privacy Policy

We keep our Privacy Policy under review in order to reflect change in privacy regulation. This Privacy Policy was last updated 31/01/2020. We will contact you if we make significant changes in the Privacy Policy.