RefSpace Privacy Policy

Part I. Scope of the obligation

1. When you download the application and browse the RefSpace website, we automatically obtain the IP address of your electronic device in order to collect information regarding your browser and operating system, both when using the browser-based application and the mobile application.
2. After downloading the RefSpace application, you will be asked to register, that is, to enter your information to create an account.
3. We may use the information we collect during the process of your registration, signing up for our newsletter, completing a survey response, communicating by email or chat, browsing refspace.com, the process of completing a purchase, or use other functions as follows:
   1. to be able to process transactions efficiently;
   2. to administer promotions, surveys, contests or other site features;
   3. to make the RefSpace service as useful to you as possible;
   4. to give you access to your feedback and transaction history; such as payment processing, rating and managing your RefSpace account, as well as providing the functionality of the Services;
   5. to personalize the user experience and enable us to deliver content and products that you may potentially be most interested in.
4. In-app pushes and email marketing: with your permission, we may send you in-app pushes and emails about the RefSpace service, new products and other updates.

Part II Consent

1. When you provide us with personal information, for example, to complete a transaction, verify your credit card, place or return an order, you consent to its collection and use only for specific purposes.
2. If we ask for your data for another purpose, such as marketing activities, we will do so by directly asking for your consent, or show you a form where you always have the right to refuse consent.
3. If, after you have consented to our collection of information, you change your mind and wish to withdraw your consent - just contact us directly by sending an email to: [email protected]

Content disclosure

1. We do not sell or transfer your personal information to any third party unless we get your permission to do so. This does not apply to the hosting of partner sites and sites that help maintain the site, conduct business and service, when the confidentiality of the information is maintained. We may only disclose your data if it is in accordance with the law, internal policies, and if it respects the rights, property or protection of others. In addition, your personal information may be transferred in situations related to entering into transactions with other RefSpace Users, e.g. when it is necessary to enter into a transaction or to cancel or withdraw it, or when it has failed. In that case, RefSpace provides a delivery address to the Buyer or a return address so that the Buyer can send the Goods back to the Seller.
2. All data except personal data may be shared with third parties for marketing, advertising or similar purposes.
3. If there is a legitimate need, we will transfer your personal data to processors and the following recipients:
   1. law enforcement agencies, courts, government agencies, fiscal institutions, public authorities, intergovernmental or supranational bodies,
   2. third parties who are parties to the legal proceedings,
   3. Third-party service providers.
4. If you choose to link your Gmail account to Subscription Services, you can use the Gmail account linking feature and agree that RefSpace can access your public Gmail account information.
5. All other provisions of this Privacy Policy will apply if RefSpace is granted permission to access data in your Gmail account, using the Gmail Integration system and the use of the acquired data is subject to additional restrictions.
6. We will use access to read the content of the Gmail message including attachments, message details (metadata), headers and settings to process the email for efficiency and productivity purposes.
7. We will not transfer your Gmail account information to any third party except as required by law in connection with a merger, acquisition or share sale.
8. RefSpace will not use Gmail for marketing purposes.
9. RefSpace will not allow the above-mentioned data to be available for inspection by others until it has received your permission, except for messages sent for security reasons such as investigating violations, ensuring compliance with the law and RefSpace's internal system, where the data has been segregated and anonymized.
10. For more information, visit:https://support.google.com/cloud/answer/9110914#privacy-policy-language

Payments and their data

1. If you make a purchase through the RefSpace app, then payment will be handled by Stripe LTD, whose payment terms and conditions and privacy policy can be found at: www.stripe.com. Familiarize yourself with them. Your transaction data is stored only for as long as necessary to complete your purchase. After that, your transaction data is deleted.
2. All direct payments by third-party service providers are aligned with PCI-DSS, managed by the PCI Security Standards Council, supporting Visa, MasterCard, American Express and Discover cards.
3. PCI-DSS requirements help ensure the security of payment transaction data performed on RefSpace and related third-party service providers.

Provision of services by a third party

1. Third-party service providers of our service have the ability to collect, use and disclose information only to the extent that the service is performed for us.
2. RefSpace has the ability to share Users' data with other entities when it is necessary for the proper conclusion or performance of the contract with the User, including at the User's request in the case of use of the Delivery Service or for the purpose:
   1. acceptance of the order for execution,
   2. service as part of the packaging and delivery of the shipment to the specified address,
   3. providing payment services, performing consulting or auditing services,
   4. User support,
   5. Cooperation in marketing campaigns.
3. We stipulate that certain third-party service providers, such as payment service providers, have their own privacy policies with respect to the information you provide to them to complete a purchase transaction.
4. When using the aforementioned services, it is a good idea to read the privacy policies of third-party service providers, which allows you to understand the ways in which information is processed by these service providers.
5. In particular, be aware that some service providers may be located or have branches in different jurisdictions than you. So if you decide to conduct a transaction that requires the use of third-party service providers, be aware that your information is subject to the regulations of the place where the service providers' branches are located. For example, if you are located in Canada and your transaction is processed by a U.S. service provider, your personal information may be disclosed under U.S. law, also taking into account the USA Patriot Act.
6. When you leave our site or are redirected to a third-party service provider's website/app, the privacy policy and Terms and Conditions of the site do not apply.
7. When you click on a link on our site, a third-party service provider may redirect you away from RefSpace. We are not responsible for the privacy policies of other sites, so we encourage you to find out for yourself.

Security of the User and his/her personal data

1. We use a variety of technologies and procedures to ensure the security of your personal information and protect it from unauthorized access or disclosure. The data you provide to us will be encrypted when transmitted over a public Internet connection using SSL technology and will be stored using AES-256 encryption on servers in a controlled manner in a secure environment that is protected from unauthorized access, use or disclosure.

Cookies

1. Cookies are small files that a website or service places on your computer or mobile equipment. They allow the site or service to recognize your browser that you use on your computer or mobile equipment. They allow the site or service to recognize your browser and retain specific information.
2. We use cookies to store your preferences, apply and sort data about site traffic and interactions so that we can provide a better experience with the site, the service, and the tools used on them. We may also use trusted third-party services to oversee the flow of information on our behalf.

The age of consent

1. By using this site, you acknowledge that you have reached the age of majority as understood by the legal provisions of your country or region to use this site. If your age gives you the legal power to do so, you may grant permission for minors under your direct care to use the site.

Information clause in compliance with RODO

1. In connection with the entry into force of Regulation (EU) 2016/679 of the European Parliament and of the Council of the EU of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as "GDPR", we declare that the way we access and process data complies with the following principles:
   1. The data controller is RefSpace Ltd. based in London at 85 Great Portland Street, W1W 7LT, United Kingdom, Company No. 14127969, hereinafter: 'Administrator'.
   2. The administrator can be reached at the email address: [email protected] or at the office address by appointment.
   3. The legal bases for the Administrator's processing of your personal data are as follows:
      1. Article 6(1)(a) GDPR - the processing of data is based on your consent to receive commercial content by email, sms, mms and phone, including commercial information about RefSpace, its services, organized events, including newsletters;
      2. Article 6(1)(b) of the GDPR - processing is necessary due to the necessity of the processing, arising from the contract and its performance, if a contract of cooperation has been concluded with you, or if a contract for Goods has been proposed by RefSpace;
      3. Article 6(1)(c) of the GDPR - the processing of data has to do with the need to comply with laws and obligations imposed by law on the Controller, e.g. in connection with the fulfillment of obligations under the general rules of law, relevant tax laws and the accounting area;
      4. Article 6 (1) (b) (d) GDPR - the data is processed to safeguard the interests of its subject or another individual;
      5. Article 6 (1) (b) (f) GDPR - processing of data in connection with the legitimate interest of the Controller to answer questions, provide information about its activities, products and services at the request of interested persons;
      6. Article 6(1)(f) of the GDPR - the processing of data takes place in connection with the Controller's authority to make analyses for the purpose of improving services and introducing new ones;
      7. Article 6(1)(f) of the GDPR - the processing of data takes place in connection with the Controller's authority to investigate/invoke or defend against complaints;
   4. Your personal data are processed voluntarily and will be processed for as long as necessary to implement the above procedures or until you object to the processing or withdraw your consent. The period for which the data will be processed may be extended by the limits of complaints, if the processing is necessary for the investigation of probable complaints or defense against such complaints. The data of anonymous users of the application will be stored for 30 days, while the data of verified users, will be stored for 10 years, calculated from the beginning of the year when the consent to process the data was given.
   5. Your personal data may be sent to our business partners, especially subcontractors, IT specialists, entities providing accounting, legal services, postal service providers only in situations of application of our purposes.
   6. You have the right to request access to data, its content and rectification, deletion, delays, processing restrictions and the right to transfer personal data. In addition, you have the right to object to data processing - if the processing is based on Article 6 (1) (e) or (f) of the GDPR. If personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of his or her personal data for such marketing, including profiling, if the processing is related to direct marketing.
   7. If the processing of your personal data is based on your prior consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place on the basis of the consent given before it was withdrawn. Withdrawal of consent can be done by sending a notice to the address given in paragraph 2 above, or in writing, to the Administrator's address.
   8. Your data will be used for the purposes of automated decision-making processes, including profiling, regulated by Article 22 paragraph 1 and 4 of the GDPR. Your data will not be transferred to third countries, except in cases where the subcontractor is based in a third country.
   9. If you believe that RefSpace's processing of your personal data violates the GDPR or RODO, you have the right to lodge a complaint through the authority dealing with the protection of personal data in the relevant EU member state where you have your permanent residence, stay, work or the place of the possible violation.
2. The following is the data we process:
   1. City
   2. Region
   3. State
   4. Time zone
   5. Browser
   6. Browser version
   7. Current URL
   8. References
   9. Reference to the original browser
   10. Operating system
   11. Height of the display
   12. Display width
   13. Last displayed
   14. The first view (originally set or edited for the first time) like the category of the data object
   15. Users of computer and mobile applications for customers
   16. IP
   17. Facebook ID
   18. Mobile ID (e.g., IDFA, ADID).
   19. operating system language
   20. Taxpayer Identification Number (if an invoice is required)
3. You can get more information about data protection on the administrator's website or directly - by contacting us. Changes to the Privacy Policy
4. We retain the right to modify the privacy policy at any time, so we suggest reviewing this section frequently. Changes to the privacy policy are binding as soon as they are published on the site. If material changes are made to the record, we will notify you of the update, so you stay in touch with us about the data we collect and use, under what circumstances, if any, we process and/or disclose it.
5. If our site merges or is acquired by another company, your data may be transferred to the new owners of the site, who may still stay with the former model of selling products and services. Other Agreements
6. We do not target our services to people under the age of 13.
7. We fully respect the principle of redress, which means that every individual has the right to initiate legal action when personal data is not processed and collected in the manner, guided by law. This principle means that not only do individuals have the right to legal action on the issue of respecting personal data, but they can also resort to legal or governmental institutions to investigate when service providers fail to comply with privacy policies.
8. If you ever wish to opt out of receiving future mailings, you can inform us via email and we will immediately remove you from ALL correspondence.
9. Users can visit our site anonymously. Once we have created this privacy policy, we will add a link to it on our home page or on the first important page when you enter our site. Our Privacy Policy link contains the word 'Privacy' and can be easily found on the page provided above. Users will be notified of any changes to the privacy policy via email. Users can change their personal information by logging into their account. Contact Information
10. If you have questions about our privacy policy, please contact us here: RefSpace Ltd - Company No. 14127969 RefSpace Ltd is based in London at 85 Great Portland Street, W1W 7LT, United Kingdom.