Privacy

1. INTRODUCTION

1.1. This policy (the Privacy Policy) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the REFSIX Services you are accepting and consenting to the practices described in this Privacy Policy.

1.2. For the purpose of the Data Protection Act 1998 (the Act), the data controller is REFSIX Limited (REFSIX, we, us), a company registered in England and Wales with registered company number 10416702 and registered address at 51 Half Moon Lane, Worthing, West Sussex, BN13 2EP.

2. DEFINITIONS

In this Privacy Policy capitalised words and expressions shall have the meanings given to them in the REFSIX Terms of Use unless defined below:

Company means the business you work for or represent (if applicable).

REFSIX Customer means any person authorised by REFSIX to access and use the REFSIX Services.

REFSIX Services means the app provided by way of the REFSIX website and/or REFSIX software from time to time.

you means each REFSIX Customer and your shall be understood accordingly.

3. INFORMATION REFSIX COLLECTS

3.1. If you wish to subscribe for access to the REFSIX app you will be required to register. When you register, REFSIX will collect personal information about you and (if applicable) information about your Company (such as the Company name, and your e-mail address). This data allows us to provide a personalised service to you. You consent to us accessing and collecting such personal information about you.

3.2. REFSIX will create an account for your subscription based on the information you give us (an Account). REFSIX may also ask that you provide other information to us for the Account. You are under no obligation to provide such information. However, if you choose to withhold requested information, REFSIX may not be able to provide the REFSIX Services to you.

4. HOW REFSIX STORES YOUR INFORMATION

Information REFSIX collects may be transferred to, stored and processed by its subsidiaries as well as its service providers and other reputable third party organisations, some of which may be situated outside the European Economic Area “EEA”. Where REFSIX does transfer your personal data outside the EEA it will use its best endeavours to put measures in place to ensure that such personal data will be adequately protected to a standard at least as high as under the Act. In addition, if you use the REFSIX Services outside the EEA, your information may be transferred outside the EEA in order to provide you with those Services. By using the REFSIX Services, you agree to the collection, transfer, storage or processing of information about you for the purposes described in this Privacy Policy.

5. HOW YOUR INFORMATION IS USED

5.1. REFSIX may use the information you provide to us to:

5.1.1. monitor, develop and improve the REFSIX Services and your experience;

5.1.2. assist in and administer the provision of the REFSIX Services to you;

5.1.3. process and deal with any complaints or enquiries made about or by you (or your Company);

5.1.4. contact you about a submission you have made to the REFSIX Services; and/or

5.1.5. understand customer trends and patterns.

6. WHEN REFSIX MAY CONTACT YOU

6.1. REFSIX may contact you:

6.1.1. in relation to the functioning of any service you have signed up for in order to ensure that REFSIX can deliver the service to you;

6.1.2. in relation to any contribution you have made to the REFSIX Services;

6.1.3. to invite you to participate in surveys about the REFSIX Services (participation is always voluntary); and/or

6.1.4. for marketing purposes as described in the next section.

6.2 Local pages will give you information about how REFSIX will contact you in relation to specific services.

7. WILL I BE CONTACTED FOR MARKETING PURPOSES?

7.1 REFSIX may send you and keep you updated with information by email or telephone (including SMS) about existing and new services, products and special offers from REFSIX.

7.2 Where requested by you REFSIX may send you information by email or telephone about related products or services of selected third parties that may be of interest to you. However, you always have the opportunity to remove your consent to such use by sending an email to support@refsix.com with a removal request.

7.3 You can tell us not to contact you or share your information with a third party either at initial registration for your access to the Account, or later by way of updates or amendments to your personal information. REFSIX may occasionally contact you about products and services REFSIX believes may be of interest to you. These contacts will only come from REFSIX (or its agents) and only if you have indicated that you do not object to these offers.

8. WILL REFSIX SHARE PERSONAL INFORMATION WITH ANYONE ELSE?

REFSIX will keep your information confidential except where disclosure is required or permitted by law. Generally, REFSIX will only use your information within our business and that of our subsidiaries or affiliates. However, sometimes REFSIX uses third parties to process your information, and if so REFSIX requires these third parties to comply strictly with its instructions and requires it not to use your personal information for their own business purposes.

9. KEEPING OUR RECORDS ACCURATE

REFSIX aims to keep its information about you as accurate as possible, but REFSIX depends on you to update your personal information whenever necessary. You can change the details you have supplied to us at any time by sending your name, Company (if applicable) and full details of the change required to support@refsix.com.

10. YOUR RIGHTS

You have the right to request a copy of the personal information REFSIX holds about you and to have any inaccuracies corrected. REFSIX charges £10 for information requests and REFSIX will ask you to prove your identity with two (2) pieces of approved photographic identification. REFSIX will use reasonable efforts to supply, correct or delete personal information about you on our files. Please address requests and questions about this or any other question about this Privacy Policy to us at support@refsix.com.

11. CHANGES TO THIS PRIVACY POLICY

REFSIX reserves the right from time to time to change or update this Privacy Policy. All changes will be published on the REFSIX Services. Each change will become effective on publication and you will be deemed to be aware of and bound by it. you should therefore review this Privacy Policy regularly to ensure that you are up-to-date with the current terms of the Privacy Policy.

12. IP ADDRESSES, COOKIES AND WEB BEACONS

12.1 REFSIX may collect information about your computer, including where available your computer’s IP address, operating system and browser type, for system administration. This information is limited to statistical data about REFSIX Customers’ browsing actions and patterns, and does not identify any individual.

12.2 For the same reason, REFSIX may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that helps us to improve the REFSIX Services and to deliver a better and more personalised service. They enable us to:

12.2.1 identify who you are and to access your Account information;

12.2.2 estimate our audience size and patterns; and

12.2.3 track preferences and to improve and update the REFSIX Services.

12.3 You may refuse to accept cookies by activating the setting on your Internet browser which allows you to refuse the setting of cookies. You can also delete cookies that have been installed on your hard drive – consult your software manual for further help. However, if you select the refuse setting, or delete cookies, you may be unable to access certain parts of the REFSIX Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

12.4 To learn more about cookies and how to disable them please visit www.youronlinechoices.com and www.allaboutcookies.org.

13. SECURITY

REFSIX has installed security measures to ensure that any personal data entered on the REFSIX Services is protected against loss, misuse or alteration. However, due to the nature of the Internet, REFSIX cannot guarantee the protection of your personal information and REFSIX cannot be responsible for any outcomes resulting from a breach of security when the REFSIX Services are used.

14. CONTACTING REFSIX AND CANCELLATION OF REGISTRATION

If you have any questions or comments about this Privacy Policy, or would like to cancel your access to the Account, please contact us at support@refsix.com.