Effective Date: September 2, 2024
Introduction
Welcome to Refine Homes!
Refine Homes L.L.C is referred to as “we”, “our” and “us” and their worldwide affiliates (collectively referred to as “Refine”) along with www.refinehome.com (“the website’’) and our mobile applications together (collectively referred to as the “platforms”) respects your privacy and is committed to protecting it.
The security, integrity and confidentiality of your information is of the utmost importance to us, and therefore, we provide this Privacy Policy to inform you of our privacy procedures and practices, as well as to describe what information we collect about you, how we obtain your information, and how we use, share, and otherwise process your information in the course of operating our business and our platforms. For purposes of this Privacy Policy, Refine is a “data controller”, which means that we are responsible for any information that can be used to identify you or that we can link to you and which we have in our possession or control (“personal information”) that we collect about you and how we process it.
Information Collected
The information we may collect from or about you includes:
1. Personal Information
When you register on the website as a user or otherwise, update your information, take part in promotions or campaigns or contests, sign into our mobile application using your personal information or a social media account, send emails to us, send support requests, or when you report a problem with our platforms, you provide us with information that we store and process. Such information may include your name, address, phone number, email address, device IP address, date of birth, passport or Emirates ID, survey participation, video and audio recordings and your interests, and any other information that you independently choose to provide to us (for example, if you send us an email or call us).
2. Purchase Information
We may collect information relating to any purchases or potential purchases of our products or services that you make (such as records of purchase).
3. Website Information
We may receive information from you as a result of your visits to, and use of, the website. This information may include information such as your IP address, the date and time you access the website, length of time you spend on the website, your browsing history (recorded by the text and graphics files that compose that page), and the Internet address of the website from which you redirected to our website.
4. Financial, Payment, and Credit Data
We may collect payment data that you provide when you make online purchases. This may include your payment instrument number (e.g., credit card, debit card), your name and billing address, and the security code associated with your payment instrument (e.g., the CSV or CVV). We may collect information relating to payment and transaction history and billing information. We may also collect personal credit information, credit reports provided by a credit reporting agency used to report on overdue credit payments and commercial credit information for the purpose of providing mortgages to you.
5. Other Information
We may collect other information so that we, including our affiliates, can provide our services to you. If you are a user of any of our products or services, we may collect information you have made publicly available.
Appointment, Order Management, Customer Service, and After-sales Service
1. Appointment for Product and/or Service Needs: When you make an appointment through Refine for products and/or services related to decoration, design, building materials, etc., you may need to provide appointment person information (such as name, phone number), site information (such as when applying for free on-site measurement services), service preferences (such as decoration style, building material brands, and/or products), etc. Your act of booking related products and/or services and providing the above information indicates your consent for us to contact you through this information to further verify your needs.
2. Order Management: When you place orders for specific products and/or services through us, our system will generate orders for the products and/or services you ordered. During the ordering process, you need to provide at least the recipient’s name, delivery address, recipient’s contact number. The order will also contain information about the products and/or services you purchased, specific order numbers, order creation times, etc. We collect this information to help you complete transactions smoothly, ensure the security of your transactions, inquire about order information, delivery, provide customer service and after-sales service, and other purposes that we explicitly inform you of. If you are ordering products and/or services for others, you need to provide the afore mentioned personal information of the actual buyer; if it involves the personal information of children, you need to obtain the consent of the corresponding guardian before providing it. For ease of querying order information and managing order information, we will collect the order information generated by you when using our services to show to you. The orders generated by you on Refine may contain your identity information, contact information, etc., all of which are sensitive information. Please be cautious about showing or providing them to others. We will also try our best to de-identify the information when displaying order information while ensuring its availability.
3. Customer Service and After-sales Service: When you contact our customer service, our system may record the communication information (text, voice, etc.) between you and the customer service, as well as use your account information for identity verification. When you need us to provide customer service related to your project or order, we may query your relevant order information to provide you with appropriate assistance and processing. When you need customer service to assist you in modifying relevant information (such as delivery address, contact information, etc.), you may also need to provide additional information other than the above information to complete the modification. In order to ensure service experience and handle service disputes, your communication information (text, voice, etc.) with our customer service may be collected. With authorization, when there is a service dispute, we may retrieve and use communication information (text, voice, etc.) as a reference for resolving disputes.
Collection Of Data
We may collect your information during the course of our relationship with you. We may provide information about your website visit to analytics and search engine providers to enhance our services. This data includes your IP address, pages visited, and browser type, but it does not contain direct personal identifiers such as your name or email address. We may also share your Meta Data with advertising networks to deliver relevant advertisements to you. In the event that the Refine or its assets are acquired, the user data we possess will be transferred as part of the acquisition. If we seek professional advice, such as from lawyers or financial advisors, we may disclose your personal information as necessary. Additionally, we may disclose your personal information if required to do so by a government or regulatory authority.
Refine will treat your personal information as confidential and will only disclose it for the following purposes:
1. If it believes it is necessary to comply with a requirement of the UAE law enforcement agencies.
2. Processing orders (if applicable);
3. Where the personal information is given for the purpose of evaluating that personal information given against present or future employment opportunities within Refine or any of its affiliated companies.
4. To administer this Website.
5. For statistical purposes to improve this Website and its services to you.
6. To notify you of products, special offers or competitions that may be of interest to You; or
7. To disclose to affiliated companies and other relevant third parties, who may contact you about their products or services that may be of interest to you.
Why Do We Collect Data
We collect your personal information as permitted and in accordance with applicable data protection laws for the following reasons:
1. The collection of the information is necessary for the performance of a contract with you or to take steps at your request to enter into a contract;
2. You have consented and approved for us to collect such data (in cases where your consent is expressly required and requested to process your personal information, for a specific purpose);
3. For our legitimate interests. Using your personal information helps us to operate, improve and minimise any disruption to the platforms and the services that we may offer to you. We also have a legitimate interest in sending you information on the services we believe will be of interest to you;
4. To comply with legal and regulatory obligations; or
5. If you have made the personal information publicly available.
Data Storage and Retention
The personal information you provide may be stored on secure servers located anywhere in the world. When you submit your personal information, you consent to its transfer, storage, and processing. We rely on approved data transfer mechanisms to ensure that your personal information is adequately protected, regardless of the location of our servers. While we have strict procedures in place to secure your data once it is received, we cannot guarantee its absolute security. Any data you send to us is done so at your own risk. In cases where you have a password to access certain parts of our websites, it is your responsibility to keep that password confidential and not share it with anyone.
How long we hold your personal information for will vary, and we will typically keep your personal information only for as long as is necessary to respond to any queries or complaints, to improve the services that we offer to you or to comply with any legal obligations to which we may be subject.
To determine the appropriate retention periods for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve such purposes through other means, and the applicable legal requirements.
We keep your personal information for as long as is necessary for the purposes for which it was requested. If you would like to delete your information from our servers, you may request us to do so by contacting us.
Data Processing
We will comply with applicable data protection laws that apply to our processing of your personal information. This ensures that we will comply with the following:
1. Process your personal information in a lawful, fair, transparent, and secure way;
2. Collect your personal information only for specific, explicit, and legitimate purposes as explained to you when collecting your personal information;
3. Not use your personal information in any way that is incompatible with those purposes;
4. Process your personal information in a manner that is adequate and relevant to the purposes for which we have collected it and limited only to those purposes;
5. Keep your personal information accurate and, where necessary, up to date; and
6. Keep your personal information in a form that identifies you only as long as necessary for the purposes we have informed you and/or as permitted by law.
We may use or process your personal information for the following purposes:
1. To provide any services that you request from us;
2. To provide a better service to you, and in particular, to keep internal records, as well as to improve our products, services, and the platforms. If you contact us via the website, or via email to the contacts set out on the website, or via our call centres, we may keep a record of that correspondence or call to improve our services and to address any specific requests or complaints;
3. To communicate with you (through various communication platforms, such as WhatsApp, SMS, phone, and email) if you have ordered, purchased, or participated in anything on the platforms;
4. To contact you for market research purposes;
5. To provide you with information about new opportunities, promotions, alert notifications, special offers and other information that we may feel is relevant to you;
6. To provide you and enable selected third parties to provide you, with information about goods or services that may interest you;
7. To improve our platforms by determining the website’s technical design specifications and identifying system performance or problem areas, for tracking activity on the website and mobile applications, preparing reports, assessing trends, and otherwise monitoring the way in which the platforms are being used;
8. To process your payments or any documents that you provide via the platforms;
9. To measure or understand the effectiveness of advertising we serve to you and others, to deliver relevant advertising to you, to make suggestions and recommendations to you and other users of our website about goods and services that may interest you or them, which may be based on your activity on our website or third parties’ website(s); and
10. To comply with legal obligations.
Sharing Of Data Collected
We will only disclose or transfer your personal information for the purposes set out in this notice:
1. To business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you;
2. To any member of our group;
3. To any competent authorities if we are legally required to comply with a request for data;
4. To our third-party service providers. We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, such as software, system, and platform support; social media and communication services. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose other than to provide services to us;
5. If we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, along with its professional advisers. If our, or any of our affiliate’s assets are acquired by a third party, personal information held by us or our affiliates about our customers will be one of the transferred assets;
6. If required in order to obtain professional advice;
7. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; and
8. To protect our rights, property, or safety, as well as that of our affiliates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Transfer Of Data Collected
The information that we collect from you may be transferred to and stored and hosted outside of the country from which you may be accessing the platforms and may be transferred to countries which do not have data protection laws or to countries where your privacy and other fundamental rights will not be protected as extensively. For example, your personal information may be processed by staff operating outside such country, who work for us or for one of our suppliers. These and all other transmissions will remain secure and under our control.
We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside your home country, and you can exercise your rights effectively.
The Security Of Your Information
Keeping your personal information secure and preventing unauthorized access is of utmost priority to us, and we take all steps reasonably necessary to protect your personal information against any unauthorised access, use, alteration, disclosure, or destruction. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
Where we have given you, or where you have created a password which is part of our services or allows you to access parts of our platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
As the transmission of information via the internet is not completely secure. We will do our best to protect your personal information, as such, we cannot guarantee the security of your information transmitted to our platforms. Any transmission of information made, is done so at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Your Rights
Under certain circumstances and applicable data protection laws, you may have the right to:
1. Access your data – request a copy of your personal information that we process about you;
2. Correct your data – request us to amend or update your personal information where it is inaccurate or incomplete;
3. Erase your data – request us to delete your personal information where it is no longer necessary for the purpose(s) for which your information was originally collected;
4. Restrict your data – request us temporarily or permanently to stop processing all or some of your personal data;
5. Object to the use of your data – at any time, object to us processing your personal information where it is based exclusively on our legitimate interests (see above) or for direct marketing purposes;
6. Receive or transmit your data in a machine-readable and structured format (otherwise known as “data portability”) – request the receipt or transmission of your personal information to another organisation, in a structured and machine-readable format; and
7. Withdraw your consent – withdraw your consent at any time to the use of your personal information for a particular purpose (where we have asked you for consent to use your information for that particular purpose). Please take note that in certain circumstances it may be lawful for us to continue processing without your consent if we have another legal basis (other than consent) for doing so.
For any of the above, please email us at support@refine.com. Subject to any overriding legal obligations, requirements and/or exemptions, we will endeavour to respond to your request as soon as possible, unless we require further information from you. We may also ask you to provide proof of your identity.
Marketing Preferences
To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or by sending an email to support@refine.com. For other marketing preferences, you can contact us via any relevant link in the marketing communication, or by sending an email to support@refine.com. Information related to controlling cookies can be found in our Cookies Policy.
Hyperlinks
Our services may contain links and may be used by you in conjunction with third-party apps, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include but are not limited to Facebook, LinkedIn, Twitter and, third-party apps like voice software and readers. The privacy practices of these third parties will be governed by the parties’ own privacy policies. We are not responsible for the security or privacy of any information collected by these third parties. Before providing any personal information to such websites, we strongly advise you to review their privacy policies.
Information that you provide to third-party companies is not covered by this Privacy Policy.
Privacy Of Minors
We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. We do not knowingly or actively collect information from children, and we do not target our platforms to children. If you become aware that a child has provided us with personal information without the parent or guardian’s consent, please contact us a support@refine.com and we will take steps to delete the information from our records.
Acceptance
You acknowledge that you have read this Privacy Policy and agree to all its terms and conditions and acknowledge that by using the Website or its Services you agree to be bound by them. If you do not agree to abide by the terms of this Agreement, you are not authorized to use or access the Website and its Services. By accessing and using the Web Site, you accept and agree to be bound, without modification, limitation, or qualification, by the Terms.
Updates Or Changes To This Privacy Policy
We may, at our sole discretion, update this Privacy Policy from time to time as we deem necessary. If there are material changes to this Privacy Policy, we will provide notice where, and in the manner required, by applicable laws, including but not limited to by email or via the platforms. Any changes to this Privacy Policy shall take effect immediately after being notified by us.
Contact Us
This Privacy Policy sets out in broad terms how we handle your personal information and safeguard your privacy. If you have any questions relating to our Privacy Policy, please send an email to support@refine.com.
