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Data Protection

Cookie Policy

This policy explains how Refinox.shop uses cookies and similar technologies to operate the website, measure its performance, and support our advertising. Our store sells exclusively on a Cash on Delivery (COD) basis: there is no online payment, no account or login, and no shopping cart or online checkout.

Last Updated: December 7, 2025 | GDPR Compliant

1. Legal Framework and Compliance

Who Manages Your Data

The data controller for this website is Advan Hong Kong Technology Limited (Business Registration No. 80583797), RM 1307 13/F Kenbo Commercial Building, 335-339 Queen's Road West, Hong Kong. Our EU-based fulfilment and logistics partner, Adamanta Sp. z o.o. (ul. Jodlowa 25, 20-825 Lublin, Poland; KRS 0001078676, VAT PL7123467638), acts as a data processor under Article 28 GDPR and is our point of contact within the European Union.

Applicable Law

Because we serve customers in the European Union, this policy is built around:

  • EU GDPR: General Data Protection Regulation (Regulation 2016/679)
  • ePrivacy rules: Cookie consent requirements applicable across the EU/EEA
  • National Laws: Local privacy laws in the European countries we serve

Your Rights Under GDPR

If you are located in the EU/EEA, you have the following rights:

  • Consent: Opt-in consent is required for all non-essential cookies
  • Access: Request information about the cookie data we process
  • Rectification: Correct inaccurate cookie-related data
  • Erasure: Request deletion of your cookie data
  • Portability: Receive your data in a machine-readable format
  • Objection: Object to processing for marketing purposes
  • Withdrawal: Withdraw your consent at any time

Legal Basis for Processing

We process cookie data based on:

  • Strictly Necessary: Essential cookies needed for the website to function
  • Consent: Analytics, advertising and marketing cookies are set only after you opt in
  • Legal Obligation: Recording your consent choices as required by law

GDPR Consent Mechanism

EU/EEA visitors are shown a cookie consent banner before any non-essential cookies are set. We operate Google Consent Mode v2, so analytics and advertising tags only fire once you grant consent. Your choices are recorded and can be changed at any time.

2. What Are Cookies?

Cookies are small text files that are stored on your device (computer, smartphone, tablet) when you visit our website. They contain information about your browsing session and help us run the site and measure how it is used.

Types of Technologies We Use

  • Cookies: Small text files stored on your device
  • Tags and pixels: Snippets that record page views and events for analytics and advertising measurement
  • Local Storage: Browser storage used by our caching and analytics tools
  • Session Storage: Temporary storage that expires when you close your browser

Why We Use Cookies

Cookies help us keep the website running, remember your cookie preferences, measure website performance with analytics, and measure the effectiveness of our advertising.

3. Categories of Cookies We Use

Strictly Necessary Cookies (Required)

These cookies are necessary for the website to function and cannot be disabled. They do not require consent:

Cookie / Technology Purpose Duration
wp-consent-api Stores your cookie consent choices and applies Consent Mode v2 Up to 1 year
WordPress / Elementor session cookies
(wordpress_*, elementor)
Maintain the technical session and correct rendering of the page Session
Breeze cache Page caching to load the website faster and more reliably Session / short-term

Analytics Cookies (Performance)

These cookies are set only after you consent. They help us understand how visitors use the website:

Service Purpose Duration
Google Analytics 4 via Google Site Kit
(_ga, _gid — property G-YG3D1SW16J)
Measures website usage, page views and aggregated visitor behaviour _ga: 2 years; _gid: 24 hours
Microsoft Clarity
(_clck, _clsk — project v4rjs4v4cf)
Aggregated usage analytics to help us improve the website _clck: 1 year; _clsk: 1 day

4. Advertising and Marketing Cookies

Google Ads & Google Tag Manager

These cookies are set only after you consent. We use Google Ads to reach customers and measure the effectiveness of our campaigns. Tags are managed through Google Tag Manager (container GTM-M9RTNV47):

Service Purpose Duration
Google Ads
(_gcl_au, _gcl_aw)
Attributes visits and conversions to our Google Ads campaigns Up to 90 days
Google Ads Conversion Linker
(conversion tags via GTM)
Measures conversions and improves measurement accuracy Up to 90 days

Personalized Advertising

We measure advertising performance and may show you relevant product advertisements. You can opt out of personalized ads through your Google Ads Settings or your browser preferences, and you can withdraw consent at any time using the controls below.

5. Functional Cookies

Enhanced Website Experience

Where applicable, functional cookies can remember basic display preferences set by our website tools:

  • Language Preferences: Remember your preferred language for the displayed content
  • Display Settings: Remember basic interface choices on the page

No Account, No Online Payment

Refinox.shop does not offer user accounts, logins, a shopping cart or an online checkout, and does not process card or online payments. We do not use cookies for those purposes. Orders are placed on a Cash on Delivery basis and confirmed directly with you.

6. How Long Do Cookies Last?

Session Cookies

These temporary cookies are deleted when you close your browser:

  • WordPress / Elementor technical session cookies
  • Page rendering and navigation state
  • Short-lived cache cookies

Persistent Cookies

These cookies remain on your device for a specified period:

  • Short-term (1-30 days): Consent records, _gid analytics cookie, _clsk session cookie
  • Long-term (up to 1-2 years): _ga analytics cookie, _clck Clarity cookie, consent record

Automatic Cleanup

Cookies automatically expire based on their set duration. You can also manually clear them through your browser settings at any time.

7. International Data Transfers

Transfers From the EU to Hong Kong

The data controller is established in Hong Kong, while fulfilment for EU orders is handled by our processor in Poland. As a result, limited cookie and order data may be transferred between the EU and Hong Kong, and to our third-party service providers:

  • Controller access: Advan Hong Kong Technology Limited may access data from Hong Kong
  • EU processor: Adamanta Sp. z o.o. processes order data within the EU to fulfil and ship your order, collect the Cash on Delivery payment, and handle returns
  • Service providers: Google (Analytics, Ads, Tag Manager) and Microsoft (Clarity) may process data globally in line with their own safeguards

Safeguards for International Transfers

For transfers of personal data from the EU/EEA to Hong Kong, we rely on the European Commission's Standard Contractual Clauses (SCC), complemented by appropriate technical and organisational measures. We do not rely on any adequacy decision for Hong Kong, as none exists.

  • Standard Contractual Clauses (SCC): EU-approved data transfer agreements for transfers to Hong Kong
  • Technical Measures: Encryption, pseudonymization and access controls
  • Data Minimisation: Only the data needed for analytics, advertising measurement and order fulfilment is shared

Your Control Over International Transfers

You can limit international data transfers tied to cookies by declining or withdrawing consent for non-essential cookies, or by contacting us to restrict data sharing with specific third parties.

8. Third-Party Cookies

External Service Providers

Some cookies are set by the third-party services we use. These are only loaded after you grant consent (except strictly necessary ones):

  • Google Analytics 4 (via Google Site Kit) — website usage analytics
  • Google Ads & Google Tag Manager — advertising measurement and conversion tracking
  • Microsoft Clarity — aggregated usage analytics

Data Sharing

When these third-party services run on our site:

  • They may set their own cookies once you have consented
  • Their own privacy policies govern how they handle your data
  • We do not control third-party cookies directly
  • You can manage them through your browser or their settings

Cookie Control Center

Manage your cookie preferences and exercise your data rights under the GDPR.

Google Ads Settings Disable Analytics Clear All Cookies Exercise GDPR Rights

9. How to Control Cookies

GDPR Cookie Consent (EU/EEA Users)

If you're in the EU or EEA, you have enhanced control options:

  • Consent Banner: Granular cookie category selection on your first visit
  • Consent Withdrawal: Change your cookie preferences at any time
  • Consent Mode v2: Analytics and advertising tags only fire after you opt in
  • Do Not Track: We honor browser "Do Not Track" signals where possible

Browser Settings

You can control cookies through your browser preferences:

  • Block All Cookies: Prevents new cookies from being set
  • Delete Existing Cookies: Removes all stored cookies
  • Block Third-Party Cookies: Only allows cookies from our website
  • Incognito/Private Mode: Automatically deletes cookies when you close the browser

Browser-Specific Instructions

  • Chrome: Settings → Privacy and Security → Cookies and other site data
  • Firefox: Options → Privacy & Security → Cookies and Site Data
  • Safari: Preferences → Privacy → Cookies and website data
  • Edge: Settings → Cookies and site permissions → Cookies and site data

Mobile Device Controls

  • iOS Safari: Settings → Safari → Block All Cookies
  • Android Chrome: Chrome menu → Settings → Site settings → Cookies
  • App Tracking: iOS 14+ allows you to disable app tracking entirely

Important Notice

Disabling strictly necessary cookies may affect basic website functionality and how the page is displayed. Analytics and advertising cookies are optional and are never required to browse the site.

10. Impact of Disabling Cookies

Website Functionality

Disabling cookies may affect:

  • Page Display: Some pages may not render or load as efficiently
  • Preferences: Basic display and language settings may not be saved
  • Consent Records: Your cookie choices may need to be set again on each visit

Measurement

  • Website performance analytics will be less accurate
  • Advertising measurement may be incomplete

Alternative Experience

If you disable non-essential cookies, you can still:

  • Browse our full product catalog
  • Read product information
  • Contact customer support
  • Place an order on a Cash on Delivery basis

11. Your Data Subject Rights

Your Rights (GDPR)

If you are located in the EU or EEA, you can exercise these rights regarding your cookie data:

  • Right of Access: Request details about what cookie data we hold about you
  • Right to Rectification: Correct any inaccurate cookie-related information
  • Right to Erasure: Request deletion of your cookie data and tracking history
  • Right to Restriction: Limit how we process your cookie data
  • Right to Portability: Receive your cookie data in a portable format
  • Right to Object: Object to processing for direct marketing purposes
  • Right to Withdraw Consent: Withdraw consent for non-essential cookies at any time

How to Exercise Your Rights

To exercise any of these rights:

  • Email: Send a detailed request to support@refinox.shop
  • Subject Line: Include "Data Subject Request - [Your Right]"
  • Verification: We may need to verify your identity for security
  • Response Time: We will respond within 30 days as required by the GDPR
  • Free of Charge: Most requests are processed free of charge

Quick Data Subject Actions

Use our Cookie Control Center above for immediate actions like clearing cookies or adjusting preferences. For more complex requests, email our privacy team.

12. Updates to This Cookie Policy

We may update this Cookie Policy to reflect changes in:

  • Technology: New tracking or measurement technologies
  • Services: Additional or removed third-party integrations
  • Legal Requirements: Changes in privacy laws or regulations
  • Business Practices: New features or functionality

GDPR Compliance Notifications

For EU/EEA users, we will provide clear notifications for material policy changes:

  • Material Changes: Advance notice where required
  • New Cookie Categories: Additional consent requests where required
  • Withdrawal Options: Clear instructions for opting out of changes

Notification Process

  • We will update the "Last Updated" date at the top
  • Significant changes will be highlighted on our website
  • Continued use implies acceptance of the updated policy

Cookie Policy Questions?

General & Privacy/GDPR Inquiries: support@refinox.shop

Data Controller: Advan Hong Kong Technology Limited (Business Reg. No. 80583797)

Hong Kong Address: RM 1307 13/F Kenbo Commercial Building, 335-339 Queen's Road West, Hong Kong

EU Representative & Processor: Adamanta Sp. z o.o., ul. Jodlowa 25, 20-825 Lublin, Poland (VAT PL7123467638)

Response Time: 72 hours for cookie inquiries, 30 days for data subject requests

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Contact Info

Rep: Liu Fei

Company: Advan Hong Kong Technology Limited

RM 1307 13/F KENBO COMMERCIAL BUILDING
335-339 QUEEN'S ROAD WEST, HK

support@refinox.shop

© 2025 Refinox.shop — All rights reserved. This website is owned and operated by Advan Hong Kong Technology Limited (Reg. No. 80583797), Hong Kong. EU orders are fulfilled by our partner Adamanta Sp. z o.o. (Lublin, Poland).