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Privacy Policy

Your privacy matters to us. This policy explains, in accordance with the EU General Data Protection Regulation (GDPR), how we collect, use, and protect your personal data when you use Refinox.shop and place an order with us.

Last Updated: December 7, 2025

1. Who We Are (Data Controller and Processor)

Data Controller

The data controller responsible for your personal data is the owner of this website:

Company: Advan Hong Kong Technology Limited
Business Registration No.: 80583797
Address: RM 1307 13/F Kenbo Commercial Building, 335-339 Queen's Road West, Hong Kong
Privacy contact: support@refinox.shop

Data Processor and EU Point of Contact (Art. 28 GDPR)

To fulfil and deliver your order within the European Union, the data controller relies on an EU-based partner who acts as a data processor under a Data Processing Agreement in accordance with Article 28 GDPR. This partner also serves as our establishment and point of contact within the EU:

Company: Adamanta Sp. z o.o.
Address: ul. Jodlowa 25, 20-825 Lublin, Poland (EU)
KRS: 0001078676
NIP / VAT: PL7123467638
REGON: 527332151
Role: Receives your name, phone number and delivery address in order to process and ship your order from within the EU, collect the cash-on-delivery (COD) payment, and handle returns.

2. Information We Collect

We only collect the data we genuinely need. Our store works on a Cash on Delivery (COD) basis only: there is no online payment, no user account, and no shopping cart. You provide your details in a simple order form, and you pay the courier in cash when your order is delivered.

Information You Provide Through the Order Form

Full name: So we know who to deliver the order to
Phone number: So the courier or our support team can contact you to confirm or arrange delivery
Delivery address: So your order can be shipped to the correct location

We do not collect or store any payment card numbers, bank details, billing accounts or online wallet information, because all payments are made in cash directly to the courier on delivery.

Information Collected Automatically

Device information: IP address, browser type, operating system
Usage data: Pages visited, time spent, and how you navigate the site
Approximate location: General location based on your IP address
Cookies and similar technologies: Used for analytics and measuring advertising, subject to your consent

3. How We Use Your Data and Legal Basis

Under the GDPR, we may only process your personal data when we have a valid legal basis. We use your data for the following purposes:

Performance of a contract (Art. 6(1)(b)): To process, prepare, ship and deliver your COD order, contact you to confirm delivery, and manage returns. For this we use your name, phone number and delivery address.
Consent (Art. 6(1)(a)): To send you marketing communications (where you have opted in) and to set non-essential analytics and advertising cookies. You can withdraw your consent at any time.
Legal obligation (Art. 6(1)(c)): To comply with accounting, tax and other legal requirements relating to your order.
Legitimate interests (Art. 6(1)(f)): To keep our website and orders secure, prevent fraud and abuse, and improve our services. We balance these interests against your rights and freedoms.

4. Who We Share Your Data With (Recipients)

We never sell your personal data. We only share it with the parties below, strictly to deliver our service:

Order Fulfilment, Delivery and Returns

Adamanta Sp. z o.o. (Poland, EU): Our EU logistics partner and data processor (Art. 28 GDPR). It receives your name, phone number and delivery address to fulfil and ship your order, collect the cash-on-delivery payment, and handle returns.
Courier / delivery companies: Receive your name, phone number and delivery address only to deliver your parcel and collect the cash payment.

Analytics and Advertising Providers

Google (Analytics, Ads, Tag Manager): Website usage statistics and advertising/conversion measurement
Microsoft (Clarity): Anonymised website usage and behaviour analytics to help us improve the site

Legal Requirements

We may disclose information when required by law, court order, or to protect our legal rights and the safety of others.

5. International Data Transfers

Your order data is collected and processed within the European Union by our logistics partner Adamanta Sp. z o.o. in Poland. Some of your personal data may, however, be transferred to the data controller, Advan Hong Kong Technology Limited, in Hong Kong.

Because Hong Kong is a country outside the European Economic Area, we protect any transfer of personal data from the EU to Hong Kong by relying on the Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses contractually guarantee that your data continues to receive a level of protection essentially equivalent to that provided under EU law.

You can request a copy of the safeguards we use for international transfers by contacting us at support@refinox.shop.

6. Data Retention

We keep your personal data only for as long as necessary for the purpose for which it was collected:

Order and delivery data: Retained for the time needed to fulfil and deliver your order and handle any returns, and then for the period required by applicable accounting and tax laws (typically several years).
Marketing data: Until you unsubscribe or withdraw your consent.
Website analytics data: Retained for a maximum of 26 months.
Cookies: Retained for the duration set out in our Cookie Policy, after which they expire or can be cleared by you.

When data is no longer needed, it is securely deleted or anonymised.

7. Your Rights Under the GDPR

As a data subject, you have the following rights regarding your personal data:

Right of access: Obtain confirmation of whether we process your data and a copy of it
Right to rectification: Correct inaccurate or incomplete data
Right to erasure: Request deletion of your data ("right to be forgotten")
Right to restriction: Ask us to limit how we use your data
Right to object: Object to processing based on our legitimate interests, including direct marketing
Right to data portability: Receive your data in a structured, commonly used, machine-readable format
Right to withdraw consent: Withdraw consent at any time, without affecting processing carried out before withdrawal

How to Exercise Your Rights

To exercise any of these rights, contact us at support@refinox.shop. We will respond within the timeframes required by law.

Right to Lodge a Complaint

If you believe we have not handled your data correctly, you have the right to lodge a complaint with a supervisory authority. As our EU processing takes place in Poland, you may contact the Polish authority (UODO - Urzad Ochrony Danych Osobowych, uodo.gov.pl), or the data protection authority in your own country of residence.

8. Cookies, Analytics and Advertising

Tools We Use

With your consent, we use the following tools to understand site usage and measure our advertising:

Google Tag Manager to manage our tracking tags
Google Analytics 4 (via Google Site Kit) to understand how visitors use the site
Google Ads to measure the effectiveness of our advertising (conversion tracking)
Microsoft Clarity to analyse anonymised website behaviour and improve usability

We do not use Facebook/Meta pixels, TikTok, Hotjar or Bing tracking on this website.

What These Tools Collect

Pages visited and time spent on the site
Approximate geographic location (country/city level)
Device and browser information
Traffic sources and general behaviour patterns

Your Advertising and Cookie Choices

You can manage or refuse non-essential cookies at any time:

Google Ads Settings: adssettings.google.com
Google Analytics Opt-out: tools.google.com/dlpage/gaoptout
Browser Cookie Settings: Disable or delete cookies in your browser preferences

For more information about Google's privacy practices, visit the Google Privacy Policy. For Microsoft Clarity, see the Microsoft Privacy Statement.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

Encryption: SSL/TLS encryption for data transmitted to and from our website
Secure storage: Restricted-access systems for storing order data
Access controls: Data is accessible only to staff and partners who need it to fulfil your order
Regular monitoring: Ongoing security review of our systems

While we take all reasonable steps to safeguard your data, no method of transmission or storage is completely secure, so we cannot guarantee absolute security.

10. Changes to This Policy

We may update this privacy policy to reflect changes in our practices, technology, or legal requirements. When we make significant changes:

We will update the "Last Updated" date at the top of this policy
We will notify you by a notice on our website where appropriate
We will obtain your consent again where required by applicable law

Your continued use of our services after changes take effect constitutes acceptance of the updated policy.

Questions About Privacy?

Email: support@refinox.shop

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

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

EU Representative / Contact: Adamanta Sp. z o.o., ul. Jodlowa 25, 20-825 Lublin, Poland