Last updated: 20 September 2024
Operated by CXDATA Ltd ("Refyner", "we", "us"), a company registered in England & Wales under company number 15100231, registered office 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ. Refyner is a CXDATA product.
Refyner forms part of the CXDATA group, and this product-specific policy is built on CXDATA's group data-protection framework. It sits alongside CXDATA's group policies — Privacy · Terms · Cookies — and where this policy is silent the CXDATA group Privacy Policy applies.
Refyner is a data preparation and scheduling product for eCommerce and subscription brands, operated by CXDATA Ltd, a company registered in England & Wales under company number 15100231, with registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ. For the purposes of the UK GDPR and the Data Protection Act 2018, CXDATA Ltd is the controller responsible for personal data we collect directly. For questions about this policy, contact privacy@refyner.com.
Our relationship to personal data depends on the context:
To run the service we store dataflow definitions, schedules, run logs, and schema/structural metadata. This is the instruction set for your dataflows – not your customers' records.
Our lawful bases under UK GDPR include performance of a contract, legitimate interests, consent (where required), and legal obligation.
Where you use AI authoring assistance, we send schema/structural metadata and only the sample rows you explicitly approve to our enterprise model provider. Your full datasets are not sent, and your data is not used to train third-party models. See our Security page for detail.
We do not sell, trade or otherwise transfer your personal data to outside parties. We share it only with trusted service providers and sub-processors who help us operate, under contract and on a need-to-know basis – including Microsoft Azure and Snowflake (hosting and warehouse infrastructure), our enterprise AI model provider, Google LLC (Google Analytics for website usage), and our payment and email providers. All are required to meet UK GDPR standards. A current sub-processor list is available on request. We may also disclose information where required by law or to protect rights, property or safety; where legally compelled, we strive to limit disclosure and, unless prohibited, will notify you.
Data collected as part of the service is held on servers physically located in the United Kingdom and Europe (Azure UK South). Where personal data is transferred across borders, we rely on appropriate safeguards such as the UK IDTA or Standard Contractual Clauses.
We use strictly necessary cookies to operate the site and, with your consent where required, analytics cookies to understand usage. You can manage preferences through your browser settings or our cookie controls. See our Cookies Policy.
We retain personal data only as long as needed for the purposes above or as required by law. Account and dataflow data are retained for the life of your account and deleted or anonymised within a reasonable period of closure, subject to legal requirements.
Depending on your location, you may have rights to access, correct, delete, restrict, or port your personal data, and to object to certain processing. To exercise these, contact privacy@refyner.com. You may also lodge a complaint with your supervisory authority – in the UK, the Information Commissioner's Office (ICO).
We apply technical and organisational measures to protect personal data, described on our Security page. Data is protected by password-controlled access, and personnel and subcontractors are bound by confidentiality obligations. No method of transmission or storage is completely secure. In the event of a personal data breach, we will notify you and the Information Commissioner's Office (ICO) within 72 hours, with details of the breach, the affected data, any impact on the service, and our remediation plan.
Refyner is a business product not directed to children, and we do not knowingly collect personal data from anyone under 16.
We may update this policy from time to time. Material changes will be notified through the service or by email, and the "last updated" date will change.
CXDATA Ltd, 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ · privacy@refyner.com.