Privacy policy

Overview

We take the protection of your personal information very seriously at Refined Capital Partners (“we/ us”).

We collect personal information from you when you contact us via our ‘contact us’ form on our website at http://refined-capital.co.uk/ (the “Site”). Maintaining the security of your data is a priority at Refined Capital Partners, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Refined Capital Partners is also dedicated to being transparent about what data we collect about you and how we use it. By using our website, you are agreeing to our Privacy Policy. We are registered with the Information Commissioner’s Office as Refined Capital Partners. We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 2018 and the General Data Protection Regulation 2018.

This policy provides you with information about:

• how we use your personal information;

• what personal information we collect;

• how we ensure your privacy is maintained; and

• your legal rights relating to your personal information.

How we use your personal information

We use your personal information:

- to contact you or keep in touch as you indicate when you provide us with your contact details;

- to make a tailored website available to you;

- to manage any registered account(s) that you hold with us;

- to verify your identity;

- for crime and fraud prevention, detection and related purposes; and

- where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

Sharing data with third parties

a. Our service providers and suppliers

In order to make certain services available to you, we may need to share your personal information with some of our service partners. These include IT service providers.

We may share some of your Personal Information with third parties to help facilitate the uses as described below. For example, we use Squarespace to power our site--you can read more about how Squarespace uses your Personal Information here: https://www.squarespace.com/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://policies.google.com/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We only allow our service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls or in line with their policies set out above. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to us and to you, and for no other purposes.

b. Other third parties

Aside from our service providers, Refined Capital Partners will not disclose your personal information to any third party. We will never sell or rent our customer information to other organisations for marketing purposes. We will never pass your email address or telephone number on to a third-party for marketing purposes.

How long do we keep your data?

We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 5 years since your last contact with us.

What personal information do we collect

Refined Capital Partners may collect the following information about you:

- your name;

- your contact details: telephone numbers (including mobile numbers) and e-mail address (Contact Information);

- your online browsing activities on our website; and

- your correspondence and communications with us.

Our website is not intended for children and we do not knowingly collect data relating to children.

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal information is collected directly, for example when you email us. 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Contact Information.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

How we protect your data

Our controls

Refined Capital Partners is committed to keeping your personal data safe and secure.

Our security measures include, as appropriate: -

- encryption of data;

- regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;

- security controls which protect the Refined Capital Partners IT infrastructure from external attack and unauthorised access; and

- internal policies setting out our data security approach and training for employees.

What you can do to help protect your data

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

Your rights

You have the following rights:

- the right to ask what personal information that we hold about you at any time,

- the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you; and

- (as set out above) the right to opt out of any marketing communications that we may send you.

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

Legal basis for Refined Capital Partners processing customers’ personal information

General

Refined Capital Partners collects and uses customers’ personal information because it is necessary for:

- the pursuit of our legitimate interests (as set out below); or

- complying with our legal obligations.

Our legitimate interests

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Refined Capital Partners including:-

- responding to any queries that you may have or the reason for you contacting us;

- protecting customers, employees and other individuals and maintaining their safety, health and welfare;

- promoting, marketing and advertising our services;

- understanding our customers’ behaviour, activities, preferences, and needs;

- improving existing services and developing new services;

- complying with our legal and regulatory obligations;

- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;

- handling contacts, queries, complaints or disputes;

- protecting Refined Capital Partners, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Refined Capital Partners;

- effectively handling any legal claims or regulatory enforcement actions taken against Refined Capital Partners;

- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders; and

- We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

How to contact us

If you have any questions about how Refined Capital Partners uses your personal information that are not answered here, or if you want to exercise your rights regarding your personal information, please contact us by the following means:

• Email us at legal@refined-capital.co.uk

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.

Updates

This policy was last updated on 9 November 2023.