Privacy Policy

Last updated:

Refrakt knows you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy outlines how we collect, use, and share your personally identifiable information through our website (www.refrakt.app) and our communications with you (collectively, the “Services”). Please read it carefully.

References to “Refrakt”, “we”, “us” or “our” in this Privacy Policy are to Refrakt Ltd, Company Number 14758721, C/O 86-90 Paul Street, London, EC2A 4NE, United Kingdom. We are the Controller of your personal data (this simply means we are responsible for what happens to your personal data).

This Privacy Policy does not apply to any third party websites, services, or applications, even if they are accessible through our Services.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we'll notify you of those changes by posting them within the Services or by sending you an email or other notification, and we'll update the “Last updated” date above to indicate when those changes become effective.

Scope of the Privacy Policy

This Privacy Policy applies to all users of our Services including without limitation, site visitors, registered user, and subscribers (all such users of the Services including account holders and non-account holders collectively referred to as “Users”).

Contact information

If you have any questions about the Privacy Policy, your personal data, or you would like to exercise any of your data protection rights, please contact us via email (support@refrakt.app).

Information we collect

This section describes the different types of Personal Data we may obtain about you.

Information that you provide directly

  • Registration: When you create an account, you provide an email address.

  • Profile information: When completing your profile you'll have the option to provide information about yourself which will be included in your public facing profile, including for instance: a profile photo, name and username, your websites, contact information, your publications, projects, exhibitions, and a short bio about you.

  • Payments: When you make payments for or within the Services, we will keep records of what you purchased, and will request financial information such as payment method or credit card information so we can charge you for your purchase. We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe, whose use of your personal data is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.

  • Public posts: You may publish any information when you post content such as images and text publicly, or to those who follow you. Please, be aware that if such information consists of someone's personal data, you must have a legal ground for the processing of such personal data.

  • Through interactive features: Information that you provide through public sharing features of the Services (which does not include one-to-one direct messages) such as comment features or social features, will be treated as public information.

  • Resolve issues: You can submit some data to support, in the case that this data is needed to resolve any issues.

  • Information related to legal requirements: Information to comply with applicable law that requires us to retain some personal data for some period of time.

Information collected automatically

  • Device information: Technical details, such as information about your hardware, device manufacturer, unique device identifiers, information about software, the operating system, and version running on your system or device, browser and plug-ins, and mobile network information.

  • Your activity: Information about your experience while using our Services, such as response time, crash reports and errors, length of visit, and the information provided to our support team. This is statistical data about our users' browsing actions.

  • Log Data: We also receive this information when you use our Services, which we refer to as Log Data. This Log Data includes your IP address, operating system, visited pages, location, hardware or device information, and cookie information.

How we use the information

We will only process information that is necessary for the purpose for which it has been collected. We will use the information for the following purposes:

  • Providing our Services, including to communicate with you, and provide customer support in relation to the Services;

  • Resolving disputes, responding to inquiries, collecting and processing payments fees (as applicable) and troubleshooting problems;

  • Collecting and processing payment;

  • Customizing your experience and otherwise measuring and improving our content and Services;

  • Enforcing our agreements, terms, conditions, and policies, and sending you notices and alerts;

  • Better understanding our Users' interests, behaviors, and demographics;

  • To inform you of updates to our terms and policies;

  • For cookies that are essential to function properly;

  • Managing our everyday business needs, including, but not limited to the following activities: auditing, administration of the Services, analytics, fraud prevention, identify verification, and enforcement of our Terms of Service, or to comply with applicable laws or regulations;

  • Auditing relating to interactions, transactions and other compliance activities, and;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.

We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent.

Information that we share with third parties

We may share your personal data with third parties as described below:

  • Our Service Providers: We share your personal data with third party service providers that provide services on our behalf; for example, we use Stripe (a third party payment provider) to receive and process your credit card transactions for us. Such third parties further include, but are not limited to, providers of: website hosting; maintenance services; email services; security services; content delivery networks; customer support operations and software services; traffic analytics services; and cloud storage and computing services.

  • Other users: If your user profile allows it, you may choose to populate certain user profile information, including, without limitation, your name, subscriptions, communities, external links, and any image content. Any user profile information uploaded may be displayed to other users to facilitate user interaction within the Service (including when you post comments or upload images through the Service). Your account privacy settings may allow you to limit the other users who can see the personal data in your user profile and/or what information in your user profile is visible to others. Your name, username, and user profile may also be displayed to other users when you interact with a post, for instance, by “liking” the post or leaving a comment.

  • Other users offering subscriptions: Users of the Services can offer paid subscriptions for their content. When you subscribe to another user's content, we provide them the information necessary (including your name and email address) to manage your subscriptions via our chosen payment provider, Stripe. We do not share your credit card information with the user.

  • Prospective sellers or buyers: We may share and/or transfer User information in connection with the sale or merger of our business or assets (subject to local laws). Also, if we go out of business, enter bankruptcy, or go through some other change of control.

  • Government authorities and/or law enforcement officials: If required for the purposes as described in this Privacy Policy, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws we may share personal data with competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals in any jurisdiction or markets, domestic or foreign.

  • With Your Consent: There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent.

In certain cases, we may anonymize your personal data in such a way that you can no longer be identified as an individual, and we reserve the right to use and share such anonymized information to trusted partners not specified here. However, we never disclose aggregated or de-identified information in a manner that could identify you as an individual.

International Transfers

We are located in the United Kingdom (UK) and generally store your personal data on servers within the UK and the European Economic Area (EEA). However, please note that some of our third party service providers who process your personal on our behalf are located in the United States (US) and your personal data is therefore also transferred to their servers in the US. We may also replicate certain data to other servers and content delivery networks globally to improve the speed and performance of our Services. As such, your personal data may be transferred internationally.

The Security of Your Information

We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your personal data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Personal Data Retention

We will retain your personal data for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.

The criteria we use to determine our retention periods include:

  • The length of time we have an ongoing relationship with you;

  • Whether there is a legal obligation to which we are subject;

  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations); and

  • Any guidelines issued by relevant legal and data protection authorities.

Your Rights

By law, you have a number of rights (subject to certain conditions and exceptions) when it comes to your personal data and can exercise any of these rights by contacting us.

  • The Right To Be Informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.

  • The Right of Access: You have the right to ask us to see all your personal data that we hold about you and information on how we use it.

  • The Right To Rectification: You have the right to ask us to correct your personal data when it is inaccurate or incomplete.

  • The Right To Erasure: You have the right to ask for deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure there are exceptions which may mean we are unable to comply with your request.

  • The Right To Restrict Processing: You have the right to “block” or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but not use it further.

  • The Right To Data Portability: You have the right to ask us to give you (or another company you choose) all the personal data we have collected from you directly in a structured and machine readable format (a format easy for computers to use and understand).

  • The Right To Lodge A Complaint: You have the right to lodge a complaint about the way we handle or process your personal data with your relevant national data protection regulator (for example, in the UK this is the Information Commissioner's Office (ICO) and other European countries have similar authorities you can contact).

  • The Right To Withdraw Consent: You have the right to withdraw your consent at any time where we rely on your consent as a lawful basis for processing your personal data.

Children's Privacy

We kindly remind you that our Services are not intended for use by children or persons under 18 years of age according to the terms of service. We do not knowingly collect or process any personal data from or with respect to children. If we become aware that we have collected personal data on behalf of a person under the age of 18, we will delete this information when we become aware of it. We will block or restrict the child from accessing our Services, or obtain consent from parents for the collection, use, and sharing of their children's personal data. If you have any reason to believe that we have collected such personal data, please inform us immediately.

Cookies

A cookie is a small piece of data that is stored on your computer or mobile device. We use cookies and similar technologies to collect additional Service usage data and to operate our Services. Our Services use cookies to distinguish you from other users. This helps us to provide you with a good experience and allows us to improve our Services.

You can set or amend your web browser controls to accept or reject cookies. Alternatively, you may wish to visit aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

If you choose to reject cookies, you will still use our Services, however, your access to some functionality and areas of our Services may be restricted.

Links to other sites

Our Services may contain links to third party services. If you click on those links, you will leave our Service. As we do not operate those sites, applications, and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check the privacy policies of every website. As a kind reminder, our Privacy Policy concerns only our Services.

Privacy Questions

We know issues of privacy and data protection are complex. But we're here to help in any way we can. So please contact us, via email (support@refrakt.app) if you have any questions about your personal data, our data practices, or this Privacy Policy.