Our privacy policy

Introduction

The Product Refinery (“TPR”, “we”, “us”, “our”) is committed to protecting the privacy of our customers and users of our website. This Privacy Policy states our policy and practices regarding the collection and use of information on our website.

We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website or through written correspondence (including e-mail)), is only used for the purposes set out in this Privacy Policy.

Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR“) and national laws implementing GDPR.

For the purpose of this Privacy Policy, the controller of personal data is The Product Refinery Limited and our contact details are set out in the Contact section at the end of this Privacy Policy.

The Information we collect

In general, you can visit the TPR website without identifying yourself or revealing any personal information.

However, you may choose to provide us with personally identifiable information. Personally identifiable information is information that can be used to identify you, such as your name, email address, telephone number, or similar information.

Within the TPR website, you can make requests for information, register to receive materials from us, and in some cases, purchase our products or services. The types of personal information collected in these circumstances may include name, location, employment details, education history, contact preferences (including email addresses & telephone number), age, salary range and billing, transaction, and credit card information (including billing address).

How we use your Personal Information

You can be assured that information you provide voluntarily will only be used in connection with your business relationship with TPR. We will hold, use and disclose your personally identifiable information for our legitimate business purposes including:

to provide our services to you;
to maintain our business relationship, where you are a user of our website or a customer;
to deal with your enquiries and complaints;
to administer our website;
to keep our website and systems secure and prevent fraud;
where relevant, to meet legal, regulatory or compliance needs;
to better understand your needs; and,
to provide a better service.

From time to time, we may also use your information to contact you for market research or, with your consent, to provide you with marketing information about our products and services we think would be of particular interest to you. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact.

We will not use or share the personally identifiable information provided to us online in ways unrelated to the uses described in this statement. More information about how we may share your information can be found at section 5.

The Legal Basis for Processing your Personal Information

Under GDPR, the main grounds that we rely upon in order to process personal information of uses of our websites and customers are the following:
(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.

How we share your Personal Information

We do not share your personal information with third parties, other than where we are required to do so by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.

If we or our business merges with or is acquired by another business or company in the future, we will share your personal information with the new owners of the business or company and their advisors. If this happens, we will notify users of our websites and customers of such event.

How long we will hold your information

We will retain your personal information for the time necessary to provide the services we perform for you, or stated by the purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information.

Your rights on Information we hold about you

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

Right of Access

You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or CompletionIf personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us at using the Contact section below.

Right of Erasure

In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal information by contacting us. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.

The above right exists only in respect of personal information that:

you have provided to us previously; and
is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent. You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.

Use of Cookies

We automatically track certain information about your behavior while visiting our website. We use this information in order to measure our website’s performance and to improve your experience with us.

We use the following cookies

Session cookies: temporary cookies that disappear when you close your browser

Persistent cookies: cookies that remain in your browser

How we use cookies

We use cookies to improve the experience with us and to give us an understanding of how TheProductRefinery.com is used. We also use cookies to improve our communication with those who visit us. We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of the TheProductRefinery.com. They include, for example, cookies that enable you to log into secure areas of the Site, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way the site works, for example, by ensuring that users are finding what they are looking for easily.
Marketing cookies. These cookies record your visit to the site, the pages you have visited and the links you have followed. We will use this information to be relevant in our communication to you.

Complaints

If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Security

We have put in place measures to ensure the security of the information we collect and store about you and will use our reasonable endeavours to protect your personal data from unauthorised disclosure and/or access including through the use of network and database security measures, but these cannot guarantee the security of any data which is collected and stored.

We use encryption when collecting or transferring sensitive data, such as credit card information.

Other websites

Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third party website, where data privacy practices are different to that of TPR.

We are not responsible for, and have no control over, information that is submitted or collected by these third parties and you should consult their privacy policies.

Internet based transfers

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Changes to our Privacy Policy

Our Privacy Policy is subject to change from time to time and, if we update it, we will post these changes on this page so that you will be aware of how we use your information.

Contact Us

If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please use the Contact Us form or send correspondence to the address below. When you contact us, we will ask you to verify your identity.

The Product Refinery

Silverstream House, 4th Floor

45 Fitzroy Street

London, England

W1T 6EB

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