Privacy Policy

1. About Us

• Company name: Refyned Limited
• Registered address: 15 Southcrofts, CW5 5SG
• Email: accounts@refyned.co.uk
• Company number: 17180108

Refyned Limited is a data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. The Type of Data We Collect

We may collect and process the following categories of personal data:

• Identity data: name, job title
• Contact data: business email address, business phone number
• Professional data: company name, industry, company size
• Technical data: IP address, browser type, device information
• Marketing interaction data: responses to campaigns, opt-out status

We do not intentionally collect sensitive personal data (special category data) or data relating to children.

3. How We Collect Personal Data

We collect personal data from the following sources:

• Publicly available sources (e.g. company websites, professional directories, LinkedIn)
• Third-party data providers and partners
• Individuals completing online forms or surveys
• Direct interactions such as email or telephone contact
• Cookies and tracking technologies on our websites

Where data is obtained from third parties, we take steps to ensure it has been collected lawfully.

4. How We Use Personal Data

We process personal data for the following purposes:

• Generating business-to-business sales leads
• Supplying lead data to our business clients
• Conducting B2B marketing and outreach campaigns
• Improving our products and services
• Compliance with legal and regulatory obligations
• Maintaining suppression lists to respect opt-outs

5. Lawful Bases for Processing

Under UK GDPR, we rely on the following lawful bases:

• Legitimate interests – for B2B lead generation and direct marketing, where those interests are not overridden by individual rights
• Consent – where required by law (e.g. certain electronic marketing)
• Legal obligation – where processing is required to comply with law

You have the absolute right to object to processing for direct marketing at any time.

6. Direct Marketing

We process personal data for business-to-business marketing purposes in line with the Privacy and Electronic Communications Regulations (PECR).

Every marketing communication provides a clear and simple way to opt out. We respect all opt-out requests promptly.

7. Data Sharing & Selling of Leads

As part of our services, we may share or sell lead data to our business clients. This data is provided strictly for legitimate business purposes.

We may also share data with:

• Data processors (e.g. hosting, CRM, analytics providers)
• Professional advisers (legal, compliance, accounting)
• Authorities where legally required

We require all recipients of personal data to implement appropriate data protection measures.

8. International Data Transfers

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as:

• UK International Data Transfer Agreements (IDTAs)
• Adequacy decisions

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy, including legal and compliance obligations. Data that is no longer required is securely deleted or anonymised.

10. Your Data Protection Rights

Individuals have the right to:

• Request access to their personal data
• Request correction of inaccurate data
• Request erasure of their data
• Object to processing for direct marketing
• Request restriction of processing
• Lodge a complaint with the Information Commissioner's Office (ICO)

ICO website: https://ico.org.uk

Requests can be made by contacting us using the details below.

11. Cookies & Tracking

Our website uses cookies and similar technologies to monitor performance and improve user experience. Further details are available in our Cookie Policy.

12. Changes to This Policy

We may update this Privacy Policy periodically. Any changes will be published on our website.

13. Contact Details

If you have any questions or wish to exercise your rights, contact:

Refyned Limited
Email: accounts@refyned.co.uk