Effective Date: 24 May 2018
1. Some key terms
Our website is hosted on Sitehost using Cirrus cloud hosting. They provide us with the online platform that allows us to offer our services to you. Your data is stored through Refresh Control and Ubiquity Engage’s data storage, databases and the general application. They store your data on a secure server behind a firewall.
3. Personal information we collect
We collect various personal information regarding you or your device. This includes the following:
- Information you provide to submit an enquiry / create an account, specifically email address, first name and last name.
- Your marketing preferences.
- The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others.
- Information you share with us in connection with surveys, contests or promotions.
- Information from your use of the Services or websites. This includes: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
- Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
- Other information you submit to us directly
4. How we collect personal information
We obtain personal information from various sources. We do this in three main ways:
- You provide some of it directly (such as by submitting an enquiry).
- We record some of it automatically when you use our Services or Websites (including with technologies like cookies).
- We receive some of it from third parties (like when you have clicked on an ad to reach our website).
We’ve described this in more detail below.
a. Personal information you provide
When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to submit an enquiry. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.
Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you make an enquiry to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
b. Personal information obtained from your use of our Services
When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.
c. Personal information obtained from other sources
If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
If you sign up for Paid Services, we obtain limited information about your payment information.
5. How we use your personal information
We use the personal information we obtain about you to:
- Provision of the Services. Create and manage your Account, provide and personalise our Services, process payments and respond to your enquiries.
- Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
- Surveys and contests. Administer surveys, contests and other promotions.
- Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Refresh Renovations and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your region, projects we have worked with you on or what we think may interest you based on other information we hold about you.
- Advertising. Analyse your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already made an enquiry or we may choose to serve you a particular advertisement based on when you completed your project or what we think may interest you based on other information we hold about you.
- Improving our Services. Analyse and learn about how the Services / Websites are accessed and used, evaluate and improve our Services / Websites (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually.
- Security. Ensure the security and integrity of our Services.
- Third party relationships. Manage our vendor and partner relationships.
- Enforcement. Enforce our Terms of Service and other legal terms and policies.
- Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
- Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
We process your personal information for the above purposes when:
Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your enquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so that we can contact you and so that you can sign in to your Refresh Renovations account to monitor the progress of your renovation.
Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
To operate the Refresh Renovations business and provide you with tailored advertising and communications to develop and promote our business.
To analyse and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Refresh Renovations is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
To provide and improve the Services, including any personalised services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
To share your personal information with other Refresh Renovations group companies that help us provide and improve the Services.
To anonymize and subsequently use anonymized information.
Protecting you and others. To protect your vital interests, or those of others.
Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our Users who have a legitimate interest in having their sites function properly and securely and analyzing the usage of their sites so they can understand trends and improve their services.
6. How we share your personal information
We share personal information in the following ways:
Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.
Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide renovation services, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Refresh Renovations or Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving Refresh Renovations ads to people who already use Refresh Renovations.
Business transfers. If we're involved in a reorganisation, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.
7. Your rights and choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information by contacting us at email@example.com or by mail at: Renovations Franchise UK Limited, Re: Privacy Compliance Officer, Level 1, Devonshire House, One Mayfair Place, London, W1J 8AJ, United Kingdom to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address or by calling us on 0800 313 4577.
You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, maintain warranties, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Renovations Franchise UK Limited
Re: Privacy Compliance Officer
Level 1, Devonshire House
One Mayfair Place
London, W1J 8AJ
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
8. How we protect your personal information
While no service is completely secure, we have an IT team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
9. How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active.
As Renovators tend to be repeat customers and come back to us after an Account becomes inactive, we don’t immediately delete your personal information when your project is complete. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.
10. Data transfers
Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in New Zealand. We also store personal information locally on the devices you use to access the Services.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
Privacy. We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S.
Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.
You can find out more information about these transfer mechanisms here.
12. How to contact us
If you are a resident of or have your principal place of business in the U.K.:
Renovation Franchise UK Ltd.
Attention: Legal - Privacy
Level 1, Devonshire House
One Mayfair Place
London, W1J 8AJ
If you are a resident of or have your principal place of business outside of the U.K.:
Renovation Franchise Ltd.
Attention: Legal - Privacy
Level 1, 287 Parnell Road
Refresh Renovations Ads. We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or browser to gather information about your activities on the Services and other sites you visit, in order to provide you with Refresh Renovations ads. For example, if you visit Refresh Renovations and also use a social media platform, you may see a Refresh Renovations ad in your social media newsfeed or timeline.
Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use the Services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
Pixels. A pixel tag, or pixel, is a small piece of code that can be embedded on websites and emails. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. For example, if you visit a Refresh Renovations page related to kitchen renovations, a pixel will help us show you an ad for that page when you later visit a renovations site.
Device Identifiers. We use device identifiers to track, analyze and improve the performance of the Services and our ads.