Privacy Notice

Who we are

Refina Branding LLC is headquartered at East Wing, Latifa Tower, Sheikh Zayed Road, Trade Centre First, Dubai, UAE. We are the data controller for the purposes of this notice.

You can contact our data protection contact at legal@refina.ae.

What data we collect and why

Contact form and email enquiries

We collect your name, work email address, organisation name, message content and any other information you choose to include.

Our lawful basis is legitimate interests (Article 8 of UAE Federal Decree Law No. 45 of 2021 on the Protection of Personal Data, "PDPL"). We use this to respond to your enquiry and assess whether we can assist you. Where our processing goes beyond responding to your initial enquiry, we will rely on consent or contract as appropriate.

We retain enquiry data for up to 24 months from the date of your last contact, unless you become a client (in which case our client data retention policy applies) or you ask us to delete it sooner.

Website analytics

We use two analytics tools, with different data profiles.

Cloudflare Web Analytics collects aggregated, anonymised data about page views and site performance using the browser's Performance API. It does not use cookies, does not store data in localStorage and does not fingerprint individual users. No personal data is collected through this tool.

PostHog is an event based analytics platform that processes behavioural data, including page views, user interactions, session data and IP addresses, to help us understand how visitors use our website. PostHog data is stored in the European Union. PostHog acts as our data processor under a Data Processing Agreement.

Our lawful basis is legitimate interests (PDPL Article 8); understanding how our website is used helps us improve it. For details of cookies used on this website, see our Cookie Policy.

Cloudflare infrastructure

Our website is hosted on Cloudflare Pages. Cloudflare processes certain technical data (including IP addresses) as part of its network operations and security services. Please refer to Cloudflare's privacy policy for details of this processing.

Spam protection (Turnstile)

Our contact form uses Cloudflare Turnstile for spam protection. Turnstile analyses browser signals to determine whether a form submission is likely to be from a human. The data processed by Turnstile is subject to Cloudflare's privacy policy linked above. We do not receive or store the signals collected by Turnstile.

Newsletter subscriptions

We collect your email address only.

Our lawful basis is consent (PDPL Article 7). You subscribe by providing your email address and confirming your consent to receive communications from us.

To unsubscribe, use the link in any email we send. You may also email legal@refina.ae at any time to request removal.

We retain your email address until you unsubscribe or we cease operating the newsletter, whichever is earlier. Unsubscribe requests are processed within 10 business days.

Who we share your data with

We do not sell your personal data. We share your data only with these parties.

• Cloudflare (United States); our hosting, CDN and security provider, acting as a data processor on our behalf.
• Resend (United States); our transactional email provider, used to send and receive messages from our business email system.
• PostHog (European Union); our event based analytics provider, processing behavioural data from website usage.
• Regulatory bodies or law enforcement; where we are required to do so by law.

All processors we use are bound by Data Processing Agreements and are required to process your data only on our documented instructions.

How we protect your data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. Our website is served exclusively over HTTPS. Access to personal data held in our email and business systems is restricted to authorised personnel only.

No method of transmission over the internet is completely secure. While we take appropriate precautions, we cannot guarantee the absolute security of data transmitted to or from our website.

International transfers

Some of our service providers process personal data outside the UAE. We transfer data to the following destinations.

• Cloudflare (United States); CDN and web infrastructure. Cloudflare's global network may process request data across multiple jurisdictions as part of its infrastructure operations.
• Resend (United States); transactional email delivery.
• PostHog (European Union); event based analytics.

For each of these transfers, Refina has entered into a Data Processing Agreement with the processor concerned. These agreements impose contractual obligations on our processors to handle your data in accordance with applicable data protection law and to implement appropriate technical and organisational security measures. These safeguards are maintained in accordance with Articles 22 and 23 of UAE Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Further details are available on request from legal@refina.ae.

Your rights

Under UAE Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (PDPL), you have the following rights.

• Access. To request a copy of the personal data we hold about you.
• Rectification. To request correction of inaccurate data.
• Erasure. To request deletion of your data where there is no compelling reason for us to retain it.
• Restriction. To request that we restrict how we process your data in certain circumstances.
• Portability. To receive your data in a structured, machine readable format (where applicable).
• Objection. To object to processing based on legitimate interests.
• Withdrawal of consent. Where we rely on consent, you can withdraw it at any time.

To exercise any of these rights, email legal@refina.ae. We will respond within 30 days in accordance with the UAE Personal Data Protection Law. Your request is free of charge.

Complaints

If you believe we have not handled your data correctly, you have the right to lodge a complaint with the UAE Data Office. You can do so at uaedataoffice.gov.ae.

We would appreciate the opportunity to address your concerns before you contact the UAE Data Office, so please reach out to us first if possible.

Changes to this notice

We will update this notice when our practices change. Material changes will be communicated to you if we hold your contact details. The "last updated" date at the top of this page reflects the most recent revision.