1. Register name

Refurbly AB.

2. Data controller

Refurbly AB ("we" or "Refurbly") is responsible for and processes personal data, customer communications and concluded contracts. We also collect analytical information from visitors to our website.

In addition to being responsible for personal data we receive from our customers, we are also responsible for personal data we receive from our partners; these are also part of the register.

It is important to Refurbly AB that you as a customer know how we process your personal data. The sections below explain how we use and process your personal data.

Please note that this privacy policy applies only to those registered in Refurbly AB's personal data register.

3. Contact details

Refurbly AB

• Company registration number: 559160-2890
• Address: Nygatan 29, 702 11 Örebro, Sweden
• Phone: (+46) 010 - 195 68 17
• Email: info@refurbly.se
• Website: www.refurbly.com (refurbly.se)

Responsible person:

• David Lundgren Fetah
• david@refurbly.se
• Nygatan 29, 702 11 Örebro, Sweden

4. Information we collect

• First and last name
• Contact details
• Permitted, prohibited or other supplementary data relating to marketing
• Company representatives' position in the organisation, information about the organisation and other similar information
• IP address
• Browser data
• URL paths on the page and time spent
• Time of visit
• Browser type and version
• Device type
• Name and email address collected from the website
• Change log

5. Source of data

5.1 Source of personal data

Data collected from the website is stored on our servers in connection with the visit. Information or data is also obtained from other service providers where possible and in accordance with the established rules.

5.2 Cookies

We use and collect analytical information through various technologies. When a user visits Refurbly AB's services, information is read using cookies and web beacon technology. We use cookies to improve the user experience on the website. A cookie is a text file that is added to your browser's internal memory when you visit or interact with a website.

You can prevent such cookies from being placed in your browser. Most modern browsers (Google Chrome, Mozilla Firefox, Internet Explorer, Safari) are set to accept cookies automatically, but you can change the settings so that cookies are not accepted. The downside of disabling cookies in your browser is that the website will not function optimally, as most cookies we use are intended to ensure website functionality, for example remembering what you have placed in your shopping cart.

If any service from Refurbly AB does not work as intended, the use of cookies is blocked.

"Web Beacon" is a technology that enables identification of which web pages and emails have been opened.

5.3 Analytics services

Refurbly AB also uses tools such as Google Analytics and other analytics tools. We use the information collected from these tools to improve Refurbly AB's services. You can find more information about Google Analytics on the Google Analytics website. You can prevent Google Analytics from collecting information by installing the Google Analytics opt-out add-on in your browser.

6. Why do we collect data?

We use the personal data we collect for the following purposes:

6.1 Customer service

Personal data is used to manage and develop the relationship between Refurbly AB and our customers. If you contact us, we use the data we collect to answer questions, resolve problems and otherwise handle your message.

6.2 Marketing

If you have consented to direct marketing, we may send you information about Refurbly AB.

Registered persons always have the right to prohibit us from sending direct marketing, market research or other types of profiling.

7. Retention period

We retain personal data for as long as required by law or as long as there is a need to store it.

8. Transfer to countries outside the EU/EEA

If Refurbly AB uses subcontractors established outside the EU/EEA, we ensure that processing takes place under protection equivalent to that within the EU/EEA, for example through the use of EU standard contractual clauses, Privacy Shield for the USA or other equivalent regulation.

9. Disclosure of personal data

We are obliged to share data with public authorities such as government agencies, the Swedish Tax Agency, the Swedish Authority for Privacy Protection or other bodies that are legally required to receive such data.

9.1 Legal grounds

We are obliged to share personal data collected by Refurbly AB with external bodies when deemed necessary (i) as required by law or by criminal or court decisions (ii) for fraud, money laundering, terrorism financing or personal protection-related or technical issues, prevention or other processing; or (iii) where it is necessary to protect Refurbly AB or its customers' property rights or otherwise required by law.

9.2 Authorised service providers

We may share customers' personal data with authorised service providers. The contracts we have with our service providers contain undertakings requiring the service provider to limit the use of personal data and to comply with the standards of this privacy policy.

9.3 Specific events

We may share personal data with third parties outside Refurbly AB's organisation, in accordance with the grounds mentioned above, when we have the data subject's consent. The data subject has the right to withdraw consent to share their personal data at any time.

10. Data subject rights

Request for access

The data subject has the right to access the personal data Refurbly AB processes about you.

Request for rectification

You may request that we correct inaccurate data we hold about you or that we delete personal data.

Request for erasure

We comply with requests for erasure of personal data to the greatest extent possible, but not where there are compelling reasons not to erase them, for example if we must retain the data for documentation purposes.

Right to object and restrict

You have the right to object to the processing of your personal data or profiling where your data is used for direct marketing purposes. You have the right to request restriction of your personal data, such as when the data is inaccurate. In special cases, you also have the right to object to how we process your personal data where processing is based on a particular situation relating to you.

Right to data portability

The data subject has the right to have their personal data transferred to a third party.

Exercising your rights

If you wish to exercise any of the above rights, please send mail or email to Refurbly AB containing the following: name, address, phone number and a copy of a valid identity document. To further verify identity, we may request additional information. We may reject requests that are unjustified or lack grounds.

11. Information security

We have implemented administrative, organisational, technical and physical security measures in the collection and processing of personal data.

Our security measures are designed and implemented in accordance with standards applicable to confidentiality, integrity and availability.

Only persons assigned duties involving the handling of personal data may process personal data. Personal data is protected with user-specific login credentials, passwords and access rights.

12. Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authorities if you object to Refurbly AB's approach and manner of processing personal data.

13. Use of circuly for subscription management

Description and purpose

On this website we use checkout and subscription management software from circuly. circuly is a software company based in Germany, with headquarters at Obernstr. 50, 33602 Bielefeld, phone: +49 176 552 884 77. This is an integrated software solution we use to cover various aspects of our subscription management, including: checkout, customer login, invoicing and payment processing, communication, returns handling and reporting.

The information is stored on servers operated by our software partner circuly. It may be used by us to contact our customers and provide our subscription services. All information we collect is subject to this privacy policy. We use all collected information solely to process the (subscription) order.

Legal basis

The legal basis for using circuly's services is Article 6(1)(f) GDPR (legitimate interest). Our legitimate interest in using this service is the efficient and customer-friendly management of subscription agreements.

Recipient

The recipient is circuly GmbH, Obernstr. 50, 33602 Bielefeld, Germany.

Data is stored on servers provided and managed by circuly and may be used by us to contact our customers and provide our subscription services.

Transfer to third country

Through use of the service, personal data may be transferred to a third country. When transferring personal data, the provider will ensure the level of protection required under the GDPR by following Article 44 et seq. of the GDPR. If there is no adequacy decision for the third country where the data recipient is based, the transfer is subject to appropriate safeguards. If you have any questions, please contact our data protection officer.

Data retention period

Data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In addition, data will be deleted if you withdraw your consent or request erasure of the personal data.

Right to object

In accordance with Article 21(1) GDPR, you have the right to object at any time to the processing of your personal data. If you exercise this right, processing for this purpose will no longer take place. Further information is available above in our privacy notice under "Data subject rights".

Contractual or legal requirement

There is no contractual or legal requirement to provide the data. Further data protection information via link:

https://www.circuly.io/data-privacy
https://www.circuly.io/data-processing-agreement