Privacy Policy

We, Refill have the utmost respect your personal data and the choices you make to connect with other users of the Refill App and on the website. We are happily GDPR compliant. We will only ask for the information required to make the site work. For example, we ask for your location to ensure that you can access the nearest Refill Stations and can make an informed decision how and where to Refill. In time we may ask for your postcode, this will be to ensure that local offers through our rewards-based app will be best directed to you. (personal data will NEVER be shared, only group trends). 

We will never sell or give your personal identification data including your name, email address, address, phone numbers and other personal identifiers to 3rd parties unless it is with your explicit consent. If, in order to send you a reward, prize or product we have to work with a 3rd party we will make it clear, at the time that we need your permission to give them your address or email for the purposes of the transaction. Our agreement with our partners ensures that they also do not breach your trust when it comes to your personal data. 

As a registered Refill user you have agreed to the Terms and Conditions of the app and website and its use. With regards to data, you have agreed for us to use your demographic information (not personal identification data) which in time may act to provide insight into the activity of our members with our 3rd party partners.  

This Policy applies between you, the User of this App and Refill – the owner and provider of this App and related Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein. 

  • 1. Data Collected 
  • 1.1. Without limitation, any of the following Data may be collected: 
  • 1.1.1. name; 
  • 1.1.2. date of birth or age range; 
  • 1.1.3. gender; 
  • 1.1.4. age; 
  • 1.1.5. contact information such as street addresses, email addresses and telephone numbers; 
  • 1.1.6. demographic information such as post code, preferences and interests; 
  • 1.1.7. financial information such as credit / debit card numbers; 
  • 1.1.8. IP address (automatically collected); 
  • 1.1.9. web browser type and version (automatically collected); 
  • 1.1.10. operating system (automatically collected); 
  • 1.1.11. a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); 
  • 1.1.12. Cookie information (see clause 10 below); and 
  • Geo-IP data designed to detect your current location. 
  • 2. Our Use of Data 
  • 2.1. Any personal Data you submit will be retained by Refill for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to seven years. 
  • 2.2. Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group. 
  • 2.3. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998 and GDPR guidelines issued in 2018. For more details on security, see clause 7 below. 
  • 2.4. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons: 
  • 2.4.1. internal record keeping; 
  • 2.4.2. improvement of our products / services; 
  • 2.4.3. transmission by email of promotional materials that may be of interest to you; or 
  • 2.4.4. contact for market research purposes which may be done using email, telephone, fax or mail. 
  • Such information may be used to customise or update the Web Site. 
  • 3. Third Party Web Sites and Services 
  • 3.1. Refill may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site, EXCEPT in the instance of Payment Service Providers where such data is stored by such Payment Service Provider in the interests of further protecting the integrity and security of such data. Any Data used by such parties is used only to the extent required by them to perform the services that Refill requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998. 
  • 4. Changes of Business Ownership and Control 
  • 4.1. Refill may, in the future, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you. 
  • 4.2. In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller. 
  • 5. Controlling Access to your Data 
  • 5.1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following: 
  • 5.1.1. use of Data for direct marketing purposes; and 
  • 5.1.2. sharing Data with third parties. 
  • 6. Your Right to Withhold Information 
  • 6.1. You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data. 
  • 6.2. You may restrict your internet browsers use of Cookies. For more information see clause 9 below. Should you elect to do so, certain capabilities of the App and Web Site may be rendered inoperable. 
  • 7. Accessing your own Data 
  • 7.1. You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. In time, Additional Data as to your marketing preferences may also be stored and you may change this at any time. 
  • 7.2. You have the right to ask for a copy of your personal Data on payment of a small fee in accordance with the provisions of the Data Protection Act 1998. 
  • 8. Security 
  • 8.1. Data security is of great importance to Refill and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online. 
  • 9. Cookies – where used 
  • 9.1. may set and access Cookies on your computer. Cookies that may be placed on your computer are detailed in Schedule 1 to this Policy. 
  • 9.2. A Cookie is a small file that resides on your computer’s hard drive and often contains an anonymous unique identifier and is accessible only by the web site that placed it there, not any other sites. 
  • 9.3. You may delete Cookies, however you may lose any information that enables you to access the Web Site more quickly. 
  • 9.4. Certain capabilities of the Web Site may be rendered inoperable should you elect to disable cookies. shall have no obligation to restore such capabilities or to provide support in respect of restoring such capabilities. 
  • 9.5. You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site. 
  • 10. Changes to this Policy 
  • 10.1. reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations. 


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