Privacy Policy
1. Data Controller
Refreshclean ("we", "us", or "our") is the data controller responsible for your personal data. Our registered address is Warwick Rd, Carlisle CA1 2WF, United Kingdom. You can contact us at support@refreshclean.world or by telephone at +44 333 777 3988.
2. Scope and Applicable Law
This Privacy Policy explains how we collect, use, store, and protect personal data when you visit refreshclean.world (the "Website") or contact us. We process personal data in accordance with:
- Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR)
- The Finnish Data Protection Act (Tietosuojalaki 1050/2018)
- The UK GDPR and Data Protection Act 2018, where applicable to our operations in the United Kingdom
This Website provides free informational content about daily outdoor movement. We do not sell products or paid services through the Website.
3. Personal Data We Collect
We may collect the following categories of personal data:
- Identity data: your name
- Contact data: email address, telephone number, postal address
- Communication data: messages you send through our contact form
- Technical data: IP address, browser type, device information, and pages visited
- Cookie data: preferences stored through our cookie consent mechanism
4. Purposes, Legal Bases, and Retention Periods
We process your personal data only where a legal basis applies under Article 6 of the GDPR:
- Responding to contact form enquiries — legal basis: consent (Article 6(1)(a)) and legitimate interest (Article 6(1)(f)). Retention: up to 24 months from your last communication.
- Operating, securing, and maintaining the Website — legal basis: legitimate interest (Article 6(1)(f)). Retention: technical logs up to 90 days.
- Complying with legal obligations — legal basis: legal obligation (Article 6(1)(c)). Retention: as required by applicable law.
- Storing cookie consent records — legal basis: consent (Article 6(1)(a)) and legal obligation. Retention: up to 12 months.
- Website analytics (only if you consent) — legal basis: consent (Article 6(1)(a)). Retention: up to 24 months.
- Advertising measurement (only if you consent) — legal basis: consent (Article 6(1)(a)). Retention: up to 12 months.
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
5. Obligation to Provide Data
You are not legally required to provide personal data to browse the Website. If you wish to use the contact form, providing your name, email address, and message is necessary to respond to your enquiry. Without this information, we cannot process your request.
6. Recipients and Processors
We do not sell your personal data. We may share data with the following categories of recipients where necessary:
- Website hosting and infrastructure providers
- Email and communication service providers
- Analytics and advertising partners (only where you have given consent)
- Professional advisers where required by law
All processors act under written data processing agreements and may process data only according to our instructions.
7. International Data Transfers
Your data may be processed within the European Economic Area (EEA) and the United Kingdom. Where data is transferred outside the EEA or UK, we implement appropriate safeguards as required by GDPR Chapter V, including Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other lawful transfer mechanisms.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted connections (HTTPS), access controls, and regular security reviews.
9. Your Rights Under the GDPR
If you are located in the EEA, including Finland, or where GDPR applies, you have the following rights:
- Right of access (Article 15): obtain confirmation and a copy of your personal data
- Right to rectification (Article 16): request correction of inaccurate data
- Right to erasure (Article 17): request deletion in certain circumstances
- Right to restrict processing (Article 18): request limitation of processing
- Right to data portability (Article 20): receive your data in a structured format
- Right to object (Article 21): object to processing based on legitimate interests or direct marketing
- Right to withdraw consent (Article 7(3)): withdraw consent at any time without affecting prior lawful processing
To exercise your rights, contact us at support@refreshclean.world. We will respond within one month, which may be extended by two further months where requests are complex, as permitted by Article 12(3) GDPR. We may request information to verify your identity before processing a request.
You have the right to lodge a complaint with a supervisory authority. If you are in Finland, you may contact the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto) at tietosuoja.fi. If you are in the United Kingdom, you may contact the Information Commissioner's Office (ICO) at ico.org.uk. You may also lodge a complaint with the supervisory authority in your country of habitual residence or place of work within the EEA.
10. Children
The Website is intended for a general audience and is not directed at children under 13 years of age. We do not knowingly collect personal data from children under 13. If you believe we have collected data from a child under 13, please contact us and we will take steps to delete such information promptly.
11. Online Advertising
We may use online advertising services, including Google Ads, to promote our informational content. Where advertising or conversion measurement technologies are used, they are activated only after you provide consent through our cookie banner. These services may process technical identifiers and interaction data in accordance with their own privacy policies. We use advertising solely to inform users about our free educational content and do not make medical or outcome-based claims in our advertisements.
12. Cookies
We use cookies and similar technologies on the Website. For detailed information, please see our Cookie Policy.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.