This policy explains what happens to your personal data when you visit refinesociety.com, sign up for the Refine Social Calendar or our emails, write to us, or interact with us on Instagram. Personal data is any information that can identify you, such as your name, email address or IP address.

In short: we collect only what we need to show you this website, to send you the content you asked for, and to answer you when you write to us. We do not sell your data. You can withdraw your consent at any time, and every email we send contains an unsubscribe link.

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

CLAVEMEDIA LTD Erofilis 3 8016 Paphos Cyprus Email: contact@refinesociety.com

CLAVEMEDIA LTD operates the brand Refine Society. We are established in the European Union, so the GDPR applies directly to everything described here.

This website is built and hosted with Onepage, a service of Onepage GmbH, Hanauer Landstraße 172, 60314 Frankfurt am Main, Germany. When you open a page, the hosting servers automatically record technical information in server log files: your IP address, the date and time of the request, the page you requested, the referring website, your browser type and version, and your operating system. This data is needed to deliver the website securely and to detect technical faults. It is not combined with other data about you.

Legal basis: our legitimate interest in a stable and secure website, Article 6(1)(f) GDPR. Log files are deleted by the hosting provider after a short period in line with its retention rules.

Onepage also provides us with aggregated visitor statistics, such as the number of page views and the countries visitors come from. These statistics are generated without cookies and without building a profile of you.

When you request the Refine Social Calendar, you enter your first name and your email address and tick the box "I agree to receive emails." By ticking it, you consent to receive the calendar and the emails described below, and you confirm that you have read this policy. We then send you a confirmation email. Only after you click the confirmation link do we add you to our list and send you the calendar. This double opt-in protects you from being signed up by someone else. We record the time of your sign-up and of your confirmation, together with the IP address used, so that we can prove your consent.

After confirmation you receive the calendar and, from time to time, further emails from Refine Society about events, invitations and our own products and editions. We call these emails occasional on purpose. You can stop them at any time by using the unsubscribe link in any email or by writing to us.

Your data takes the following path: the sign-up form on this website stores your entry in the lead area of Onepage. An automation built with Make forwards your first name, email address and the page you signed up from to our email service Kit. Kit sends the confirmation email and all further emails. Kit also records whether an email was delivered, opened and which links were clicked, which helps us understand what our readers find useful and keep the list clean.

Legal basis: your consent, Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future. The processing that took place before your withdrawal remains lawful.

Retention: we keep your data for as long as you are subscribed. When you unsubscribe, your address is removed from the active list. Your email address may remain on a suppression list so that we do not contact you again by mistake. This is based on our legitimate interest in respecting your decision, Article 6(1)(f) GDPR. Proof of your original consent is kept for as long as it may be needed to document that the emails were lawful.

If you contact us by email, we store your message and the contact details you provide in order to answer you. Our mailboxes are hosted by IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany.

Legal basis: Article 6(1)(b) GDPR where your enquiry relates to a contract or a product, otherwise our legitimate interest in answering enquiries, Article 6(1)(f) GDPR. We delete the correspondence once your request has been dealt with and no statutory retention period requires us to keep it.

Refine Society publishes on Instagram, a service of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. When you follow, like or message our account, Meta processes your data under its own responsibility and its own privacy policy, which you can find at privacycenter.instagram.com/policy. We receive the information Instagram shows us, such as your username and the content of your messages.

To answer direct messages and comments quickly, we use Manychat, a service of Manychat, Inc., San Francisco, USA. Manychat processes your Instagram username, the messages you exchange with us and your replies to automated questions, so that we can send you the right link or answer. If you choose to share your email address in such a conversation, for example to receive the Social Calendar, it enters the sign-up process described in section 4, including the confirmation email. Manychat transfers data to the United States on the basis of the EU standard contractual clauses and has appointed a representative in the European Union, reachable at art-27-rep-manychat@rickert.law.

Legal basis: your consent when you message us or reply to an automated question, Article 6(1)(a) GDPR, and our legitimate interest in managing our Instagram communication, Article 6(1)(f) GDPR.

At present this website sets only the cookies that are technically necessary to display it and to remember your choice in the cookie banner. We do not use advertising pixels or profiling tools.

If we add analytics or marketing tools in the future, for example a tag manager, web analytics, heat maps or an advertising pixel, they will run only after you have given your consent in the cookie banner. We will describe each tool in this section before it is activated, and you will be able to change or withdraw your choice at any time through the banner.

Legal basis for any non-essential cookie: your consent, Article 6(1)(a) GDPR, together with the applicable rules on electronic communications.

We work with a small number of providers who process data on our behalf and only on our instructions. We have concluded data processing agreements with each of them in accordance with Article 28 GDPR.

Onepage GmbH, Frankfurt am Main, Germany: website, forms and lead storage. IONOS SE, Montabaur, Germany: domain and email hosting. Kit, Inc. (formerly ConvertKit), Boise, Idaho, USA: email delivery and subscriber management. Kit is certified under the EU-US Data Privacy Framework. Make, a service of Celonis, Inc., New York, USA: the automation that forwards sign-ups to Kit. Celonis is certified under the EU-US Data Privacy Framework. Manychat, Inc., San Francisco, USA: Instagram message automation, on the basis of the EU standard contractual clauses. Meta Platforms Ireland Limited, Dublin, Ireland: Instagram, acting as an independent controller for the platform.

Some of the providers above are based in the United States. Where data is transferred there, this takes place either under the EU-US Data Privacy Framework, which the European Commission has recognised as providing adequate protection for certified companies, or under the standard contractual clauses approved by the European Commission. You can request a copy of the relevant safeguards from us.

We keep personal data only for as long as the purpose it was collected for requires. Subscriber data stays with us until you unsubscribe. Enquiries are deleted once they are resolved. Where tax or commercial law requires us to retain certain records, those records are kept for the statutory period and then deleted.

Under the GDPR you have the right to access the personal data we hold about you (Article 15), to have it corrected (Article 16) or deleted (Article 17), to restrict its processing (Article 18), to receive it in a portable format (Article 20), and to object to processing based on our legitimate interests (Article 21). Where processing is based on your consent, you may withdraw that consent at any time (Article 7(3)).

To exercise any of these rights, write to contact@refinesociety.com. We may ask you to confirm your identity before we act on a request.

You also have the right to lodge a complaint with a supervisory authority (Article 77). The authority responsible for us is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, dataprotection.gov.cy. You may also contact the data protection authority in the country where you live.

This website and all services we use transmit data over encrypted connections (TLS). You can recognise the encrypted connection by the padlock symbol in your browser. Access to subscriber data is limited to the people who need it to run Refine Society.

Our website, emails and products are intended for adults. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with data, please contact us and we will delete it.

We update this policy when our services or the law change. The date at the top shows the current version. Substantial changes that affect subscribers will also be announced by email.

CLAVEMEDIA LTD Erofilis 3 8016 Paphos Cyprus Email: contact@refinesociety.com