I. Preamble

Refiny Company Limited ("Refiny" or "we" or "our" or "us") operates by the regulations outlined in the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR. Recognizing the significance of the personal information entrusted to us, we view it as our duty to manage, protect, and handle your data responsibly. To grasp the types of personal data we gather or process and the reasons behind their use, please examine this policy.

The term "personal data" is defined by the Personal Data (Privacy) Ordinance as any data that:

• Relating directly or indirectly to a living individual.
• Enabling the identity of the individual to be directly or indirectly ascertained.
• In a form allowing the data's access or processing.

The primary goal of this policy is to inform and ensure your comprehension of how we manage, gather, utilize, reveal, and process your information. Modifications made to this Privacy Policy become effective upon publication on this website. We strongly advise regular review of this page for the most up-to-date information.

By furnishing us with your data, you acknowledge having thoroughly read and comprehended this policy, providing consent to the collection, use, processing, and disclosure of your data as delineated here.

Your Rights

Refiny does not claim ownership of the information you submit through our platform or other means of data collection. You maintain ownership and control over the information you provide through our platform.

Refiny's Rights

We possess copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights connected to our Platform. The utilization of these rights mandates explicit authorization and adherence to our Terms and Conditions.

II. Collection of Personal Data

1. Automated Information Gathering

Cookies: Our website and Refiny Application are structured to automatically assemble anonymous information about site visitors. This aids in understanding visitor behavior and traffic patterns, serving statistical purposes, and refining the quality of our services.

2. Information Supplied by You

Your Personal Data: At Refiny, the personal data you might furnish encompasses, though is not limited to, your name, age, birth date, mobile and landline numbers, residential or mailing addresses, email ID, passport details, or any other forms of identification. This also includes any additional individual-oriented information exchanged during our interactions with you.

Your Messages: The content of messages relayed during our service provision is retained. Messages, comprising chats, photos, videos, voice messages, files, and shared location details, are stored upon delivery and are accessible to both Refiny staff and authorized government entities. This message content is housed on our server. For platform improvement, details indicating your device's indicated country, model, and operating system, as well as the visibility of "last login" time and read receipts, are maintained for Refiny staff access.

How We Gather Your Personal Information: Our collection of your personal data occurs through various means:

·        Interaction with our personnel, such as chats, emails, phone or video calls, physical correspondence, face-to-face meetings, social media platforms, and our website.

·        Completion of forms.

·        Inputting details into our documents.

·        Requesting inclusion in our mailing list.

·        Reacting to Refiny's ads, promotions, or initiatives.

·        Receiving references from partners or third parties in case of referrals.

·        Submittal of your data for any other purposes.

If you provide us with personal data concerning a third party (e.g., information about your spouse, children, parents, business associates, or employees), you assure and affirm that you have obtained the essential consent from the third party to share their personal data with us for the intended objectives.

III. Purposes for Collection, Use, and Disclosure of Your Personal Data

Refiny Company Limited ("Refiny" or "we" or "our" or "us") utilizes the collection, use, and disclosure of your Personal Data for the subsequent objectives:

1. Due Diligence: Verifying information to ensure compliance and authenticity.
2. Payment Processing: Managing transactions linked to our services.
3. Addressing Inquiries: Responding swiftly to your questions, feedback, and requests.
4. Business Operations Management: Overseeing day-to-day company functions.
5. Internal Protocols and Procedures: Adhering to internal guidelines and protocols.
6. Provision of Updates: Communicating developments in our services, applications, and business processes.
7. Service Request Handling: Assessing and managing applications for services provided by Refiny, including Vietnam Company Establishment Consultation, Hong Kong Company Establishment Consultation, United States Company Establishment Consultation, General Payment Gateway Consulting.
8. Risk Oversight: Assessing and managing commercial risks, encompassing risk management for the safety and security of our affiliates, employees, premises, and services.
9. Compliance with Legal and Regulatory Standards: Managing legal proceedings, including drafting and reviewing documents, and transaction documentation, and ensuring adherence to applicable laws, regulations, codes of practice, or guidelines provided by legal or regulatory bodies.
10. Investigative and Reporting Activities: Conducting inquiries related to disputes, billing, or fraud, preparing reports on non-compliance cases, and engaging in financial reporting and audits.
11. Project Supervision: Overseeing internal company projects.
12. Feedback and Research: Requesting feedback, conducting surveys, market research, and analysis to enhance services and for statistical purposes.
13. Marketing and Communication: Should you have consented to receive marketing or promotional information through various communication channels, Refiny may periodically reach out to you with details about our products and services.

We highly regard the precision and integrity of your Personal Data, as it is pivotal in providing our products and services. It's important that the details submitted to us are thorough, precise, authentic, and accurate.

Before gathering information for objectives beyond or unrelated to the original purpose, we will request your consent and provide advanced notification, unless expressly and voluntarily consented by the data subject. Any prior consent given can be retracted through written notice.

IV. Precision and Length of Storage

1. Duration of Retention: Refiny Limited ("Refiny") will retain your Personal Data for the period relevant to the original objectives for which the information was collected or utilized. If necessary for legal or business reasons, this duration might be extended.
2. Data Disposal: Ensuring responsible handling, Refiny is dedicated to erasing or permanently deleting Personal Data once it's no longer needed for the mentioned purposes.

V. Data Security

1. Security Measures: Refiny Limited will implement all practical and reasonable steps to safeguard your Personal Data from unauthorized access, processing, accidental use, loss, or erasure.
2. Account Protection: Users are responsible for maintaining the security of their devices and Refiny accounts. Timely notification to us is essential in the event of any unauthorized account usage or security breach related to your account or our services.
3. Third-Party Permissions: Our services permit users to invite new individuals into their interactions and access company profiles, granting access to personal information and business data. It's crucial to note that we conduct due diligence exercises for new user invitations. Refiny Limited cannot be held accountable for the unauthorized use of Personal Data by individuals invited by the account holder.

VI. Exemptions

Personal Data shared by Refiny in due diligence processes related to proposed business transactions is exempted from specific provisions of data protection principles by applicable laws.

VII. Contact Us

1. Contact Information: For inquiries regarding your Personal Data, our Privacy Policy, Subject Access or Correction Requests, withdrawal of consent for Personal Data use as outlined in this Policy, or accessing and rectifying your Personal Data records, please contact our Data Protection Officer at: info@refiny.com.
2. Withdrawal of Consent: If you decide to retract your consent to any or all use or disclosure of your Personal Data, please note that it may impact Refiny's ability to continue providing services or access to the Refiny Website. Such withdrawal could lead to the termination of our services.