Privacy Policy

1. Data Controller

Elbowshrefine, located at 4 Grand Canal Square, Dublin 2, Ireland, is the data controller responsible for your personal data.

Contact: supportuse@elbowshrefine.world | Phone: +353 1 618 0000

Data Protection Representative: Siobhan O'Brien

2. Data We Collect

2.1 Information You Provide

When you contact us through our forms, we collect:

• Name
• Email address
• Message content
• Any other information you choose to provide

2.2 Automatically Collected Data

When you visit our website, we may collect:

• IP address
• Browser type and version
• Device information
• Pages visited and time spent
• Referring website
• Date and time of access

2.3 Cookies and Tracking Technologies

We use cookies as described in our Cookie Policy. You can manage your cookie preferences through our cookie consent banner.

3. Legal Basis for Processing

We process your personal data based on:

• Consent: When you submit forms or accept cookies
• Legitimate interests: To improve our website and services
• Legal obligations: To comply with applicable laws
• Contract performance: To provide requested services

4. Purpose of Data Processing

We use your data to:

• Respond to your inquiries and provide support
• Improve our website functionality and user experience
• Analyze website usage and performance
• Comply with legal obligations
• Prevent fraud and ensure security
• Send relevant information if you have opted in

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

• Service providers: Hosting, email, analytics services that process data on our behalf
• Legal authorities: When required by law or to protect our rights
• Business transfers: In case of merger, acquisition, or asset sale

All third parties are required to maintain appropriate security measures and use your data only as instructed.

6. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions
• Other legally recognized transfer mechanisms

7. Data Retention

We retain your personal data only as long as necessary:

• Contact form submissions: 3 years from last contact
• Analytics data: 26 months
• Cookie data: As specified in our Cookie Policy
• Legal obligations: As required by applicable law

After the retention period, data is securely deleted or anonymized.

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of access: Request a copy of your personal data
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion of your data
• Right to restriction: Limit how we use your data
• Right to data portability: Receive your data in a structured format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent at any time
• Right to lodge a complaint: File a complaint with your supervisory authority

To exercise these rights, contact us at supportuse@elbowshrefine.world. We will respond within 30 days.

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

• HTTPS encryption for all data transmission
• Secure server infrastructure
• Access controls and authentication
• Regular security assessments
• Employee training on data protection
• Incident response procedures

While we strive to protect your data, no method of transmission over the internet is completely secure.

10. Children's Privacy

Our website is not intended for children under 16. We do not knowingly collect data from children. If you believe we have collected data from a child, please contact us promptly.

11. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you.

12. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated revision date. Significant changes will be communicated through prominent notice on our website.

13. Contact Information

For questions about this Privacy Policy or to exercise your rights:

14. Supervisory Authority

You have the right to lodge a complaint with the Irish Data Protection Commission: