PRIVACY POLICY

Last updated: 24th April 2026

Refined Advisory (“Refined”, “we”, “us”) operates with a strict commitment to confidentiality, discretion, and the responsible handling of information. We recognise that the nature of our work often involves sensitive commercial and strategic data, and we treat such information with the highest level of care.

This Privacy Policy outlines how we collect, use, and protect personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. INFORMATION WE COLLECT

We collect only the information necessary to operate effectively and deliver our services. This may include:

  • Personal identification details (e.g. name, email address, company, role)

  • Information provided through enquiries, correspondence, or engagements

  • Business and project-related information (e.g. brand positioning, product concepts, manufacturing requirements)

  • Records of communications with Refined

  • Limited technical data (e.g. IP address, website usage), where applicable

2. USE OF INFORMATION

Personal data is processed solely for legitimate business purposes, including:

  • Managing enquiries and maintaining professional communication

  • Evaluating and onboarding client engagements

  • Delivering advisory services and producing strategic recommendations

  • Conducting research relevant to client work

  • Maintaining and improving our operations and digital platforms

Refined does not engage in unsolicited marketing and does not monetise personal data.

3. LAWFUL BASIS FOR PROCESSING

We rely on the following lawful bases under UK GDPR:

  • Legitimate Interests — to operate, develop, and deliver our services

  • Contractual Necessity — to fulfil obligations arising from client engagements

  • Consent — where data is voluntarily provided or required by law

4. CONFIDENTIALITY AND PROFESSIONAL DISCRETION

Confidentiality is fundamental to our operations. All client and prospective client information—whether personal, commercial, or strategic—is treated as strictly confidential.

Disclosure occurs only where necessary to deliver services and is limited to relevant parties on a controlled, need-to-know basis, subject to appropriate confidentiality and data protection safeguards.

5. DATA SHARING

Refined does not sell, rent, or otherwise commercialise personal data.

Where necessary, limited data sharing may occur with:

  • Professional advisers and service providers supporting our operations

  • Carefully selected third parties relevant to a client engagement (e.g. manufacturing or production partners)

All third parties are required to adhere to appropriate confidentiality and data protection standards.

6. DATA RETENTION

We retain personal data only for as long as is necessary to:

  • Fulfil the purpose for which it was collected

  • Comply with legal and regulatory requirements

  • Maintain appropriate internal business records

Data is securely deleted or anonymised when no longer required.

7. DATA SECURITY

We implement appropriate technical and organisational measures to safeguard personal data against unauthorised access, misuse, loss, or disclosure.

While we apply robust security practices, no system can be guaranteed to be completely secure.

8. YOUR RIGHTS

Under applicable data protection laws, you have the right to:

  • Access the personal data we hold about you

  • Request correction of inaccurate or incomplete data

  • Request erasure of data where applicable

  • Restrict or object to processing

  • Request data portability

Requests can be made using the contact details below.

9. COOKIES AND WEBSITE DATA

Our website may use cookies or similar technologies to support functionality and improve user experience. You may manage or disable cookies through your browser settings.

10. THIRD-PARTY WEBSITES

Our website may contain links to external websites. Refined is not responsible for the content, security, or privacy practices of such sites.

11. UPDATES TO THIS POLICY

We reserve the right to amend this Privacy Policy at any time. Any updates will be published on this page with a revised effective date.

12. CONTACT

For all privacy-related enquiries or to exercise your rights, please contact:
Enquiries@refinedadvisory.co.uk