Privacy Policy

Dear visitor to rafinex.com,

We would like to inform you below about how we handle your data when visiting our website. We will not publish your data nor pass it on to any third parties without your consent. Below we explain what types of data we collect when you visit our website and precisely how it is used:

What personal data we collect and why we collect it

We only process personal data collected from our users insofar as this is necessary for the provision of a functional web presence and our content and services. As a rule, personal data provided by our users is only processed with their consent. One exception is where statutory regulations permit the processing of data.

Legal Basis for Data Processing

Art. 6 (1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis whenever we obtain the consent of the person concerned (“data subject”) for the processing of their personal data.

Art. 6 (1)(b) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data which is necessary for performing a contract to which the data subject is a party. The same applies to processing that is required for carrying out pre-contractual measures.

Art. 6 (1)(f) of the EU General Data Protection Regulation (GDPR) serves as the legal basis when processing is necessary to safeguard a legitimate interest of Rafinex or a third party, and provided this legitimate interest is not outweighed by the data subject’s interests and fundamental rights and freedoms.

Data Storage Duration

The personal data of the data subject is erased, anonymised or blocked as soon as the purpose of the storage ceases to apply. In addition, storage may take place if required by European or national law in EU regulations, laws or other regulations to which Rafinex is subject. Blocking, anonymisation or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data in order to conclude or fulfil the contract.

Rights of the Data Subject

As the data subject whose personal data is collected within the scope of the above-mentioned services, you have the following rights, unless any legal exceptions apply in individual cases:

  • Information (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 (1) GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection to processing (Art. 21 GDPR)
  • Withdrawal of consent (Art. 7 (3) GDPR)
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

Contact forms

There is a contact form on our website that can be used to contact us electronically. If you use this option, the data entered voluntarily in the input screen is transmitted to us and stored. This normally comprises your email address, first name and surname. 

We inform you about the actual processing of data while you are using the form and we obtain your consent. Reference is also made to the privacy notice. The data is used solely for processing the conversation.

The legal basis for processing the data when using the contact form, if the user’s consent has been given, is Art. 6 (1)(f) of the EU General Data Protection Regulation (GDPR). Personal data from the input screen is processed solely for the purpose of acting on the contact request.

The data is deleted as soon as it is no longer needed to achieve the purpose for which it was collected. This is the case when the relevant conversation with the user has ended or when the user’s request has finally been processed. The conversation has ended when it is apparent from the circumstances that the issue in question has been finally clarified. The user may at any time withdraw their consent to the processing of personal data via the contact details listed.

Your personal data will only be transmitted to government organisations and authorities if required by law and/or for the purpose of prosecution in the event of attacks on our network infrastructure. Forwarding to third parties for other purposes does not take place.

Cookies & Analytics

If you have given your consent to cookies, Google Analytics, a web analysis service of Google Ireland Limited (“Google”) is used on this website. The use includes the “Universal Analytics” operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus analyze a user’s activities across devices. We use Google Analytics to monitor and improve the user experience on our website.

Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users interact with the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. For more information on terms of use and data protection, please visit https://www.google.com/analytics/terms/gb.html or https://policies.google.com/?hl=en.

Purposes of the Processing

On behalf of the operator of this website, Google will use this information to evaluate the use of the website, to compile reports on website activity and to provide the website operator with other services related to website and Internet use.

Legal Basis

The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 lit. a GDPR.

Recipients or Categories of Recipients

The recipient of the collected data is Google.

Transfer to Third Countries

Personal data will be transferred to the USA under the EU-US Privacy Shield on the basis of the European Commission’s adequacy decision. You can download the certificate here.

Duration of Data Storage

The data sent by us and linked to cookies, user-identifiers (e.g. User-IDs) or advertising-identifiers are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

Rights of the Persons affected

You can revoke your consent at any time with effect for the future by blocking the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functionalities of this website to their full extent.


You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the Browser Add-on. Opt-out cookies will prevent future collection of your data when you visit this website. To prevent Universal Analytics from collecting data across different devices, you must opt-out on all systems used.

Embedded content from other websites

Articles on this site may include embedded content (e.g. we use YouTube to serve video content). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

What rights you have over your data

If you have submitted your contact details on this site (or by other means), you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

How to contact us

If you have any questions about Rafinex’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us on the details below:

Address:
Rafinex S.à r.l.
16 Ginzegaass
Senningerberg 1670
Luxembourg

Email: contact@rafinex.com

Changes to our Privacy Policy

Our company keeps its Privacy Policy under regular review and places any updates on this web page. This privacy policy was last updated on 30 October 2019.