Privacy Policy

Last updated: May 23, 2018

This privacy policy describes how we treat and use the information we collect when you visit or use our Refinery29.uk or Refinery29.de websites, mobile-optimized versions of these websites, or software applications to which this policy is linked (collectively, “Website(s)”), including when you sign-up for our newsletters. Refinery 29 Limited registered in England and Wales under company number 08279936 and with registered offices at 256-260 Old Street, London EC1 9DD United Kingdom manages our UK and German Websites and is the data controller of the personal information collected on these Websites.

Portions of the Website are hosted and operated in the United States by Refinery 29 Inc. For more information on how we ensure that your privacy is respected, see ‘Security and Retention’ below.

We provide you this privacy policy to help you understand the kinds of information we may gather about you when you visit the Website or use any of its services, how we may use and disclose the information, and how you can control, correct and/or update the information.

Refinery29 may make changes to this privacy policy at any time. If and when we do, we will inform you by posting the revised privacy policy on this Website. You are responsible for periodically visiting our Website and this privacy policy to check for any changes. Any changes that are made to this privacy policy will apply to both any personal information that we hold prior to the effective date of the amended privacy policy and any personal information that we collect on or after such effective date. Your continued use of the Website after this privacy policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the privacy policy, as amended. For ease of reading, we have divided this privacy policy into several sections:

  1. Collection of Information You Provide to Use the Website and Its Features
  2. Data we collect using Cookies & Pixels
  3. Customer service
  4. Business administration & legal compliance
  5. Third parties, Links to Other Sites & Co-branded sections of the Website
  6. Social networks & social media integration
  7. How to access your personal data & your other rights
  8. Security & retention of your personal data
  9. Children
  10. Jurisdictional issues
  11. Contact Us

Collection of Information You Provide to Use the Website and Its Features

Newsletters and Marketing Information. You may choose to voluntarily provide us with your email address so that we may send you newsletters as well as marketing information, offers and other information regarding opportunities and functionality that we think would be of particular interest to you. We may use your email address for these purposes based on your consent.

Surveys and Sweepstakes. When you complete a survey or enter a sweepstakes or contest you may be asked to provide personal information such as your name, email address, social media network usernames and aliases. You may also be asked to provide answers to questions about a variety of topics such as your buying preferences, annual income, and other demographic or profile information. It is necessary for us to use your personal information to perform our obligations in accordance with any contracts that we may have with you. It is also in our legitimate business interest to use your personal information for survey and sweepstakes in order to make the Website useful and informative.

Public Forum. If you elect to post material to any blogs or forums, or otherwise participate in our community boards that may be offered on our Website, then any personal information you provide, may be available for all others to view. It is in our legitimate interest to use the information you provide in this context to ovide the applicable services on the Website. Even after you terminate your account, all such materials submitted by you on the Website or our social media channels will be retained by us and we will continue to disclose such materials publicly. However, you can ask us to delete or remove your personal information in some circumstances. Please see the section of this policy on “How to access your personal data and your other rights” for more information. By using these interactive forums, you agree that we are not responsible for any information that you disclose or communicate in such forums, and any disclosure you make are at your own risk.

Updating your information. If you want to update the information you have previously provided to us through your use of our Website and its features, you can write to us at Refinery 29 Limited, 256-260 Old Street, London, United Kingdom, EC1 9DD or email us: privacy@refinery29.com

Data we collect using Cookies & Pixels

What are “cookies”? A cookie is a small text file placed on your device when you visit a website. You can accept or decline cookies through your browser settings or other software. Our website uses cookies to distinguish you from other users of our Website. We also use pixels and web beacons (which are usually small, transparent graphic images), to gather information regarding your visit to and use of the Website. This technology helps us to provide you with a good experience when you browse our website and also allows us to make improvements. This privacy policy sets out our use of cookies technology and supplements our cookies policy which we encourage you to read here Cookie Policy.

Analytics. The use of cookies technology provides us with information about your use of our Website including the date and time of your visit, the features and information for which you searched and viewed, the email you opened, which advertisements you clicked, the operating system and device information you used, the amount of time spent on a page, the website you originated from and the websites visited after leaving our Website. We may use this information to analyze, benchmark and conduct research of our users’ interaction with the Website and advertisements and to gain insights that can help us improve the design and performance of the Website.

We may share your personal information with a third party service providers to assist us with customer insight analysis and research. Some of these third party providers may be located in the USA (or elsewhere). For more information on how we ensure that your privacy is respected, see 'Security and Retention'below.

We may also use Google Analytics to analyze the audience of the website and improve our content. No personal information is collected from Google Analytics. For further information on the privacy policy concerning Google Analytics, please go here,//support.google.com/analytics/answer/6004245?hl=en

Our Website also features Nielsen’s proprietary measurement software which will allow you to contribute to market research, like Nielsen’s TV Ratings. Please see www.nielsen.com/digitalprivacy for more information or to opt-out of contributing to such research.

Advertising. We may also use cookies to determine what advertisements you see, control the sequence of advertisements and make sure you don't see the same advertisement too many times. We may use third-party vendors to connect information collected on the Website with information collected from other websites, devices and media channels and then show you advertising based on this combined information. We may also customize the advertisements that you see based upon geographic location information, which we may determine through your IP address. We may use this information to deliver customized advertising to you on this Website, on other websites and on other channels. We use your data in this way on the basis that we have a legitimate interest in doing so where you have accepted the relevant cookies that enable it.

We may share your personal information with third party service providers to assist us with ad serving, optimization and analytics. Some of these third party providers may be located in the USA (or elsewhere). For more information on how we ensure that your privacy is respected, see ‘Security and Retention’below.

We may use Facebook to deliver ads on the Website. Facebook may use information you share on Facebook and information gathered from your use of other websites and apps to delivery ads to you. To learn more about this type of advertising and your choices about it, visit https://www.facebook.com/about/ads.

Other Use of Cookies. For contests or sweepstakes, we may use cookies in order to track your progress and the number of entries in some promotions. For polls or surveys, we may use cookies to help ensure that an individual can't vote more than once on a particular question or issue.

Legal Basis for Information Collected for Analytics and Advertising Purposes. Where personal information is anonymised, we are not required to establish a legal ‘condition’ to make use of it, as the information will no longer constitute personal information from which you can be individually identified and will no longer be regulated under data protection laws. We may share aggregate and anonymous usage information with our prospective and actual business partners, advertisers and other third parties for any business purpose. However, our collection and use of anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the great products and services to you and our other customers.

Control and Removal of Cookies. You can delete cookies by changing your privacy preferences in your Internet browser or by using the menu made available on the cookie banner. You also have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our website that depend on cookies.

Some of the network advertisers, ad agencies and other vendors we work with to serve ads on third party websites and across the internet, or analytics providers which provide us with information regarding use of the website and effectiveness of our ads may be members of the Network Advertising Initiatives, the Digital Advertising Alliance Self-Regulatory Program for Online Behavioral Advertising and/or the European Interactive Digital Advertising Alliance. To opt-out from receiving interest-based advertising from some or all of the participating companies, please visit http://www.aboutads.info/choices/ and http://www.youronlinechoices.eu/. To opt-out of participating in Google Analytics data follow the instructions: https://tools.google.com/dlpage/gaoptout. Please note opting out through these mechanisms does not opt you out of being served advertising. You will still receive other types of online advertising from participating companies and any type of advertising from non-participating companies, and the web sites you visit may still collect information for other purposes. Note our Website is currently not setup to respond or process web browser “Do Not Track” (“DNT”) signals.

For more information regarding our use of cookies, web beacons and similar technologies, please read our Cookie Policy. Our policy includes the name of each cookie used on our website, their purpose and how long each cookie stays on your device for.

To find out more information about cookies, please visit www.allaboutcookies.org.

Customer Service

We may collect your personal information, including your name and contact information, in order to provide you customer service including to answer your inquiries and to notify you about changes to our Website or any products or services we offer or provide though it. We do not share your personal information for this purpose. It is in our legitimate business interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you and fulfill any contractual obligations.

Business Administration and Legal Compliance

We may collect your personal information, including your name and contact information, in order to provide you customer service including to answer your inquiries and to notify you about changes to our Website or any products or services we offer or provide though it. We do not share your personal information for this purpose. It is in our legitimate business interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you and fulfill any contractual obligations.

Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Third Parties, Links to Other Sites and Co-Branded Sections of the Website

We may disclose your personal information to third parties to enable third party service providers to provide products, services or functions on our behalf or to help us to operate our business and the Website. Such service providers may include vendors and suppliers that provide email services, customer service, and/or marketing assistance. Some of these third party providers may be located in the USA (and elsewhere) For more information on how we ensure that your privacy is respected, see ‘Security and Retention’ below.

Links to third party sites. As a curator of information, Refinery29 often links out to other sites. We are not responsible for any content that appears on these sites, nor do we endorse them. All third party websites are out of our control and are not covered by this privacy policy.

Third parties may display advertisements on our Service. These advertisements may be determined by the use of cookies, web beacons and other similar technologies which you have been served with by third parties. Refinery29 is not responsible for the privacy practices employed by any third party not under its direct control.

Partnerships & Co-branded features. If we partner with a retailer or other third party to offer online shopping opportunities, promotions, contests or sweepstakes, polls, surveys, services, subscriptions and other applications, then personally identifiable information you provide in connection with the above transactions may be collected directly by the third party (unless you object and your objection is binding under a law applicable to you). These third parties will use your information in accordance with their own privacy policy. In some cases, such as where a provider’s service is embedded in our Website (such as an embedded video or social network tool), you must contact the third party to learn about your objection options, and the third party (not us) will be responsible for addressing your objection.

Certain portions of the Website may be co-branded with a business partner or subject to a different privacy policy that is either the partner's privacy policy or a privacy policy developed jointly by Refinery29 and our partner (collectively the "Co-branded Policy"). The partner's collection, use and dissemination practices regarding any data or personal information provided by, or obtained from users of these Co-branded portions of the Website will be governed by the Co-branded Policy. Please read the Co-branded Policy for each Co-branded Website before providing any personal information.

Social Networks and Social Media Integration

In order to participate in social networking features, you may need to provide Twitter, Facebook and other social media usernames and aliases. If you use your login credentials from a social networking site (e.g., Facebook, Twitter, Instagram, Pinterest) ("SNS") on our Website, we may receive information from such SNS in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the SNS ("SNS Terms"). If you elect to share your information with these SNS, we will share information with them. The SNS Terms of these SNS will apply to the information we disclose to them. Additionally, if you make an election with respect to a SNS while on our Website (for instance, if you elect to “follow” us on one of the SNS, or “Like” us on Facebook), your election will be reflected and may be shared with your social network within the applicable SNS. We reserve the right to use and disclose all personally identifiable information and other information about you that we receive through SNS in the same ways described in this privacy policy.

You are encouraged to read all policies and information on the applicable social media services to learn more about how they handle your information before using any such features made available to you through our Website. We are not responsible for any acts or omissions by any social media service provider or your use of features on their platforms.

How to access your information and your other rights

Users in the EEA have the following rights in relation to the personal information we hold about you:

  • Your right of access and rectification. Upon request, we will provide you with the information about you that we have processed, and the opportunity to correct, update or modify this information, to the extent required by law. If you require additional copies, we may need to charge a reasonable fee. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Please note that this right entitles you to be told about personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
  • Your right to stop receiving direct marketing communications. You can unsubscribe from receiving newsletters or commercial emails at any time. You can unsubscribe by clicking on the “Unsubscribe” link in the footer of any Refinery29 email and following the instructions. But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile. In order to cancel your account/ profile, please email support@refinery29.uk (for users in Europe) and support@refinery29.com (for users in the U.S.A.).

If you have consented to receive our newsletter or other emails from us and/or third parties in Germany, your consent wording was as follows:

"I subscribe to the email newsletter of Refinery 29 about its latest and greatest updates. I consent to a use of my personal data for that purpose. I can withdraw my consent at any time and can object to the use of my personal data for marketing purposes or market or opinion research."

Or when entering a prize draw:

"I agree to the Official Rules. I consent to receiving emails from Refinery 29, [named third party], about their latest and greatest updates. I consent to a use of my personal data by these parties for that purpose. I can withdraw my consent with respect to any of these parties at any time and can object to a use of my personal data for marketing purposes or market or opinion research. (Please see the links to the privacy policy below for contact and additional information)."

  • Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. Please note that asking us to stop processing your data will not cause us to stop storing it. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
  • Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for continuing that processing. If you ever object to us continuing to process your personal information for direct marketing then we will stop processing it for that purpose.
  • Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
  • Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Exercising your rights. To exercise any of your rights, please send us an email at, for Europe: legal@refinery29.uk or write to us at Refinery 29 Limited, Attn. Legal, 256-260 Old Street, London EC1 9DD United Kingdom.

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information.

Security and Retention

We store the information collected through the Website on restricted database servers. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. Although we take appropriate measures to safeguard against unauthorized disclosures of your information, we cannot guarantee its absolute security.

Where we transfer your personal data from the EEA to countries outside of it (either amongst our company group, or where we engage data processors who operate outside of the EEA) we take steps to ensure that your personal data is kept safely, securely and in compliance with all applicable privacy laws. We may do this using a variety of legal mechanisms permitted to us by applicable privacy law, which includes engaging processors located in jurisdictions which have privacy laws considered adequate by the European Union, and by using approved Standard Clauses to control those processors’ activities.

We retain personal information for as long as is necessary for the purposes for which it was collected. When we no longer need the information for such purpose and are no longer legally required to retain the information, we will destroy, erase or de-identify the information, unless otherwise permitted by applicable law.

Children

We do not offer the Website to anyone under the age of majority in their jurisdiction of residence and do not knowingly collect personal information from children under 13. No one under age 13 may provide any information to or on the Website. If you are under 13, do not use or provide any personal information on or through the Website, register on the Website, or use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, email address or any screen name or user name you may use.

If you are the parent or guardian of a child whom you believe has disclosed personal information to us, please contact us at legal@refinery29.com so that we may delete and remove such child’s information from our systems. In addition, in the event that a minor under the age of 18 in California uses the Website, the minor may request that Refinery29 remove content or information posted by the minor on the Website by sending an email to privacy@refinery29.com. However, such removal may not remove all traces of such posting everywhere online, since content or information may have been shared by others. Refinery29 may not have to comply with this removal requirement if: (i) federal or state law requires that we maintain the content or information; (ii) the content was stored or posted (or reposted) by a third party other than the minor contacting Refinery29; (iii) we anonymize the content or information so that the minor cannot be identified; (iv) the minor received compensation or other consideration for providing the content; or (v) the minor does not follow the instructions in this section.

Jurisdictional Issues

Refinery29 makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United States, England and Germany. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.

Contact Us

If you have questions about this privacy policy, or about the Website, please contact us at Refinery 29 Inc., Attn. Legal Department, 225 Broadway, 23rd Floor, New York, NY 10007, legal@refinery29.com.