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Privacy Policy

Last updated August 19, 2025

This Privacy Notice for Refine Technologies, Inc. (doing business as Refine) ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services").

Please read this Privacy Notice carefully. If you have any questions or concerns about our privacy practices, please don't hesitate to contact us.

Table of Contents

1. Research Use For Model Training2. What Information Do We Collect?3. How Do We Process Your Information?4. What Legal Bases Do We Rely On To Process Your Personal Information?5. When And With Whom Do We Share Your Personal Information?6. Do We Use Cookies And Other Tracking Technologies?7. Do We Offer Artificial Intelligence-Based Products?8. How Do We Handle Your Social Logins?9. Is Your Information Transferred Internationally?10. How Long Do We Keep Your Information?11. How Do We Keep Your Information Safe?12. Do We Collect Information From Minors?13. What Are Your Privacy Rights?14. Controls For Do-Not-Track Features15. Do United States Residents Have Specific Privacy Rights?16. Do Other Regions Have Specific Privacy Rights?17. Do We Make Updates To This Notice?18. How Can You Contact Us About This Notice?19. How Can You Review, Update, Or Delete The Data We Collect From You?
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1. Research Use For Model Training

A core value at Refine is that the content you upload is strictly confidential. We will not train any large language models on confidential data. Our AI model providers (listed below) are also prohibited from training models on such data by their enterprise legal contracts with Refine.

The content you upload may not be shared or sold by us or our providers to any third party.

Your data is protected by state-of-the-art security practices in collaboration with Microsoft Azure. When you delete a session in your history, we delete all its data permanently and unrecoverably.

We may use your interactions with comments to improve feedback ranking and quality. You may opt out of such use by notifying help@refine.ink from the email address associated with your Refine account.

For more information about our AI service providers' privacy practices:

  • Google Privacy Policy and Gemini API Terms
  • OpenAI Enterprise Privacy Policy

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2. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: names, email addresses, usernames, billing addresses, contact or authentication data, passwords.

We do not process sensitive information.

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: http://www.refine.ink/cookie-policy.

The information we collect includes: Log and Usage Data (service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files), Device Data (information about your computer, phone, tablet, or other device you use to access the Services including IP address, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information).

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

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3. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process the personal information for the following purposes listed below:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

To process user-submitted content. We process the drafts or papers that users upload — which may incidentally contain personal information — in order to generate and return feedback as part of our service.

To determine the effectiveness of promotional campaigns. We track responses to campaigns and communications.

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4. What Legal Bases Do We Rely On To Process Your Personal Information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: Send users information about special offers and discounts on our products and services, Analyze how our Services are used so we can improve them to engage and retain users, Diagnose problems and/or prevent fraudulent activities, Understand how our users use our products and services so we can improve user experience, Assess and improve our marketing strategies to reach the right audience without being intrusive.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the data controller under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a data processor on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the data controller responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way, For investigations and fraud detection and prevention, For business transactions provided certain conditions are met, If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim, If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records, If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced, If the collection is solely for journalistic, artistic, or literary purposes, If the information is publicly available and is specified by the regulations, We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

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5. When And With Whom Do We Share Your Personal Information?

Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents (third parties) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows: Advertising, Direct Marketing, and Lead Generation: Google AdSense, AI Service Providers: Google Cloud AI and OpenAI, Allow Users to Connect to Their Third-Party Accounts: Google account, Cloud Computing Services: Microsoft Azure and Google Cloud Platform, Functionality and Infrastructure Optimization: Termly.io and Microsoft Azure, Invoice and Billing: Stripe, User Account Registration and Authentication: Google Sign-In

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

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6. Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a sale/sharing (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: http://www.refine.ink/cookies.

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7. Do We Offer Artificial Intelligence-Based Products?

Use of AI Technologies

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, AI Products). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

We provide the AI Products through third-party service providers (AI Service Providers), including OpenAI and Google Cloud AI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions: Text analysis, AI automation, AI document generation, AI insights, AI research

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

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8. How Do We Handle Your Social Logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

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9. Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information, including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

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10. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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11. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

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12. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@refine.ink.

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13. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying STOP or UNSUBSCRIBE to the SMS messages that we send, or by contacting us using the details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. You will then be removed from the marketing lists. However, we may still communicate with you regarding service-related announcements or other non-promotional information.

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14. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

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15. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Yes. If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Louisiana, Mississippi, Montana, New Hampshire, New Jersey, New Mexico, New York, North Dakota, Ohio, Oregon, Tennessee, Texas, Utah, Virginia, or Wyoming, you may have the right to: Request access to a copy of the specific pieces of personal information that we have collected about you and the categories of personal information we collect, the sources of that information, our business purpose for collecting that information, and the categories of third parties with whom we share information. Request deletion of the personal information we have collected from you, subject to certain exceptions. Correct inaccuracies in your personal information. Get a copy of your information in a portable and readily useable format. Opt-out of the sale or sharing of your personal information to third parties. You may make such requests by contacting us by using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. We will validate your request by verifying your identity to the extent possible. If we are unable to verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of validating your request, which we will only use for that purpose. If you are an authorized agent submitting a request on behalf of a consumer, we may need additional information to verify your identity as an authorized agent.

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16. Do Other Regions Have Specific Privacy Rights?

If you are located in the United Kingdom, you have the right to make a request regarding your personal information to the extent provided under the applicable laws. You may request: What personal information we hold about you, How we use your personal information and on what legal basis, For how long we store your personal information, Who it has been, or will be, shared with, Whether there are automated decision-making processes that affect you. You may submit your request using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. If you believe we are processing your information in breach of applicable law, you have the right to lodge a complaint with your local data protection authority.

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17. Do We Make Updates To This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws. When we make material changes to this Privacy Notice, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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18. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@refine.ink or by post to: Refine Technologies, Inc. Privacy Department, [Address to be provided], United States. If you are located in the European Union or United Kingdom and have an unresolved concern about our privacy practices, you have the right to lodge a complaint with the local data protection authority responsible for your jurisdiction.

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19. How Can You Review, Update, Or Delete The Data We Collect From You?

You have the right to request access to, update, or delete your personal information. You can request these actions by visiting https://www.refine.ink/privacy-requests or by contacting us directly. We will respond to your request in accordance with applicable data protection laws.

Privacy Questions?

If you have questions about our privacy practices, please contact us at:

Refine Technologies, Inc. - Privacy Department

131 Continental Dr suite 305, Newark, DE 19713, USA

Email: privacy@refine.ink

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