Data protection is of a particularly high priority for the management of Refiner SAS.

This Privacy Policy applies to:

The use of refiner.io website and
Customers of Refiner SAS, using the Refiner Services to process Personal Data of their own clients.

1. Definitions

The following definitions are based on the terms used by the European legislator for the adoption of the Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (the General Data Protection Regulation or “GDPR”).

Consent: Consent of the Data Subject is any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Controller: Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; where the purposes and means of such Processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Data Subject: Data Subject is any identified or identifiable natural person, whose Personal Data is processed by the Controller responsible for the Processing.

Personal Data: Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor: Processor is a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

Profiling: Profiling means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation: Pseudonymisation is the Processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.

Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third party or not. However, public authorities which may receive Personal Data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as Recipients; the Processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the Processing.

Refiner Service: Means the survey software platform, as well as any related applications, developed and published by Refiner SAS, and used by customers of Refiner SAS in accordance with the Agreement, as defined in Refiner SAS Terms of Service.

Restriction of Processing: Restriction of Processing is the marking of stored Personal Data with the aim of limiting their Processing in the future.

Third party: Third party is a natural or legal person, public authority, agency or body other than the Data Subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorised to process Personal Data.

2. Identification

Refiner SAS acts in two distinct capacities under the GDPR, depending on the nature of the Personal Data processed and the purposes of such Processing:

2.1. Refiner SAS as Data Controller

As the publisher of the refiner.io website, Refiner SAS acts as a Data Controller in respect of:

Personal Data collected from visitors to the refiner.io website (including server log data, cookies, and contact form submissions);
Personal Data of its own customers and their team members (including account registration data, billing information, and correspondence); and
Personal Data processed for its own marketing and recruitment purposes. In this capacity, Refiner SAS alone determines the purposes and means of Processing.

The contact details of Refiner SAS as Controller are as follows:

Refiner SAS
10 rue de Penthièvre
75008 Paris
France
Email: contact@refiner.io
Website: https://refiner.io

The Data Protection Officer of Refiner SAS as a Controller is:

CEO Moritz Dausinger
Refiner SAS
10 rue de Penthièvre
75008 Paris
France
Email: contact@refiner.io
Website: https://refiner.io

Any Data Subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

2.2. Refiner SAS as Data Processor

When customers of Refiner SAS use the Refiner Services to collect, store, or otherwise process Personal Data of their own end-users (User Data, including survey responses and Contact Data imported into the Refiner platform), Refiner SAS acts exclusively as a Data Processor on behalf of such customers.

In this capacity, the customer acts as the Data Controller and alone determines which Personal Data are imported into its Refiner account and for what purposes. Refiner SAS processes such Personal Data solely on the documented instructions of the customer, in accordance with the Data Processing Agreement (“DPA”) entered into between Refiner SAS and the customer. Refiner SAS does not use customers’ end-users’ Personal Data for its own purposes.

3. Location

Refiner SAS data centers are located in the European Union within the EU-WEST-1 (Ireland) data center of the AWS cloud. Refiner SAS might send its customers data to sub-Processors for analytics & billing purposes. However, Refiner SAS does not send any of the customers’ clients’ data or their survey responses to any third-party Processor without the customers’ Consent. Without any action from the customers’ side, all the clients’ Personal Data and their survey responses stay on Refiner SAS servers and won’t leave the European Union.

4. International Transfers

All Company Data processed by Refiner SAS in its capacity as Data Processor is stored within the European Economic Area (EEA), in the EU-WEST-1 (Ireland) data center operated by Amazon Web Services EMEA SARL (AWS Europe). No Personal Data of customers’ end-users is transferred outside the EEA by default.

However, certain Subprocessors engaged by Refiner SAS for analytics, billing, or operational purposes may process data outside the EEA, including in the United States. In such cases, Refiner SAS ensures that any transfer of Personal Data to a third country is carried out in compliance with Chapter V of the GDPR, on the basis of one of the following transfer safeguards:

Standard Contractual Clauses (SCCs) adopted by the European Commission pursuant to its Implementing Decision (EU) 2021/914 (“SCCs for Transfers”); or
Certification of the Subprocessor under the EU-U.S. Data Privacy Framework (DPF), where applicable; or
An adequacy decision of the European Commission covering the country of destination.

Where neither an adequacy decision nor the DPF applies, Refiner SAS conducts a Transfer Impact Assessment (TIA) prior to the transfer, in accordance with applicable Supervisory Authority guidance.

Refiner SAS engages Subprocessors in two categories:

Subprocessors with access to Company Data (i.e. Personal Data of customers’ end-users processed through the Refiner platform); and
Subprocessors with access to Company Staff Data (i.e. Personal Data of the customer’s own team members).

Refiner SAS will inform customers of any intended addition or replacement of Subprocessors at least fourteen (14) days in advance, giving customers sufficient time to object prior to the engagement of the new Subprocessor, in accordance with the Data Processing Agreement.

5. Rights of Data Subject

If the Data Subject wishes to exercise any of the following rights, he or she may, at any time, contact Refiner SAS’ Data Protection Officer.

Right of confirmation

Each Data Subject shall have the right to obtain from the Controller the confirmation as to whether or not Personal Data concerning him or her are being processed.

Right of access

Each Data Subject shall have the right to obtain from the Controller free information about his or her Personal Data stored at any time and a copy of this information. The Data Subject has the right to access the following information:

the purposes of the Processing;
the categories of Personal Data concerned;
the Recipients or categories of Recipients to whom the Personal Data have been or will be disclosed, in particular Recipients in third countries or international organisations;
where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the Controller rectification or erasure of Personal Data, or Restriction of Processing of Personal Data concerning the Data Subject, or to object to such Processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the Personal Data are not collected from the Data Subject, any available information as to their source;
the existence of automated decision-making, including Profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such Processing for the Data Subject.

Furthermore, the Data Subject shall have a right to obtain information as to whether Personal Data are transferred to a third country or to an international organisation. Where this is the case, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

Right to rectification

Each Data Subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning him or her. Taking into account the purposes of the Processing, the Data Subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

Right to erasure (Right to be forgotten)

Each Data Subject shall have the right to obtain from the Controller the erasure of Personal Data concerning him or her without undue delay, and the Controller shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies, as long as the Processing is not necessary:

The Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The Data Subject withdraws Consent to which the Processing is based and where there is no other legal ground for the Processing.
The Data Subject objects to the Processing and there are no overriding legitimate grounds for the Processing.
The Personal Data have been unlawfully processed.
The Personal Data must be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject.
The Personal Data have been collected in relation to the offer of information society services referred to in the GDPR.

Where the Controller has made Personal Data public and is obliged pursuant to the GDPR to erase the Personal Data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other Controllers Processing the Personal Data that the Data Subject has requested erasure by such Controllers of any links to, or copy or replication of, those Personal Data, as far as Processing is not required.

Right of Restriction of Processing

Each Data Subject shall have the right to obtain from the Controller Restriction of Processing where one of the following applies:

The accuracy of the Personal Data is contested by the Data Subject, for a period enabling the Controller to verify the accuracy of the Personal Data.
The Processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests instead the restriction of their use.
The Controller no longer needs the Personal Data for the purposes of the Processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims.
The Data Subject has objected to Processing pursuant to the GDPR pending the verification whether the legitimate grounds of the Controller override those of the Data Subject.

Right to data portability

Each Data Subject shall have the right to receive the Personal Data concerning him or her, which was provided to a Controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another Controller without hindrance from the Controller to which the Personal Data have been provided, as long as the Processing is based on Consent pursuant to the GDPR, or on a contract pursuant to the GDPR, and the Processing is carried out by automated means, as long as the Processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller. Furthermore, in exercising his or her right to data portability, the Data Subject shall have the right to have Personal Data transmitted directly from one Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

Right to object

Each Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to Processing of Personal Data concerning him or her. This also applies to Profiling based on the GDPR provisions. Refiner SAS shall no longer process the Personal Data in the event of the objection, unless Refiner SAS can demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the Data Subject, or for the establishment, exercise or defence of legal claims.

If Refiner SAS processes Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to Processing of Personal Data concerning him or her for such marketing. This applies to Profiling to the extent that it is related to such direct marketing. If the Data Subject objects to Refiner SAS to the Processing for direct marketing purposes, Refiner SAS will no longer process the Personal Data for these purposes.

In addition, the Data Subject has the right, on grounds relating to his or her particular situation, to object to Processing of Personal Data concerning him or her by Refiner SAS for scientific or historical research purposes, or for statistical purposes pursuant to the GDPR, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.

Automated individual decision-making, including Profiling

Each Data Subject shall have the right not to be subject to a decision based solely on automated Processing, including Profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) is not authorised by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, or (3) is not based on the Data Subject’s explicit Consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) it is based on the Data Subject’s explicit Consent, Refiner SAS shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and contest the decision.

Each Data Subject shall have the right to withdraw his or her Consent to Processing of his or her Personal Data at any time.

6. Legal basis for Processing

Art. 6(1) a) of the GDPR serves as the legal basis for Processing operations (Consent of the Data Subject).

If the Processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, as is the case, for example, when Processing operations are necessary for the supply of goods or to provide any other service, the Processing is based on Article 6(1) b) of the GDPR. The same applies to such Processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.

When Refiner SAS is subject to a legal obligation by which Processing of Personal Data is required, such as for the fulfillment of tax obligations, the Processing is based on Art. 6(1) c) of the GDPR.

In rare cases, the Processing of Personal Data may be necessary to protect the vital interests of the Data Subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his/her name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other Third party. Then the Processing would be based on Art. 6(1) d) of the GDPR.

Finally, Processing operations could be based on Article 6(1) f) of the GDPR. This legal basis is used for Processing operations which are not covered by any of the abovementioned legal grounds, if Processing is necessary for the purposes of the legitimate interests pursued by Refiner SAS or by a Third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data.

7. Collection of data and Processing/sub-Processing

Collection of general data and information

Refiner.io website collects a series of general data and information when a Data Subject or automated system calls up the website. This general data and information are stored in the server log files. Collected information and data may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Refiner SAS does not draw any conclusions about the Data Subject. Rather, this information is needed to (1) deliver the content of the website correctly, (2) optimize the content of the website as well as its advertisement, (3) ensure the long-term viability of the information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Refiner SAS analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of the company, and to ensure an optimal level of protection for the Personal Data processed. The anonymous data of the server log files are stored separately from all Personal Data provided by a Data Subject.

Registration on the website

The Data Subject has the possibility to register on the website. Which Personal Data are transmitted to the Controller is determined by the respective input mask used for the registration. The Personal Data entered by the Data Subject are collected and stored exclusively for internal use by the Controller, and for its own purposes. The Controller may request transfer to one or more Processors that also uses Personal Data for an internal purpose which is attributable to the Controller. By registering on the website of the Controller, the IP address — assigned by the Internet service provider (ISP) and used by the Data Subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of the services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the Controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution. The registration of the Data Subject, with the voluntary indication of Personal Data, is intended to enable the Controller to offer the Data Subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to exercise their rights according to Section 5 of the present Privacy Policy.

Payment method: data protection provisions about the use of Stripe as a payment Processor

On this website, the Controller has integrated Stripe components. Stripe is an online payment service provider, which allows purchases on an account or a flexible installment payment.

The operating company of Stripe is Stripe Payments Europe, Limited, North Wall Quay Dublin 1., Ireland.

The Personal Data transmitted to Stripe is usually first name, surname, address, date of birth, sex, email address, IP address, telephone number, mobile phone number, as well as other data necessary for the Processing of an invoice or installment purchase. The Processing of the purchase contract also requires such Personal Data, which are in connection with the respective order. In particular, the exchange of payment information such as bank details, card number, date of validity and CVC code, cumulative number, item number, data on goods and services, prices and taxes, information on the previous purchase behavior or other details of the financial situation of the Data Subject.

The purpose of the transmission of the data is, in particular, the identification check, payment administration, and fraud prevention. The Controller shall provide Stripe with Personal Data, in particular, if a legitimate interest in the transmission exists. The Personal Data exchanged between Stripe and the Data Subject for the data Processing shall be transmitted by Stripe to economic agencies. This transmission is intended for identity and creditworthiness checks.

The Data Subject is able to revoke the Consent to the handling of Personal Data at any time from Stripe. A revocation shall not have any effect on Personal Data which must be processed, used or transmitted in accordance with (contractual) payment Processing.

Contact possibility via the website

The website contains information that enables a quick electronic contact to Refiner SAS, as well as direct communication with the company, which also includes a general address of the so-called electronic mail (email address). If a Data Subject contacts the Controller by email or via a contact form, the Personal Data transmitted by the Data Subject are automatically stored. Such Personal Data transmitted on a voluntary basis by a Data Subject to the data Controller are stored for the purpose of Processing or contacting the Data Subject. There is no transfer of this Personal Data to third parties.

Users of the website are given the opportunity to subscribe to Refiner SAS’s newsletter. The input mask used for this purpose determines what Personal Data are transmitted, as well as when the newsletter is ordered from the Controller.

Refiner SAS informs its customers and business partners regularly by means of a newsletter about enterprise offers. Refiner SAS’s newsletter may only be received by the Data Subject if (1) the Data Subject has a valid email address and (2) the Data Subject registers for the newsletter shipping. A confirmation email will be sent to the email address registered by a Data Subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the Data Subject is authorized to receive the newsletter.

During the registration for the newsletter, Refiner SAS also stores the IP address of the computer system assigned by the Internet service provider (ISP) and used by the Data Subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a Data Subject at a later date, and it therefore serves the aim of the legal protection of the Controller.

The Personal Data collected as part of a registration for the newsletter will only be used to send the newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of Personal Data collected by the newsletter service to third parties. The subscription to the newsletter may be terminated by the Data Subject at any time. The Consent to the storage of Personal Data, which the Data Subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of Consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the Controller, or to communicate this to the Controller in a different way.

The newsletter of Refiner SAS contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Refiner SAS may see if and when an email was opened by a Data Subject, and which links in the email were called up by Data Subjects.

Such Personal Data collected in the tracking pixels contained in the newsletters are stored and analyzed by the Controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the Data Subject. These Personal Data will not be passed on to third parties. Data Subjects are at any time entitled to revoke the respective separate declaration of Consent issued by means of the double-opt-in procedure. After a revocation, these Personal Data will be deleted by the Controller. Refiner SAS automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Cookies

Refiner.io website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. Through the use of cookies, Refiner SAS can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on the website can be optimized with the user in mind. Cookies allow Refiner SAS, as previously mentioned, to recognize the website users. The purpose of this recognition is to make it easier for users to utilize the website. The Data Subject may, at any time, prevent the setting of cookies through the website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the Data Subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

Data protection for applications and the application procedures

The data Controller shall collect and process the Personal Data of applicants for the purpose of the Processing of the application procedure. The Processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by email or by means of a web form on the website to the Controller. If the data Controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of Processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the Controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the Controller are opposed to the erasure.

Sub-Processing

For the purpose of various Processing directly linked to the use of the website, the application procedures and/or the Refiner Service, the Controller uses Third Party Processing services which list, purposes and functionality are detailed in Appendix A to this Privacy Policy.

8. Data retention, transfer, erasure of data

Period for which the Personal Data will be stored

The criteria used to determine the period of storage of Personal Data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Routine erasure and blocking of Personal Data

The data Controller shall process and store the Personal Data of the Data Subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the GDPR or other regulations to which the Controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by the GDPR or another applicable regulation expires, the Personal Data are routinely blocked or erased in accordance with legal requirements.

9. Security measures

Pseudonymisation and Encryption

Personal Data is encrypted in transit using a minimum of TLS 1.2 and at rest using AES-256 encryption. All backups are encrypted. Refiner SAS implements Pseudonymisation where appropriate to reduce the risk associated with the Processing of Personal Data.

Confidentiality, Integrity, Availability and Resilience

Regular automated backups are performed. Business continuity and disaster recovery procedures are in place to restore availability of Personal Data within appropriate timeframes following a physical or technical incident. Infrastructure is redundant and hosted within the EEA.

Testing and Evaluation

Regular penetration testing and vulnerability assessments are conducted. The effectiveness of technical and organisational measures is reviewed on a periodic basis.

Access Control

Multi-factor authentication (MFA) is required for access to systems processing Personal Data. Role-based access control (RBAC) is applied on the basis of the principle of least privilege. Access rights are reviewed regularly. All personnel with access to Personal Data are subject to confidentiality obligations.

Data Protection during Transmission and Storage

All data transmissions use encrypted channels (TLS). Unencrypted transmission of Personal Data is prohibited. Personal Data is stored on encrypted servers (AES-256) and logically separated from data of other customers.

Event Logging and Monitoring

Audit logs of access to Personal Data are maintained. Intrusion detection and security monitoring systems are in place.

Incident Management

A documented procedure for the detection, investigation, classification and notification of Personal Data Breaches is maintained. An internal escalation process is aligned with the 72-hour notification obligation under Article 33 GDPR.

Accountability and Data Governance

A data protection point of contact has been appointed. All staff with access to Personal Data receive regular data protection training. Contractual confidentiality obligations are imposed on all such staff. Data retention and deletion policies are aligned with the processing durations set out in the Data Processing Agreement.

Physical Security

Physical access controls at data processing sites are ensured by Subprocessors (in particular AWS Europe), which comply with ISO 27001 or equivalent standards.

10. Data Breach

10.1. Refiner SAS acting as Data Processor — Notification to the Customer (Controller)

Where a Personal Data Breach affects Personal Data processed by Refiner SAS on behalf of a customer, Refiner SAS shall notify the customer (as Data Controller) without undue delay and, in any event, no later than seventy-two (72) hours after becoming aware of the breach. Such notification shall include at a minimum:

a description of the nature of the Personal Data Breach, including where possible the categories and approximate number of Data Subjects concerned and records affected;
the contact details of a point of contact from whom further information can be obtained;
the likely consequences of the Personal Data Breach; and
the measures taken or proposed to address the breach, including where appropriate measures to mitigate its possible adverse effects.

Where it is not possible to provide all information at the same time, the initial notification shall contain the information available at that time, with further information provided without undue delay. Refiner SAS shall cooperate with the customer and take such steps as are directed by the customer to assist in the investigation, mitigation and remediation of the breach, in accordance with the Data Processing Agreement.

10.2. Refiner SAS acting as Data Controller — Notification to the Supervisory Authority and Data Subjects

Where a Personal Data Breach affects Personal Data processed by Refiner SAS in its capacity as Data Controller (e.g. data of its own customers, website visitors or job applicants), Refiner SAS shall notify the competent Supervisory Authority without undue delay and, where feasible, within seventy-two (72) hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons (Article 33 GDPR). Where the breach is likely to result in a high risk to the rights and freedoms of individuals, Refiner SAS shall also communicate the nature of the breach, its likely consequences, and the measures taken or proposed to the affected Data Subjects without undue delay (Article 34 GDPR). Refiner SAS shall document all Personal Data Breaches, including the facts surrounding the incident, its effects and the remedial action taken, in accordance with Article 33(5) GDPR.

11. Data Protection Impact Assessment and Prior Consultation

Refiner SAS, as a Processor, shall provide reasonable assistance to its customers with any data protection impact assessments according to the Data Processing Agreement (“DPA”).

12. Audit rights

Audit rights relating to Refiner SAS as a Processor are detailed in the DPA.

Appendix A – List of Sub-Processing

Provider	Purpose
AWS Europe	Cloud infrastructure and hosting provider used for application hosting, data storage, backups, networking, and related operational services within the European Union.
ChartMogul	Subscription analytics and revenue reporting platform used to analyze billing and subscription metrics.
ChargeBee	Subscription billing and invoicing platform used to manage customer subscriptions, payments, and invoices.
Customer.io (Peaberry Software Inc.)	Customer messaging and email delivery platform used for transactional and product-related communications.
Fathom Analytics (Conva Ventures Inc.)	Privacy-focused web analytics service used to measure website traffic and usage trends.
Google Analytics	Web analytics service used to analyze website traffic, usage behavior, and product performance.
Google Workspace	Productivity and communication platform used for email, document management, internal collaboration, and customer communications.
HubSpot France SAS	Customer relationship management and support platform used to manage sales, customer communications, and support interactions.
IpData LLC	IP Address based geo coding used for advanced in-app survey targeting (optional)
Slack	Internal communication and collaboration platform used for operational coordination and customer support workflows.
Stripe Europe	Payment processing platform used to process customer payments and manage related billing information.

Privacy Policy