Privacy Policy

At Refresh Works Limited, a company incorporated in Hong Kong (“Refresh”), we recognise the importance of your personal data that we collect from you (“personal information”). This privacy policy (the “Privacy Policy”) outlines how we collect, hold, use, manage, protect and process your personal information when you use the Refresh app, our websites, applications, programmes, servers, and software, including the following:

any websites owned and operated by us, including https://refresh.works;
any official social media channels created and operated by us, including but not limited to Facebook, Instagram, TikTok, Twitter and YouTube;
any applications used to deliver the Refresh app, including but not limited to applications on iOS, Android or through the website (collectively, the “App”); and
any other services or programs offered by us that make reference to this Privacy Policy (together with the above, the “Services”),

where any of the above are owned by Refresh or its affiliates (as defined in the Companies Ordinance (Cap. 622 of the laws of Hong Kong)) (collectively, “we”, “us” or “our”).

This Privacy Policy applies to any interactions you make with the Services. By continuing to use our Services and by providing your personal information to us, you are deemed to have consented to the terms of this Privacy Policy and our Terms of Use (accessible here: https://www.refresh.works/terms-of-use). We may, at our sole discretion, change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of the terms of the current Privacy Policy.

If you do not consent to this Privacy Policy, please cease using the Services immediately and notify us that you do not consent by email to hello@refresh.works.

What is personal information?

Personal information includes information or an opinion about an individual that’s identified or reasonably identifiable. This can include a person’s name, age, gender, address, postcode and contact details.

Any personal information that has undergone the process of de-identification is no longer personal information. You acknowledge and accept that any personal information (including sensitive information) that has been de-identified and/or anonymised is no longer personal information and/or sensitive information. For the avoidance of doubt, aggregate information about our users is not personal information as aggregate information cannot identify any individuals.

What personal information do we collect?

We may collect the following types of personal information:

name;
email address;
telephone number and other contact details;
age or date of birth;
skincare product usage, including your inventory of skincare, routines saved and any additional product information you save in the App;
your device ID, device type, geo-location information, traffic to and from our App and website, browser data, screen resolution, ad data, IP address and standard web log information;
app usage information, such as how you use the App, your device language, and dates and times you interacted with the App;
any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
online activity data, such as information about your usage of the App and our website, including pages or screens viewed, session duration, navigation paths between pages or screens, information about your activity on such pages or screens, access times and length of access;
information you provide to us through surveys;
information you provide to the app voluntarily, including diary entries saved in the App; or
any other personal information that may be required in order to facilitate your dealings with us.

The information we collect may include sensitive information, including your health information. Health information includes any information or an opinion about your health (including illness, disability or injury). For example, if you provide your allergies or diary entries containing information or opinions about your health into the Refresh app, we will be collecting your health and/or sensitive information.

How do we collect personal information?

We may collect the above types of personal information either directly from you, or from third parties. We may collect this information when you:

register on our website or app;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; or
interact with our App, website, services, content and advertising, including provision of your personal information (whether directly or indirectly) by you into the Refresh app.

Why do we collect, use and disclose personal information?

We collect, hold, use and disclose your personal information for the following purposes:

to enable you to access and use the App or features on our website;
to personalise your experience, as your personal data will allow us to respond and cater to your individual needs in the App, including but not limited to suggesting new skincare products that are relevant to you;
to operate, protect, improve and optimise the App, Services, business and user experience, by using your personal information to perform analytics, conduct research, for advertising and marketing, develop new features and products, improve customer service and to process transactions;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
to administer rewards, surveys, contests, product purchases or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
to consider your employment application (if applicable).

If you do not provide your personal information to us, we will not be able to provide you access to the App or the Services, as we will not be able to help you track your skincare usage, products that you own and provide recommendations to improve your skincare usage, all of which are core features of the App (whether existing or planned).

Usage of your personal information for direct marketing purposes

For the avoidance of doubt, we may use your data for direct marketing purposes, including but not limited to suggesting new skincare products for purchase through third parties. If you do not consent to your personal information being used for such purposes, please cease using the Services immediately and notify us that you do not consent by email to hello@refresh.works. Upon receipt of such notification, we will cease using your personal information in direct marketing and disable your access to the Services.

By your continued use of the App and the Services, you are indicating that you do not object to our use of your personal information for the purposes of direct marketing.

Do we disclose your personal information to third parties?

We may disclose your personal information for the purposes described in this Privacy Policy to:

our employees and associated companies;
third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
professional advisers, dealers and agents;
payment systems operators (e.g. merchants receiving card payments);
our existing or potential agents, business partners or partners, such as skincare brands, retailers and advertisers;
our sponsors or promoters of any competition that we conduct via our services;
anyone to whom our assets or businesses (or any part of them) are transferred or sold;
specific third parties authorised by you to receive information held by us; and/or
other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by applicable law.

Where you are making purchases through the App from a third party, we may be required to disclose your personal information such third party to facilitate the transaction, such as your email, skincare profile, demographic information and geo-location data. Such third parties may also have existing personal information about you that they may combine with personal information we share. By proceeding with any transactions with a trusted third party made through the App or our website, you consent to our disclosure of your personal information to such third party.

If you do not consent to our disclosure of your personal information, please cease usage of the App and the Services immediately.

Cross-border disclosure of personal information

We use global information systems to operate the Refresh app. Consequently, we may disclose your personal information to third party suppliers of information systems, such as cloud providers located in the United States of America and Australia.

When you provide your personal information to us, you consent to the disclosure of your information to such third party suppliers. We will, however, take reasonable measures to ensure that any overseas recipient will deal with your personal information in a way that is consistent in line with relevant data protection and privacy laws and regulations, including those in Australia and Hong Kong.

Retention, administration & management of personal information

We have taken all reasonably practicable steps to safeguard your personal information from unauthorised or accidental access, processing, erasure, loss or use. However, we cannot guarantee the security of your personal information.

Where personal information that you have provided us is incorrect, we have taken all reasonably practicable steps to ensure that you can amend your personal information in the App. This includes amending information such as your skin profile, your skincare usage and your geo-location data. If, for any reason, you are unable to amend your personal information, you can inform us by email to hello@refresh.works of any amendments needed, and we take reasonable steps to ensure it is corrected. If we are unable to do so, we will provide you the reasons why. We may also need to verify your identity when you request your personal information.

Your personal information collected by us will be retained for as long as it is reasonably necessary for the purposes disclosed in this Privacy Policy, and we may anonymise, de-identify, destroy or delete any information or personal information provided by you thereafter, unless required by law, regulation or other business or audit requirements.

Using our website, App and cookies

We may collect personal information about you when you use and access our App and website.

We may also use ‘cookies’ or other similar tracking technologies on our website or in our App that help us track your usage and remember your preferences. Cookies are small files that store information on your computer or mobile phone. They enable us to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser or operating system settings, but our App and website may not work as intended for you if you do so.

Our advertising and third-party partners may also transmit cookies to your browser or device, when you click on advertisements that appear on the Services. Further, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. For the avoidance of doubt, this Privacy Policy does not cover the use of cookies by any third parties. The privacy policies that apply to third party websites may differ substantially from this Privacy Policy, so we encourage you to read them before using those websites. Please also be aware that cookies placed by third parties may continue to track your activities online even after you have ceased using the Services, and those third parties may not honour ‘Do Not Track’ requests that you have set using your browser or device.

If you do not consent to our use of cookies, please adjust your browser and device settings accordingly, or cease usage of the App and the Services.

Making a complaint

If you wish to make a complaint about the way we have handled your personal information, you can contact us by email to hello@refresh.works. Please include your name, email address and/or telephone number, and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. All personal information you provide in relation to the complaint shall be handled in accordance with this Privacy Policy. If you think that we have failed to resolve the complaint in a satisfactory manner, you may notify us of such and we will provide you with information about the further steps you can take.

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact our Data Protection Officer by email to hello@refresh.works.

Effective: 1 May 2023