Legal
Privacy Policy
Last updated 2 October 2026
This policy explains what personal information Refined Digital (“we”, “us”) collects through refined-digital.co.uk, why we collect it, and the rights you have over it. We are the data controller for that information under the UK General Data Protection Regulation and the Data Protection Act 2018.
Who we are
Refined Digital is a web design and software studio based in Belfast, Northern Ireland, run by Raymond Kavanagh. You can contact us about anything in this policy at rkavanagh@refined-digital.co.uk or on +44 7740 579426.
What we collect
When you send an enquiry. The contact form asks for your name, email address, and a message, and optionally your phone number, business name and the type of project. We only receive what you choose to type in.
When you email or call us. We keep the correspondence and whatever contact details come with it.
When you visit the site. Our hosting provider automatically records standard technical information for each request, such as your IP address, browser type and the page requested, to keep the site running and secure. We don’t use this to identify you.
Cookies and tracking
This website does not set cookies and does not use analytics, advertising or tracking scripts. Our fonts are served from our own domain, so loading a page doesn’t send your details to a third-party font service.
How we use it, and our lawful basis
- To reply to your enquiry and discuss a possible project — based on our legitimate interest in responding to people who contact us, or on taking steps at your request before entering into a contract.
- To deliver work you’ve engaged us for, and to invoice for it — as necessary for our contract with you.
- To keep business and tax records — to meet our legal obligations.
- To protect the website from abuse and spam — based on our legitimate interest in keeping it secure.
We don’t sell your information, add you to a mailing list, or use it for automated decision-making.
Who we share it with
We use a small number of service providers who process information on our behalf and only on our instructions:
- Resend, which delivers the contact form to our inbox.
- Our email provider, where enquiries and correspondence are stored.
- Our website hosting provider, which serves the site and keeps the request logs described above.
Some of these providers may process data outside the UK. Where they do, we rely on the safeguards UK data protection law requires, such as UK adequacy regulations or the UK International Data Transfer Addendum. We may also disclose information where the law requires it.
How long we keep it
Enquiries that don’t lead to a project are deleted within two years of our last contact. If you become a client, we keep project and billing records for six years after the work ends, to meet accounting and tax requirements.
Your rights
You have the right to:
- ask for a copy of the personal information we hold about you;
- ask us to correct anything that is inaccurate;
- ask us to delete it, or to restrict how we use it;
- object to us using it on the basis of legitimate interests;
- ask for information you gave us to be transferred to you or someone else.
To use any of these, email rkavanagh@refined-digital.co.uk. We’ll respond within one month. There’s no charge.
Complaints
If you’re unhappy with how we’ve handled your information, please tell us first so we can put it right. You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. If you live in Ireland, you can contact the Data Protection Commission at dataprotection.ie.
Changes to this policy
If how we handle personal information changes, we’ll update this page and the date at the top.