Legal
Privacy Policy
Last updated: 10 August 2026
01. Who's responsible for your data
Refresh Design S.L., C. Cactus, 30, 35015 Las Palmas de Gran Canaria, Spain, is the data controller for the personal data collected through refresh-design.com. Contact us about privacy at support@refresh-design.com.
02. What we collect
Depending on how you use the site, we collect: name, email address, phone number and postal address (when you send an enquiry, request a quote, or check out); billing address and, for businesses, a VAT/CIF number (at checkout); the content of any message you send us; and, only with your consent, anonymised analytics data (pages viewed, approximate location, device type) via Google Analytics 4.
03. Why we collect it, and on what basis
- To reply to an enquiry and provide a quote — legal basis: your consent and our legitimate interest in responding to you.
- To process an order and deliver a service — legal basis: performance of a contract with you.
- To issue invoices and meet tax obligations — legal basis: legal obligation.
- To understand how the site is used, only if you consent — legal basis: your consent (Google Analytics 4, loaded only after you accept).
04. How long we keep it
Enquiry and contact data: up to 24 months from your last contact with us, unless you ask us to delete it sooner. Order and invoice data: as long as Spanish tax law requires (currently up to 6 years). Analytics data: per Google Analytics 4's own retention settings, currently 14 months.
06. International transfers
Google Analytics 4 may process data outside the EU/EEA, under Google's Standard Contractual Clauses and its own compliance measures. This only ever happens if you've given analytics consent.
07. Your rights
Under GDPR and the Spanish LOPDGDD, you can ask us to: access the data we hold about you, correct it, delete it, restrict or object to its processing, or receive a copy in a portable format. Write to support@refresh-design.com and we'll respond within one month. If you're not satisfied with our response, you can complain to the Spanish data protection authority (Agencia Española de Protección de Datos, aepd.es).
09. Security
We apply reasonable technical and organisational measures to protect your data — encrypted connections (HTTPS) throughout, and access to stored data limited to what running the studio requires.
10. Changes to this policy
If this policy changes materially, we'll update the date at the top of this page.
11. Contact
support@refresh-design.com · 928 33 10 64 · C. Cactus, 30, 35015 Las Palmas de Gran Canaria, Spain.