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Privacy policy

# PRIVACY POLICY

Last Updated: 05/08/2025

This Privacy Policy describes how JMT Holdings LTD operating as The Refined Luxury (“The Refined Luxury”, “we”, “our”, or “us”) collects, uses, stores, and discloses your personal information when you access our website, purchase products, use our services, communicate with us, or otherwise interact with our business.

By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy.

## 1. Personal Information We Collect

We may collect and process the following categories of personal information:

### Contact Information
Including:
- Full name
- Billing address
- Shipping address
- Email address
- Phone number

### Transaction Information
Including:
- Purchases
- Order history
- Cart activity
- Wishlist activity
- Payment confirmations
- Returns and exchanges

### Payment Information
Payments are securely processed through third-party payment providers. We do not directly store full credit card or payment card details.

### Account Information
Including:
- Login credentials
- Account preferences
- Saved information
- Communication preferences

### Device & Usage Information
Including:
- IP address
- Browser type
- Device information
- Website interaction
- Browsing behaviour
- Cookies and analytics data

### Communications
Including:
- Emails
- WhatsApp messages
- Instagram messages
- Contact form submissions
- Customer service conversations

## 2. How We Collect Information

We collect information:
- Directly from you
- Automatically through website technologies
- Through Shopify and integrated services
- Through cookies and analytics tools
- Through advertising and marketing platforms
- Through communication platforms

## 3. How We Use Your Information

We may use your personal information to:

### Provide Our Services
Including:
- Processing orders
- Delivering products
- Managing accounts
- Facilitating sourcing requests
- Providing customer support
- Managing SPA/restoration bookings

### Improve Website Experience
Including:
- Website analytics
- Product recommendations
- Performance optimisation
- User experience improvements

### Marketing & Advertising
Including:
- Email marketing
- Retargeting advertisements
- Promotional campaigns
- Social media advertising
- Product announcements

You may unsubscribe from marketing communications at any time.

### Security & Fraud Prevention
Including:
- Identity verification
- Fraud detection
- Chargeback prevention
- Transaction monitoring
- Account protection

For certain high-value transactions, we may request identification documents for security and fraud prevention purposes.

### Legal & Compliance Purposes
Including:
- Compliance with applicable laws
- Dispute resolution
- Enforcement of policies
- Legal investigations
- Accounting and tax obligations

## 4. Shopify & Third-Party Services

Our website is hosted by Shopify, which provides the e-commerce platform powering our store.

Shopify may process personal information to:
- Operate the website
- Process transactions
- Improve services
- Prevent fraud
- Provide analytics and advertising tools

We may also share limited information with trusted third-party providers including:
- Payment processors
- Shipping providers
- Analytics providers
- Marketing platforms
- Email marketing providers
- Customer communication tools

These providers process information only as necessary to perform their services.

## 5. Cookies & Tracking Technologies

We use cookies and similar technologies including:
- Essential cookies
- Analytics cookies
- Advertising cookies
- Functionality cookies

These technologies help us:
- Operate the website
- Analyse traffic
- Improve user experience
- Deliver targeted advertisements
- Remember preferences

We may use:
- Meta Pixel
- Google Analytics
- Shopify analytics tools
- Advertising and retargeting technologies

You may control cookie preferences through your browser settings.

## 6. Marketing Communications

By subscribing to newsletters, submitting forms, contacting us, or making purchases, you may receive marketing communications from us through:
- Email
- WhatsApp
- SMS
- Social media platforms

You may opt out of marketing communications at any time through unsubscribe links or by contacting us directly.

## 7. Data Retention

We retain personal information only for as long as reasonably necessary for:
- Business operations
- Legal obligations
- Accounting requirements
- Fraud prevention
- Dispute resolution
- Enforcement of agreements

Certain transaction and communication records may be retained for legal and security purposes.

## 8. International Data Transfers

Your personal information may be processed or stored outside Malta and the European Economic Area through Shopify and third-party providers.

Where applicable, we rely on recognised legal mechanisms for international data transfers, including standard contractual clauses and equivalent safeguards.

## 9. Your Rights

Subject to applicable law, you may have the right to:
- Access your personal information
- Correct inaccurate information
- Request deletion of your information
- Object to certain processing
- Withdraw consent
- Request data portability
- Restrict processing in certain circumstances

To exercise any of these rights, please contact us using the details below.

We may require identity verification before processing certain requests.

## 10. Security

We implement reasonable security measures to protect your personal information.

However, no method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

We recommend that you avoid sending sensitive information through unsecured communication channels.

## 11. Third-Party Links

Our website may contain links to third-party websites or platforms.

We are not responsible for:
- Third-party privacy practices
- External website content
- Third-party security measures

Users should review the privacy policies of external websites separately.

## 12. Children’s Privacy

Our services are not intended for individuals under the age of 18.

We do not knowingly collect personal information from children.

If you believe a child has provided us with personal information, please contact us immediately.

## 13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:
- Legal requirements
- Operational changes
- Website updates
- New services
- Regulatory obligations

Updated versions will be published on our website with the revised “Last Updated” date.

## 14. Contact Information

The Refined Luxury  
Operated by JMT Holdings LTD

Email: julia@therefinedluxury.com  
WhatsApp: +356 99781101