Privacy Policy

1. Refundit App Privacy Policy

Refundit (“Refundit”, “Company” “we” or “us”) respects the privacy of the users of the App (“User” or “you”), and is committed to protecting the personal data that Users share with it. We believe that you have a right to know our practices regarding the personal data we may collect and use when you use App. In case you have any further questions you can always contact our data protection officer (DPO) via support@refundit.tax. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at refundit.tax/terms-and-conditions (“TOU”), into which this Privacy Policy is incorporated thereto by reference

2. Who are we?

Refundit develops and manages the App.

• Refundit as a “data controller” First, Refundit acts as a service provider towards you. Via the App, we assist you with the filing of a digital VAT refund request with a local tax authority and provide you with the refund when granted by the local tax authority. In this respect, Refundit is responsible for the processing of personal data collected via the App.
• Refundit as a “data processor” Second, Refundit acts as a service provider towards the local tax authorities (data controller). The personal data you provide to us via the App will be included in databases to which the local tax authorities will have access to facilitate and support the exercise of their public task and authority. These databases will be managed in accordance with the instruction we receive from the local tax authorities as data controller.

3. Your Consent (PLEASE READ CAREFULLY!)

By installing the app on your mobile device, entering into, connecting to, accessing and/or using the app, you agree to the terms and conditions set forth in this privacy policy (the “privacy policy”), including to the collection and processing of your personal information (as defined below). If you disagree to any term provided herein, you may not install, access and/or use the app and you are requested to promptly uninstall the app from your mobile device. For avoidance of doubt, you hereby consent to the collection, processing, transfer and use of your personal information. You also acknowledge and confirm that you are not required to provide us with your personal information and that such information is voluntarily provided to us.

4. Which personal data do we collect?

We only collect the personal data you provide us with via the App. This includes:

• identification data: surname, fi rst name, full home address, e-mail address, phone number;
• account data: log-in and (encrypted) password
• logs relating to access and use of the app
• photo of the passport (including full name, birth date and birthplace, nationality, passport number, national ID number, country and date of issuance/expiry of the passport and other information mentioned on the passport)
• travel data: date and time of arrival and departure from EU, photo of the outbound boarding pass;
• information on the purchased product: photo of the receipt, price, VAT, type of product, store of purchase, date of purchase and other information possibly included on the purchase voucher;
• electronic localisation data: location at the time of taking the photograph of the receipt in order to verify whether the user of the mobile application is physically in the store, location at the time of confirmation of homecoming;
• IP-address and unique device identifier;
• financial specificities: bank account number, PayPal account information;

In order to have access to the location data and camera of your mobile device, a specific authorization is requested via pop-up screens. Without the provision of the personal data above, you cannot make use of the App. In addition to the above categories of personal data, we may process any other type of personal data you voluntarily provide to us, as well as the information we deduce or generate in this context.

5. How Do We Collect Information on Our Users?

There are two main methods we use: A. We collect information through your entry, connection, installation, access and/or use of the App. In other words, when you are using the App we are aware of it and may gather, collect and store the information relating to such usage. For example, when you are using the App we collect data produced by your device, such as your geo-location. B. We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account and when you fill out our refund request. We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below. We collect such data in this manner in order to achieve the purposes set forth in this Privacy Policy.

6. What do we use personal data for?

We use your personal data for the following purposes:

• Providing the service of filing a digital VAT refund request and receiving VAT refunds.
• Technical assistance and support.
• Support and facilitate the local tax authorities in exercising their public tasks.
• Maintain and improve Refundit’s services, enhance and improve the User’s experience while using the App, learn about the preferences of Users and general trends on and uses of the App.
• Contact Users with updates, new features, or other news about the Refundit app or similar services or products offered by us (including by way of newsletter).
• Send push notifications to the User’s device after the User has agreed to accept push notifications from us. Users can deactivate push notification by changing their settings within our App.
• Verify the User’s identity when he/she signs in to the App, as well as verifying User’s identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our App.
• Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our App’s Users as well as in order to safeguard our App.
• Take security, fraud prevention, and money laundering prevention measures.
• If you have consented thereto, send direct marketing messages to the Users relating to third party services or products, monitor the behaviour of User for advertising purposes, commercialise or sell personal data of the Users to / with potential business partners or third parties.

Your bank account details are only collected for the purpose of performing a refund payment. We process your personal data based on one of the following legitimate grounds:

• The processing is necessary to provide you with the services you request us to offer via the App;
• The processing is necessary for the purposes of the legitimate interests pursued by Refundit or by a third party, such as:
• The good execution and continuation of our activities and the broadening or improvement of our services;
• The information and communication towards our contractual relations of the products and services of Refundit that we consider relevant taking into consideration of their previous purchases/sales or requests;
• The protection of our organization, our activities and our partners;
• The processing is necessary for compliance with our legal obligations;
• You have consented to the processing.

7. Whom do we share your personal data with?

Refundit may engage sub-contractors (“data processors”) with respect to the processing of your personal data (e.g. cloud storage providers, IT service providers). Refundit ensures to only engage sub-contractors providing sufficient guarantees towards the lawful processing and security of your personal data. As explained above, Refundit shares your personal data with local tax authorities in order to enable them to review you digital VAT refund request and to facilitate and support the exercise of their public task and authority. Refundit also shares your personal data with payment service providers in order to transfer an awarded refund in accordance with your instructions. Refundit may share your Personal Data with any entities affiliated to Refundit. We may also need to transfer your personal data to other recipients such as public authorities, enforcement authorities, public prosecutors and courts, our attorneys, advisors or other services providers, auditors or other third parties, if we estimate in good faith that such disclosure is reasonably necessary or useful (e.g. in order for us to comply with a legal obligation or procedure, in the context of a merger, acquisition or reorganization of our company or group, to broaden or improve our activities, to protect our rights and interests or the security and safety of our organization, our infrastructure, our activities, our clients, partners or the public, fully taking into account our obligations under the applicable personal data protection laws. In this respect, Refundit will transfer your Personal Data across borders. For transfers outside of the European Economic Area, Refundit will ensure an adequacy decision by the European Commission is in place for the recipient country or organisation, or that appropriate or suitable safeguards are in place, a copy of which can be obtained by contacting Refundit at support@refundit.tax.

8. Payment

We provide VAT Refunds either by bank transfers or by using our Online Payment Processors, such as PayPal, which enable Users to receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. Refundit is not affiliated with such Online Payment Processors, as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

9. Your rights with respect to your personal data

You have the right to request access to your personal data and to request information about the processing of your personal data. You have the right to have inaccurate personal data rectified and to request the deletion of your personal data. You have the right to object to the processing of your personal data or to have the processing restricted. You have the right to stop using the services of Refundit at any time and ask for the termination of your account. Please note that as from the date of termination, you will no longer be able to access your account. You have the right to request a copy of the personal data you have provided us with, to receive this in a structured manner and to request us to transfer your personal data to another controller. You can exercise all rights as described above by sending an e-mail to support@refundit.tax. Please attach a copy of your passport or other suitable form of identity proof to your request, enabling us to verify your identity in order to prevent unlawful access to your personal data. We will answer to your request in accordance with the legal conditions of these rights within a period of one month. If you are of the opinion that your privacy rights have not been respected, you can file also file a complaint with the competent supervisory authority of your choice. You can exercise all rights described above without any charge.

10. Automated decision-making

As some refund requests are handled automatically (i.e. without human intervention / no check by an officer of the local tax authority), it is possible that you will be subject to a decision based solely on automated processing. At the time of the creation of your account, you will need to consent to such possible automated decision-making in order to be able to use the App. You can at any time request that an officer of the local tax authority individually reviews the acceptance or refusal of a refund request by sending an e-mail to support@refundit.tax.

11. Deletion or Modification of Personal Information

If for any reason you wish to delete your Account, to update or modify your Personal Information included in your Account and/ or change your e-mail address please send us an e-mail with adequate detail of your request to: support@refundit.tax, and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain and use your Personal Information after termination of your Account, for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms and/or to enable the User to reinstate his/her Account, all as permitted under any applicable privacy laws. Aggregate and/or anonymous information derived from your Account and/or use of the App may remain on Refundit’s servers indefinitely.

12. Minors

The App is intended for Users over the age of eighteen (18). Therefore, Refundit does not intend and does not knowingly collect personal data from minors under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the App. If we learn that we collected personal data from minors under the age of eighteen (18) we will delete that personal data as quickly as possible. Please contact Refundit at support@refundit.tax if you have reasons to suspect that Refundit collected personal data from minors under the age of eighteen (18) and we will delete that data as quickly as possible.

13. How do we safeguard data?

We take reasonable measures to maintain the security and integrity of our App and collected personal data and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your personal data is hosted on servers which provide advanced strict security standards (both physical and logical). Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal data will never occur. REFUNDIT SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

14. Third Party Service Providers

We may be using third party software or service in order to collect, host, store and/or process the information detailed herein. Refundit uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such software includes without limitation PayPal which privacy policy can be found at www.paypal.com/en/webapps/mpp/ua/privacy-full. Please note that Refundit does not control such third-party service providers. Please read their terms of use and privacy policies to understand their privacy practices.

15. International Data Transfer

We transfer information collected about you, including Personal Information, to affiliated entities, or to other third-party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

16. Links to Third Party Websites

Certain links provided permit our Users to leave this App and enter non-Refundit sites or services. Please note that our privacy notice does not apply for the processing of personal data done on these sites or services. We advise our Users to carefully read the privacy notices of the concerned sites or services to be informed about the processing of their personal data on such sites or services.

17. Direct Marketing

If you no longer wish to receive our direct marketing messages, you can send an e-mail to support@refundit.tax or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you. You hereby agree that we may use your contact details you provided us with (including, without limitation, email address) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services. You may withdraw your consent by sending a written notice to support@refundit.tax or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

18. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App and any personal data collected with respect thereto. Refundit reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the App and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with.