Privacy Policy

1. Who We Are

Controller: Refine Development Inc.

Contact: info@refine.dev

Refine provides an AI-powered development and configuration platform. Refine does not host, deploy, or operate customer applications or production environments.

2. Scope of This Policy

This Privacy Policy applies to personal data processed by Refine in connection with providing the Services.

It does not apply to:

• Applications, websites, or services built using Refine and deployed by customers in their own environments
• End-user data processed by those applications

Customers are solely responsible for the privacy practices of applications they deploy.

3. Personal Data We Collect

Depending on how you use the Services, we may process the following categories of personal data:

3.1 Account and Contact Information

• Name
• Email address
• Account identifiers
• Billing and subscription information

3.2 Usage and Technical Data

• Log data
• IP address
• Device and browser information
• Usage metadata (features used, timestamps, error logs)

3.3 Content Submitted to the Service

Content you submit to the Services may include:

• Prompts, instructions, or configuration inputs
• Generated code, text, or other AI outputs
• Application metadata and project artifacts

Important: Such content may contain personal data depending on how you use the Services. We recommend that you do not submit sensitive or special category personal data (as defined under GDPR) unless strictly necessary.

4. How We Use Personal Data

We process personal data for the following purposes:

• To provide, operate, and maintain the Services
• To authenticate users and manage accounts
• To provide customer support
• To monitor performance, security, and abuse
• To improve and develop the Services
• To develop, test, and improve Refine's artificial intelligence and machine learning systems (subject to opt-out rights described below)
• To comply with legal obligations

5. Artificial Intelligence and Model Training

5.1 AI Processing

Refine uses artificial intelligence technologies to generate outputs based on user inputs. This may involve processing prompts, configurations, and related metadata.

5.2 Model Improvement and Training

Unless you opt out as described below, Refine may use Customer Content and AI Output:

• To improve the functionality, reliability, and quality of the Services
• To develop, test, and train Refine's proprietary AI and machine learning models

Where feasible, Refine applies aggregation, anonymization, or de-identification techniques when using data for these purposes.

5.3 Opt-Out of Model Training

You may opt out of having your Customer Content used for AI model development, testing, or training by:

• Contacting Refine support, or
• Upgrading to an Enterprise plan that provides enhanced data-handling controls

Opting out will not affect your ability to use the core functionality of the Services, although certain advanced or enterprise-level features may require a paid plan.

6. Legal Bases for Processing (GDPR)

Where the GDPR applies, Refine relies on the following legal bases:

• Contract: To provide and operate the Services
• Legitimate Interests: To secure, maintain, and improve the Services, including AI model improvement (balanced against user rights and subject to opt-out)
• Consent: Where required (e.g., certain cookies or communications)
• Legal Obligation: To comply with applicable laws and regulations

7. Third-Party Service Providers

We use trusted third-party service providers to operate and improve the Services, including:

• Cloud infrastructure providers
• AI and machine learning service providers
• Analytics and monitoring providers
• Payment and billing processors
• Customer support tools

These providers process personal data only on our instructions and for the purposes described in this Policy.

Refine does not provide hosting or runtime infrastructure for customer applications.

User-Directed Integrations

The Services may allow you to connect to third-party services or platforms, such as databases, hosting providers, or deployment platforms, at your discretion.

When you choose to connect or deploy to third-party services (for example, database providers or deployment platforms), any data processed by those services is governed by their respective privacy policies and terms. Refine does not control, operate, or assume responsibility for such third-party services, and does not process runtime or end-user data from deployments made to those platforms.

Refine acts solely as a technical intermediary to facilitate user-initiated connections and does not independently collect or use data processed by third-party services selected by users.

8. International Data Transfers

Refine is based in the United States. Personal data may be transferred to and processed in countries outside your jurisdiction, including the United States.

Where required by law, we rely on appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Other lawful transfer mechanisms

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy:

• Account data: retained while your account is active
• Usage logs and technical data: retained for a limited period for security and operational purposes
• Customer Content: retained in accordance with account settings and deletion requests
• Backup data: retained for a limited time before deletion or anonymization

Retention periods may vary depending on legal and operational requirements.

10. Your Rights

Depending on your location, you may have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request deletion of your data
• Object to or restrict processing
• Request data portability
• Withdraw consent where processing is based on consent
• Lodge a complaint with a data protection authority

To exercise your rights, contact us at info@refine.dev.

11. Security

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. However, no system is completely secure.

12. Children's Privacy

The Services are not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated via email or prominent notice before becoming effective.

14. Contact Us

If you have any questions about this Privacy Policy or our data practices, contact us at:

Refine Development Inc.

📧 info@refine.dev