Privacy policy

Last Updated: 29/07/2026

This Privacy Policy explains how The Refined Luxury Trading LLC ("TRL", "we", "our", "us") collects, uses, and protects your personal data when you use our website or client portal, purchase products, book services, subscribe to a membership, enrol an item in Royale, or otherwise engage our services. We act as a data controller.

We process personal data in accordance with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) ("PDPL"). Where we process the personal data of individuals resident in the European Economic Area, we also comply with Regulation (EU) 2016/679 ("GDPR") to the extent applicable.

1. Who We Are

The Refined Luxury Trading LLC

For any privacy matter, contact us at info@therefinedluxury.com with the subject line "Data Request."

2. Data We Collect

  • Identity and contact data — name, email address, phone number, postal address, and identification details where required for high-value transactions or Royale enrolment.
  • Account data — your portal login credentials (stored securely) and account preferences.
  • Item and service data — descriptions, serial or reference numbers, photographs, condition reports, and service history of items submitted to us.
  • Transaction and financial data — orders, quotes, invoices, membership and Royale records, consignment and resale records, and payment history. We do not store full payment card numbers; card payments are processed by Stripe.
  • Communications data — correspondence with us via email, WhatsApp, phone, or the portal.
  • Usage and device data — information collected automatically through cookies and similar technologies, as described in our Cookie Policy.

3. How We Use Your Data & Legal Basis

Purpose Legal basis
Providing products, services, the portal, memberships, and Royale; processing payments; issuing quotes and invoices; managing consignment and resale Performance of a contract
Complying with UAE VAT, AML, and commercial record-keeping obligations Legal obligation
Managing client relationships, securing our systems, preventing fraud, maintaining item and service records Legitimate interests
Sending direct marketing (new arrivals, offers, events) Consent

Transactional communications necessary to deliver your service — quotes, invoices, service and status updates, renewal reminders, collection and delivery notifications — are sent as part of performing our contract with you and do not require separate marketing consent.

4. Marketing

We only send direct marketing to clients who have explicitly opted in. You may withdraw consent at any time by using the unsubscribe link in any marketing email, replying STOP to a marketing SMS or WhatsApp, or contacting info@therefinedluxury.com. Withdrawing marketing consent does not affect transactional communications. We do not sell, rent, or share your contact data with third parties for their own marketing.

5. Service Providers (Processors)

We share personal data with trusted providers who process it on our behalf under appropriate data-processing agreements, including:

  • Supabase — secure database and authentication infrastructure.
  • Stripe — payment processing.
  • Resend — transactional and (where consented) marketing email delivery.
  • Zoho — accounting, invoicing, and VAT records.
  • Application and hosting providers — for operating the website and portal.
  • Communication tools — such as WhatsApp, for client correspondence.
  • Analytics providers — where enabled, as described in our Cookie Policy.

Each provider is required to maintain the confidentiality and security of your data and to process it only as instructed.

6. International Transfers

Some providers process data on servers located outside the UAE. Where personal data is transferred internationally, we ensure appropriate safeguards are in place in accordance with applicable law.

7. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure — including access controls, encrypted connections, role-based staff access on a need-to-know basis, and secure storage of documents and photographs.

8. Data Retention

We retain personal data only for as long as necessary for the purposes it was collected, or as required by law:

Data Category Retention Period
Client contact and identity records Duration of relationship + 3 years after last interaction, or until a valid erasure request
Transaction records (orders, quotes, invoices, memberships, Royale) 7 years from the date of transaction
Payment records 5 years from the date of payment
Item records, photographs, and condition reports Duration of relationship + 5 years
Authentication records 7 years from the date of assessment
Consignment and Royale agreements 7 years from the date of execution
Marketing consent records Until withdrawal of consent + 1 year

Where you request erasure and we are legally required to retain certain records (for example, VAT invoices), we delete all data not subject to a mandatory retention obligation and inform you in writing of what is retained and why.

9. Your Rights

Subject to applicable law, you have the right to: access your data; request correction of inaccurate data; request erasure; restrict processing; data portability; and object to processing based on legitimate interests, including direct marketing. To exercise any right, contact info@therefinedluxury.com with the subject line "Data Request." We will respond within 30 days. EEA residents may lodge a complaint with their local data protection supervisory authority.

10. Children

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18.

11. Changes to This Policy

We may update this Policy from time to time. The version in force is the one published on our website or portal, identified by the "Last Updated" date above.