Privacy Policy

Refaire Inc. ("Refaire," "we," "us," or "our") provides AI-powered product support, diagnostics, troubleshooting, guided workflows, and related services for businesses and the people who use their products. This Privacy Policy explains how we collect, use, disclose, retain, and otherwise process personal information in connection with our websites, applications, AI-powered support experiences, and other products and services (collectively, the "Services").

This Privacy Policy also explains the different roles Refaire may have when processing personal information. In many cases, Refaire provides the Services to a business customer and processes information on that customer's behalf. In other cases, Refaire determines why and how personal information is processed for its own business purposes.

1. Scope and Our Role

1.1 When Refaire acts for a Business Customer

Companies, manufacturers, distributors, service organizations, and other organizations may use Refaire to provide AI-powered support experiences to their customers, employees, technicians, or other users ("Business Customers").

When you use a Refaire-powered experience provided by a Business Customer, the Business Customer generally determines the purposes and means of processing your personal information. In those circumstances, the Business Customer generally acts as the "controller," "business," or similar responsible party under applicable privacy law, and Refaire acts as its "processor," "service provider," or "contractor."

The Business Customer's privacy notice, customer agreement, or other terms may provide additional information about how that Business Customer uses your information. If you have a privacy request relating to a Refaire-powered experience provided by a Business Customer, you should generally contact that Business Customer first. Refaire will assist the Business Customer with privacy requests as required by applicable law and our agreement with the Business Customer.

1.2 When Refaire acts for its own purposes

Refaire acts as a controller or business when we determine the purposes and means of processing personal information for our own activities, such as:

  • operating our public websites and Refaire-administered applications;

  • administering Business Customer accounts;

  • managing billing, contracts, and business relationships;

  • providing customer and technical support;

  • securing, monitoring, and improving the Services;

  • communicating about our products and services; and

  • complying with legal obligations and protecting our rights.

In some cases, Refaire may provide a support experience directly under the Refaire brand. For those interactions, Refaire may act as the controller or business to the extent we determine the purposes and means of the processing.

1.3 Definitions used in this Policy

For clarity:

  • "Business Customer" means an organization that purchases, configures, deploys, or otherwise uses the Services for business purposes.

  • "Customer Content" means information, documents, product data, knowledge bases, manuals, specifications, procedures, catalogs, and other content a Business Customer or its authorized users provide to the Services.

  • "End User Content" means information an individual submits, streams, or otherwise provides through a Refaire-powered experience, including messages, images, video, audio, files, feedback, and diagnostic information.

  • "Service Data" means account, usage, device, telemetry, security, billing, support, and operational information generated through use of the Services.

2. Personal Information We Process

The information we process depends on how you interact with Refaire and how a Business Customer configures the Services.

2.1 Account and contact information

We may process:

  • name;

  • business contact information, such as email address, telephone number, job title, company, and mailing address;

  • account credentials and authentication information;

  • account settings and preferences; and

  • information you provide when requesting a demo, contacting support, communicating with us, or participating in a business relationship.

2.2 Conversation and support information

When you interact with an AI-powered support experience or other support feature, we may process:

  • questions, prompts, chat messages, and conversation history;

  • troubleshooting responses and support requests;

  • diagnostic observations and reported symptoms;

  • repair, remediation, or workflow steps;

  • recommendations and results;

  • feedback, ratings, corrections, and whether a recommended resolution was successful; and

  • communications with Refaire, a Business Customer, or support personnel.

2.3 Images, video, and audio

Depending on the features you use, we may process images, video, audio, or other media that you choose to submit or stream to the Services. This may include:

  • photographs or video of products, equipment, components, installations, defects, damage, error messages, or surrounding context;

  • voice input;

  • equipment sounds or other audio used for diagnostic purposes; and

  • metadata associated with submitted media.

Media may incidentally contain personal information, such as a person's image, voice, home or workplace surroundings, documents visible in the background, or information displayed on a screen. You should avoid including unnecessary personal or sensitive information in media you submit.

Camera and microphone access is subject to your device or browser permissions. You can generally change those permissions through your device or browser settings.

2.4 Product, technical, and diagnostic information

We may process information such as:

  • product name, model, SKU, serial number, configuration, or version;

  • component, part, bill-of-materials, or compatibility information;

  • warranty, maintenance, repair, or service history, where provided;

  • error codes, symptoms, operational conditions, or performance information;

  • diagnostic classifications, detected conditions, likely causes, and recommended actions; and

  • other technical information needed to provide the Services.

2.5 AI-generated information and inferences

The Services may generate or derive information from inputs and other available context, including:

  • product or component classifications;

  • likely faults, defects, symptoms, or causes;

  • troubleshooting recommendations;

  • repair or remediation steps;

  • product or part recommendations;

  • confidence signals or other system-generated assessments; and

  • summaries, structured records, or other inferences used to provide or evaluate the Services.

2.6 Device, usage, and network information

We may automatically collect or generate:

  • IP address;

  • browser type and settings;

  • device type, operating system, and device identifiers;

  • approximate location derived from IP address;

  • pages or features viewed or used;

  • dates, times, frequency, and duration of activity;

  • referring and exit pages;

  • application and system logs;

  • performance and error information; and

  • security, fraud-prevention, and authentication data.

2.7 Payment and transaction information

If you purchase Services directly from Refaire, we may process billing contact information, subscription details, invoices, payment status, and limited payment-related information. Payment card information may be processed by our payment processor rather than stored directly by Refaire.

2.8 Information from Business Customers and other sources

We may receive personal information from:

  • Business Customers and their authorized users;

  • systems integrated with the Services, such as customer support, CRM, commerce, warranty, product, or service systems;

  • authentication providers;

  • payment processors;

  • analytics and security providers;

  • business partners; and

  • publicly available or lawfully obtained business information.

3. How We Use Personal Information

Depending on our role and the applicable context, we may use personal information to:

3.1 Provide and operate the Services

  • create and administer accounts;

  • authenticate users;

  • deliver AI-powered product support and diagnostic experiences;

  • analyze product issues, images, video, audio, text, and technical data;

  • generate troubleshooting, repair, product, part, or workflow recommendations;

  • maintain conversation and support history;

  • provide requested integrations and functionality;

  • process transactions and administer subscriptions;

  • provide support and respond to requests; and

  • perform obligations under our agreements.

3.2 Secure and maintain the Services

  • detect, prevent, investigate, and address fraud, abuse, security incidents, and technical problems;

  • maintain system reliability, availability, and performance;

  • debug and repair errors;

  • authenticate users and manage access;

  • enforce contractual and platform rules; and

  • protect Refaire, our Business Customers, end users, and others.

3.3 Evaluate and improve the Services

Subject to applicable law and our agreements with Business Customers, we may use information to:

  • measure performance and usage;

  • evaluate the accuracy, safety, and usefulness of AI outputs;

  • test and improve product features and workflows;

  • improve retrieval, classification, diagnostic, and recommendation systems;

  • develop new features and services; and

  • conduct quality assurance, research, and analytics.

Our use of Customer Content and End User Content for AI model training or generalized model improvement is described in Section 4.

3.4 Communicate and manage our business

Where Refaire acts for its own purposes, we may use personal information to:

  • manage Business Customer relationships;

  • provide administrative, security, product, and policy notices;

  • respond to inquiries and support requests;

  • send marketing communications where permitted by law;

  • plan and operate business events;

  • manage contracts, invoicing, and accounting;

  • conduct business analytics; and

  • evaluate corporate transactions or business opportunities.

3.5 Comply with law and protect legal interests

We may use personal information to comply with applicable law, legal process, regulatory requirements, and lawful requests; establish, exercise, or defend legal claims; enforce our agreements; protect safety and rights; and prevent unlawful or harmful activity.

4. How Refaire Uses AI and Data for Model Improvement

Refaire uses artificial intelligence and related computational systems to analyze information and generate product-support outputs. Depending on the feature and Business Customer configuration, AI systems may process text, images, video, audio, product information, technical data, retrieved knowledge, or other context.

4.1 AI-generated outputs

AI-generated outputs may include product identification, diagnostic assessments, likely causes, troubleshooting steps, repair guidance, recommended parts or products, summaries, classifications, and other support information.

AI outputs may be incomplete or inaccurate and should be evaluated in light of the product, circumstances, safety requirements, and any instructions provided by the applicable manufacturer or Business Customer. Refaire's Services are not intended to replace qualified professional judgment where professional evaluation is appropriate.

4.2 Customer data and generalized model training

Subject to applicable law and our agreements, Refaire may use:

  • de-identified or aggregated information;

  • performance measurements and quality signals;

  • corrections and feedback;

  • synthetic or derived data that is not reasonably capable of identifying an individual; and

  • information a Business Customer has expressly authorized for such use,

to evaluate and improve the Services, including AI systems, retrieval systems, diagnostic models, workflows, and safety mechanisms.

Where Refaire uses de-identified information, we maintain it in de-identified form and do not attempt to reidentify it except as permitted or required by law.

4.3 Customer-specific improvement

A Business Customer may instruct or authorize Refaire to use that customer's data to configure, evaluate, fine-tune, or improve customer-specific functionality. Such processing is governed by our agreement with the Business Customer and applicable law.

4.4 Third-party AI and infrastructure providers

We may use third-party providers to support cloud infrastructure, AI or model inference, transcription, storage, security, observability, and related functionality. These providers may process information on our behalf subject to contractual, technical, and organizational protections. Where Refaire acts as a processor, our use of subprocessors is subject to our agreement with the applicable Business Customer.

5. How We Disclose Personal Information

We may disclose personal information as described below.

5.1 Business Customers

If you use a Refaire-powered experience provided by a Business Customer, information from your interaction may be made available to that Business Customer. Depending on the configuration and purpose of the experience, this may include:

  • messages and conversation history;

  • images, video, audio, and files you submit;

  • product and diagnostic information;

  • AI-generated classifications, recommendations, and summaries;

  • troubleshooting or repair outcomes;

  • feedback; and

  • associated usage and session information.

The Business Customer may use that information for customer support, service administration, product improvement, warranty or repair operations, analytics, quality assurance, or other purposes described in its own privacy notice and terms.

5.2 Service providers and subprocessors

We may disclose information to vendors and service providers that support functions such as:

  • cloud hosting and data storage;

  • AI and model infrastructure;

  • transcription and media processing;

  • security, authentication, and fraud prevention;

  • observability, logging, and performance monitoring;

  • analytics;

  • communications and customer support;

  • payment processing;

  • professional services; and

  • other infrastructure required to provide the Services.

These providers are permitted to process information only for authorized purposes and subject to applicable contractual obligations.

5.3 Integrations and third-party services

If a Business Customer or user enables an integration or directs us to interact with a third-party service, we may disclose information to that service as necessary to provide the requested functionality. The third party's processing is governed by its own terms and privacy practices where it acts independently.

5.4 Legal, safety, and rights-related disclosures

We may disclose information when we reasonably believe disclosure is necessary or appropriate to:

  • comply with applicable law, regulation, legal process, or lawful government request;

  • protect the rights, property, safety, or security of Refaire, our Business Customers, end users, or others;

  • enforce agreements and policies;

  • detect, investigate, or prevent fraud, security incidents, abuse, or unlawful activity; or

  • establish, exercise, or defend legal claims.

5.5 Corporate transactions

Information may be disclosed or transferred in connection with a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to applicable law and contractual restrictions.

6. Cookies, Analytics, and Marketing Technologies

We may use cookies, pixels, local storage, and similar technologies on our public websites and other Refaire-controlled online properties to operate the Services, remember preferences, understand usage, measure performance, secure the Services, and support business-to-business marketing.

We do not use Customer Content or End User Content submitted through a Business Customer's Refaire-powered support experience for cross-context behavioral advertising or targeted advertising.

Some analytics or marketing technologies used on our public websites may involve disclosures that are considered a "sale," "sharing," or targeted advertising under certain U.S. state privacy laws even when no money is exchanged. Where required by applicable law, we provide mechanisms to opt out of such processing and recognize applicable browser-based opt-out preference signals, such as Global Privacy Control.

You can also control many cookies through your browser settings. Disabling certain cookies may affect functionality.

7. No Sale of Customer or End User Content

Refaire does not sell Customer Content or End User Content for monetary consideration.

Refaire does not use Customer Content or End User Content from Business Customer support experiences to build advertising profiles about individuals or to target advertisements to them across unrelated services.

This section does not prevent Refaire from using service providers or subprocessors to provide the Services, from disclosing information at a Business Customer's direction, or from processing de-identified or aggregated information as described in this Policy and our agreements.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, as required by our agreements, or as required or permitted by law.

8.1 Customer Content and End User Content

Where Refaire processes Customer Content or End User Content on behalf of a Business Customer, retention is generally governed by the Business Customer's configuration, instructions, and agreement with Refaire. At the end of the applicable relationship, Refaire will delete or return Customer Content as required by the applicable agreement, subject to limited exceptions such as legal obligations, security requirements, dispute preservation, and backup retention.

8.2 Refaire-controlled information

For information Refaire processes for its own purposes, retention periods depend on factors such as:

  • the length of our relationship with you or the Business Customer;

  • the type, sensitivity, and volume of the information;

  • the purposes for which it was collected;

  • security, fraud-prevention, and operational needs;

  • contractual commitments;

  • applicable statutes of limitation; and

  • legal, regulatory, tax, accounting, or reporting obligations.

Residual copies may remain in backups for a limited period before being overwritten or deleted in accordance with our backup processes.

De-identified or aggregated information that is not personal information may be retained for longer periods.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure. Depending on the context, these safeguards may include access controls, encryption, logging, authentication controls, security monitoring, and logical separation of Business Customer data.

No security measure can guarantee absolute security. You are responsible for protecting your credentials and for using the Services in accordance with applicable security instructions.

Where Refaire processes information on behalf of a Business Customer, additional security commitments may be described in our agreement with that Business Customer.

10. Your Privacy Choices and Rights

Depending on where you live and applicable law, you may have rights to:

  • access or obtain a copy of your personal information;

  • correct inaccurate personal information;

  • delete personal information;

  • obtain a portable copy of certain information;

  • object to or restrict certain processing;

  • withdraw consent where processing is based on consent;

  • opt out of certain sales, sharing, targeted advertising, or profiling;

  • limit certain uses of sensitive personal information where applicable;

  • obtain information about certain automated decision-making practices where applicable;

  • appeal a denial of a privacy request where provided by law; and

  • lodge a complaint with an applicable regulator or supervisory authority.

These rights are subject to legal limitations and exceptions.

10.1 Requests relating to a Business Customer's Refaire-powered experience

If your request concerns personal information processed by Refaire on behalf of a Business Customer, please submit your request to that Business Customer. Because the Business Customer generally controls that information, Refaire may refer or forward your request to the Business Customer and will assist it as required by law and contract.

10.2 Requests relating to Refaire-controlled information

To submit a request concerning information for which Refaire acts as controller or business, contact:

privacy@refaire.ai

We may need to verify your identity before completing a request. Where permitted by law, you may use an authorized agent. We will not discriminate against you for exercising applicable privacy rights.

11. Additional U.S. State Privacy Disclosures

Residents of certain U.S. states may have additional rights under comprehensive state privacy laws. This section applies only to the extent the relevant law applies to Refaire and the processing at issue.

The categories of personal information we may collect are described in Section 2. The sources of that information are described throughout Section 2, and the business and commercial purposes for processing are described in Sections 3 and 4. The categories of recipients are described in Section 5.

We do not sell Customer Content or End User Content for monetary consideration. We do not use Customer Content or End User Content from Business Customer support experiences for targeted advertising.

With respect to Refaire's public websites, some analytics or marketing technology disclosures may be treated as "sale," "sharing," or targeted advertising under certain state privacy laws. Where applicable, you may opt out using our cookie or privacy controls, and we will process recognized opt-out preference signals such as Global Privacy Control as required by law.

If we deny a privacy request and applicable law provides a right to appeal, our response will explain how to submit an appeal.

11.1 California

If the California Consumer Privacy Act, as amended ("CCPA"), applies to Refaire and the relevant processing, California residents may have rights to know/access, correct, delete, obtain information about categories of collection and disclosure, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive non-discriminatory treatment for exercising their rights.

Refaire does not knowingly sell or share personal information of individuals under 16 for cross-context behavioral advertising.

Where required, Refaire will honor valid opt-out preference signals for sale or sharing.

12. European Economic Area, United Kingdom, and Switzerland

This section applies to the extent the General Data Protection Regulation, UK GDPR, Swiss data protection law, or similar applicable law applies.

12.1 Controller and processor roles

Where Refaire provides Services on behalf of a Business Customer, Refaire generally processes personal data as a processor and the Business Customer is responsible for determining the lawful basis for processing and providing required notices to end users.

Where Refaire processes personal data for its own purposes, Refaire acts as controller.

12.2 Legal bases

Where Refaire acts as controller, we process personal data based on one or more of the following legal bases, as applicable:

  • Contract: processing necessary to enter into or perform a contract with you.

  • Legitimate interests: processing necessary for legitimate interests such as operating, securing, supporting, improving, and marketing our business, provided those interests are not overridden by your rights and interests.

  • Consent: where we ask for and receive your consent.

  • Legal obligation: where processing is necessary to comply with law or legal obligations.

  • Protection of rights: where processing is necessary to establish, exercise, or defend legal claims or protect vital or important interests as permitted by law.

12.3 EEA/UK/Swiss privacy rights

Subject to applicable law, you may have rights to access, rectify, erase, restrict, object to processing, receive data portability, withdraw consent, and lodge a complaint with a competent supervisory authority.

Where processing is based on our legitimate interests, you may have the right to object based on your particular situation. Where personal data is processed for direct marketing, you may object at any time.

12.4 Automated processing

The Services use AI and automated systems to generate product-support outputs and recommendations. These outputs generally are intended to support product diagnosis, troubleshooting, repair, product selection, quality workflows, or related assistance and are not intended by Refaire to make decisions that produce legal or similarly significant effects about an individual.

If a Business Customer configures or uses the Services in a context involving legally regulated automated decision-making or significant decisions about individuals, that Business Customer is responsible for determining the applicable legal requirements, notices, lawful basis, and end-user rights, and Refaire will provide processor assistance as required by applicable law and contract.

13. International Data Transfers

Refaire is based in the United States, and we and our service providers may process personal information in the United States and other countries.

Where applicable law requires a legal mechanism for an international transfer, we use recognized safeguards as appropriate, which may include adequacy decisions, Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Addendum or other recognized UK transfer mechanisms, or other lawful transfer safeguards.

Where Refaire acts as a processor, international transfer terms may also be addressed in our data processing agreement with the applicable Business Customer.

14. AI Transparency

Refaire-powered experiences may use artificial intelligence to interact directly with individuals and generate responses, recommendations, or other outputs.

Where required by applicable law, Refaire and/or the applicable Business Customer will provide notice that an individual is interacting with an AI system. Refaire may provide product-level features designed to support Business Customers in meeting applicable AI transparency obligations.

The applicable Business Customer remains responsible for notices and disclosures required by law for its deployment and use of the Services, except to the extent Refaire has an independent legal obligation as a provider.

15. Children's Privacy

Refaire's business and administrator accounts are intended for adults and authorized business users.

Refaire-powered product-support experiences are not directed to children under 13, or a higher minimum age where required by applicable law. We do not knowingly collect personal information from children in violation of applicable law.

A Business Customer may impose additional age restrictions or requirements for its own products or support experiences. If you believe a child has provided personal information to Refaire in a manner that violates applicable law, contact privacy@refaire.ai. If the information was processed on behalf of a Business Customer, we may coordinate with that Business Customer to address the request.

16. Third-Party Services and Links

The Services may contain links to or integrations with websites, applications, and services operated by third parties. Where a third party processes information for its own purposes, its privacy practices are governed by its own privacy notice, not this Privacy Policy.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, data practices, legal requirements, or other circumstances. When required by law, we will provide notice of material changes and obtain consent where required.

The "Last updated" date at the top of this Policy indicates when it was most recently revised.

18. Contact Us

For questions about this Privacy Policy or Refaire's privacy practices, or to exercise applicable rights concerning information for which Refaire acts as controller or business, contact:

Refaire Inc.

Email: privacy@refaire.ai

If your request relates to a Refaire-powered experience offered by another company, please contact that company first. We will assist the applicable Business Customer as required by law and contract.