Privacy policy
PHOX REFILL LTD
PRIVACY POLICY
Last Updated: 23 February 2026
This Privacy Policy explains how PHOX REFILL LTD (“we”, “us”, “our”) collects, uses and protects your personal data when you visit or purchase from www.phoxwater.com (the “Site”).
We are committed to protecting your privacy and handling your personal data transparently and securely.
1. Who We Are
PHOX REFILL LTD
Company No. SC844343
Registered office: Clyde Offices, 2nd Floor, 48 West George Street, Glasgow, G2 1BP
For the purposes of UK data protection law, we are the data controller of your personal data.
Contact: service@phoxwater.com
If you are not satisfied with how we handle your data, you may contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.
2. What Personal Data We Collect
A. Information You Provide
(i) Name
(ii) Billing and delivery address
(iii) Email address
(iv) Telephone number
(v) Account login details
(vi) Order and subscription history
(vii) Communications with us
B. Payment Information
Payments are processed securely through Shopify Payments and other authorised payment providers.
If you choose Klarna, your personal data will be shared with Klarna for credit assessment and payment processing in accordance with Klarna’s privacy policy.
We do not store full payment card details.
C. Technical & Usage Information
When you visit our Site, we may automatically collect:
(i) IP address
(ii) Device type
(iii) Browser type and version
(iv) Pages viewed
(v) Time spent on pages
(vi) Referral source
(vii) Interactions with advertisements
This is collected via cookies and tracking technologies.
D. Marketing & Advertising Data
If you opt in to marketing, we collect:
(i) Email address
(ii) Marketing preferences
(iii) Interaction data (e.g. email opens, clicks, website behaviour following email links)
(iv) We also use tracking technologies that allow us to:
(v) Measure advertising performance
(vi) Build custom audiences
(vii) Deliver relevant advertising
3. How We Use Your Personal Data
We process your personal data for the following purposes:
A. To:
(i) Perform Our Contract With You
(ii) Process orders
(iii) Deliver products
(iv) Manage subscriptions
(v) Process payments
(vi) Handle returns and refunds
Legal basis: Performance of contract.
B. To
(i) Provide Marketing Communications
(ii) Send newsletters
(iii) Send promotional offers
(iv) Recommend products
Legal basis: Consent.
You can unsubscribe at any time.
C. To Improve Our Website & Advertising
We use analytics tools including:
(i) Google Analytics
(ii) Meta (Facebook/Instagram) Pixel
(iii) Klaviyo tracking
These tools help us:
(i) Understand how visitors use our Site
(ii) Measure advertising effectiveness
(iii) Improve customer experience
(iv) Deliver relevant advertisements
Legal basis: Consent (for non-essential cookies).
D. Fraud Prevention & Legal Compliance
(i) Prevent fraudulent transactions
(ii) Comply with tax and regulatory obligations
Legal basis: Legal obligation and legitimate interests.
4. Advertising & Tracking Technologies
We use third-party services including:
(i) Klaviyo (email marketing and behavioural tracking)
(ii) Meta Platforms Ireland Ltd (advertising and audience matching)
(iii) Google LLC (analytics and advertising services)
(iv) Shopify Inc. (e-commerce platform hosting and analytics)
These providers may use cookies, pixels and similar technologies to:
(i) Track visits and interactions
(ii) Measure ad performance
(iii) Create custom audiences
(iv) Deliver targeted advertising
Where required by law, we obtain your consent before placing non-essential cookies.
You can manage cookie preferences via your browser settings or cookie banner.
5. International Transfers
Some service providers (including Shopify, Google and Meta) may process personal data outside the UK.
Where this occurs, we ensure appropriate safeguards are in place in accordance with UK GDPR, such as:
(i) Standard Contractual Clauses; or
(ii) Adequacy decisions.
6. Data Retention
We retain personal data only as long as necessary:
(i) Order and transaction data: up to 6 years for tax purposes
(ii) Marketing data: until consent is withdrawn
(iii) Analytics data: as determined by platform settings
7. Your Rights
Under UK data protection law, you have the right to:
(i) Access your personal data
(ii) Correct inaccurate data
(iii) Request deletion
(iv) Restrict processing
(v) Object to processing
(vi) Data portability
(vii) Withdraw consent
To exercise your rights, contact: service@phoxwater.com
You may also complain to the ICO at www.ico.org.uk.
8. Security
We implement appropriate technical and organisational security measures.
However, no system is completely secure.
9. Changes to This Policy
We may update this Privacy Policy from time to time.
The “Last Updated” date reflects the most recent update.