Privacy Policy

The Refill app and website are run by City to Sea CIC who act as the data controller in relation to the personal data submitted. City to Sea’s registered address is:

Studio 5 York Court,
Wilder Street,

V.4.1 February 2021 Edited & customised by: Lanie Sibley, Head of App Growth, City to Sea CIC, Studio 5 York Court, Wilder Street, Bristol BS2 8QH.

1. Personal Data Collected 

Depending on whether you choose to create a Refill account, are registering as a refill station and how you use the app, the following personal data may be collected:

  • name;
  • date of birth or age range;
  • gender;
  • contact information such as street addresses, email addresses and telephone numbers;
  • Facebook login details (i.e. Name and email address);
  • demographic information such as post code, preferences and interests;
  • IP address (automatically collected);
  • web browser type and version (automatically collected);
  • operating system (automatically collected);
  • a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected);
  • Cookie information (see clause 10 below); and
  • Geo-IP data designed to detect your current location.
  • In time we may ask for your postcode, this will be to ensure that local offers through our rewards-based app will be best directed to you.
  • If you do not create a Refill account and continue to use the app, any data will be logged as anonymous. 

2. How we use your personal data

We collect personal data from you for the following purposes:

  • As a Refill app user we will also use aggregated demographic information (not personal identification data) to provide insight into the activity of our users – this will be shared with third parties we work with to analyse the data.
  • As a Refill Station, we also share Data regarding Refill Stations (specifically name of premises, address and postcode) from within our Delivery Partner’s area of supply with the Delivery Partner on a monthly basis. Each of City to Sea and the Delivery Partner complies with Data Protection Legislation when Processing CTS Data.


3. Lawful basis for using personal data

We rely on the following lawful bases for using your personal data:

  • As part of our agreement with users and refill stations via our terms and conditions [], most of the uses of personal data we collect is necessary for the performance of that contract with you;
  • Where we would like to send you electronic marketing, we will always ask for your prior consent;
  • We have a legitimate interest to use high level personal data for analysis purposes to ensure the app is working effectively and to look at where we can make improvements to it.


4. Disclosures to third parties

  • Refill may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site, EXCEPT in the instance of Payment Service Providers where such data is stored by such Payment Service Provider in the interests of further protecting the integrity and security of such data. Any Data used by such parties is used only to the extent required by them to perform the services that Refill requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.
  • If, in order to send you a reward, prize or product we work with a third party, we will make it clear.


5. Changes of Business Ownership and Control

  • Refill may, in the future, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
  • In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller

6.Your rights

  • Under data protection legislation, you have a number of rights in relation to the use of your personal data. Further information in relation to your rights is available on the Information Commissioner’s Office website. If you wish to make a request in relation to any of these rights, please contact us at: [email protected] Or write to us at: Unit D, Albion Dockside Building, Hanover Place, Bristol, BS1 6UT
  • Where you have a query or complaint that we have not been able to resolve to your satisfaction, you may also make a complaint to the Information Commissioner’s Office.

7. Security

  • Refill have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data collected via our app and website. The personal data collected via use of the app is stored in a Firebase database and only accessed by a small number of people within City to Sea with a requirement to use the data. Most of the information is stored and used in a pseudonymised format with reference only to a unique identifier. We do need to retain a link to information that will identify you in order to fulfil requests to erase personal data.



 8. Retention of personal data

  • We will retain personal data for our app users and refill stations for as long as those accounts are active with us and deemed as a reasonable amount of time. If you delete your account your personal data will be deleted.
  • If you wish to request that any of your personal data collected via the Refill app be deleted, please contact us at: [email protected] Or write to us at: Unit D, Albion Dockside Building, Hanover Place, Bristol, BS1 6UT


 9. Cookies

  • This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
  • Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
  • Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
  • This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information.
  • Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.


10. Changes to this Policy

  • reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and we will notify you of such changes within a reasonable time period.