RECLAIM TIME LTD
FOCUSME (Trading Name)
PRIVACY POLICY
LAST UPDATE: November 1, 2023
Introduction.
1.1 Reclaim
Time Ltd (“Company,” or “we,” or “us,” or “our”) is committed to safeguarding
the privacy of our website and service users (“users,” or “you”).
1.2 This
policy applies where we are acting as a data controller with respect to your
personal data, in other words, where we determine the purposes and means of the
processing of that personal data.
1.3 Terms
of Service. Use of the Company Service is subject to the terms of our Terms of
Service through our online form,
which is hereby incorporated and made part of this Privacy Policy. By using the Company Service, you agree
to be bound by our Terms of Service.
1.4 Your
use of the Company Service is subject to the terms and conditions set forth in
this Privacy Policy (the “Privacy
Policy”).
PLEASE READ THIS PRIVACY POLICY CAREFULLY.
BY ACCESSING OR USING THE COMPANY SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ,
UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND
OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO
NOT ACCESS OR USE THE COMPANY SERVICE.
2.0 Personally Identifiable Information.
Personally Identifiable Information is information that identifies a specific
person. When you engage in certain activities via the Company Service,
including but not limited to creating an account, sending feedback, or
otherwise participating in the Company Service (collectively, “Identification
Activities”), we may ask you to provide certain information about
yourself. If you elect to engage in an
Identification Activity we may ask you to provide us with certain personal
information about yourself, such as your name, address (including zip code),
email address, credit card information, telephone number and/or any other
information you provide to us, to process your transaction, send communications
about them to you, and populate forms for future transactions. When you enroll in the Company Service, we
may also ask you to provide us with additional information, such as credit card
information. Depending on the Identification Activity, some of the information
we ask you to provide may be identified as mandatory and some identified as
voluntary. If you do not provide
mandatory information for an Identification Activity, you will not be permitted
to engage in that Identification Activity with the Company Service. Depending on the Identification Activity,
Company might not re-ask you for Personally Identifiable Information if such
are already stored with us. If you
enroll in the Company Service through a third party (such as Facebook or
Google) then Company may receive Personally Identifiable Information from such
third party and by using the Company Service, you consent to such receipt of
Personally Identifiable Information and its use pursuant to this Privacy Policy
by Company.
We may use or share Personally Identifiable
Information to provide products and/or services to you, administer sweepstakes
and contests, enhance the operation of the Company Service, improve our
marketing and promotional efforts, analyze use of the Company Service, improve
the Company Service, and tailor your experience with third parties as provided
below in this Privacy Policy. We may also use Personally Identifiable
Information to troubleshoot, resolve disputes, accomplish administrative tasks,
contact you, enforce our agreements with you, including our Terms of Service
and this Privacy Policy, comply with applicable law, and cooperate with law
enforcement activities.
2.1 How we use your personal data.
In
this Section 2 we have set out:
(a) the general categories of personal
data that we may process;
(b) the purposes for which we may process
personal data; and
(c) the legal bases of the processing.
2.2 We
may process data about your use of our website and services (“usage
data”). The usage data may include your IP address, geographical location,
browser type, version, operating system, referral source, length of visit, page
views and website navigation paths, and information about the timing, frequency
and pattern of your service use. If you choose that we store your application
settings and data (optional), then “usage data” may include the configuration
of our application (e.g. block lists and rules), your computer usage history
(e.g. website browsing and application usage). The source of the usage data is
our analytics tracking system, via both our desktop application and browser
extensions. This usage data may be processed for the purposes of analyzing the
use of the website and services. The legal basis for this processing is your
consent or our legitimate interests, namely monitoring and improving our
website and services.
2.3 We
may process your account data (“account data”). The account data may include your name and
email address. The source of the account data is you. The account data may be
processed for the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is
your consent or our legitimate interests, namely monitoring and improving our
website and services.
2.4 We
may process your information included in your personal profile on our website
(“profile data”). The profile
data may include your name, address, telephone number, email address, profile
pictures, gender, date of birth, interests and hobbies, educational details and
employment details. The profile data may
be processed for the purposes of enabling and monitoring your use of our
website and services. The legal basis for this processing is your consent or
our legitimate interests, namely monitoring and improving our website and
services.
2.5 We
may process information that you post for publication on our website or through
our services (“publication data”). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is your consent or
our legitimate interests, namely monitoring and improving our website and
services.
2.6 We
may process information contained in any inquiry you submit to us regarding
goods and/or services (“inquiry data”). The inquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is your consent or
our legitimate interests, namely monitoring and improving our website and services.
2.8 We
may process information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website
(“transaction data”). The transaction data may include first and last
names, an email address to be used as a login, billing contact information,
credit card number and a password. The transaction data may be processed for
the purpose of supplying the purchased goods and services and keeping proper
records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate interests.
2.9 We
may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters (“notification data”).
The notification data may be processed [for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this processing
is your consent or our legitimate interests, namely monitoring and improving
our website and services.
2.10 We
may process information contained in or relating to any communication that you
send to us (“correspondence data”). The correspondence data may
include the communication content and metadata associated with the
communication. Our website will generate
the metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis for this processing
is your consent or our legitimate interests, namely monitoring and improving
our website and services.
2.11 We
may process any of your personal data identified in this policy where necessary
for the establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of
others.
2.13 In
addition to the specific purposes for which we may process your personal data
set out in this Section 2, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
2.15 Please
do not supply any other person’s personal data to us unless we prompt you to do
so.
3. Providing your personal data to
others
3.1 Financial
transactions relating to our website and services may be handled by our payment
services providers. We will share transaction data with our payment services
providers only to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and queries
relating to such payments and refunds.
3.2 We
may disclose your inquiry data to one or more of those selected third-party
suppliers of services via APIs identified on our website for the purpose of
enabling them to connect your account with their Services. Each such third
party will act as a data controller in relation to the inquiry data that we
supply to it. Each such third party will
supply to you a copy of its own privacy policy, which will govern that third
party’s use of your personal data.
3.3 In
addition to the specific disclosures of personal data set out in this Section
3, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4. About cookies
4.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
4.2 Cookies
may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
4.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
5. Cookies that we use
5.1 We
use cookies for the following purposes:
(a) authentication – we use cookies to
identify you when you visit our website and as you navigate our website.
(b) status – we use cookies to help us to
determine if you are logged into our website.
(c) personalization – we use cookies [to
store information about your preferences and to personalize the website for
you.
(d) security – we use cookies as an
element of the security measures used to protect user accounts, including
preventing fraudulent use of login credentials, and to protect our website and
services generally.
(e) advertising – we use cookies to help
us to display advertisements that will be relevant to you.
(f) analysis – we use cookies [to help us
to analyze the use and performance of our website and services; and
(g) cookie consent – we use cookies [to
store your preferences in relation to the use of cookies more generally.
6. Cookies used by our service
providers
6.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
6.2 We
use Google Analytics to analyze the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/.
7. Managing cookies
7.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
7.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
7.3 If
you block cookies, you will not be able to use all the features on our website.
8.0 Non-Personally Identifiable
Information. Non-Personally Identifiable Information is
information that does not identify a specific person. This type of information
may include things like the Uniform Resource Locator (“URL”) of the website you
visited before coming to the Company Service or otherwise participating in the
Company Service, the URL of the website you visit after leaving the Company
Service, the type of browser you are using, your Internet Protocol (“IP”)
address, mobile carrier information, mobile device information, or general and/or
aggregated location data that does constitute Personally Identifiable
Information. We, and/or our authorized Third-Party Service Providers, may
automatically collect this information when you visit or use the Company
Service using electronic tools like Cookies and Web beacons or Pixel tags, as
described below in this Privacy Policy.
Most of the other information we collect for mobile, such as your mobile
device identification and mobile device type, the request type, your mobile
carrier, your mobile carrier user identification, and the content of your
request, does not by itself identify you to Company, though it may be unique or
consist of or contain information that you consider personal. We use
Non-Personally Identifiable Information to troubleshoot, administer the Company
Service, analyze trends, gather demographic information, comply with applicable
law, and cooperate with law enforcement activities. We may also share this
information with our authorized Third-Party Service Providers to measure the overall
effectiveness of our products and services.
9. Analytics
We continuously improve our websites and
our products, and we utilize different third-party web analytics tools to help
us do so. We are interested in how visitors use our websites, our desktop
tools, our mobile applications, what they like and dislike, and where they have
problems. Our products, desktop tools and mobile applications use analytical
tools to understand feature usage patterns, to enhance and improve your product
experience and offer you specific usage tips and guidance. In connection with
normal business operations, as well as to increase functionality and enhance
your user experience, this usage information may be linked to personal
information that we have about individual users. We maintain ownership of this
data and we do not share this type of data about individual users with third
parties.
Our mobile applications will also use
analytical tools to help gather non-personally identifiable data about download
and application usage. In our use of mobile applications, we may utilize
Geolocation data but only if you specifically opt-in to collection of such data
in connection with a particular service. We may use information such as IP
addresses to determine the general geographic locations areas of our visitors,
but this information is not correlated to personal information about individual
users. The web beacons used in conjunction with these tools may gather data
such as what browser a person uses, what operating systems are used, domain
names, MIME types, what is downloaded, and what content, products and services
are reviewed when visiting or registering for services at one of our websites
or using one of our mobile applications.
This information is used solely to assist
us in maintaining a more effective and useful websites and products for our
customers. This data will not be shared with third parties without your prior
consent or unless required by law.
10. Your rights
10.1 In
this Section 9, we have summarized the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.
10.2 Your
principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory
authority; and
(h) the right to withdraw consent.
10.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee.
10.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
10.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully process. However, there are exclusions of the right to erasure.
The general exclusions include where processing is necessary: for exercising
the right of freedom of expression and information; for compliance with a legal
obligation; or for the establishment, exercise or defense of legal claims.
10.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful, but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require
personal data for the establishment, exercise or defense of legal claims; and
you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defense of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of
important public interest.
10.7 You
have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or
defense of legal claims.
10.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
10.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
10.10 To
the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for
the performance of a contract to which you are party or in order to take steps
at your request prior to entering into a contract, and such processing is
carried out by automated means, you have the right to receive your personal
data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights
and freedoms of others.
10.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.
10.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
11. Children.
The Company Service are not directed to people
under the age of thirteen (13). If you become aware that your child has
provided us with personal information without your consent, please contact us
at the email address listed below. If we become aware that a child under thirteen
(13) has provided us with personal information, we take steps to remove such
information and terminate the child’s account.
12. Retaining and Deleting Personal Data
12.1 This Section sets out our data
retention policies and procedure, which are designed to help ensure that we
comply with our legal obligations in relation to the retention and deletion of
personal data.
12.2 Personal data that we process for any
purpose or purposes shall be kept until such time as we receive a request for
deletion from you.
12.3 Notwithstanding the other provisions
of this Section, we may retain your personal data where such retention is
necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural
person.
13. Who Can I Ask If I Have Additional
Questions?
For additional inquiries about the privacy
of your information, you can contact us by emailing us at .
14. Types of Data Collected
Our application may access, collect, use,
and share the following types of personal and sensitive user data:
14.1 Usage Data: This includes data about
when and how you use our application, which features you use, and any settings
or configurations you might change.
14.2 Device Data: Information about your
device such as operating system, device model, and unique identifiers.
14.3 Personal Identifiers: We collect your
email address and name for account creation and personalization of your
experience.
15. Data Sharing and Third Parties
We may share your personal and sensitive
data with third parties in the following circumstances:
15.1 Service Providers: We may share data
with third-party service providers that help us operate and maintain our
application.
15.2 Legal Requirements: If required by
law, we may disclose your data to authorities or third parties.
16. Secure Data Handling
We employ strict data handling and security
procedures to ensure the safety and confidentiality of your personal and
sensitive user data. This includes encryption during data transfer, secure
storage solutions, and restricted access to data.
17. Data Retention and Deletion
17.1 We retain personal data for as long as
necessary to provide our services, support your product, and fulfill the
transactions you have requested, or for other essential purposes such as
complying with our legal obligations, and resolving disputes.
17.2 If you wish to request the deletion of
your personal data, you can contact us at .
