隐私政策

Reclaim Time Ltd (FocusMe) – Last updated: June 18, 2026

1. Introduction

1.1 Reclaim Time Ltd (“Company,” or “we,” or “us,” or “our”) commits to safeguarding the privacy of our website and service users (“users,” or “you”).

1.2 This policy applies where the company acts as data controller regarding personal data – determining purposes and means of processing.

1.3 Company service usage is subject to our Terms of Service, which are incorporated into this Privacy Policy. Use signifies agreement to both documents.

1.4 Service usage is subject to terms and conditions set forth in this Privacy Policy.

This policy requires users to read carefully and acknowledge understanding. If you disagree, you should exit and not access the service.

2. Personally Identifiable Information

2.0 Personally Identifiable Information identifies specific persons. During “Identification Activities” (account creation, feedback, participation), the company may request personal information including name, address, zip code, email, credit card information, and telephone number. Some information is mandatory; some voluntary. Information not provided may prevent activity completion.

The company may receive personal data from third parties (Facebook, Google) when users enrol through them.

Uses: Provide products/services, administer sweepstakes, enhance operations, improve marketing, analyse usage, tailor experiences, troubleshoot, resolve disputes, contact users, enforce agreements, comply with law, and cooperate with law enforcement.

2.1 How Personal Data Is Used

Section 2.1 outlines general categories, purposes, and legal bases for processing.

2.2 Usage Data

The company processes data about website and service usage (“usage data”). This includes IP address, geographical location, browser type/version, operating system, referral source, visit length, page views, navigation paths, and service usage timing/frequency/patterns.

Optional Storage: If users choose, “usage data” may include application configuration (block lists, rules) and computer usage history (website browsing, application usage).

Source: Analytics tracking system via desktop application and browser extensions.

Purpose: Analysing website and service use.

Legal Basis: User consent or legitimate interests (monitoring/improving website and services).

2.3 Account Data

The company processes account data including name and email address.

Source: User-provided.

Purposes: Operating website, providing services, ensuring security, maintaining database backups, communicating with users.

Legal Basis: Consent or legitimate interests.

2.4 Profile Data

The company processes personal profile information including name, address, telephone, email, profile pictures, gender, date of birth, interests, hobbies, educational and employment details.

Purposes: Enabling and monitoring website and service use.

Legal Basis: Consent or legitimate interests.

2.5 Publication Data

The company processes information posted for publication on the website or through services.

Purposes: Enabling publication and administering website/services.

Legal Basis: Consent or legitimate interests.

2.6 Inquiry Data

The company processes information contained in inquiries about goods/services.

Purposes: Offering, marketing, and selling relevant goods/services.

Legal Basis: Consent or legitimate interests.

2.8 Transaction Data

The company processes transaction information including purchase details.

Data Types: First and last names, email login address, billing contact information, credit card numbers, passwords.

Purposes: Supplying purchased goods/services and maintaining transaction records.

Legal Basis: Contract performance or steps toward contract formation and legitimate interests.

2.9 Notification Data

The company processes information provided for email notifications and newsletters.

Purposes: Sending relevant notifications and newsletters.

Legal Basis: Consent or legitimate interests.

2.10 Correspondence Data

The company processes communication content and associated metadata from user messages.

Source: Website generates metadata from contact forms.

Purposes: Communicating with users and record-keeping.

Legal Basis: Consent or legitimate interests.

2.11 Legal Claims Data

The company may process personal data necessary for establishing, exercising, or defending legal claims in court or administrative proceedings.

Legal Basis: Legitimate interests (protection/assertion of legal rights).

2.13 Compliance & Vital Interests

The company may process personal data when necessary for legal compliance or protecting vital interests of individuals.

2.15 Third-Party Data

Users should not supply other persons’ personal data unless prompted.

3. Providing Personal Data to Others

3.1 Financial transactions are handled by payment service providers. The company shares transaction data only to the extent necessary for payment processing, refunds, and complaints/queries.

3.2 The company may disclose inquiry data to third-party service suppliers via APIs to enable account connection. Each third party acts as data controller and provides its own privacy policy.

3.3 The company may disclose personal data when necessary for legal compliance, protecting vital interests, or establishing/exercising/defending legal claims.

4. About Cookies

4.1 A cookie is a file containing an identifier (letter/number string) sent by a web server to a browser and stored. The identifier is sent back with page requests.

4.2 Cookies may be “persistent” (stored until expiry unless deleted) or “session” (expire when browser closes).

4.3 Cookies typically don’t identify users personally, but the company’s stored information may be linked to cookie data.

5. Cookies Used by Company

5.1 The company uses cookies for:

1. Authentication – Identifying users during visits and navigation
2. Status – Determining login status
3. Personalisation – Storing preferences and personalising the website
4. Security – Protecting accounts from fraud and protecting website/services
5. Advertising – Displaying relevant advertisements
6. Analysis – Analysing website/service use and performance
7. Cookie Consent – Storing cookie use preferences

6. Cookies Used by Service Providers

6.1 Service providers use cookies stored on user computers during website visits.

6.2 Google Tag Manager (GTM): Manages loading third-party analytics and advertising scripts. Sets cookies for performance/measurement. Loads Google Analytics to analyse website use. Google’s privacy policy.

6.3 Meta Pixel: Measures advertising campaign effectiveness and visitor interaction. Sets cookies for conversion tracking and audience building. Meta’s privacy policy.

6.4 FirstPromoter: Manages affiliate referral program. Sets cookies tracking referral sources and attributing conversions. FirstPromoter privacy policy.

6.5 Customer.io: Sends transactional and marketing emails. Uses cookies and tracking pixels for engagement measurement. Customer.io privacy policy.

6.6 Paddle: Payment and subscription management provider. Sets cookies for fraud detection and transaction processing. Paddle privacy policy.

6.7 Freshdesk (Freshworks): Manages customer support tickets. Stores correspondence and contact details. Freshworks privacy policy.

6.8 Back4App (Parse): Stores application data including accounts, device registrations, and plan configurations. Back4App privacy policy.

6.9 ProfitWell (Paddle): Analyses subscription metrics and revenue data for logged-in users. Sets cookies identifying returning subscribers. Covered under Paddle’s policy.

6.10 Microsoft Clarity: Understands user website interaction through session recordings and heatmaps. Uses cookies for behavioural data collection. Microsoft privacy policy.

6.11 Cookie Consent for EEA/UK/Switzerland: Uses cookie consent mechanism obtaining consent before loading non-essential cookies and tracking scripts (sections 6.2, 6.3, 6.4). Essential cookies for payment, security, and core functionality load without prior consent. Users may withdraw consent by clearing the “fme_consent” cookie.

7. Managing Cookies

7.1 Most browsers allow refusing cookies and deleting them. Methods vary by browser/version. Updated information available:

1. Chrome
2. Firefox
3. Opera
4. Internet Explorer
5. Safari
6. Edge

7.2 Blocking all cookies will negatively impact website usability.

7.3 Blocking cookies will prevent using all website features.

8. Non-Personally Identifiable Information

8.0 Non-Personally Identifiable Information doesn’t identify specific persons. This includes visited URLs before/after the Company Service, browser type, IP address, mobile carrier information, mobile device information, and general/aggregated location data not constituting personal identification.

The company and authorised third-party providers automatically collect this information using electronic tools (Cookies, Web beacons, Pixel tags). Most mobile information (device identification, type, carrier information, request type, request content) doesn’t identify users to the Company, though it may be unique or contain personally-considered information.

Uses: Troubleshooting, administering Company Service, analysing trends, gathering demographics, complying with law, cooperating with law enforcement. Information may be shared with authorised third-party providers measuring product/service effectiveness.

9. Analytics

The company continuously improves websites and products using third-party web analytics tools. The company is interested in how visitors use websites, desktop tools, mobile applications – preferences, dislikes, and problem areas.

Application Usage: Products, desktop tools, and mobile applications use analytical tools understanding feature usage patterns, enhancing product experience, and offering usage tips/guidance. Usage information may link to personal information about individual users in normal business operations and functionality enhancement. The company maintains data ownership and doesn’t share individual user data with third parties.

Mobile Analytics: Mobile applications use analytical tools gathering non-personally identifiable download and application usage data. Geolocation data requires specific user opt-in for particular services. IP addresses determine general geographic visitor areas, but this information isn’t correlated to individual user personal information.

Web Beacons: Beacons used with these tools gather data about browser type, operating systems, domain names, MIME types, downloads, and content/products/services reviewed when visiting/registering at websites or using mobile applications.

Purpose: Maintaining more effective, useful websites and products for customers. Data isn’t shared with third parties without prior consent or legal requirement.

10. Your Rights

10.1 This section summarises data protection law rights. Some rights are complex; users should read relevant laws and regulatory authority guidance for full explanations.

10.2 Principal rights under data protection law:

1. Right to access
2. Right to rectification
3. Right to erasure
4. Right to restrict processing
5. Right to object to processing
6. Right to data portability
7. Right to complain to supervisory authority
8. Right to withdraw consent

10.3 Right to Access: Users have the right to confirmation regarding whether the company processes personal data and, where applicable, access to personal data with additional information including processing purposes, concerned personal data categories, and data recipients. The company will provide a personal data copy (first copy free; additional copies subject to reasonable fees) if others’ rights/freedoms aren’t affected.

10.4 Right to Rectification: Users have rights to rectify inaccurate personal data and complete incomplete personal data considering processing purposes.

10.5 Right to Erasure: In some circumstances, users have erasure rights without undue delay. Circumstances include: personal data no longer necessary for collection/processing purposes; consent withdrawal; processing objection; direct marketing processing; unlawful processing. However, erasure right exclusions exist where processing is necessary for: freedom of expression/information exercise; legal obligation compliance; legal claim establishment/exercise/defence.

10.6 Right to Restrict Processing: In some circumstances, users have processing restriction rights. Circumstances include: personal data accuracy contestation; unlawful processing with erasure opposition; company no longer needing personal data for processing but user requiring it for legal claim establishment/exercise/defence; objection to processing pending verification. Where restriction is applied, the company may continue storing personal data but only process with: user consent; legal claim establishment/exercise/defence; another natural/legal person’s rights protection; important public interest reasons.

10.7 Right to Object: Users have rights to object to personal data processing based on their particular situation, but only where processing legal basis is task performance in public interest/official authority exercise or legitimate interests pursuit by company or third parties. Upon objection, the company ceases processing unless demonstrating compelling legitimate grounds overriding user interests/rights/freedoms or processing is for legal claim establishment/exercise/defence.

10.8 Right to Object to Direct Marketing: Users have rights to object to personal data processing for direct marketing (including profiling). The company ceases processing for this purpose upon objection.

10.9 Right to Object to Research/Statistical Processing: Users have rights to object to personal data processing for scientific/historical research or statistical purposes based on their particular situation, unless processing is necessary for public interest task performance.

10.10 Right to Data Portability: To the extent processing legal basis is consent or contract necessity, and processing occurs through automated means, users have rights to receive personal data in structured, commonly-used, machine-readable format. This right doesn’t apply where it would adversely affect others’ rights/freedoms.

10.11 Right to Complain: Where users consider processing infringes data protection laws, they have legal rights to lodge complaints with supervisory authorities responsible for data protection. Users may do so in EU member states of habitual residence, work place, or alleged infringement place.

10.12 Right to Withdraw Consent: Where processing legal basis is consent, users have rights to withdraw consent at any time. Withdrawal doesn’t affect processing lawfulness before withdrawal.

11. Children

Company services aren’t directed to people under thirteen years old. Parents/guardians should contact the company if aware of children providing personal information without consent. The company removes information and terminates child accounts upon discovering children under thirteen provided personal information.

12. Retaining and Deleting Personal Data

12.1 This section sets out data retention policies and procedures ensuring legal compliance regarding personal data retention/deletion.

12.2 Personal data processed for any purpose is kept until users request deletion.

12.3 Notwithstanding other provisions, the company may retain personal data where retention is necessary for legal compliance or protecting vital interests of individuals.

13. Additional Questions

For additional privacy inquiries, please contact us by email at .

14. Types of Data Collected

The company application may access, collect, use, and share personal and sensitive user data:

14.1 Usage Data: Data about application use including features interacted with, use duration/frequency, and settings/configuration changes.

14.2 Device Data: Device information such as operating system, device model, and unique identifiers.

14.3 Personal Identifiers: Name and email address collected during account creation, used for account management, communication, and experience personalisation.

15. Data Sharing and Third Parties

The company may share personal and sensitive data with third parties in these circumstances:

15.1 Service Providers: Data sharing with trusted third-party service providers assisting in application operation/improvement.

15.2 Legal Requirements: Law-required data disclosure to authorities or third parties.

16. Secure Data Handling

The company employs strict data handling and security measures protecting personal and sensitive data. Measures include data-in-transit encryption, secure storage solutions, and restricted data access.

17. Data Retention and Deletion

17.1 The company retains personal data as long as necessary for service provision, fulfilling policy purposes, and complying with legal obligations and resolving disputes.

17.2 Users wishing to request deletion can contact us by email at .