Version 1.1 from 22.05.2022
The document explains the personal data we collect, how and where we may use it, how we protect it, who has access to it, with whom we share it, and how you may correct it.
1. General information
S.C. FOKUSEK ENTERPRISE S.R.L. (hereafter mentioned as Fokusek), with its official headquarters in Lucian Blaga 6, Valcea, Romania, registered in the Valcea Trade Register with number J38/597/2019, fiscal code 41018706, e-mail firstname.lastname@example.org processes personal data in agreement with the European legislation on data protection (GDPR – Regulation EU 2016/679). Our Data Protection Officer can be found at the following contacts: email@example.com, Phone: 4021 -206.34.70
Fokusek offers software, data security products, and services specifically for iOS and macOS systems. Our goal is to ensure information and network security by providing quality products and services in these areas while also respecting the privacy and personal data of customers, Internet users, and business partners.
For this purpose, we collect only that personal data absolutely necessary for the specified purposes, on a best efforts basis. For the collected information and data, we strive to apply adequate solutions to anonymize them, or at least pseudonymize them.
None of our users can’t be identified specifically. All the telemetric data is anonymous and provided by the Microsoft AppCentral framework.
Personal data according to the European legislation definition (GDPR – Regulation 2016/679) means:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;
In this context, Fokusek processes personal data for the following main purposes:
To ensure network and information security by: assuring the correct and efficient operation of its products and services, according to the technical specifications, and for their improvement, including analyzing the reported IT security issues, delivering and customizing the related services to the user's needs and developing new technologies;
support or counseling services for its users of Fokusek products;
To make statistical analysis;
2. Personal data collected
Fokusek may collect personal information from its users in the following ways:
directly provided by a user via the customer's support channel;
2.1. Personal data directly provided by a user
The data used for support services are kept for different periods of time, depending especially if the problem has been solved and the exact method of communication with the support services, but in no case, the data will be kept for more than five years after the last communication took place. This period is necessary for Fokusek to be able to defend any legal complaints on contractual issues that may arise.
As regards the use of these data for marketing purposes, the legal basis we use is a legitimate interest for marketing communications with users of our products (based on Recital 47 of GDPR and Romanian law 506/2004, art 12 (2) that is implementing the EU E-privacy directive), unless those persons have opted out.
3. Protecting Personal Data, Confidentiality, and data protection are of vital importance for us. Access to the collected personal data is restricted only to Fokusek employees.
Fokusek may use other IT companies to process the collected personal data. These companies are considered data processors and have strict contractual obligations to keep the confidentiality of the processed data and to offer at least the same level of security as Fokusek. Data processors have the obligation not to allow third parties to process personal data on behalf of Fokusek and to access, use and/or keep the data secure and confidential.
Fokusek may host personal data in Romania, Ireland, as well as in European Union or any other jurisdiction which offers adequate level of personal data protection according to European Union standards, including companies that are certified under the US-EU Privacy Shield program.
Due to confidentiality obligations and security requirements the specific information regarding the name and details for each processor used will be provided only to competent authorities.
The following types of data processor are being used:
hosting services in Romania, Ireland and US;
support channel communications in Romania, Ireland, Poland and US;
marketing services (including email marketing) in Romania and US.
All our data processors in US are certified in the US-EU Privacy Shield program.
Unfortunately, transferring data over the Internet cannot be 100% secure. Consequently, despite our efforts to protect personal data, Fokusek cannot assure or guarantee the security of the information transmitted by the user until the information is on our servers. Any information you transmit is done on your own risk.
4. Your personal data rightsAccording to European Union applicable data protection legislation (GDPR), data subjects shall have the right to access to data, rectification, erasure, restriction on processing, objection to processing and right to data portability.
For exercising these rights, you may send a written request via email to Data Protection Officer at firstname.lastname@example.org
You also have the right to lodge a complaint with a competent supervisory authority on data protection.
5. VPN services
Fokusek does not collect or store any information related to the users of the VPN services. Our VPN servers are log free and can not associate any IP address to a user.
The Fokusek developers' team maintains several packages and applications that make it easier to work with Google APIs:
- iMail Pro wraps the Gmail API (iMail Pro's use and transfer of the information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.)
All of these packages and applications are governed by common policies recorded here. These packages use internal resources owned by the “Fokusek Enterprise API Packages” project on the Google Cloud Platform. That is the name you will see on a consent screen. Exception: iMail Pro does NOT use any resources owned by Fokusek API Packages, due to special requirements around Gmail and its scopes.