Version 1.1, from 20.09.2019
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.
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 System. Our goal is to ensure information and network security by providing quality products and services in these areas while also respecting 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 to pseudonimyze them.
None of our users can't be identified specifically. All the telemetric data is anonymous and provided by 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:
2. Personal data collected
Fokusek may collect personal information from its users from in the following ways:
The data used for support services is 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 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.
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:
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.
According 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.
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.