Last updated December 29,
2021
Thank you for choosing to be part of our community
at FocusChange Ltd Sikhana Online Sikhana
Online [email protected] .
This privacy notice describes how we might use
your information if you:
- Visit our website
at https://sihkana.online
- Engage with us in other related ways ― including
any sales, marketing, or events
In this privacy notice,
if we refer to:
- "Website," we are referring to
any website of ours that references or links to this policy
- "Services," we are referring to
our
Website,
The purpose of this
privacy notice is to explain to you in the clearest way possible what
information we collect, how we use it, and what rights you have in relation to
it. If there are any terms in this privacy notice that you do not agree with,
please discontinue use of our Services
immediately.
Please read this privacy
notice carefully, as it will help you understand what we do with the information
that we collect.
TABLE
OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you disclose to
us
In
Short: We collect personal
information that you provide to
us.
We collect personal
information that you voluntarily provide to us when you
The personal
information that we collect depends on the context of your interactions with us
and the
Personal
Information Provided by You. We collect names ; phone numbers ; email addresses ; mailing addresses ; job titles ; usernames ; passwords ; billing addresses ;
Payment
Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number (such as a credit card
number), and the security code associated with your payment instrument. All
payment data is stored byStripe https://stripe.com/gb/privacy
All personal
information that you provide to us must be true, complete and accurate, and you
must notify us of any changes to such personal information.
Information automatically
collected
In Short:
Some information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
We automatically
collect certain information when you visit, use or navigate the
Like many
businesses, we also collect information through cookies and similar
technologies.
The information we
collect includes:
- Log and Usage Data. Log and usage data is
service-related, diagnostic, usage and performance information our servers
automatically collect when you access or use our
Website
- Device
Data. We collect device data such as information about your computer,
phone, tablet or other device you use to access the
Website . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
2. HOW
DO WE USE YOUR
INFORMATION?
In Short:
We process your information for purposes based on legitimate
business interests, the fulfillment of our contract with you, compliance with
our legal obligations, and/or your
consent.
We use personal
information collected via our
In legal terms, we
are generally the "data controller" under European data protection laws since we
determine the means and/or purposes of the data processing we perform. However,
if you are a business customer with whom we have entered into a data processing
agreement for the provision of corporate services to you, then you would be the
"data controller" and we would be the "data processor" under European data
protection laws since we would be processing data on your behalf in accordance
with your instructions.
We use the
information we collect or receive:
- To facilitate account creation and logon
process. If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the information you
allowed us to collect from those third parties to facilitate account creation
and logon process for the performance of the contract.
- To post testimonials. We post
testimonials on our
Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your
information to request feedback and to contact you about your use of our
Website .
- To enable user-to-user
communications. We may use your information in order to enable
user-to-user communications with each user's consent.
- To manage user accounts. We may
use your information for the purposes of managing our account and keeping it in
working order.
- To send
administrative information to you. We may use your personal information
to send you product, service and new feature information and/or information
about changes to our terms, conditions, and policies.
- To protect
our Services. We may use your information as part of our efforts to
keep our
Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce
our terms, conditions and policies for business purposes, to comply with legal
and regulatory requirements or in connection with our contract.
- To
respond to legal requests and prevent harm. If we receive a subpoena or
other legal request, we may need to inspect the data we hold to determine how to
respond.
- Fulfill and manage your orders.
We may use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the
Website .
- Administer prize draws and
competitions. We may use your information to administer prize draws and
competitions when you elect to participate in our competitions.
- To deliver and facilitate delivery of
services to the user. We may use your information to provide you with
the requested service.
- To respond to user inquiries/offer support
to users. We may use your information to respond to your inquiries and
solve any potential issues you might have with the use of our Services.
- To send you
marketing and promotional communications. We and/or our third-party
marketing partners may use the personal information you send to us for our
marketing purposes, if this is in accordance with your marketing preferences.
For example, when expressing an interest in obtaining information about us or
our
Website , subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
- Deliver
targeted advertising to you.
We may use your information to develop and display personalized content and
advertising (and work with third parties who do so) tailored to your interests
and/or location and to measure its effectiveness.
In
Short: We only share information with your consent, to comply
with laws, to provide you with services, to protect your rights, or to fulfill
business obligations.
We may process or share your data that
we hold based on the following legal basis:
- Consent: We may process your data
if you have given us specific consent to use your personal information for a
specific purpose.
- Legitimate Interests: We may
process your data when it is reasonably necessary to achieve our legitimate
business interests.
- Performance of a Contract: Where
we have entered into a contract with you, we may process your personal
information to fulfill the terms of our contract.
- Legal Obligations: We may
disclose your information where we are legally required to do so in order to
comply with applicable law, governmental requests, a judicial proceeding, court
order, or legal process, such as in response to a court order or a subpoena
(including in response to public authorities to meet national security or law
enforcement requirements).
- Vital Interests: We may disclose
your information where we believe it is necessary to investigate, prevent, or
take action regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your
data or share your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors, Consultants and Other Third-Party
Service Providers. We may share your data with third-party vendors,
service providers, contractors or agents who perform services for us or on our
behalf and require access to such information to do that work. Examples include:
payment processing, data analysis, email delivery, hosting services, customer
service and marketing efforts. We may allow selected third parties to use
tracking technology on the
Website , which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Third-Party Advertisers. We may
use third-party advertising companies to serve ads when you visit or use the
Website . These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
In Short: We only
share information with the following
We only share and disclose your information with
the following
Data Analytics Services
Payment Processors
Sales & Marketing Tools
User Account Registration & Authentication Services
In
Short: We may use cookies and other tracking technologies to
collect and store your information.
We may use cookies
and similar tracking technologies (like web beacons and pixels) to access or
store information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice
6. IS
YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may
transfer, store, and process your information in countries other than your
own.
Our servers are located inUnited
Kingdom United
Kingdom
If you are a
resident in the European Economic Area (EEA) or United Kingdom (UK), then these
countries may not necessarily have data protection laws or other similar laws as
comprehensive as those in your country. We will however take all necessary
measures to protect your personal information in accordance with this privacy
notice and applicable law.
European
Commission's Standard Contractual Clauses:
We have implemented
measures to protect your personal information, including by using the European
Commission's Standard Contractual Clauses for transfers of personal information
between our group companies and between us and our third-party providers. These
clauses require all recipients to protect all personal information that they
process originating from the EEA or UK in accordance with European data
protection laws and regulations.
7. HOW
LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this privacy notice unless otherwise required
by law.
We will only keep your personal
information for as long as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is required or permitted by law
(such as tax, accounting or other legal requirements). No purpose in this notice
will require us keeping your personal information for longer than
When we have no
ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup archives),
then we will securely store your personal information and isolate it from any
further processing until deletion is possible.
8. HOW
DO WE KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to protect your personal information through a
system of organizational and technical security
measures.
We have implemented appropriate
technical and organizational security measures designed to protect the security
of any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the Internet
or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security, and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and
from our
9. DO
WE COLLECT INFORMATION FROM
MINORS?
In
Short: We do not knowingly collect data from or market to
children under 18 years of age.
We do not knowingly
solicit data from or market to children under 18 years of age. By using the
[email protected]
10.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In some regions
(like the EEA and UK), you have certain rights under applicable data protection
laws. These may include the right (i) to request access and obtain a copy of
your personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; and (iv) if applicable, to
data portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. To make such a request,
please use the contact
details provided below. We will consider and act upon any
request in accordance with applicable data protection
laws.
If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at any time.
Please note however that this will not affect the lawfulness of the processing
before its withdrawal, nor will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
If you are a resident in the EEA or UK
and you believe we are unlawfully processing your personal information, you also
have the right to complain to your local data protection supervisory authority.
You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a
resident in Switzerland, the contact details for the data protection authorities
are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have
questions or comments about your privacy rights, you may email us at [email protected] .
Account
Information
If you would at any time like to review or change
the information in your account or terminate your account, you can:
Log in to your account settings and update your user account.
Contact us using the contact information provided.
Upon your request to terminate your account, we
will deactivate or delete your account and information from our active
databases. However, we may retain some information in our files to prevent
fraud, troubleshoot problems, assist with any investigations, enforce our Terms
of Use and/or comply with applicable legal requirements.
Cookies
and similar technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your browser to
remove cookies and to reject cookies. If you choose to remove cookies or reject
cookies, this could affect certain features or services of our
Opting
out of email marketing: You can unsubscribe from our marketing
email list at any time by clicking on the unsubscribe link in the emails that we
send or by contacting us using the details provided below. You will then be
removed from the marketing email list — however, we may still communicate with
you, for example to send you service-related emails that are necessary for the
administration and use of your account, to respond to service requests, or for
other non-marketing purposes. To otherwise opt-out, you may:
Contact us using the contact information provided.
11.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers
and some mobile operating systems and mobile applications include a Do-Not-Track
("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected.
At this stage no uniform technology standard for recognizing and implementing
DNT signals has been finalized. As such, we do not currently respond to DNT
browser signals or any other mechanism that automatically communicates your
choice not to be tracked online. If a standard for online tracking is adopted
that we must follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
12. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if you are a resident of California, you are
granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83,
also known as the "Shine The Light" law, permits our users who are California
residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to
third parties for direct marketing purposes and the names and addresses of all
third parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like to make
such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age,
reside in California, and have a registered account with
CCPA Privacy
Notice
The California Code
of Regulations defines a "resident"
as:
(1) every individual who is in the State of
California for other than a temporary or transitory purpose
and
(2) every individual who is domiciled in the State
of California who is outside the State of California for a temporary or
transitory purpose
All other individuals are defined as
"non-residents."
If this definition of "resident"
applies to you, we must adhere to certain rights and obligations regarding your
personal information.
What categories of personal
information do we collect?
We have collected
the following categories of personal information in the past twelve (12)
months:
| Category | Examples | Collected |
A.
Identifiers | Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address and account
name | |
B. Personal information categories listed in the
California Customer Records statute | Name, contact information, education, employment,
employment history and financial information | YES |
C. Protected classification
characteristics under California or federal
law | Gender and date of
birth | |
D. Commercial
information | Transaction information, purchase history,
financial details and payment information | |
E. Biometric
information | Fingerprints and
voiceprints | |
F. Internet or other similar network
activity | Browsing history, search history, online behavior,
interest data, and interactions with our and other websites, applications,
systems and advertisements | |
G. Geolocation
data | Device location | |
H. Audio, electronic, visual, thermal, olfactory,
or similar information | Images and audio, video or call recordings created
in connection with our business activities | |
I. Professional or employment-related
information | Business contact details in order to provide you
our services at a business level, job title as well as work history and
professional qualifications if you apply for a job with
us | |
J. Education
Information | Student records and directory
information | |
K. Inferences drawn
from other personal information | Inferences drawn from any of the collected
personal information listed above to create a profile or summary about, for
example, an individual’s preferences and
characteristics |
We may also collect
other personal information outside of these categories instances where you
interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support
channels;
- Participation in customer surveys or contests;
and
- Facilitation in the delivery of our Services and
to respond to your inquiries.
How do we use and share your personal
information?
- Targeting cookies/Marketing cookies
You may contact us
[email protected] ,
If you are using an authorized agent
to exercise your right to opt-out we may deny a request if the authorized agent
does not submit proof that they have been validly authorized to act on your
behalf.
Will your information be shared with
anyone else?
We may disclose your personal
information with our service providers pursuant to a written contract between us
and each service provider. Each service provider is a for-profit entity that
processes the information on our behalf.
We may use your
personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not
considered to be "selling" of your personal data.
- Category A.
Identifiers, such as contact details, like your real name, alias, postal
address, telephone or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address and account name.
- Category B.
Personal information, as defined in the California Customer Records law, such as
your name, contact information, education, employment, employment history and
financial information.
The categories of third parties to whom we
disclosed personal information for a business or commercial purpose can be found
under "WHO WILL YOUR INFORMATION BE SHARED
WITH?".
Your rights
with respect to your personal data
Right to request
deletion of the data - Request to delete
You can ask for the
deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation or any processing that may be
required to protect against illegal activities.
Right to be
informed - Request to know
Depending on the
circumstances, you have a right to know:
- whether we collect and use your personal
information;
- the categories of personal information that we
collect;
- the purposes for which the collected personal
information is used;
- whether we sell your personal information to third
parties;
- the categories of personal information that we
sold or disclosed for a business purpose;
- the categories of third parties to whom the
personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting
or selling personal information.
In accordance with applicable law, we are not
obligated to provide or delete consumer information that is de-identified in
response to a consumer request or to re-identify individual data to verify a
consumer request.
Right to Non-Discrimination for the
Exercise of a Consumer’s Privacy Rights
We will not
discriminate against you if you exercise your privacy
rights.
Verification
process
Upon receiving your request, we will
need to verify your identity to determine you are the same person about whom we
have the information in our system. These verification efforts require us to ask
you to provide information so that we can match it with information you have
previously provided us. For instance, depending on the type of request you
submit, we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or we may
contact you through a communication method (e.g. phone or email) that you have
previously provided to us. We may also use other verification methods as the
circumstances dictate.
We will only use personal information
provided in your request to verify your identity or authority to make the
request. To the extent possible, we will avoid requesting additional information
from you for the purposes of verification. If, however, we cannot verify your
identity from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your identity, and
for security or fraud-prevention purposes. We will delete such additionally
provided information as soon as we finish verifying
you.
Other privacy
rights
- you may object to the processing of your personal
data.
- you may request correction of your personal data
if it is incorrect or no longer relevant, or ask to restrict the processing of
the data.
- you can designate an authorized agent to make a
request under the CCPA on your behalf. We may deny a request from an authorized
agent that does not submit proof that they have been validly authorized to act
on your behalf in accordance with the CCPA.
- you may request to opt-out from future selling of
your personal information to third parties. Upon receiving a request to opt-out,
we will act upon the request as soon as feasibly possible, but no later than 15
days from the date of the request submission.
To exercise these rights, you can contact us
[email protected] ,
13. DO
WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will
update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from
time to time. The updated version will be indicated by an updated "Revised" date
and the updated version will be effective as soon as it is accessible. If we
make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your
information.
14. HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this
notice, you may James Randall ,[email protected] ,
If you are a resident in
the United Kingdom, the "data controller" of your personal information is FocusChange Ltd .
15. HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your
country, you may have the right to request access to the personal information we
collect from you, change that information, or delete it in some circumstances.
To request to review, update, or delete your personal information, please sikhana.online/data-access-request
