Thank you for choosing to be part of our community at
FocusChange Ltd , doing business as Sikhana Online (" Sikhana
Online ," "we," "us,"
or "our"). We are committed to protecting your personal
information and your right to privacy. If you have any questions or concerns
about this privacy notice or our practices with regard to your personal
information, please contact us at email@example.com.
This privacy notice describes how we might use your information if you:
- Visit our website
- 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
Website, and other related services, including any sales, marketing, or events
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
register on the Website, express an interest in obtaining information about
us or our products and Services, when you participate in activities on the Website
or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the
Website , the choices you make and the products and features
you use. The personal information we collect may include the following:
Personal Information Provided by You. We collect
names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; billing addresses; and other
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 by
You may find their privacy notice link(s) here:
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
This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your
IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about
how and when you use our Website
and other technical information. This information is primarily needed to
maintain the security and operation of our Website ,
and for our internal analytics and reporting purposes.
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
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
for a variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business interests,
in order to enter into or perform a contract with you, with your consent, and/or
for compliance with our legal obligations. We indicate the specific processing
grounds we rely on next to each purpose listed below.
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 firstname.lastname@example.org 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
- 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
- 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
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.
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
- Fulfill and manage your orders.
We may use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the
- 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
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).
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
- Legitimate Interests: We may
process your data when it is reasonably necessary to achieve our legitimate
- 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
- 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
categories of third
We only share and disclose your information with the following
third parties. If
we have processed your data based on your consent and you wish to revoke your
consent, please contact us using the contact details provided in the section
below titled "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?". Data Analytics Services Payment Processors Sales & Marketing Tools User Account Registration & Authentication Services
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 in
Kingdom . If you are accessing our
Kingdom , please be aware
that your information may be transferred to, stored, and processed by us in our
facilities and by those third parties with whom we may share your personal
information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above),
in and other
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.
Our Standard Contractual
Clauses can be provided upon request. We have
implemented similar appropriate safeguards with our third-party service
providers and partners and further details can be provided upon request.
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
the period of time in which users have an account
with us .
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
is at your own risk. You should only access the Website
within a secure environment.
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
you represent that you are at least 18 or that you are the parent or guardian of
such a minor and consent to such minor dependent’s use of the Website .
If we learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at email@example.com .
10. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as
the European Economic Area (EEA) and United Kingdom (UK), you have rights that
allow you greater access to and control over your personal information. You may
review, change, or terminate your account at any time.
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
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.
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
To opt-out of interest-based advertising by advertisers on our Website
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
the Website ,
you have the right to request removal of unwanted data that you publicly post on
the Website .
To request removal of such data, please contact us using the contact information
provided below, and include the email address associated with your account and a
statement that you reside in California. We will make sure the data is not
publicly displayed on the Website ,
but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g. backups, etc.).
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:
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
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
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
- Participation in customer surveys or contests;
- 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
by email at firstname.lastname@example.org, or by referring to the contact details at the
bottom of this document.
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
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
- the categories of personal information that we
- the purposes for which the collected personal
information is used;
- whether we sell your personal information to third
- 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.
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
- you may request correction of your personal data
if it is incorrect or no longer relevant, or ask to restrict the processing of
- 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 at email@example.com, or by referring to the contact details at the
bottom of this document. If you have a complaint about how we handle your data,
we would like to hear from you.
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
contact our Data Protection Officer
(DPO) , James Randall, by email at
firstname.lastname@example.org, or by post
If you are a resident in the United Kingdom, the "data controller" of your personal information is
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