1. Scope
This Policy is applied to all the information (including personal data), which Refocus LLC ; hereinafter Refocus) collects from all users accessing and using any websites, programs, products and/or services provided by Refocus (hereinafter Websites and Services respectively).
Refocus may also collect personal data from its business partners (hereinafter Partners), whose websites, programs, products or services you are accessing and using. (e.g. from Refocus advertisers).
2. Purpose
At Refocus we recognize the importance of protecting your personal information when accessing and using Refocus Websites and Services, and we are committed to processing it responsibly and in compliance with applicable data protection laws.
In this Policy Refocus informs you about the following:

• extent of personal information, legal framework and purpose of personal information processing;
• Refocus roles and responsibilities when processing personal information;
• your rights throughout this process.

3. Categories of processed personal information
Refocus may collect the following categories of your personal information when accessing and using Refocus Websites and Services:

• Your personal information, such as: your name, phone number, E-mail, your instant messaging services credentials (e.g. Telegram);
• Electronic data (e.g. Cookies);
• date and time of accessing and using Refocus Websites and/or Services.

Refocus doesn’t purposefully collect sensitive personal information (race, political views, medical information and biometric data). Refocus doesn’t collect personal information for the purpose of creating user profile that can significantly affect your rights and freedoms.
Refocus doesn’t verify provided personal information and can’t judge its value or whether you are legally capable to provide personal information. Nevertheless, Refocus presumes that you provide accurate personal information and update it timely.
4. Legal framework
Refocus doesn’t have the right to process your personal information without appropriate legal grounds. Therefore, Refocus processes your personal information only if:

• processing is required for fulfilling Refocus contractual obligations with you, including operation of Websites and Services;
• processing is required for statutory obligations compliance;
• processing is legislatively prescribed.

5. Purpose of processing
Refocus processes your personal information only for certain purposes, and only the information that is relevant to fulfilling these purposes. More specifically, Refocus processes your personal information for the following purposes:

• in order to give you access to Websites and Services;
• in order to give you access to your account once you are registered with Refocus Websites/Services;
• in order to communicate with you for the purpose of sending notifications, requests and information relevant to Websites and Services, fulfilling contractual obligations and handling your enquiries and requests;
• in order to make Websites and Services more user-friendly;
• in order to protect your rights and rights of Refocus;
• in order to collect, process and submit statistical data, Big Data and similar studies.

6. Personal information protection
Personal information can be processed automatically with no Refocus employees involvement. In case certain information needs to be processed by an employee, access to it is given only to those employees who need it to carry out their tasks. To protect personal information and ensure that information is treated in a confidential manner, all Refocus employees must comply with processed personal information confidentiality requirements.
Refocus also applied sufficient technical and security measures to protect personal information from unauthorized, accidental or unlawful destruction, loss, alteration, dishonest use, disclosure or access, as well as other illegal ways of personal information processing. These measures were applied with regard to modern technologies, implementation costs and risks related to personal information processing and its specifics.
7. Storage
Your personal information is stored on the territory of the European Union, United States, Russia or Canada.
8. Retention period
Refocus maintains your personal information as long as it’s necessary for fulfilling the purpose it was collected for or for compliance with legislations and regulations requirements.
9. Your rights
If provided by applicable legislation, you reserve the right to do the following:

• access your personal information processed by Refocus;
• update already submitted personal information;
• remove your personal information.

If provided by applicable legislation, you may have other rights, not mentioned above.
In order to exercise the rights mentioned above, contact Refocus by E-mail or in written form.
9. Cookies
Cookies are small text files that get stored in your browser or on your device through websites, applications, online and advertising resources. Refocus uses Cookies and similar technologies for such purposes as:

• identifying unique Refocus Services user;
• storing user parameters and settings;
• determining content popularity;
• managing and evaluating the efficiency of marketing campaigns;
• analyzing websites traffic, trends and tendencies as well as general understanding of online behavior and user engagement with Refocus Services.

Refocus may authorize third parties to provide it with audience statistical analysis and place advertising online on its behalf, monitor its effectiveness and inform Refocus about it. These individuals and companies may use Cookies to identify your device when you are accessing and using Refocus and other Websites and Services.
10. Changes and Updates
Refocus reserves the right to update or change this Policy at any time at its own discretion, including but not limited to cases related to changes in applicable legislation and changes in Websites and Services operation developments.
Refocus encourages you to periodically review this Policy for the latest information on our privacy practices.