Privacy Policy

Who We Are

This Privacy Policy describes how Refocus Data LLC (“Refocus Data,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information obtained from our clients, prospects, website visitors, and individuals who interact with us in connection with our managed services and related business activities. We are committed to handling your information responsibly and in compliance with applicable law.

Refocus Data LLC is a Managed Service Provider (MSP) that delivers IT infrastructure management, cybersecurity, cloud solutions, helpdesk support, and related technology services to businesses and organizations. We operate as a data controller and, in certain service contexts, as a data processor on behalf of our clients.

Personal Data We Collect

The following categories of personal data may be collected by Refocus Data LLC through your use of our services, website, or direct interactions with us. This data is collected solely to deliver and support our managed IT services and will not be shared with third parties.

Identity & Contact Information

• Full name
• Job title and employer / organization name
• Business email address
• Personal email address (when provided)
• Business phone number
• Mobile / cell phone number
• Business mailing address

Account & Authentication Data

• Usernames and login credentials for client portals and service platforms
• Account security information (e.g., multi-factor authentication settings)

Financial & Billing Information

• Billing name and address
• Payment method details (processed securely via our payment processor)
• Invoice and transaction history

Communications Data

• Emails, support tickets, and chat messages sent to us
• Notes and records from phone or video calls
• Information submitted through website contact forms

Technical & Device Data

• IP addresses and device identifiers
• Browser type and operating system
• System and network telemetry collected during managed service delivery
• Log files and audit trails from IT infrastructure monitoring

Website Usage Data

• Pages visited and time spent on our website
• Referring URLs and navigation paths
• Cookie and analytics data (see Section 7)

How We Collect Information

We collect the personal data listed above through the following channels:

Information You Provide Directly

• Name, job title, and employer/organization name
• Business and personal contact information (email address, phone number, mailing address)
• Login credentials for client portals and service platforms
• Billing and payment information
• Communications you send us (emails, support tickets, chat messages, forms)
• Information provided when completing service agreements or onboarding documents

Information Collected Automatically

• Device identifiers, IP addresses, and browser/OS information
• Website usage data, cookies, and analytics (pages visited, time on site, referral source)
• System and network telemetry data collected as part of managed service delivery
• Log files and audit trails generated through IT infrastructure monitoring

Information from Third Parties

• Data from third-party integrations and software platforms used in service delivery
• Publicly available business information
• Referrals from partners or other clients

How We Use Your Information

Service Delivery and Operations

• Providing, managing, and improving our managed IT services
• Responding to service requests, incidents, and helpdesk tickets
• Monitoring and maintaining client networks, systems, and endpoints
• Onboarding new clients and configuring service environments

Business Communications and Marketing

• Sending account-related notices, invoices, and service updates
• Communicating about new services, promotions, and company news
• Sending SMS/text messages and transactional communications (see Section 8)
• Responding to inquiries submitted through our website or other channels

Legal, Compliance, and Security

• Complying with applicable laws, regulations, and legal obligations
• Preventing fraud, unauthorized access, and other security threats
• Enforcing our agreements, terms of service, and policies
• Protecting the rights and safety of our clients, employees, and the public

Sharing of Personal Information

We do not sell your personal information. We may share information in the following limited circumstances:

• Service Providers: We engage trusted third-party vendors and subcontractors who assist in delivering our services (e.g., cloud platform providers, security tool vendors, payment processors). These parties are bound by confidentiality obligations and are only permitted to use information for the purposes we specify.
• Business Partners: With your consent or as necessary for service delivery, we may share information with technology partners, resellers, or referral partners.
• Legal Requirements: We may disclose information when required by law, court order, or governmental authority, or when we believe disclosure is necessary to protect our rights or the safety of others.
• Business Transfers: In the event of a merger, acquisition, sale of assets, or other business transaction, personal information may be transferred as part of that transaction. We will notify you as required by applicable law.
• With Your Consent: We may share information for other purposes with your prior consent.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, maintain our business relationship with you, comply with legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we delete or anonymize it in accordance with our data retention schedule.

Cookies & Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience, analyze site traffic, and support marketing efforts. You may control cookie preferences through your browser settings. Disabling certain cookies may limit the functionality of our website.

Types of Cookies We Use

• Essential cookies: Required for basic website functionality
• Analytics cookies: Help us understand how visitors use our website (e.g., Google Analytics)
• Marketing cookies: Used to deliver relevant content and advertisements

Data Security

We implement administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, multi-factor authentication, regular security assessments, and employee training.

While we take reasonable precautions, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.

SMS & Text Messaging Disclosure

Refocus Data LLC operates an SMS/MMS messaging program to communicate with clients and prospects. The following disclosures apply to all text messages sent by Refocus Data LLC.

Types of Messages We Send

• Transactional messages: Service alerts, appointment reminders, incident notifications, ticket updates, and account security notifications
• Informational messages: IT tips, service updates, maintenance windows, and company announcements
• Marketing messages: Promotions, new service offerings, and event invitations (with your prior consent)

Message Frequency

Message & Data Rates

How to Opt Out

How to Get Help

Consent to Receive SMS Messages

By providing your mobile phone number and opting in to our messaging program, you expressly consent to receive recurring automated text messages from Refocus Data LLC at the mobile number provided. Consent is not a condition of purchasing any product or service.

No Sharing of SMS Opt-In Data

Program Links

Privacy Policy   |   Terms & Conditions

Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information, including:

• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Deletion: Request deletion of your personal information (subject to legal retention obligations)
• Right to Opt Out: Opt out of the sale of personal information (we do not sell personal information) or opt out of marketing communications
• Right to Data Portability: Request your information in a machine-readable format
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise any of these rights, please contact us using the information in Section 12. We will respond to your request within the timeframe required by applicable law (typically 30–45 days). We may need to verify your identity before processing your request.

Children’s Privacy

Our services are directed to businesses and are not intended for individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us immediately and we will take steps to delete it.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will post the updated policy on our website with a new effective date and, where appropriate, notify you by email or other means. Your continued use of our services after the effective date of an updated policy constitutes your acceptance of the changes.

Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us:

We are committed to resolving any complaints about our collection or use of your personal information. If you have concerns that are not addressed to your satisfaction, you may have the right to contact your applicable data protection authority.