FOCUS PRO — PRIVACY POLICY

1) Introduction

Focus Pro ("Focus Pro," "we," "us," "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use the Focus Pro mobile app and related services (collectively, the "Service").

This policy is intended to apply worldwide, including in jurisdictions with privacy laws such as the European Economic Area and the United Kingdom (GDPR/UK GDPR), California (CCPA/CPRA), and Brazil (LGPD).

2) Who is responsible for your data (Controller)

Data Controller: Focus Pro Germany
Address: Aachen, Germany
Email (privacy): [email protected]
Email (support): [email protected]
EU/UK Representative: Not separately appointed.
Data Protection Officer: Not separately appointed.

3) What information we collect

We collect information in the following categories, depending on how you use the Service:

A. Account and identity information

• Account identifiers: email address (including Apple "Private Relay" email if you choose that option), display name, sign-in provider identity, and anonymous/guest account status
• Optional profile photo URL (when provided by your sign-in provider or uploaded by you)
• Authentication metadata: sign-in method (e.g., Apple, Google), user ID/identifier from the sign-in provider, and tokens/credentials necessary to keep you signed in (stored securely)

B. User-generated content (the content you create)

Tasks, to-do items/categories, habits, habit completions, notes, note metadata, pomodoro/focus sessions, daily stats, calendar events, notification preferences/history, locale, and other synced settings you choose to store in the Service

C. Usage, diagnostics, and device information

• Technical/device information used to operate the app: device model, operating system version, app version, platform, and timezone
• Current build status: Focus Pro does not ship Firebase Analytics or Firebase Crashlytics

On-device-only data (not treated as backend-collected data): note drafts, legacy offline note cache, downloaded ambient audio files, focus quota counters, theme/locale preferences, and saved iOS Family Controls selections

D. Notifications data

Notifications in Focus Pro are primarily local notifications scheduled on your device

If you enable iOS Live Activities, iOS may generate Live Activity update tokens; active tokens may be stored in your user profile to support Live Activity updates

E. Purchases and subscriptions

Subscriptions are processed by Apple App Store and/or Google Play. We do not collect or store your full payment card details. We may receive and store:

• Subscription status (active/inactive), product/plan identifiers, and transaction/receipt validation data needed to confirm entitlements
• Promo entitlement records when applicable (promo grant records and promo grant audit events keyed by normalized email)

F. Support communications

If you contact us, we collect the content of your message and contact information, plus any attachments or screenshots you choose to provide.

G. Information from third parties

We receive information from:

• Apple and Google sign-in providers (account identifiers and profile data you allow them to share)
• App stores (subscription/transaction confirmation)

4) How we use your information

We use information to:

• Provide the Service (create/sync your tasks, habits, notes, and sessions across devices)
• Operate accounts and authentication
• Send notifications you request (timers, reminders, habit prompts, and optional Live Activity updates)
• Provide subscription features, promo entitlements, and verify access rights
• Customer support and responding to inquiries
• Security and fraud prevention (protect accounts, prevent abuse, debug incidents)

No selling of personal information: We do not sell personal information.

No "sharing" for cross-context behavioral advertising: We do not share personal information for cross-context behavioral advertising.

5) Legal bases for processing (EEA/UK – GDPR/UK GDPR)

If you are in the EEA/UK, we rely on the following legal bases:

• Contract (performance of a contract): to provide core app features (account, syncing, storing your content, subscription entitlements)
• Legitimate interests: to secure the Service, prevent abuse, and improve reliability (e.g., debugging and service analytics)
• Consent: for optional features such as push notifications (you can change this in device/app settings)
• Legal obligation: to comply with applicable laws, lawful requests, or enforce rights

6) How we share information

We share information only as described below:

A. Service providers (processors)

We use service providers to host, store, and process data to operate the Service, including Firebase Authentication, Cloud Firestore, Cloud Functions for Firebase, and Firebase Storage.

B. Sign-in providers

If you use "Sign in with Apple" or Google Sign-In, those providers process authentication under their own privacy policies.

C. App stores and payment platforms

Apple and Google process payments and may provide us subscription confirmation needed to unlock features.

D. Legal, safety, and enforcement

We may disclose information if we believe in good faith it is necessary to:

• comply with law, regulation, subpoena, court order, or valid governmental request
• protect the rights, safety, and security of users, Focus Pro, or the public
• investigate and defend against claims

E. Business transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction (subject to legal requirements and notice where required).

F. With your direction/consent

We share information when you explicitly request or consent (for example, if you choose to export/share your data).

7) International data transfers

We may process and store information in countries outside your country of residence, including the United States (for example, when using cloud providers).

For transfers from the EEA/UK, we use appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) (commonly used by cloud providers, including Firebase-related SCC resources)
• Where applicable, transfers to US recipients certified under the EU-U.S. Data Privacy Framework (when the recipient is certified and the mechanism is available)

8) Data retention

Account/profile data and synced user content are retained until you delete your account or request deletion.

When the deletion flow completes, Focus Pro removes account-linked data from active systems, including Firestore user data, Firebase Storage profile photos, and promo grant records tied to your account email (when present).

Provider backups may persist temporarily for disaster recovery and are removed on provider backup cycles.

Apple App Store and Google Play billing history are retained under Apple/Google platform policies and are not deleted by Focus Pro.

9) Security

We implement administrative, technical, and physical safeguards designed to protect information, such as:

• encryption in transit (TLS/HTTPS)
• access controls and least-privilege permissions
• secure authentication
• monitoring and incident response practices

No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

10) Your choices and controls

You can control certain privacy features:

• Notifications: manage through your device settings and in-app settings
• Account information: update within the app
• Delete account: in-app (Settings → Account → Delete Account) or by contacting [email protected]
• Data access/export/correction requests: contact [email protected]

11) Your rights (by region)

A. Rights for all users

• Access your personal information
• Correct inaccurate data
• Delete your personal information
• Port your data (receive a copy in a structured format)
• Object / restrict certain processing (in some jurisdictions)

B. EEA/UK (GDPR/UK GDPR)

You may have the right to:

• object to processing based on legitimate interests
• withdraw consent (where processing is based on consent)
• lodge a complaint with your local supervisory authority

C. California (CCPA/CPRA)

California residents may have rights to:

• know what personal information is collected/used/disclosed
• request deletion
• request correction
• opt out of "sale" or "sharing" (we do not sell; and we do not share for cross-context behavioral advertising as described above)
• limit the use and disclosure of sensitive personal information (if applicable)
• use Global Privacy Control (GPC) as a valid opt-out signal where applicable

We will not discriminate for exercising privacy rights.

D. Brazil (LGPD)

You may have rights to confirmation of processing, access, correction, anonymization/blocking/deletion, portability, and revocation of consent (where applicable).

E. Other US states and other countries

Many jurisdictions provide similar rights (access, delete, correct, portability, opt-out of certain processing). We honor applicable rights based on your location and the nature of the request.

12) How to exercise your rights

To exercise privacy rights:

• In-app: Settings → Account → Delete Account (for deletion)
• Email: [email protected] (for access, export, correction, deletion requests)

We will respond within the time required by applicable law (often 30–45 days). To protect users, we may verify your identity before fulfilling certain requests.

13) Children's privacy

The Service is not intended for children under 13, and in some regions (including parts of the EEA) the minimum age may be 16 for certain data processing. We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact [email protected] and we will take steps to delete it.

14) Third-party services

Our Service integrates with:

• Firebase Authentication
• Cloud Firestore
• Cloud Functions for Firebase
• Firebase Storage
• Sign in with Apple
• Google Sign-In
• Apple App Store billing
• Google Play billing

These third parties process data under their own terms and privacy policies.

15) Changes to this policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice (for example, in-app notice), and update the "Last updated" date. Your continued use after the effective date means you accept the updated policy, to the extent permitted by law.

16) Contact us

Privacy: [email protected]
Support: [email protected]
Mailing address: Aachen, Germany