Privacy Policy

1. Core Privacy Facts

The Service is designed so that:

• Raw video/images of you are NOT processed on our servers and are NOT stored by us.
• Derived results produced by local (on-device) processing MAY be transmitted to and stored by us.

If you enable camera-based features, analysis runs locally on your device. The Service may store derived results such as attention/focus metrics, timestamps, session summaries, and related analytics. Derived results can be personal data if they relate to an identifiable person.

By registering for and using the Service, you acknowledge and agree that raw video is not uploaded/stored by us and that derived results may be stored and processed as described in this Privacy Policy. Where consent is legally required (for example, non-essential cookies), we will request it separately and you can withdraw it at any time.

2. Personal Data We Collect

Depending on how you use the Service, we may collect:

A. Account Data

• Email address and account identifiers
• Authentication data (passwords are stored only in hashed form; we do not store plaintext passwords)

B. Usage and Device Data

• Service usage events (feature usage, interactions, error events)
• Device and technical data (device type, operating system, app version, language, time zone)
• Network data (IP address; approximate location inferred from IP for security and fraud prevention)

C. Derived Results (from on-device processing)

• Attention/focus-related metrics and signals produced locally on your device (e.g., scores, intervals, session statistics, reminders triggered)
• These are NOT raw video/images

D. Communications

• Support requests, feedback, survey responses, and messages you send to us

E. Cookies and Similar Technologies

• Essential cookies for authentication and core functionality
• Optional analytics cookies only where permitted and, where required, with your consent

3. How We Use Personal Data

We use personal data to:

• Provide the Service (account creation, authentication, core functionality, storing and showing derived results/history)
• Maintain and improve the Service (debugging, performance monitoring, product analytics, quality improvements)
• Train, evaluate, and improve our attention/focus machine-learning models using anonymized derived data (e.g., gaze direction, attention metrics, session statistics) — see “Use of Anonymized Data for Model Training” below for details and your withdrawal right
• Secure the Service (fraud prevention, abuse detection, account protection)
• Provide customer support and communicate with you (service notices, responding to requests)
• Manage subscriptions and billing status (if you purchase paid plans)
• Comply with legal obligations and enforce our Terms

4. Legal Bases (GDPR)

We process personal data under the following legal bases, depending on context:

• Contract (Art. 6(1)(b)): to provide the Service you request
• Legitimate interests (Art. 6(1)(f)): security, fraud prevention, service improvement, and certain analytics
• Consent (Art. 6(1)(a)): where required by law (e.g., non-essential cookies, certain optional analytics)
• Legal obligation (Art. 6(1)(c)): when we must comply with applicable laws

5. Special Category Data and Biometrics

We do not intentionally collect or process special category data (such as health data) and we do not use camera-based features to identify you. We do not create biometric templates for the purpose of uniquely identifying you. However, attention/focus metrics may still be personal data and are treated accordingly.

6. Use of Anonymized Data for Model Training

To improve attention/focus detection quality, we may use derived results produced on your device (for example, gaze direction signals, attention/focus metrics, session statistics, and event traces) to train, evaluate, and improve our machine-learning models. Before any such use, the data is aggregated and/or anonymized so that it no longer identifies you and cannot reasonably be linked back to you or your account.

We do not use raw video or images for model training — raw camera input is processed only on your device and never reaches our servers. Anonymized data may be retained and used for model development for as long as it remains useful for those purposes.

Your withdrawal right: you can ask us to stop using your data for model training at any time, and request deletion of derived results associated with your account. Anonymized data that has already been incorporated into trained models cannot always be removed from those models, but we will stop using your future data for training and remove any still-identifiable records on request. Email contact@focuszen.io to exercise this right.

7. Sharing and Disclosure

We may share personal data with:

• Service providers that help us operate the Service (hosting, databases, analytics, error monitoring, customer support tools)
• Payment providers (if you purchase a subscription)
• Legal and safety disclosures if required by law or to protect rights, safety, and security
• Business transfers (e.g., merger, acquisition)

We do not sell personal data.

8. International Transfers

If personal data is transferred outside the EEA/UK, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) and/or the UK International Data Transfer Addendum, or we rely on adequacy decisions where applicable.

9. Data Retention

We keep personal data only as long as necessary for the purposes described:

• Account data: for as long as your account remains active, and for a reasonable period after deletion
• Derived results: for as long as needed to provide history, analytics, and Service functionality
• Security logs: retained for a limited period appropriate for security and troubleshooting
• Billing records: retained as required by tax/accounting laws

You may request deletion at contact@focuszen.io

10. Security

We use appropriate technical and organizational measures to protect personal data, including encryption in transit, access controls, and security monitoring. No system is perfectly secure, but we work to protect your data.

11. Your Rights (GDPR)

You may have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your personal data
• Restrict processing
• Data portability
• Object to processing based on legitimate interests
• Withdraw consent (where processing is based on consent)
• Lodge a complaint with a supervisory authority in your country

To exercise your rights, email contact@focuszen.io

12. Cookies (Web)

If you use the web version, we use essential cookies required for login and core operation. Where we use optional analytics cookies, we will ask for consent when required and provide controls to withdraw consent.

13. Children

The Service is not intended for children under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided personal data, contact contact@focuszen.io

14. Changes to This Privacy Policy

We may update this Privacy Policy at any time. We will post the updated version and change the "Last updated" date above. If changes are material, we will provide additional notice where appropriate.

15. Contact

For privacy questions and requests: contact@focuszen.io