Privacy Policy

1. Introduction

At Focusence, we are committed to protecting your privacy and ensuring that your personal data is handled in a safe and responsible manner. This Privacy Policy describes the types of personal information we collect, how we use, disclose, and protect it, as well as the choices available to you regarding your information. We comply with the General Data Protection Regulation (GDPR) and other relevant data protection laws applicable in Cyprus and the European Union.

By using our services, you agree to the terms outlined in this Privacy Policy. If you do not agree with this policy, you should not use our services.

2. Data Controller

Focusence is the data controller for your personal data. This means we determine the purposes and means of processing your personal data. If you have any questions or concerns regarding the processing of your personal data, you can contact us via the contact information provided at the end of this document.

3. Information We Collect

3.1 Personal Identification Information

• Name
• Email address
• Phone number
• Postal address
• Gender
• Date of birth

3.2 Account Information

• Username
• Password (hashed)
• Profile picture
• Preferences (such as notifications, language, etc.)

3.3 Usage Data

• IP address
• Browser type and version
• Device type
• Time zone
• Access times and dates
• Referring URL
• Pages viewed
• Duration of visits

3.4 Payment Information

• Billing information, including credit card details
• Transaction history
• Payment confirmation

3.5 Communication Data

• Messages, feedback, and survey responses
• Customer support inquiries
• User-generated content (comments, posts, etc.)

4. How We Use Your Data

We use the personal data we collect for various purposes, including but not limited to:

• To provide and maintain our services. This includes creating and managing your account, processing payments, and delivering features that enhance your user experience.
• To communicate with you. We use your data to send you transactional emails (e.g., billing information, service updates), as well as promotional messages, surveys, and newsletters (subject to your consent).
• To personalize your experience. Your preferences help us offer a more tailored and relevant experience.
• To improve our services. We analyze usage data to identify trends, fix bugs, and optimize our features that align with user preferences.
• To comply with legal obligations. We may need to process personal data for compliance with applicable laws, including anti-fraud measures, taxation, and other regulatory requirements.

5. Legal Basis for Processing Your Data

Under the GDPR, we rely on the following legal bases for processing your personal data:

• Consent: Where you provide us with your explicit consent (e.g., to send marketing communications, cookies, or for data collection).
• Contractual Necessity: To fulfill our obligations under our agreement with you (e.g., process payments, provide the service).
• Legal Obligation: When we need to comply with legal requirements (e.g., tax law, fraud prevention).
• Legitimate Interests: To improve our services, ensure the security of our app, and protect our business interests.

6. How We Share Your Data

We do not sell your personal data. However, we may share your information under the following circumstances:

• Service Providers: We may share your data with third-party service providers who help us operate our business. These include:
  • Payment processors (e.g., for billing)
  • Cloud storage providers
  • Email marketing services
  • Customer support tools
  • Analytics platforms
  These third parties are obligated to protect your data in accordance with our instructions and applicable data protection laws.
• Business Transfers: In the event that we are involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. We will notify you before your data is transferred and becomes subject to a different privacy policy.
• Legal Obligations: We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When your account is terminated, we will delete or anonymize your personal data, unless we are obligated to retain it for legal reasons (e.g., financial records for tax purposes).

8. Your Rights Under GDPR

As a user of our services, you have the following rights under the GDPR:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: If any of the data we hold is inaccurate or incomplete, you can ask us to correct it.
• Right to Erasure: You can request the deletion of your personal data under certain circumstances (e.g., when the data is no longer necessary for the purposes for which it was collected).
• Right to Restrict Processing: You can request that we limit the processing of your personal data in certain cases (e.g., if you contest the accuracy of the data).
• Right to Object: You can object to the processing of your personal data based on our legitimate interests.
• Right to Data Portability: You have the right to request a copy of your data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: If we process your data based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at the details provided at the end of this policy.

9. Security of Your Data

We implement appropriate technical and organizational measures to safeguard your personal data from unauthorized access, alteration, disclosure, or destruction. This includes encryption, firewalls, and secure access controls. Despite our efforts, no method of transmission over the internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

10. Cookies and Tracking Technologies

We use cookies and other tracking technologies to enhance your experience and gather information about your use of our services. Cookies are small files stored on your device that allow us to recognize you when you return to our website or app.

You can manage your cookie preferences through your browser settings or by using our cookie management tools. Please note that if you disable cookies, certain features of our services may not function properly.

11. International Data Transfers

As part of our global operations, your personal data may be transferred to, and stored at, destinations outside the European Economic Area (EEA). Where this occurs, we ensure that the transfer is subject to appropriate safeguards, such as Standard Contractual Clauses, to protect your data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the date of the latest revision will be reflected at the top of the page. We encourage you to review this policy periodically to stay informed about how we are protecting your data.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: