Privacy and Cookie Policy

This Privacy Policy applies to the collection of your personal data as well as to the use of “cookies” and similar technologies in the context of the Focusly application (“App” or “Focusly”). The operator of the application is the company FOCUSLY Sp. z o. o. with registered office in Warsaw, ul. Skierniewicka 16/20, 01-230 Warszawa (Poland), registered in the Business Register of the State Court Register, which is maintained by the District Court of Warsaw. XIV. Economic Department of the State Court Register, KRS-number: 0 000 906 254, REGON: 389 239 372, Tax ID: 1 133 035 742 (“Focusly”, “We” or “Our”).

Your Privacy is important to us!

We recognize that your privacy is very important to you and that it is your right to control what information we process about you and how we process it. We know that providing personal data is an act of trust and we take that trust seriously. Focusly will never sell, rent or otherwise disclose your personal data, except as outlined in the Privacy and Cookie Policy, provided that we have an appropriate legal basis for such a disclosure (your consent or a legal obligation). Focusly is the controller of your personal data and takes appropriate steps to ensure security of your data.

By installing and starting to use the App or by your continued use of our services following the posting of new versions of this Privacy Policy (as applicable), you confirm that you rear and agree to be bound by provisions of the Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy forms part of and should be read in conjunction with our Terms of Use and any additional applicable terms on our services.

For important reasons, we may periodically be required to make changes to our Privacy Policy (for example if we substantially change the way our services or the App functions, or following legislative changes). We will notify you of these changes by e-mail and/or through an in-App popup, as well as by posting the modified Privacy Policy on the dedicated website: https://focusly.co/. We recommend that you revisit this Privacy Policy regularly.

Should we start using your personal data in a manner materially different from that stated at the time of collection, we will also notify you by e-mail and/or through an in-App popup. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy.

What data we process

In the course of your use of our services, we collect the following personal data:

Registration data: your e-mail address and password, first name, last name and credit card details. We process this information in order to create and manage your account with us, contact you as well as to enable payment for our services. We only use payment information, such as credit card numbers, as necessary for completing a particular transaction or providing a service and to prevent fraud or abuse of our services. Provision of registration data is mandatory – otherwise, we will not be able to provide our services to you. For the purpose of fraud prevention, we also process your data from the registration form,information about your interaction with the Focusly Application and data about your device and the operating system.

Legal basis of processing: processing of your registration data is necessary for the purpose of concluding and performing the contract with you (i.e. for creation of your user account with us and offering services to you).

Data collected through your use of our services: when you use our services, we collect information about your in-App subscriptions and your user interaction with Focusly. We collect such data in order to:

tailor our services to your needs, which is the essence of services we provide,
to enhance our relationship with you
to help deliver first-rate experience through improving our services, customizing the content and advertising materials
to identify content you share when you use the our services
compiling aggregate data for internal and external business purposes
conducting research. Focusly’s legitimate interest in preventing fraud.

By doing that, we may profile your personal data, which means that we may use the data we collect to adjust the services we provide to meet your needs. In such cases, we do not, use your personal data in a way that would result in automated decision-making that could affect your legal rights, produce legal effects or otherwise similarly affect you (i.e. we do not use algorithms to make decisions which would have an impact on your individual legal rights or significantly affect your legal status or rights under the agreement between us). Provision of such data is necessary if you wish to use our tailored services – otherwise we will not be able to give you customized content.

Legal basis of processing:

performance of the contract with you, for processing of data for the purpose of tailoring services to your needs;
our legitimate interest in direct marketing of our services for processing your data for customizing advertisements.

Marketing. We also process your data for general marketing purposes, i.e. sending you marketing e-mails, provided that you did not opt out from such forms of communication. In processing your data for this purpose, we pursue our legitimate interest in direct marketing of our own services, which constitutes the legal basis for processing of your data. Provision of your personal data is voluntary, but if you don’t provide us with your e-mail address, we will not be able to reach out to you.

Legal basis of processing: our legitimate interest in direct marketing of our services.

Log data.As you use the Services, our servers automatically record information that the browser sends whenever it points to a website or online service (“Log Data“). Log Data may include, but is not limited to: your computer’s Internet Protocol address, browser type, the web page you were visiting before you came to one of the Sites and the particular information you search for on a Site. We process such data for the purpose of ensuring security, recording your preferences and for general marketing purposes.

Legal basis of processing: our legitimate interest in

ensuring security;
direct marketing of our services.

Data collected from Facebook. If you choose to log into the App via Facebook, we will collect your user name, e-mail address and profile picture. We will process such data for the purpose of enabling your login. We do not collect any other personal data from Facebook, however, we may be using Facebook analytical services based on anonymized, aggregated data.

Legal basis of processing: processing of your data is necessary for the purpose of concluding and performing the contract with you (i.e. for creation of your user account with us and offering services to you).

Your rights

You have the right to object to the processing of your data by us, when it is based on legitimate interest (in particular when processed for marketing purposes). You also have the right to request that we correct or delete your data, if you find out that certain information about you is incorrect or outdated. You also have an option to update and correct your personal data in directly in your user account, in the settings pane of the App.

If your data is processed based on consent, you have the right to withdraw it at any time, however, the withdrawal shall not affect the legality of processing conducted prior to the withdrawal.

If you file a request that we stop processing your data and delete it, we will do so unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data, for example for accounting or tax purposes) which will entitle us to keep your personal data for a longer period. You also have the right of access to your data, to request a copy of data that we process about you, as well as the right to data portability and to restriction of processing.

We process your personal data only for as long as necessary for the purposes, for which it was collected. In establishing the appropriate retention period for your personal data, we take into account, among others, the following criteria:

whether you express continuous interest in our services,
whether you still have an account with us and if you use it,
whether there are specific legal obligations to retain your data (e.g. for accounting and tax purposes).

We entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular we use data processors, whom we select carefully, to store your data on secure servers located within the territory of the EU. Appropriate safeguards are applied, in particular we take care to appoint only trusted and verified processors and we sign GDPR-compliant data processing agreements with them.

We share your personal data with payment service providers for the purpose of processing your payments. The transfer is made based on our legitimate interest and because it is necessary for the performance of contract with you. We may also be obliged to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).

Focusly may also be obliged to share your data in case it buys or sells subsidiaries or business units, in connection with a corporate transaction, such as a sale, merger, consolidation or asset sale, or an internal reorganization, or in the unlikely event of an insolvency. If such a transaction or event required the transfer of customer information, that information remains protected by the regulations of any pre-existing Privacy Policy or equivalent. You will also be notified of such a transfer beforehand. We also entrust the processing of your personal data to entities providing for us anti-fraud services.

If you have any questions about the processing of your data or if you wish to exercise your rights, please contact the Data Protection Officer appointed by Focusly: iod@focusly.co. In addition, you are entitled to lodge a complaint with a data protection authority.

Our use of cookies and similar technologies

In order to improve the operation of the App, we use cookies, web beacons, device fingerprinting and similar technologies. We also make use of Google Analytics tools.

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The following types of cookies are used on the Website:

Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Strictly necessary cookies – These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
Performance cookies – These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
Functionality cookies – These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device. These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
Targeting or advertising cookies – These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

Web beacons (also known as pixel tags) are transparent image files used to monitor your journey around a single interact with the Website and its content.

Device fingerprinting is a technology which allows us to collect information about your device (what browser or operating system you use, plug-ins, time zone, other settings). We use this information to identify you and to ensure security of our website.

Cookies and similar technologies (web beacons, device fingerprinting) are used for statistical purposes, to adapt the website content, performance and structure to users’ individual preferences, to provide users with advertising content adapted to their preferences. Cookies and web beacons for ads targeting purposes can be linked to other online services, such as Facebook. Please note that cookies may collect personal information to enhance the site’s functionality. Such data is stored in encrypted form and the access to them is limited. Cookies that are used by the third parties via the Website, including in particular the users of the website, are subject to their own privacy policy

Handling and use of “cookies” and similar technologies is allowed automatically. However, these settings can be changed at any time. For details on how cookies are handled and used, see the settings of your web browser. You can learn more about cookies and similar technologies and check how to disable them for the browser you use by visiting the following website: http://www.allaboutcookies.org.

Google Analytics: we use third party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Products use Google Analytics & Firebase code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visit www.google.com/analytics.

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.

For the above purposes, we may require that you share with us the following information:

(a) Android Advertising ID.

(b) Apple’s Advertising Identifier (IDFA)

(c) Personal information including, for example, e-mail address and information about your usage of the Products and information collected by tracking technologies.

(d) Device Information such as operating system version, device type, and system performance information.

The information that we request will be retained by us and used as described in this privacy policy.The App does use third party services that may collect information used to identify you.Link to privacy policy of third party service providers used by the App:

(a) Google Play Services

(b)Apple Customer Privacy Policy.