Privacy Policy

Last updated: March 15, 2025

This Privacy Policy regulates the download, access, and use of the mobile applications (hereinafter, the “APPS”) owned by FociiLabs, which are available to users free of charge on Google Play (Android) and Apple Store (iOS) and can be accessed through the links available on the website (https://fociilabs.com/). By downloading and using the APPS, users acknowledge having accepted and consented unreservedly to this Privacy Policy.

1. Responsible for Apps

FociiLabs LLC (hereinafter “FociiLabs”), with Tax Identification Number 7502345744, and registered office at 7151 Moffatt Rd., Richmond, BC V6Y3G9, Canada, and email: support@fociilabs.com, is the owner and responsible for the APPS.

2. Object

The APPS are designed to provide users with quick and simple access to motivational phrases, daily affirmations, jokes, vocabulary, curiosities, and other general interest content (hereinafter “content”) via their mobile devices, customizable to the frequency of their choice.

3. Privacy Policy

In compliance with applicable personal data protection regulations, FociiLabs informs users that personal data provided through the APPS, email (support@fociilabs.com), or other communication methods will be processed by FociiLabs as the Data Controller.

3.1 What is Personal Data and What Data is Processed?

FociiLabs collects the following data:

  • Universally Unique Identifier (UUID): A randomly generated identifier assigned to each user upon installation of the APPS. This UUID does not contain or link to any personally identifiable information such as name, email, or contact details. It is used solely to distinguish individual users within the APPS.
  • Debug Feedback Data: When users submit debug feedback, FociiLabs collects information about the device type (e.g., manufacturer and model) and Android version (or iOS version for Apple devices). This data is used to troubleshoot issues and improve the APPS’ performance.

FociiLabs does not collect:

  • Personal data such as name, email address, or phone number (unless voluntarily provided by the user via email to support@fociilabs.com).
  • Location data (e.g., IP-based geolocation, GPS data).

Additionally, FociiLabs automatically collects limited technical information when users access or use the APPS, including:

  • Log and Usage Data: Basic diagnostic and performance information (e.g., usage timestamps, error reports) that does not identify the user but helps maintain APP functionality.
  • Device Data: Device type, operating system version, and similar non-identifying technical details.
  • Push Notifications: Optional notifications about account or APP features, which can be disabled in device settings (no additional data is collected for this purpose).

This information is collected solely to ensure the security, operation, and improvement of the APPS.

3.2 Data Controller

Data is processed by FociiLabs LLC.

FociiLabs processes the collected data for the following purposes, with corresponding legal bases and retention periods:

  • Provision of Requested Services
    • Purposes: a. Deliver the APPS’ functionality using the UUID to track user preferences or settings within the APPS. b. Provide customer support if users contact FociiLabs via email. c. Troubleshoot and resolve technical issues using debug feedback data.
    • Legal Basis: Performance of a contract (i.e., providing the APPS’ services as requested by the user).
    • Retention: The UUID is retained for the duration of the user’s interaction with the APPS (e.g., until uninstallation). Debug feedback data is kept only as long as necessary to address reported issues, then securely deleted.
  • Service Improvement
    • Purposes: Analyze device type and OS version from debug feedback to enhance APP compatibility and performance.
    • Legal Basis: Legitimate interest of FociiLabs to improve its services.
    • Retention: Data is anonymized or aggregated after use and retained only as long as needed for analysis, then deleted.
  • Data Recipients: FociiLabs shares data only with:
    • Service providers (e.g., cloud or analytics providers) under strict confidentiality agreements, where necessary for APP operation or debugging.
    • Public authorities, if required to comply with legal obligations.

All data is treated confidentially with appropriate security measures. FociiLabs does not share the UUID or debug data with third parties for marketing or unrelated purposes.

3.4 Minors

The APPS are intended for adults. Given the minimal data collection (UUID and debug feedback), FociiLabs does not knowingly collect data from minors. If a minor’s use is detected, FociiLabs will delete any associated UUID and notify relevant authorities if required. Users are encouraged to report such incidents to support@fociilabs.com.

3.5 International Transfers

FociiLabs, based in the Canada, may transfer the UUID and debug data internationally to service providers (e.g., for cloud storage or analytics). Users consent to this transfer by accepting this Privacy Policy. Examples include:

FociiLabs ensures compliance with applicable data protection laws in the user’s country of residence, applying adequate safeguards. Given the anonymized nature of the UUID and debug data, risks associated with international transfers are minimal.

3.6 Exercise of Rights

Users have the following rights over their data:

  • Access: Confirm if data (e.g., UUID) is processed and obtain details.
  • Rectification: Correct any inaccuracies (though unlikely given the data’s nature).
  • Deletion: Request removal of the UUID or debug data.
  • Limitation: Restrict processing under certain conditions.
  • Opposition: Object to processing based on personal circumstances.
  • Portability: Receive the UUID in a machine-readable format (debug data is not portable as it is not personal).

To exercise these rights, users should email support@fociilabs.com with sufficient identification (e.g., the UUID, if known). Given the minimal data collected, most requests will relate to deletion of the UUID.

3.7 Data Protection Officer and Complaints

For inquiries, contact support@fociilabs.com. For data protection issues, reach the Data Protection Officer at dpo@fociilabs.com. Users may also file complaints with their local data protection authority, though the minimal data collection reduces the likelihood of disputes.

3.8 Security

FociiLabs implements technical and organizational measures to protect personal data per applicable regulations, using secure HTTPS protocols for data transfers to prevent interception.

3.9 Third-Party Data

FociiLabs does not collect third-party data through the APPS. If users provide such data via email, they confirm having obtained prior consent for its transfer.

3.10 Changes to the Privacy Policy

FociiLabs may update this Privacy Policy, with the latest version available in the APPS. Significant changes (e.g., introducing new data collection) will be communicated in advance via the APPS or email (if provided), allowing users to exercise their rights.