Welcome to the Focus App Privacy Policy ("Policy"). There’s a bunch of very detailed information below, but If you want the condensed version, here it is: the personal data you share with Focus is primarily used to provide you with the best Focus experience. We are committed to keeping your data safe and private, [and we do not share individualized personal information with third parties for their own direct marketing purposes[].
PURPOSE
This Policy describes how Focus Dating LLC (“us,” “we” or “Focus”) collects, uses, stores, protects, discloses, and otherwise processes the personal data you provide while using the Focus application or the Focus website (collectively referred to as the “Service”).
As described in the Terms and Conditions of Use, we require users of the
Service to be at least 18 years of age. Focus does not knowingly collect any
information about or market to children, minors or anyone under the age of
18. If you are less than 18 years old, we request that you do not submit
information to us. If we become aware that anyone under the age of 18 has
registered with us and provided us with personal information, we will
terminate that person's registration and delete their Registration
Information from Focus. If we do delete a profile because you violated our
minimum age requirement, we may retain your email and IP address to ensure
that you do not try to create a new profile.
If you suspect that a user is under the age of 18, please use the report profile mechanism available through the Service.
As used in this Policy, “personal data” is data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We need certain personal data in order to:
Provide you with access to our Service and any other information or services that you request from us.
Fulfill any other purpose for which you provide it.
Give you notices about your Account, including expiration and renewable notices.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when Service updates are available, and of changes to any products or services we offer or provide through it.
To process your personal data as outlined below, we rely on the following legal bases:
Contractual Performance: The primary reason we process your personal data is to perform the contract that you have with us. For example, as you use our Service, we use your personal data to create and maintain your Account, limit access to the platform, to make it visible to other users and to recommend other users to you.
Legitimate Interests: We may also use your personal data where we have legitimate interests to do so. For instance, we review users’ actions while using our Service to improve our Service, and we process personal data for administrative, fraud detection and other legal purposes.
Consent: We may also ask for your consent to use your personal data for specific reasons. You may withdraw your consent at any time by contacting us as stated at the end of this Policy.
When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, which may include but is not limited to:
Name;
Username;
Email address;
Mobile number;
Gender identity;
Date of birth;
Sexual preference;
Photographs;
Location;
Login information and friend lists for social media accounts that you connect to your Focus Account (this could include, for example, your Facebook account ("Social Media Accounts");
Answers to prompts;
Your height;
Religious beliefs; and
Political beliefs.
You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your “Profile” page.
The information we collect helps to enhance the App and verify our Users are not robots.
When setting up or editing your profile, we have indicated which types of data are optional to provide (as opposed to mandatory). Your Registration Information allows us to match you with relevant people. Some of the personal data you choose to provide us with may be considered “special” or “sensitive”, such as your racial or ethnic origins, sexual orientation, political beliefs, and religious beliefs (“Sensitive Personal Data”). By choosing to provide this personal data, you consent to our processing of that data.
When you use the Service, we may collect personal data as you take actions within the Service, such as your interaction with other Focus users and your habits and behavior in using the Service. This may include but is not limited to passing, liking, commenting, messaging, blocks and abuse reports. Collecting this information allows us to optimize the Service for our users by refining our recommendation algorithm, diagnosing bugs or issues, developing new features, and monitoring for behavior that violates our Terms and Conditions of Use. This information is also used for financial reporting.
Please think carefully about the information you disclose about yourself to other members. We do not recommend that you share directly on your profile your email address, phone number, full name or addresses, credit card details, social security number, drivers' license details and other sensitive information which may be misused.
Please remember that photographs that you post on Focus may reveal information about yourself as well. When you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to allowing Focus to process your information and make it public to other users.
When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please note, if you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account.
We collect contact information in order to send you communications regarding our service, which you have the option of unsubscribing from.
We collect and analyze feedback that you provide in surveys, focus groups, and during Focus-sponsored events. This information is used to provide the Focus team with insights to improve the Service.
If you contact us via email, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you and about you from other Users.
When you use the Service we may collect some personal data about you automatically. This personal data includes but is not limited to: app version and build number, attribution campaign and source, authentication state, push token, device OS and version, device model, signup date, and first subscription date. Information we receive through Facebook include DOB, email, Facebook ID, first and last name, and gender. This personal data allows us to troubleshoot issues as well as detect fraud. This personal data also allows us to send alerts or communications in the form of push notifications, if you choose to opt into them.
If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the App and make it easier for you to interact with other Users, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.
If you have enabled location services, but wish to turn it off, you can do so on the iPhone app by routing to settings > privacy >location services> Focus.
Our primary concern is protecting your data and privacy to ensure you have the best experience while you’re on Focus. We may use and allow others to use “cookies” to know if you’ve used or visited our Service. The cookies we collect enable us to learn how users interact with Focus, which helps us make a better product for you.
Cookies are small files stored onto your device based on sites or apps you access. They typically contain information about the source of the cookie, and if or when the cookie will expire. Cookies may also have information about your device, user settings, browsing history or activity. These are specific for web browsers, and since Focus is a mobile-web app there are a few limited use-cases for cookies on Focus:
When you visit our help center, you are redirected from the app to the help page on focusdating.co.
When you visit focusdating.co through a web browser.
In both of these scenarios, Focus uses Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including where visitors have come from and the pages they visited. For more information about Google's Privacy Policy, please visit http://www.google.com/intl/en/policies/ .
First-party and third-party cookies:
There are first-party cookies and third-party cookies. First-party cookies are placed on your device directly by us. For example, we use first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of our website.
Third-party cookies are placed on your device by our partners and service providers. For example, we use third-party cookies to measure user numbers on our website or to enable you to share content with others across social media platforms. These third parties may use tracking technologies to collect information about you when you use this app. [The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.]
Session and persistent cookies:
There are session cookies and persistent cookies. Session cookies only last until you close your browser. We use session cookies for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently. Persistent cookies have a longer lifespan and aren't automatically deleted when you close your browser. These types of cookies are primarily used to help you quickly sign-in to our website again and for analytical purposes.
If you are hungry to learn more about cookies, including flash cookies/local storage devices, the following websites provide useful information:
Pages of the App [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages [or opened an email] and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
Our Service requires that you register with and/or connect using Facebook. We may collect personal data that you elect to allow us access to through their API. This data includes photos, videos, workplace, education, hometown, contact information and friend connections. Data from social networks may enhance your experience, but this data is not required in order to use our Service. We will comply with these services’ respective terms and policies with regard to how we use your data.
Other users may provide personal data about you as they use the Service (for example, if a man is referred to sign-up for Focus).
We may collect personal data about you from our partners, for example, data that is received from Focus ads displayed on a partner’s website(s) or information that these partners may pass along regarding a campaign’s success.
Our goal is to deliver you the best Focus experience possible. In order to do so, we may use your Registration and other information to:
offer you our services and features;
contact you with information about the App (e.g., updates and new offerings);
personalize the App and the content we deliver to you;
conduct research and analytics about how you use and interact with the App;
resolve disputes between you and other Users; and
investigate fraud, protect our legal rights, and enforce our Terms & Conditions.
We may share your personal data with other users, with service providers, and with partners who help us operate the Service, in the event of a business transaction and for law enforcement purposes, as set out below:
We will share personal data with other users when you voluntarily disclose that information on the Service. For example, we will display your profile to other users when we match you with them.
We may share your personal data with third parties to provide you with the Service (such as analytics services or customer relationship management services). We vet all service providers before we provide them with your personal data to ensure we have appropriate contractual safeguards in place.
If Focus is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, dissolution, bankruptcy or other change of control or ownership, we may transfer personal data in relation to that transaction.
We may share your personal data in the following circumstances: to comply with a legal process, like a court order, subpoena or search warrant, a government investigation or other legal requirements to help in the prevention or detection of crime (subject to applicable law); or to protect the safety of any person.
We may also share your personal data to enforce legal rights, including: to mitigate Focus' liability in an actual or threatened lawsuit; to protect our legal rights and legal rights of our users, partners or other interested parties; to enforce our agreements with you; and to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
We may share your personal data if we have first obtained your consent to do so.
To perform the contract that you have with us, we use automated decision-making and/or profiling in regard to your personal data, including Sensitive Personal Data, to match you with relevant people. We use automated decision-making and profiling to recommend matches to you based on your profile and the people you engage with. We also use automated decision-making and profiling to moderate “bad users” by flagging user profiles that may contain explicit content. If you choose to opt out of automated decision-making and profiling, we will not be able to provide our Service to you and you will be prompted to delete your Account. We do not otherwise use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Your data is accessible only on a need-to-know basis by Focus employees and third-party service providers.
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at [insert e-mail address here].
From time to time we may disclose your contact information to third parties [to allow them to market their products or services to you or for other marketing purposes]. This may be information we received from you offline and online. If you want us to stop further sharing of your email contact information with third parties (if we have your email contact information), you may notify us at [insert e-mail address here]. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you chose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users' personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users' online activities over time and across different online services when the users use the operator's service. We do not knowingly permit third parties to collect personal information about an individual User's online activities over time and across different online services when using the App.
When you delete your Account on Focus, we take reasonable efforts to make sure it is no longer viewable on the App. This means your profile is removed from distribution and anyone you are matched with will no longer have access to your profile or conversation. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
To prevent abuse and/or misuse of Focus by a User following forced termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.
We reserve the right to retain certain anonymized data for improvement of the Service, but this information will not be shared with other Users. We will scrub the unique components from the data, but keep certain usage metrics in order to ensure our Service continues to provide a quality experience to all our Users.
Please note that simply deleting the app from your phone does NOT delete your Account, as we have no way of knowing if you did this. To delete your Account, you navigate to “Settings” within the app and proceed to the bottom to Delete.
SECURITY
Focus takes reasonable measures to prevent the unauthorized access or alteration of (and disclosure or destruction of) your personal data, but ultimately, we make no assurances about our ability to prevent any such issues. We may suspend your use of all or part of the Service without notice if we suspect or detect any breach of security.
Unfortunately no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some tips to help keep your data secure:
Please make sure you log out of your Account after use.
Please don't share your social media password with anyone else.
Change your social media password periodically.
If you believe that your Account or personal data is no longer secure, please notify us immediately at [ help@focusdating.co].
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.
Below, we have outlined some of the tools you have access to, in order to control your personal data:
Tools in the Service: The Service provides certain tools that allow you to access, rectify or delete information that you provided through the Service and which is associated with you.
Device Permissions: Mobile operating systems have permission controls, such as access to camera and location services. You can control these options through your device’s settings. Please note that changing these settings may result in lost functionality within the Service.
Account Deletion: You can delete your account within the Service at any time by navigating to Settings > Account > Delete Account.
Uninstall: If you uninstall the app, you can stop the app from collecting all information. Please note that this will not delete your Account and we will retain the unique identifier associated with your device.
Opt-out. You may contact us at any time (as set out at the end of this Policy) to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the United States. Please note that your use of the Services may be ineffective upon opting out.
Reviewing your information: Applicable privacy laws may give you the right to review the personal data we maintain about you. To request access to your personal data, please contact us as set out at the end of this Policy.
Updating your information: If you think the information we hold about you is inaccurate or that we are not entitled to use it and would like to request rectification, deletion, or objection to our processing of this personal data, please contact us as set out at the end of this Policy.
Moving your information. Your data is portable – i.e., you have the flexibility to move your data to other service providers as you wish. To request this movement, please contact us as set out at the end of this Policy.
Accountability: Some countries, including those in the European Union, provide you with a right to file a complaint with the appropriate data protection authority if you have an issue with how we process your personal data.
For your protection, we may ask you to prove your identity before we answer any requests related to the above items. Note that we may reject a request for certain reasons, including if it is unlawful or if fulfilling the request will infringe upon a trade secret or other intellectual property or upon the privacy of another user.
The Service includes user-generated profiles and interactive messaging services. Please remember that any information that is disclosed in these areas may be seen and copied by other users and you should exercise caution when deciding to disclose personal data.
The Service may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies of those websites to confirm that you understand and agree with their policies.
We reserve the right, at any time, to add to, change, update, or modify this Policy. If any changes are made to this Privacy Policy, we will reflect the “Effective Date” for the updated Policy below. When making material change to this Policy, we will notify you via email before the changes take effect so that you can review the updates.
If after reviewing this Policy, you still have questions about our information practices, please contact us at help@focusdating.co with the subject line “Privacy Policy.”
Your access to the App, as well as this Privacy Policy are governed and interpreted by the laws of the state of New York other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the state of New York. By using the App, you are consenting to the exclusive jurisdiction of the courts of the United States and the State of New York. You agree that such courts shall have in personam jurisdiction and venue and waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail.
Focus Dating LLC is a Delaware Limited Liability Company. Our registered address is located at 2035 Sunset Lake Rd, Suite B-2, Newark, DE 19702.
Effective Date May 6, 2019.