SmartZonesIndicators ("we", "us", "our"), a company registered in France, develops and publishes FocusFlow, a Pomodoro timer application for iOS and watchOS ("the App"). We are committed to protecting your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the French Data Protection Act (Loi n 78-17 du 6 janvier 1978, as amended), and applicable privacy laws.
This Privacy Policy explains what data we collect, why we collect it, how we process it, and what rights you have regarding your personal data.
Contact:
Data Protection Officer (DPO): Pursuant to Article 37 of the GDPR, we are exempt from the obligation to appoint a Data Protection Officer as we do not carry out large-scale processing of special categories of data or large-scale systematic monitoring of individuals. For any privacy-related request, please contact us at support@smart-zones-indicators.com.
| Data | Purpose | Legal Basis | Retention |
|---|---|---|---|
| Focus profile type (e.g., Short Focus, Hyperfocus, Creative, Standard) | Personalize timer settings and suggestions | Legitimate interest (Art. 6(1)(f)) | Until account deletion or profile reset |
| Preferred session duration | Configure default timer | Legitimate interest (Art. 6(1)(f)) | Until account deletion or profile reset |
| Focus goals | Tailor the experience | Legitimate interest (Art. 6(1)(f)) | Until account deletion or profile reset |
| Preferred soundscape | Audio preferences | Legitimate interest (Art. 6(1)(f)) | Until account deletion or profile reset |
| Data | Purpose | Legal Basis | Retention |
|---|---|---|---|
| Session history (start time, duration, type, completion status, interruptions) | Statistics, insights, streak tracking | Contract performance (Art. 6(1)(b)) | Stored locally; retained until you delete the App or clear data |
| Momentum and streak data | Dashboard and motivation features | Contract performance (Art. 6(1)(b)) | Stored locally; rolling 30-day window |
| Badges and achievements | Gamification | Contract performance (Art. 6(1)(b)) | Stored locally; retained until account deletion |
| App settings and preferences | App functionality | Contract performance (Art. 6(1)(b)) | Until account deletion |
If you grant permission, we may read the following from Apple HealthKit:
| Data | Purpose | Legal Basis | Retention |
|---|---|---|---|
| Heart rate during sessions | Correlate focus quality with biometric data | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) | Processed locally in real time; never stored outside HealthKit |
| Sleep data | Sleep-focus correlation insights | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) | Processed locally in real time; never stored outside HealthKit |
| Heart rate variability | Stress and recovery insights | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) | Processed locally in real time; never stored outside HealthKit |
HealthKit data never leaves your device. It is not transmitted to our servers, not stored in any cloud service, not shared with any third party, and not used for advertising.
| Data | Purpose | Legal Basis | Retention |
|---|---|---|---|
| Subscription status (active/expired, tier) | Unlock premium features | Contract performance (Art. 6(1)(b)) | Duration of subscription + 1 year |
| Transaction identifiers (from StoreKit) | Purchase verification | Contract performance (Art. 6(1)(b)) | Duration of subscription + 1 year |
Payment processing is handled entirely by Apple. We never receive or store your payment method details (credit card numbers, billing address, etc.).
All data processing occurs locally on your device. This includes:
FocusFlow uses rule-based heuristics to provide personalized insights and suggestions (e.g., optimal session duration, best time of day to focus, soundscape recommendations). These are deterministic algorithms based on your session history and profile preferences. No machine learning models, neural networks, or artificial intelligence systems are used. These heuristics do not produce legal effects or similarly significant effects on you. You may adjust or ignore any suggestion at any time.
If you enable iCloud sync on your device, your session history, preferences, and profile data may be synced via Apple CloudKit to your other Apple devices signed into the same Apple Account. This data is:
You can disable iCloud sync for FocusFlow at any time in your device Settings > [Your Name] > iCloud.
We do not sell, rent, or share your personal data with any third party. The only data transmissions that occur are:
| Recipient | Data | Purpose |
|---|---|---|
| Apple (App Store Connect) | Anonymized, aggregated analytics | App Store standard analytics (opt-in by user at device level) |
| Apple (CloudKit) | Session data, preferences (if iCloud sync enabled) | Cross-device synchronization |
| Apple (StoreKit) | Transaction data | Purchase processing and verification |
| Data Category | Retention Period |
|---|---|
| Onboarding profile data | Until profile reset or app deletion |
| Session history | Until app deletion or manual data clearing |
| Momentum/streak data | Rolling 30-day window |
| HealthKit data | Processed in real time; never persistently stored by FocusFlow |
| Purchase records | Duration of subscription + 1 year |
| App preferences | Until app deletion |
When you delete the App, all locally stored data is permanently removed from your device. If iCloud sync was enabled, you may also delete cloud data via Settings > [Your Name] > iCloud > Manage Storage.
We implement appropriate technical and organizational measures to protect your data:
As a data subject, you have the following rights:
| Right | Description |
|---|---|
| **Access** (Art. 15) | Request a copy of your personal data |
| **Rectification** (Art. 16) | Correct inaccurate data |
| **Erasure** (Art. 17) | Request deletion of your data ("right to be forgotten") |
| **Restriction** (Art. 18) | Restrict processing of your data |
| **Data Portability** (Art. 20) | Receive your data in a structured, machine-readable format |
| **Objection** (Art. 21) | Object to processing based on legitimate interest |
| **Withdraw Consent** (Art. 7(3)) | Withdraw consent at any time (e.g., HealthKit access) without affecting prior processing |
To exercise any of these rights, contact us at: support@smart-zones-indicators.com
We will respond within 30 days of receiving your request, in accordance with Article 12(3) of the GDPR.
Since most data is stored locally on your device, many of these rights can be exercised directly:
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will:
Given that FocusFlow processes data locally on your device and does not maintain centralized user databases, the risk of a data breach affecting multiple users is extremely limited.
FocusFlow is not directed at children. In accordance with Article 8 of the GDPR and French law (Article 45 of Loi n 78-17), users must be at least 15 years old in France (or the applicable minimum age in their country of residence, which is 16 years in most EU member states) to use the App.
FocusFlow is a productivity tool. It is not a medical device within the meaning of Regulation (EU) 2017/745 (EU Medical Device Regulation). It does not diagnose, treat, cure, monitor, or prevent any medical condition, including but not limited to attention disorders. The focus profiles (Short Focus, Hyperfocus, Creative, Standard) are productivity preferences and do not constitute medical assessments.
If you have concerns about attention, concentration, or any other health matter, please consult a qualified healthcare professional.
You have the right to lodge a complaint with a supervisory authority. For users in France, the competent authority is:
CNIL (Commission Nationale de l'Informatique et des Libertes)
3 Place de Fontenoy, TSA 80715
75334 Paris Cedex 07, France
https://www.cnil.fr
We may update this Privacy Policy from time to time. Changes will be communicated through the App (in-app notification or updated "Last Updated" date). Continued use of the App after changes constitutes acceptance of the revised policy. For material changes, we will provide prominent notice.
For any privacy-related questions, requests, or complaints:
SmartZonesIndicators
Email: support@smart-zones-indicators.com