Privacy Policy – Focado App

Version 1.0.0 | 30/11/2025

This Privacy Policy explains how Fulmin processes your personal data when you use the Focado mobile application (“the App”). By using the App, you agree to this policy. If you do not agree, please do not use the App.

ENTITY NAME: Fulmin
ADDRESS: Anemoonstraat 10, 9030 Mariakerke, Belgium
EMAIL: info@fulmin.be
COMPANY / VAT NUMBER: BE0652.649.256
DEVELOPER IDENTITY: Fulmin is a Belgian software company developing productivity and collaboration tools.

1. Data controller

Fulmin (“we”, “us”) is responsible for the processing of your personal data in the context of the Focado App. We only process data that is necessary for the functioning, improvement and security of the App.

No separate EU representative or DPO is required. You can contact us at any time via info@fulmin.be.

2. What data do we collect?

Depending on which features you use, we may process the following categories of data:

• Account & profile: name, display name, email address, avatar, preferred language, groups/teams.
• User content: tasks, lists, notes, events, habits, journal entries, comments, shared items, attachments (images, files, audio), and optional voice notes.
• Usage & diagnostics: in-app actions, crash reports, performance metrics, error logs.
• Device & log data: device model, operating system, app version, IP address (temporary), timestamps.
• Notifications: push notification tokens (e.g. FCM tokens).
• Contacts & collaboration: email addresses or user IDs of people you invite or collaborate with.
• Advertising (AdMob): advertising identifiers, coarse location, ad interaction data.
• Location (optional): only if you enable location-based features; disabled by default.

Your content may be stored locally on your device (via Drift) and in the cloud (Firebase Cloud Firestore) to enable synchronization between devices and secure backups.

3. Purposes and legal bases

We process your data for the following purposes and based on the following legal grounds:

Where processing is based on consent, you can withdraw that consent at any time via the App settings (where available) or by contacting info@fulmin.be.

4. Third-party processors and services

We use third-party services to operate the App. These providers may process data in the European Economic Area (EEA) or in other countries with appropriate safeguards:

• Firebase Authentication – user authentication and sessions
• Firebase Cloud Firestore – data storage and synchronization
• Firebase Cloud Messaging – push notifications
• Firebase Crashlytics & Analytics – diagnostics and performance
• Google AdMob – advertisements within the App

Data processed by these services is subject to the privacy policies of Google and its affiliates. We rely on appropriate legal mechanisms (such as Standard Contractual Clauses) for international data transfers.

We do not sell your personal data.

5. Data sharing

We only share your data with:

• our service providers (as processors) under appropriate contracts;
• other users you explicitly collaborate or share with inside the App;
• authorities where required by applicable law.

6. Data retention

We retain your data only as long as necessary for the purposes described above:

• Account & profile data: kept while your account remains active.
• User content: stored until you delete it or delete your account.
• Logs & diagnostics: kept according to provider defaults (typically 90 days–24 months).
• Backups: temporary backups may be created and retained for operational and security reasons.

When you request account deletion, we delete or anonymize your personal data unless we are legally required to keep certain data longer.

7. Synchronization & backups

The App uses local storage (Drift) and cloud storage (Firebase Firestore) to keep your data in sync across devices. As part of normal infrastructure operations, secure backups may be created and stored temporarily in Google Cloud.

8. International data transfers

Where data is transferred outside the EEA, we rely on legal mechanisms such as the EU Standard Contractual Clauses (SCCs) or other GDPR-compliant safeguards to protect your data.

9. Your rights

Under applicable data protection law (including GDPR, where applicable), you have the right to:

• request access to your personal data;
• correct inaccurate or incomplete data;
• request deletion of your data (“right to be forgotten”);
• request restriction of processing;
• receive your data in a portable format, where technically feasible;
• object to certain processing operations (e.g. based on legitimate interests);
• withdraw consent at any time, where processing is based on consent.

You can exercise these rights by contacting info@fulmin.be.

You also have the right to lodge a complaint with a supervisory authority, for example the Belgian Data Protection Authority (GBA).

10. Children’s privacy

The App is not directed at children under the age of 16. If we discover that we have collected personal data from a child without appropriate consent, we will delete that data.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse or alteration. No method of transmission or storage is completely secure, but we make reasonable efforts to protect your information.

12. Account deletion

You can request full deletion of your account at any time:

• via the in-app account deletion option (where available);
• or by emailing info@fulmin.be.

After deletion, we will remove or anonymize your personal data, except where we must retain certain information for legal or regulatory reasons.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the version and date at the top of this page. For material changes, we may also notify you within the App or by email.