1. Controller and scope
The data controller for Focaria is Victor Orrego, an individual, with a contact address at Medellin, Colombia. Focaria is the app's name, not a separate legal entity from its controller. Contact soportefocaria@billdefendai.com with privacy questions or to exercise your rights.
This policy describes the Focaria app for iPhone and iPad and inquiries you send us about it. It does not replace the policies of Apple or external services you visit. A Focaria website using cookies or additional analytics must provide separate information about those practices.
2. Summary
You do not need to create a Focaria account or provide us with your name or email to use the app. Study progress and your collection are saved on your device. However, subscription and update services process information outside your device, as described below. An identifier without your name does not necessarily make the data non-personal.
3. Information processed and purposes
Local progress and preferences
The app saves sessions, duration, dates, timer status, energy, packs, cards and duplicates, along with language preferences, notification settings, and onboarding choices. These records let you resume a session, calculate statistics, goals and streaks, and maintain your collection.
Focaria does not send this history or collection to its own server for synchronization. It does not record which books you read, what you study, or your activity in other apps. Device backups may include Focaria data depending on your settings and the backup provider's terms.
Subscriptions and purchase screens
Apple processes payments. Focaria uses RevenueCat to verify purchases, restore access, and manage offers and Focaria Pro status. Information processed includes transaction and product identifiers, dates, subscription status, an SDK-generated customer identifier, language, and technical details needed to provide that service.
RevenueCat may also record purchase-screen views and interactions to assess how offers perform. This is separate from sending study history. The app does not send a name, email address, or personal account identifier to RevenueCat. We do not receive your full payment card number or Apple password.
App updates
Focaria uses Expo/EAS Update to check for and download compatible updates. These connections provide the service with technical request data, such as IP address, platform, app or update versions, and technical installation or update identifiers. They are used for update delivery, compatibility, and service operation, not to store your collection.
Optional permissions
- **Motion:** if you enable this feature and the system permits it, orientation and motion readings are processed on your device to tilt cards. They are not sent to our providers or kept as a movement history.
- **Notifications:** if authorized, the app schedules local alerts when a session ends. This feature does not register a remote push notification token.
You can decline these permissions and continue using other features; cards remain touch-interactive. You can change permissions in your device settings and turn off session alerts in the app.
Support inquiries
If you contact us, we receive your email address, message, and any attachments you choose to send. We use them to respond and resolve your request. Do not send passwords, full payment card numbers, unnecessary identity documents, or sensitive information unrelated to the issue.
4. Grounds for processing
Where a legal basis is required, we rely on performance of the service for requested features, purchases, and support; legal obligations for records we must retain; and legitimate interests in maintaining a secure and reliable service for necessary security and operational measures, subject to your rights.
For permissions or processing requiring consent, we request it specifically and you may withdraw it. Where offer analytics requires consent in your jurisdiction, it must be obtained before activation. Using the app is not treated as blanket consent to optional processing.
5. Providers and disclosures
We share only information needed for the described purposes with the providers involved:
- **Apple:** store, billing, subscriptions, and system services. See its [Privacy Policy](https://www.apple.com/legal/privacy/).
- **RevenueCat:** subscription and offer infrastructure. See its [Privacy Policy](https://www.revenuecat.com/privacy).
- **Expo:** update distribution. See its [Privacy Policy](https://expo.dev/privacy).
- **Email or support provider:** [PROVEEDOR_SOPORTE], to receive and respond to inquiries you voluntarily send.
We require providers processing information on our behalf to make security, confidentiality, and data protection commitments appropriate to the information and applicable law. Apple also processes information under its own obligations as the store provider.
We may disclose information when legally required or necessary to address a claim or protect security, limited to relevant information. Focaria does not sell personal information or share it for cross-app or cross-site behavioral advertising. The version described does not integrate advertising networks.
6. International processing
Providers may process information outside your country, including in the United States. Where international transfer safeguards are legally required, the following apply: [GARANTIAS_TRANSFERENCIAS]. You may request information about those safeguards using our contact email. Publishing this policy does not replace agreements or mechanisms that must be established with providers.
7. Retention and deletion
- **Local data:** remains while the app's data is kept on your device. To remove it on iOS, use "Delete App", not merely "Offload App", which keeps documents and data. System backups are managed separately. Deleting this data may cause your collection to be lost.
- **Subscriptions and related records:** retained according to [CRITERIO_RETENCION_SUSCRIPCIONES], considering access validation and restoration, legal obligations, and dispute resolution. Records Apple retains for its own obligations are also governed by its policies.
- **Support inquiries:** retained according to [CRITERIO_RETENCION_SOPORTE], and longer only when a legal obligation or ongoing claim justifies it.
- **Updates:** technical logs are retained under the provider's operational and security retention periods. You may request information about applicable periods.
You may request deletion of information we process outside your device. We will verify the request using proportionate information needed to locate the record and explain any legally required retention. Because there is no Focaria account, we may be unable to associate a technical record with you without additional details, such as a purchase reference. We will not ask for your Apple password or full payment card number.
Deleting the app, requesting deletion, or stopping use does not cancel an active subscription: manage it separately through Apple.
8. Your rights and choices
Depending on applicable law, you may request access, correction, deletion, restriction, or portability of your information, object to certain processing, and withdraw consent without affecting processing before withdrawal. You may lodge a complaint with the appropriate data protection authority.
Email soportefocaria@billdefendai.com with your request. We will respond within applicable legal deadlines and request only information reasonably needed to verify it. We cannot retrieve or export from a server a history that exists only on your device. We do not use your information for automated decisions producing legal or similarly significant effects.
## 9. Children and minors
Focaria is intended for people meeting the minimum age of 6 years and applicable authorization requirements. We do not knowingly request information from children who do not meet those requirements. If you are a parent or guardian and believe we received a child's information without necessary authorization, contact us so we can investigate and take appropriate action.
10. Security and changes
We apply reasonable security measures and use HTTPS connections for subscription and update services. No system guarantees absolute security. Local storage protection also depends on your device and settings.
We will update this policy if features, providers, or practices change. We will state the new effective date and communicate important changes appropriately, requesting additional consent where required.
Privacy contact: soportefocaria@billdefendai.com.