Below is a full replacement draft for your Privacy Policy. I’d still have a lawyer review before publishing, especially because AppMetrica/Yandex is now a third-party analytics processor.
Privacy Policy for Focus - Screen Time Control
Effective Date: July 8, 2026
Focus - Screen Time Control is designed with a privacy-conscious, local-first approach. Your focus sessions, selected restrictions, preferences, intention notes, reflection text, local activity insights, and TrueDepth face-tracking data are stored and processed on your device by default.
This Privacy Policy explains how Focus - Screen Time Control ("Focus," "we," "us," or "our") handles personal information when you use the Focus iOS application (the "App").
By downloading, installing, accessing, or using Focus, you acknowledge that you have read and understood this Privacy Policy, including how we collect, use, and share information as described here. If you do not agree with this Privacy Policy or our Terms, do not use the App.
Data Controller
Focus is operated by Dilshodi Kahori. For privacy questions or requests, contact us through the support email listed on the Focus App Store page.
1. Introduction
This Policy applies to your use of Focus on iOS worldwide, including where laws such as the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) apply.
Our Privacy Principles
• Focus data is stored locally on your device by default.
• We minimize personal data collection wherever possible.
• We do not operate developer servers that host your Screen Time selections, focus session history, intention notes, reflections, or TrueDepth face-tracking data.
• TrueDepth face-tracking data is processed locally on your device only for the guided reset exercise and is not stored or transmitted by Focus.
• Screen Time, Family Controls, Device Activity, and Managed Settings features are handled through Apple system frameworks.
• We use privacy-minimized analytics to understand app usage, improve product quality, and measure trial and subscription conversion.
• We do not send selected app names, website/domain names, Screen Time history, intention notes, reflection text, TrueDepth/face/camera values, raw session IDs, or user-entered content to analytics providers.
2. Information We Collect
A. Purchases
Examples: Subscription product IDs, purchase result status, restore result status, entitlement status, trial status, and subscription conversion status.
Purpose: Enable premium features, restore purchases, verify subscription access, measure trial and subscription conversion, and prevent abuse.
Shared with: Apple App Store / StoreKit. Limited purchase and trial-related analytics events may be processed by AppMetrica as described below.
B. User Content
Examples: Intention notes, reflection text, session labels, focus preferences, selected focus presets, and other information you enter in the App.
Purpose: Provide focus sessions, personalize your local experience, and display local history and insights.
Shared with: Not sent to our developer-operated servers or analytics providers as part of normal App use.
C. Usage Data
Examples: Focus session duration, selected focus purpose, session completion status, interruption/reflection status, app activity insights generated by the App, screen views, button taps, trial feature usage, and product interaction events.
Purpose: Provide App functionality, local insights, product analytics, feature improvement, subscription/trial analysis, and operational reliability.
Shared with: Local usage data stays on device by default. Privacy-minimized analytics events may be processed by AppMetrica.
D. Analytics Data
Focus uses AppMetrica, an analytics service provided by Yandex LLC and/or its affiliates, to understand how people use the App, improve onboarding, measure trial and subscription conversion, diagnose product issues, and improve product quality.
Analytics events may include:
• App launches.
• Screen views.
• Button taps.
• Onboarding steps.
• Paywall views.
• Purchase and restore result status.
• Trial started, trial status, trial conversion, trial expiration, and trial lapse events.
• Focus session started/completed events.
• Session duration buckets, such as under_15, 15_30, 31_45, 46_60, and over_60.
• Selection count buckets, such as none, 1_3, 4_10, and 11_plus.
• Trial remaining buckets, such as less_than_1_day, 1_2_days, 2_3_days, and expired.
• Basic device, app, session, and technical information processed by AppMetrica to provide analytics and reporting.
We do not send to AppMetrica:
• Selected app names.
• Website or domain names.
• Screen Time history.
• Intention notes.
• Reflection text.
• TrueDepth, face, camera, blink, gaze, head-pose, or reset values.
• Raw session IDs.
• User-entered content.
• Exact selected app/category/site identifiers.
Focus is not affiliated with, sponsored by, endorsed by, or otherwise officially associated with Yandex or AppMetrica. AppMetrica is an independent third-party analytics provider. AppMetrica’s processing is governed by Yandex’s applicable terms and privacy documentation. We do not control Yandex’s independent systems, policies, or processing practices beyond the configuration of the App and the data we choose to send from Focus.
E. Diagnostics
Current status: Focus may use local on-device diagnostic logs for development troubleshooting and operational reliability. We do not send TrueDepth face-tracking values, selected app names, website/domain names, Screen Time history, intention notes, reflection text, or user-entered content through diagnostic logging.
F. Device Information
Examples: Device model, operating system version, app version, language/region settings, technical identifiers, and session-related metadata processed by Apple or AppMetrica where needed for platform services, analytics, security, or App functionality.
Purpose: Platform compatibility, subscription management, analytics, security, permission handling, and operation of Apple system features.
Shared with: Apple where applicable, and AppMetrica for analytics as described in this Policy.
G. Advertising Data
Focus does not enable third-party advertising in this App version. Focus does not use AppMetrica for advertising, remarketing, or cross-context behavioral advertising in this App version.
If advertising, remarketing, attribution, or similar features are enabled in a future release, this Privacy Policy and App Store privacy disclosures will be updated.
3. Screen Time and Permission-Related Data
Depending on the features you use, Focus may process:
• Apps, websites, or categories you select for restriction.
• Focus session schedules, timers, and duration settings.
• Device Activity and Managed Settings data required to apply temporary shields or restrictions.
• Local session history and focus insights.
• User-provided intention notes, preferences, and reflections.
Apple's Screen Time, Family Controls, Device Activity, and Managed Settings frameworks are designed to protect sensitive app and usage information. Focus uses these frameworks only after you grant the required authorization.
Focus does not send your selected blocked apps, selected websites, selected domains, selected categories, or full Screen Time history to AppMetrica.
4. TrueDepth and Face Data
Focus includes an optional guided reset exercise called "Eye and Head Reset." If you choose this exercise, Focus uses Apple's TrueDepth camera and ARKit face tracking to process temporary face-tracking values on your device.
Information processed during the exercise may include:
• Eye blink values.
• Eye gaze direction values.
• Head pose or orientation values.
• A temporary neutral head pose used only as an in-memory reference during the current exercise.
Focus does not collect, store, transmit, or share:
• Photos or videos of your face.
• Camera captures or screenshots.
• Depth maps.
• Face meshes.
• Facial images.
• Biometric identifiers.
• Face data used to identify, recognize, authenticate, profile, advertise to, or track you.
TrueDepth face-tracking values are never sent to AppMetrica, Apple analytics, developer-operated servers, advertising providers, or third-party analytics providers.
5. Data We Do Not Collect or Send to Analytics
We do not collect or send to analytics providers:
• Your full Screen Time history.
• Your selected blocked apps, websites, domains, or categories.
• Your exact selected app/category/site identifiers.
• Your intention notes.
• Your reflection text.
• User-entered content.
• TrueDepth face-tracking values.
• Photos, videos, depth maps, face meshes, facial images, or biometric identifiers.
• Raw session IDs.
• Payment card numbers or card security codes.
• Precise geolocation.
• Contacts.
• Photos, camera captures, scanned documents, or files.
6. How We Use Information
We use information to:
• Provide focus sessions, app/site/category restrictions, timers, and session configuration.
• Request and manage Apple Screen Time-related permissions.
• Apply temporary shields or restrictions using Apple system frameworks.
• Provide local focus history and insights.
• Verify guided reset exercise completion using on-device TrueDepth face tracking when you choose the Eye and Head Reset exercise.
• Verify and manage subscription entitlements through Apple StoreKit.
• Understand app usage through privacy-minimized analytics.
• Measure onboarding, trial, paywall, subscription, and retention performance.
• Improve App reliability, usability, and product quality.
• Respond to support requests.
• Comply with legal obligations.
TrueDepth Use Limitation
TrueDepth face-tracking values are used only to verify that you completed the guided Eye and Head Reset exercise before ending a locked focus session. Focus does not use TrueDepth or face data for identification, facial recognition, authentication, advertising, analytics, profiling, tracking, sale, or cross-context behavioral advertising.
Legal Bases Under GDPR, Where Applicable
• Contract necessity: To provide features you request.
• Consent: For permissions such as Screen Time authorization, camera access, notifications, or other processing where consent is required.
• Legitimate interests: App security, reliability, product analytics, debugging, abuse prevention, and product improvement where permitted by law.
• Legal obligation: Compliance with tax, accounting, regulatory, or legal requirements.
Where applicable law requires consent for analytics or related processing, we will request consent or provide controls as required.
7. Permissions We Request
Focus requests only permissions tied to specific App functionality.
A. Screen Time / Family Controls Authorization
Why: To allow Focus to help you select and temporarily restrict apps, websites, or categories during focus sessions.
Control: You can manage or revoke permissions through iOS Settings, Screen Time settings, or system permission controls.
B. Device Activity and Managed Settings
Why: To schedule focus sessions, monitor configured limits where applicable, and apply temporary shields or restrictions.
Control: These features depend on Apple system permissions and platform availability.
C. Camera / TrueDepth Camera
Why: To allow Focus to use Apple's TrueDepth camera and ARKit face tracking for the optional Eye and Head Reset exercise.
Control: You can deny camera permission, revoke it later in iOS Settings, or choose a non-camera reset exercise where available.
D. Notifications, If Enabled
Why: To send focus session reminders, session completion alerts, or other App-related notices.
Control: You can disable notifications in iOS Settings at any time.
8. Local-First Focus Data Handling
Focus session data, settings, selected restrictions, preferences, intention notes, reflections, and insights are stored on your device by default.
We do not operate a developer backend server that collects or hosts your Focus sessions, selected restrictions, intention notes, reflection text, local insights, or TrueDepth face-tracking values as part of normal App use.
Focus does use AppMetrica for privacy-minimized product analytics. Analytics events are limited as described in this Policy and do not include selected app names, website/domain names, Screen Time history, intention notes, reflection text, TrueDepth/face/camera values, raw session IDs, or user-entered content.
9. When Data May Leave Your Device
Data may leave your device when:
• You contact support and choose to share information with us.
• Apple processes subscription, App Store, StoreKit, Screen Time framework, camera permission, ARKit/TrueDepth, notification, or operating system data as part of its platform services.
• AppMetrica processes privacy-minimized analytics events and related device/app/session information.
• You use iCloud, device backup, or other Apple services that may back up or sync App data according to your Apple settings.
• You share screenshots, logs, or other information using iOS sharing tools or third-party services.
10. Third-Party Services
We use platform and infrastructure providers. Their policies also apply to their processing.
A. Apple App Store / StoreKit
Use: In-app subscriptions and purchase restoration.
Data: Apple processes payment, billing, and transaction data.
We receive: Subscription and entitlement status and transaction verification results, not full payment card details.
B. Apple Screen Time, Family Controls, Device Activity, and Managed Settings
Use: Permission requests, app/site/category selection, scheduling, activity monitoring, and temporary restrictions or shields.
Developer access: We do not receive unrestricted access to your full Screen Time history.
C. Apple ARKit / TrueDepth Camera
Use: Optional guided Eye and Head Reset exercise verification.
Developer access: Focus receives temporary face-tracking values needed to determine whether the exercise cues were completed. Focus does not receive or store photos, videos, depth maps, face meshes, facial images, or biometric identifiers, and does not send TrueDepth face-tracking values to third parties.
D. Apple iCloud / Device Backup, Where Applicable
Use: Apple may back up or sync App data depending on your device, iCloud, and backup settings.
Provider processing: Apple manages iCloud and backup infrastructure under its own privacy terms.
E. Apple Push Notification Service, If Notifications Are Enabled
Use: Push notification delivery.
Data: Push token and notification routing metadata.
F. AppMetrica by Yandex
Use: Privacy-minimized product analytics, app usage measurement, onboarding and paywall analysis, trial and subscription conversion measurement, session reporting, and product improvement.
Data: App launches, screen views, product interaction events, trial/subscription result status, duration buckets, selection count buckets, trial remaining buckets, device/app/session/technical information, and other analytics data described in this Policy.
Not sent: Selected app names, website/domain names, Screen Time history, intention notes, reflection text, TrueDepth/face/camera values, raw session IDs, or user-entered content.
Relationship: Focus is not affiliated with, sponsored by, endorsed by, or officially associated with Yandex or AppMetrica. AppMetrica is an independent third-party provider. We are responsible for our configuration of Focus and the data we choose to transmit to AppMetrica, but we do not control Yandex’s independent systems, policies, or processing practices.
References:
• Apple Privacy Policy: https://www.apple.com/legal/privacy/
• Apple App Store Privacy Information: https://www.apple.com/app-store/privacy/
• Yandex Privacy Policy: https://yandex.com/legal/confidential/
• Yandex AppMetrica Terms: https://yandex.com/legal/metrica_termsofuse/
11. Advertising
Focus currently does not enable third-party advertising, personalized advertising, remarketing, or cross-context behavioral advertising.
Focus does not sell personal information and does not share personal information for cross-context behavioral advertising in this App version.
TrueDepth face-tracking values are never used for advertising.
12. No Sale of Personal Information
Focus does not sell personal information. We do not trade, broker, or sell your personal information to third parties.
Focus does not share personal information for cross-context behavioral advertising in this App version.
TrueDepth face-tracking values are not sold, shared, rented, traded, disclosed for advertising, or used for cross-context behavioral advertising.
13. Subscriptions and Payments
Subscriptions are handled through Apple's in-app purchase system.
• Apple manages billing and payment information.
• We do not receive your full payment card details.
• We receive transaction outcomes and entitlement status required to unlock premium features.
• We may send privacy-minimized subscription and trial result events to AppMetrica for analytics.
• Subscription management, cancellation, and refunds are governed by Apple's billing policies and your Apple account settings.
14. Data Retention
We retain information only as long as needed for the purposes described above.
A. Local Focus Data
Focus settings, preferences, selected restrictions, intention notes, reflections, and session history are stored locally until you delete them, delete the App, reset your device, or clear related data through available App or system controls.
B. TrueDepth Face-Tracking Values
TrueDepth face-tracking values are processed in memory only during the active Eye and Head Reset verification flow. Focus does not persist these values. They are discarded when the exercise ends, the screen is dismissed, the ARKit session is paused, or the App no longer needs them for the current verification.
C. Analytics Data
Analytics data processed through AppMetrica is retained according to AppMetrica/Yandex settings, policies, and applicable terms. We use analytics data to understand app usage, improve product quality, and measure trial and subscription performance.
D. Support Communications
If you contact support outside the App, we retain communications as needed to respond, resolve issues, and satisfy legal obligations.
E. Subscription Records
Entitlement state is processed as needed to provide premium access. Transaction handling and primary billing records are maintained by Apple.
15. Security
We use reasonable technical and organizational safeguards, including:
• iOS platform security controls, app sandboxing, and secure Apple APIs.
• Least-privilege access to permissions.
• Apple Screen Time and Family Controls frameworks for sensitive app restriction functionality.
• Apple ARKit and TrueDepth system permission controls for optional camera-based reset verification.
• Local, in-memory processing for TrueDepth face-tracking values.
• Privacy-minimized analytics event design.
• Encrypted communication where applicable.
• Operational safeguards to reduce unauthorized access, alteration, disclosure, or loss.
No method of transmission or storage is 100% secure, but we implement measures appropriate to the risks.
16. User Rights
Depending on your jurisdiction, you may have rights regarding personal information.
A. GDPR, EEA/UK Where Applicable
You may have rights to:
• Access personal data.
• Correct inaccurate data.
• Delete data.
• Restrict or object to certain processing.
• Data portability.
• Withdraw consent at any time, where processing is based on consent.
• Lodge a complaint with your local supervisory authority.
B. CCPA/CPRA, California
You may have rights to:
• Know/access categories and specific personal information.
• Request deletion.
• Request correction.
• Limit use/disclosure of sensitive personal information, where applicable.
• Opt out of sale or sharing for cross-context behavioral advertising.
Current statement: We do not sell personal information and do not share personal information for cross-context behavioral advertising in this App version.
C. PIPEDA, Canada
You may request:
• Access to personal information.
• Correction of inaccuracies.
• Information about how your data is used and disclosed.
• Withdrawal of consent, subject to legal or contractual limits.
D. TrueDepth and Face Data Rights
Focus does not persist TrueDepth face-tracking values, so we cannot access, export, correct, or delete those temporary values after an exercise session ends. You can prevent future TrueDepth processing by denying or revoking camera permission in iOS Settings or by choosing a non-camera reset exercise where available.
E. Local Data
Much of your Focus data is stored locally on your device. We may not be able to access, export, or delete local data on your behalf. You can delete local App data by using available App controls, deleting the App, or managing device backups and iCloud settings through Apple system settings.
F. How to Submit a Privacy Request
Submit requests using the support contact listed on the Focus App Store product page, with the subject line: "Privacy Request".
17. International Transfers
If you use third-party services, such as Apple App Store, StoreKit, iCloud, backups, notification services, Apple system frameworks, or AppMetrica, your information may be processed in countries other than your own.
Where required, service providers apply transfer safeguards under their legal frameworks, such as contractual safeguards and comparable protection mechanisms.
Focus does not transfer TrueDepth face-tracking values, selected app names, website/domain names, Screen Time history, intention notes, reflection text, raw session IDs, or user-entered content to AppMetrica.
18. Children’s Privacy
Focus is not directed to children under 13 and is not intended to knowingly collect personal information from children under 13.
If you are under the age of majority where you live, you should use Focus only with the consent and supervision of a parent or legal guardian.
If you believe a child has provided personal information, contact us through the support contact listed on the App Store page, and we will take appropriate steps.
19. Changes to This Policy
We may update this Privacy Policy from time to time to reflect legal, technical, or product changes.
When we make material changes, we will update the "Effective Date" and, where required, provide additional notice.
If we later decide to collect or use additional information for advertising, remarketing, cross-context behavioral advertising, personalization, recommendations, or similar purposes, we will describe the categories of data, purposes, storage, sharing, retention, and user choices in an updated version of this Privacy Policy and in our App Store privacy disclosures where applicable.
20. Contact Information
For privacy questions or rights requests, use the support contact listed on the Focus App Store product page and include:
• Your request type, such as access, deletion, correction, objection, or consent withdrawal.
• Your country/state of residence.
• The email address associated with your Apple account communication, if relevant.
• A description of the Focus-related data or issue involved.
This helps us process your request efficiently and in compliance with applicable law.