Privacy Policy
This policy explains how Deeptegrity Kft. processes personal data when you visit the focusing.app website (the “Website”).
It does not cover The Focusing App itself. The desktop application is governed by its own Privacy Policy, which is presented in the application, together with its own Terms of Service. If you install or use the application, that policy applies to everything the application does.
The short version for this Website: no account is required, and the Website sets no cookies of its own except the one that stores your cookie-banner choice, set only after you choose. Two optional measurement tools exist, a Reddit advertising pixel and a Google Ads tag (Section 2.2), governed by one choice: where prior consent is required they load only if you allow them, everywhere else they load unless you opt out, and a Global Privacy Control signal switches them off everywhere. Everything the Website does is described in Section 2: serving the site, the advertising measurement, the region-availability notice, the optional interactive demo, and the optional pilot-request form.
1. Who Is Responsible (Controller)
Deeptegrity Kft.
1117 Budapest, Baranyai utca 27, Hungary
Email: legal@deeptegrity.com
The Company has not appointed a Data Protection Officer, as it does not meet the mandatory appointment thresholds under Article 37 of the GDPR. Direct all data protection inquiries to the email address above.
2. What the Website Processes
The Website is a static site. It has no login, no user accounts, and no comment or upload functionality. Each of its processing activities is described below.
2.1 Serving the site (hosting and security)
The Website is served by Cloudflare, our hosting and content-delivery provider, acting as our processor. Cloudflare processes connection data (IP address, request metadata) to deliver the pages, to protect the site against abuse, and to perform the edge geolocation described in Section 2.2. The installer links on the Website point to our download host (download.thefocusing.app); connection data involved in serving those downloads is processed in the same way and for the same purpose. Legal basis: our legitimate interest in operating and securing the Website (GDPR Art. 6(1)(f)).
2.2 Cookies and advertising measurement (Reddit and Google)
The Website can include two advertising measurement tools: a Reddit advertising measurement pixel, which tells us whether our advertising on Reddit brings visitors here, and a Google Ads tag (gtag.js), which tells us whether our advertising on Google does the same and which of our Google ads lead to download clicks. One choice governs both. Whether they load is decided on every request, server-side, from two inputs: where your request is geolocated (performed by Cloudflare at the network edge and, like all IP-based geolocation, approximate) and the choice you have stored.
- Where prior consent is required (the EU/EEA, the United Kingdom, Switzerland, Canada, Brazil, South Korea, and any request we cannot place), they load only after you accept them in the cookie banner (Accept all, or the Advertising toggle under Manage preferences). Until then, neither is loaded, and no measurement data about your visit is collected or shared. The Google tag is not loaded in any reduced or “cookieless” form either: without your consent it is simply absent.
- Everywhere else, including the United States, they load by default, and you can switch them off at any time via the footer dialog (Section 8).
- Global Privacy Control (GPC) always wins: if your browser sends the GPC signal, neither the pixel nor the Google tag is ever injected, in any region, whatever choice is stored.
While the Reddit pixel runs, our own script additionally reports page-interaction events through it (sections viewed, scroll depth, time on page, demo launches, download clicks). While the Google tag runs, it records your visit and, where you arrived by clicking one of our Google ads, connects that visit to the ad click for conversion measurement; the one page-interaction event we report through it is a conversion event when you click a desktop download link. We signal to Google that the data may be used for measurement only: the tag’s personalized-advertising setting (ad_personalization) is switched off, so your visit is not used to build remarketing audiences for us.
The cookies involved:
| Cookie | Set by | Purpose | Duration |
|---|---|---|---|
| fa_consent | Us (first-party) | Remembers your cookie-banner choice, accept or reject, together with when you made it. Set only when you make a choice; it is how both your consent and your refusal are honored on later visits. | 180 days |
| _rdt_uuid and other Reddit cookies | The Reddit pixel | Advertising measurement and attribution, under Reddit’s control. Set only while the pixel is allowed to load. | Set by Reddit; see Reddit’s privacy policy |
| _gcl_au and other _gcl_* cookies | The Google Ads tag (first-party, on our domain) | Advertising conversion measurement and attribution: linking a visit, and a download click if you make one, to the Google ad that brought you here. Set only while the tag is allowed to load. | Typically 90 days (_gcl_au); see Google’s cookie documentation |
One neighboring first-party item is not a cookie: for visitors whose request the same approximate edge geolocation described above places in a region where the app is not offered yet, the Website shows a dismissible availability notice, and its desktop download links open that notice instead of starting a download. Whether it appears is decided from that geolocation and from nothing else; the legal basis is our legitimate interest in telling visitors where the app is offered (Art. 6(1)(f)). If you dismiss the notice, the dismissal is remembered in your browser’s local storage (fa_region_notice, kept until you clear your browser data). It is strictly functional, identifies nobody, and nothing about it leaves your device.
Changing your mind. The Cookie settings link in the footer of every page reopens the dialog. Accepting loads both tools from that moment on. Rejecting stops them: no further events are sent from the page you are on (the Google tag is switched to denied consent signals immediately), neither tool is injected on any further page, and their identifier cookies are expired where technically possible. Withdrawing consent does not affect the lawfulness of processing that happened before the withdrawal (Art. 7(3)). If we later add a new advertising tool, a previously stored acceptance does not extend to it: where the banner is how consent is collected, it asks again before the new tool runs; in the opt-out regions of Section 8, the new tool is covered by the same footer opt-out, and a stored opt-out keeps applying to it automatically.
For the data collected through these tools, Reddit, Inc. and Google (Google Ireland Limited and Google LLC) each determine their own further purposes and means, and each may set cookies or similar identifiers under its own control, on our domain (the _gcl_* cookies above) or on its own domains; see their privacy policies for details. To the extent we are regarded as a joint controller for the collection and transmission of this data, this policy provides the required transparency, and the banner and Section 8 provide the choices. Legal basis: where the banner is shown, your consent (Art. 6(1)(a), alongside the national rules implementing the ePrivacy Directive on storage of and access to information in your device); in the United States and other opt-out regions, our legitimate interest in measuring the effectiveness of our advertising (Art. 6(1)(f)), together with the opt-outs in Section 8.
2.3 The interactive demo
If you choose to launch the interactive demo, the demo’s rendering engine and font files are loaded from Google’s content delivery networks (www.gstatic.com and fonts.gstatic.com), which receive your IP address as part of serving those requests. Nothing is loaded from Google unless you launch the demo. This content delivery is separate from the Google Ads tag in Section 2.2 and involves no advertising cookies. The demo runs in your browser and transmits nothing to us; while the Reddit pixel is allowed to run (Section 2.2), the launch itself is reported as a page-interaction event. To make repeat launches faster, the demo stores its files in your browser’s local cache storage; that data stays on your device and you can clear it in your browser at any time. Legal basis: our legitimate interest in demonstrating the product to visitors who request it (Art. 6(1)(f)).
2.4 The pilot-request form and its bot protection
Pages that contain the pilot-request form are protected by Cloudflare Turnstile. Turnstile loads when the form approaches your viewport or when you interact with it, whether or not you submit, and processes connection and browser data to distinguish people from bots, with Cloudflare acting as our processor. Legal basis: our legitimate interest in preventing abuse (Art. 6(1)(f)).
If you submit the form, we process what you enter (organization name, organization type, device count, your name, your work email address, and any notes) together with your IP address, your country, the page of the Website you submitted from, and the time of submission.
- Purpose: responding to your request and scoping a pilot with you, and preventing abuse of the form. Nothing else. Your details are not added to any marketing list and are not shared with anyone beyond the processors below.
- Legal basis: steps taken at your request prior to entering into a contract (Art. 6(1)(b)); abuse prevention under our legitimate interest (Art. 6(1)(f)).
- How it travels: the submission is received by a Cloudflare Worker and delivered as an email (including the IP address, country, page, and time noted above) via Postmark, operated by AC PM LLC, an ActiveCampaign company, to our business mailbox. Cloudflare and AC PM LLC act as our processors. The submission is not stored in any database of ours beyond that mailbox.
- Retention: for as long as the conversation is live, and thereafter only as long as we need it to resume the conversation, after which it is deleted.
2.5 Email correspondence
If you email us (for example at hello@focusing.app), we process your email address and the content of your message in order to respond. Legal basis: our legitimate interest in handling your request (Art. 6(1)(f)) or, where the correspondence concerns a contract, Art. 6(1)(b). We keep correspondence for as long as needed to handle the matter and, where relevant, to document what was agreed, after which it is deleted.
3. What the Website Does Not Do
- The Website itself sets one cookie at most: fa_consent, which stores your cookie-banner choice and is set only when you make one (Section 2.2). The Reddit pixel and the Google Ads tag may set further cookies (Reddit’s under its control, Google’s _gcl_* on our domain), but only while they are allowed to load.
- Where prior consent is required, no analytics or measurement data is collected unless you have allowed it; everywhere, a stored opt-out or a GPC signal switches both advertising tools off.
- We do not sell personal data, and we do not share it with data brokers.
- We build no visitor profiles and do no cross-site tracking of our own.
- The Website’s own fonts, styles, and scripts are self-hosted. Third-party scripts load only as described in this policy: the Reddit pixel and the Google Ads tag when your consent state allows them (Section 2.2), the demo’s rendering engine if you launch the demo (Section 2.3), and Cloudflare Turnstile on pages with the pilot-request form (Section 2.4).
4. Recipients of Your Data
| Recipient | Role | Purpose |
|---|---|---|
| Cloudflare, Inc. (and EU affiliates) | Processor | Website hosting/CDN, installer downloads (R2 storage), security, edge geolocation, Turnstile bot protection, pilot-form endpoint |
| AC PM LLC (Postmark, an ActiveCampaign company) | Processor | Email delivery of pilot-request submissions |
| Google LLC (www.gstatic.com, fonts.gstatic.com) | Content delivery for the demo’s engine and fonts | Receives your IP address only if you launch the interactive demo |
| Reddit, Inc. | Controller of its own further processing (only while the pixel is allowed to load; see Section 2.2) | Advertising measurement pixel |
| Google Ireland Limited / Google LLC | Controller of its own further processing (only while the Google Ads tag is allowed to load; see Section 2.2) | Google Ads advertising and conversion measurement |
Authorities receive data only where the law compels us. We share personal data with no one else.
5. International Transfers
The recipients named in Section 4 are or may be located in the United States. Transfers of personal data outside the EU/EEA take place only with appropriate safeguards under Chapter V of the GDPR. No other transfers take place.
6. Retention
- Connection data / server logs: processed by Cloudflare for the short operational periods required to serve and secure the site; we run no long-term server-side logging of our own.
- Pilot-request submissions and email correspondence: as described in Sections 2.4 and 2.5.
- Cookie-banner choice: stored only in your browser (the fa_consent cookie, 180 days); we keep no server-side copy.
Nothing else about you is stored on our side.
7. Your Rights (GDPR)
You have the right to:
- access your personal data (Art. 15);
- rectification of inaccurate data (Art. 16);
- erasure (Art. 17);
- restriction of processing (Art. 18);
- data portability (Art. 20);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent at any time, without affecting prior processing (Art. 7(3)), where processing is based on consent; for this Website that is the cookie-banner consent to advertising measurement (Section 2.2), withdrawable at any time via the Cookie settings link in the footer.
To exercise any right, email legal@deeptegrity.com. We respond within the statutory time limits.
Complaints: You may lodge a complaint with the Hungarian supervisory authority, Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), www.naih.hu, or with the supervisory authority of your EU country of residence.
8. Your US Privacy Choices
This section is for residents of US states with comprehensive privacy laws, e.g., California, Colorado, Connecticut, Texas, Virginia.
Notice at collection. On the Website, unless you opt out, internet activity information (page interactions) is collected via a Reddit advertising pixel and a Google Ads tag (Section 2.2), which may constitute “sharing” for cross-context behavioral advertising under California law. If you submit the pilot-request form, we collect the identifiers and professional information you enter (Section 2.4), which we do not sell or share. We do not knowingly collect data of consumers under 16 for sharing. This section concerns the Website only; the application does not sell or share personal information (see its own Privacy Policy, presented in the application).
Your Privacy Choices: right to opt out of sharing. You can opt out of the sharing associated with the Reddit pixel and the Google Ads tag, together:
- In the footer: the Your Privacy Choices link (also labeled Cookie settings) on every page opens a dialog where one click (Reject all) opts you out of both. The opt-out is stored in a first-party cookie (fa_consent, Section 2.2) and honored server-side on every later page: neither tool is injected.
- Automatically: enable Global Privacy Control (GPC) in your browser. We honor GPC server-side: when your browser sends the GPC signal, neither the pixel nor the Google tag is ever injected. No account or extra steps needed. To enable GPC, see your browser’s privacy settings or globalprivacycontrol.org.
- By request: email legal@deeptegrity.com with the subject “Privacy Choices”.
You also have rights to know/access, delete, and correct your personal information, and the right not to be discriminated against for exercising these rights. We do not use or disclose sensitive personal information for purposes requiring a right to limit. To exercise rights, email legal@deeptegrity.com; we may need to verify your identity. Authorized agents may submit requests on your behalf; we may require proof of authorization.
9. Children
The Website is not directed to children under 16, and we do not knowingly process the personal data of children under 16. If you believe a child has provided us data, contact legal@deeptegrity.com and we will delete it.
10. The Focusing App
The Focusing App (the desktop application) processes data in fundamentally different ways than this Website, and is governed by its own Privacy Policy and Terms of Service, both presented in the application before and during use. Nothing in this Website policy describes, limits, or extends the application’s processing; the application’s own documents are the sole and complete statement of it.
11. Changes to This Policy
We may update this policy at any time; the version published on this page, with the date above, is the version in force. For material changes we will make the change reasonably prominent on the Website.
12. Contact
Deeptegrity Kft.
1117 Budapest, Baranyai utca 27, Hungary
legal@deeptegrity.com