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: we set no cookies and require no account. For visitors outside the United States, no analytics or measurement of any kind runs. For visitors in the United States only, advertising measurement runs as described in Section 2.2. Everything the Website does is described in Section 2: serving the site, the US-only advertising measurement, 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 United States visitors only: Reddit advertising measurement
For visitors whose requests are geolocated to the United States, a Reddit advertising measurement pixel is injected server-side into the page. The pixel is not served to visitors whose requests are geolocated elsewhere, including the EU/EEA and the United Kingdom; geolocation is performed by Cloudflare at the network edge and, like all IP-based geolocation, is approximate. For these US visitors, our own script additionally reports page-interaction events through the pixel (sections viewed, scroll depth, time on page, demo launches, download clicks).
For the data collected through the pixel, Reddit, Inc. determines its own further purposes and means, and it may set cookies or similar identifiers under its own control; see Reddit’s privacy policy 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 Section 8 provides the opt-outs. We honor the Global Privacy Control (GPC) signal automatically: if your browser sends GPC, the pixel is never injected. See Your US Privacy Choices (Section 8). Legal basis: our legitimate interest in measuring the effectiveness of our advertising in the United States (Art. 6(1)(f)).
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. The demo runs in your browser and transmits nothing to us; for US visitors, the launch itself is reported as a page-interaction event as described in Section 2.2. 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 no cookies. (For US visitors only, the Reddit pixel described in Section 2.2 may set cookies under Reddit’s control.)
- No analytics or measurement runs for visitors outside the United States.
- 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 advertising pixel for US visitors (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 (US visitors only; see Section 2.2) | Advertising measurement pixel |
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.
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; none of the Website’s processing described above currently relies on consent.
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, for US visitors only, internet activity information (page interactions) is collected via a Reddit advertising pixel, 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:
- Automatically: enable Global Privacy Control (GPC) in your browser. We honor GPC server-side: when your browser sends the GPC signal, the pixel is never 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