Privacy Policy

Version 1.0 · Effective [TO COMPLETE: publication date]

Focofly is an app to organize your day, your goals and your habits together with Ada, an AI-powered assistant. To work, it needs to store what you tell it. This policy explains, plainly, what data we use, why, who we share it with and how you can delete it.

If anything is unclear, write to us at hola@eientech.io.

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1. Who is responsible for your data

The controller of your data is eien innovations tech E.A.S., a company incorporated in the Republic of Paraguay.

• Contact email (privacy and support): hola@eientech.io
• Registered address: [TO COMPLETE: registered address]
• Phone: [TO COMPLETE: contact phone number]

[LEGAL REVIEW] Art. 27 of Law No. 7593/2025 requires at least the registered address, a phone number and an email address or equivalent channel. If the app is offered to people in the European Union, an EU representative may be required (Art. 27 GDPR).

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2. What data we use and why

We group it by how you use the app.

2.1 Your account

• Email and password, if you sign up with email.
  • We don't store your password ourselves: our authentication provider (Supabase) manages it.
• Google account, if you sign in with Google. Google shares your email and, depending on your settings, your name and profile picture.
• Apple account, if you sign in with Apple. It lets you hide your real email. [CONDITIONAL ON BLOCKER #2]
• An internal user identifier, used to link your content to your account.

Why: to create your account, sign you in and keep your information separate from other people's.

2.2 Your profile

• Name. [CONDITIONAL ON BLOCKER #8: today the name is required]
• Other optional data: role or profile (for example, "freelancer"), working hours, personal values, a free-text description of yourself for Ada, and your age.
• Data set automatically: your time zone, taken from your phone, and the language you choose.

Why:

• The time zone makes "today" your today and makes reminders arrive on your schedule.
• We pass your name, role, working hours, values and description to Ada so her answers take your context into account.
• We don't use your age for anything other than keeping it in your profile. [LEGAL REVIEW: data minimization principle (Art. 4, Law 7593/2025). We recommend no longer asking for it.]

2.3 What you organize in the app

Everything you create or write in the app is stored with your account so you can see it on your phone:

• life areas;
• goals, with their description, why they matter to you, obstacles and definition of success;
• milestones;
• tasks, with their notes and subtasks;
• habits, with their per-day variants and the record of what you completed;
• what you jot down in quick capture;
• your conversations with Ada.

The app also remembers a few things it learns from your use, such as that a certain word you type in quick capture belongs to a certain area.

Why: so the app works. It's the reason it exists.

Many people use Focofly to organize their eating, exercise or wellbeing. If you choose to write about your health, that text is treated like the rest of your content: we store it for you and, when relevant, pass it to Ada (see section 3). We don't ask for health data and we don't use it for anything else. [LEGAL REVIEW: health data is "sensitive" under Art. 3 of Law 7593/2025 and Art. 9 GDPR. We need to assess whether specific consent is required (Art. 20, Law 7593/2025).]

2.4 Progress photo (optional)

When you create a goal, you can add a photo from your gallery as a starting point.

• The photo is sent to Ada so she can take it into account when building the plan.
• We don't store it in our database.
• We only access the photo you pick, not the rest of your gallery.

2.5 Voice

You can dictate instead of typing, both in quick capture and in the chat with Ada.

• Who transcribes: your phone's speech recognition service.
  • On iPhone, Apple's speech recognition may send the audio to Apple's servers to transcribe it.
  • On Android, the system speech recognition service (usually Google's) may also process it on its servers.
• What reaches us: only the transcribed text, and only when you confirm sending it.
• What we don't do: we don't receive, record or store your audio.

The processing of the audio is governed by Apple's or Google's privacy policy, depending on your phone.

2.6 Notifications

If you accept notifications, we store a notification identifier for your device and its operating system (iOS or Android).

• What we send you:
  • reminders for your habits, at the time you chose;
  • an evening prompt to review your day;
  • an invitation to talk with Ada.
• What we record: which notification was sent and when, so we don't send the same one twice.
• Important: a habit reminder includes the name of the habit (for example, "time for: run 20 minutes"). That text goes through Expo's notification service and Apple's or Google's, and may be visible on your lock screen.
• How to turn them off: from your phone's notification settings.

2.7 Messages you send us

If you send us feedback or a bug report from the app:

• we store the text;
• we store your user identifier only if you check that you want us to contact you.

If you email us, we use your address and your message only to reply to you.

2.8 Technical logs

Like any internet service, our server produces technical logs to operate and to detect errors.

• They may include the IP address you connect from and the path of each request.
• Today they may also include fragments of the text you dump into quick capture. [REVIEW: remove this sentence if blocker #7 is resolved]
• Logs are kept by our hosting provider. [TO COMPLETE: DigitalOcean log retention period]

2.9 What we don't do

• We don't sell your data.
• We don't use your data for advertising, ours or anyone else's.
• We don't track you across other apps or websites. We don't use your phone's advertising identifier.
• We don't include third-party analytics, advertising or measurement tools.
• We don't ask for your location.

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3. Ada and artificial intelligence

This is the most important part, so we explain it in detail.

3.1 Who is behind Ada

Ada runs on language models from Anthropic, PBC (United States), which acts as our service provider: it processes your information on our behalf and to provide you the service.

Before you use Ada for the first time, the app will explain what is shared with Anthropic and ask you to accept it. You can withdraw that permission at any time from [TO COMPLETE: location in the app]. If you do, Ada and the features that depend on her stop working, but the rest of the app keeps working. [CONDITIONAL ON BLOCKER #1]

3.2 What we send to Anthropic and when

We only send what each task needs.

What we never send to Anthropic: your email, your password, your user identifier, your age or your audio.

Some of these calls happen without you tapping an Ada button: for example, when you open the Today screen and the app builds the day's plan, or when it sorts a capture that was left pending. [CONDITIONAL ON BLOCKER #1: these calls must wait until you accept the use of Ada]

3.3 What Anthropic does with that information

Under its current commercial terms:

• It doesn't train its models on your information. Its Commercial Terms say: "Anthropic may not train models on Customer Content from Services."
• It deletes it within 30 days. Its Privacy Center states that, for API users, it automatically deletes inputs and outputs within 30 days.
  • Exception: if its safety systems flag a conversation as a possible violation of its Usage Policy, it may keep it for up to 2 years (and the classification scores for up to 7).

Sources, accessed on September 21, 2026:

• Anthropic, Commercial Terms of Service (effective June 17, 2025): https://www.anthropic.com/legal/commercial-terms
• Anthropic Privacy Center, "Is my data used for model training?": https://privacy.anthropic.com/en/articles/7996868-is-my-data-used-for-model-training
• Anthropic Privacy Center, "How long do you store my organization's data?": https://privacy.anthropic.com/en/articles/7996866-how-long-do-you-store-my-organization-s-data

[LEGAL REVIEW] Confirm that eien innovations tech E.A.S.'s Anthropic account operates under those commercial terms and that Anthropic's data processing addendum (DPA) has been accepted.

3.4 What Ada keeps in the app

Ada's replies and the proposals she makes are stored in your account, like the rest of your content: the chat history, your goal summaries and the day's plan.

3.5 Ada proposes, you decide

• Changes to your plan: when Ada proposes to replan your day or a goal, only the changes you approve are applied.
• Capture sorting: Ada sorts what you jot down in quick capture on her own (she assigns an area, a priority or a date). You can always change it.
• A goal's initial plan: if you create a goal with the assistant, Ada builds the initial plan (milestones, tasks and habits) when you finish setting it up. You can edit or delete it afterwards.
• Decisions with significant effects: none of Ada's decisions have legal effects or significantly affect you. She is an organization tool. Even so, you can ask us to review any result.
• Ada's limits: she can be wrong. She is not a health, nutrition, psychology or finance professional, and her suggestions don't replace that kind of advice (see the Terms of Use).

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4. Who we share your data with

We don't share your data with anyone for their own benefit. We work with these providers, which process data on our behalf and only to provide the service:

Some of these providers process data under their own policies (Apple and Google, when you use their voice or sign-in services):

• Supabase: https://supabase.com/privacy
• DigitalOcean: https://www.digitalocean.com/legal/privacy-policy
• Anthropic: https://www.anthropic.com/legal/privacy
• Expo: https://expo.dev/privacy
• Apple: https://www.apple.com/legal/privacy/
• Google: https://policies.google.com/privacy

[LEGAL REVIEW]

• Apple's Guidelines (5.1.1(i)) require confirming that third parties with access to the data provide the same or equal protection as this policy describes. Verify that data processing agreements (DPAs) are accepted with Supabase, DigitalOcean, Anthropic and Expo.
• Confirm whether notification delivery on Android uses Google's Firebase Cloud Messaging: the Android project has no such configuration (see annex, T-32).

We may also disclose data if a law or a competent authority requires it.

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5. International transfers

We are based in Paraguay, but our providers process data mainly in the United States. That means your data leaves your country.

• Paraguay: we make these transfers because they are necessary to provide the service you requested, including user authentication and support (Art. 19, Law No. 7593/2025), and because you expressly accept the AI part before using it.
• European Union, European Economic Area or United Kingdom: we rely on the safeguards our providers offer, such as the standard contractual clauses approved by the European Commission or their participation in the EU-U.S. Data Privacy Framework, where applicable.

[LEGAL REVIEW] Verify the specific mechanism for each provider (SCCs, DPF) and whether a transfer impact assessment is needed.

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6. How long we keep your data

• Your account and your content: for as long as you have an account. When you delete it, they are deleted (see section 7).
• Notification identifiers: for as long as you have an account. If you sign out or uninstall the app, the identifier is deactivated.
• Server technical logs: [TO COMPLETE: log retention period].
• At Anthropic: up to 30 days, or up to 2 years if the conversation was flagged by its safety systems (see section 3.3).
• Messages you send us from the app or by email: [TO COMPLETE: period, for example until the request is resolved plus 12 months].

[LEGAL REVIEW] Art. 4 of Law 7593/2025 (storage limitation) requires not keeping data longer than necessary. Today there is no automatic deletion of old data while the account is active. Assess whether that is enough.

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7. How to delete your account and your data

From the app: on the Today screen, tap the profile icon (top left) → delete account → confirm twice.

• What gets deleted: your account, your profile and all your content (areas, goals, milestones, tasks, habits, logs, conversations with Ada, plans, notification identifiers), as well as your user in our authentication system. [CONDITIONAL ON BLOCKER #4]
• What may remain:
  • our providers' backups, until they rotate; [TO COMPLETE: Supabase backup period for the subscribed plan]
  • what was already sent to Anthropic, until its retention periods expire (section 3.3);
  • technical logs, until their retention period expires (section 6);
  • feedback you sent from the app without asking to be contacted, which is not linked to your account.
• If you signed in with Apple: we also revoke Focofly's access to your Apple account. [CONDITIONAL ON BLOCKER #2]
• Without the app: if you can't get into the app, email hola@eientech.io from your account's email address and we'll delete it for you.

Deleting your account cannot be undone.

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8. Your rights

You can ask us at any time for:

• Access: to know what data of yours we hold and to get a copy.
• Rectification: to correct data that is wrong or outdated. You can edit most of it directly in the app.
• Erasure: to delete your data. You can do it yourself from the app (section 7).
• Objection: to object to our processing of your data on grounds relating to your particular situation.
• Portability: to receive your data in a structured, machine-readable format (JSON), or to have us send it to another service where technically feasible.
• Withdrawal of consent: for example, the consent you gave to use Ada. This doesn't affect what was done before you withdrew it.
• Review of automated decisions: to have a person review a result produced by Ada.

How to exercise them:

• Email hola@eientech.io from the email address linked to your account (so we know it's you).
• It's free.
• We reply within at most 30 calendar days (Art. 26, Law No. 7593/2025).

[LEGAL REVIEW] Data export doesn't exist in the app today: it's done manually. Define the internal procedure.

If you're not satisfied with our reply, you can file a complaint with the supervisory authority:

• In Paraguay: the Agencia Nacional de Protección de Datos Personales (Arts. 26 and 51, Law No. 7593/2025), or through a habeas data action.
• If you live in another country: with your country's data protection authority.

8.1 If you live in the European Union, the European Economic Area or the United Kingdom

In addition to the above, the General Data Protection Regulation (GDPR) gives you the right to restrict processing and to lodge a complaint with your country's supervisory authority.

The legal bases we rely on are:

• Performance of a contract (Art. 6(1)(b) GDPR): your account, storing your content and the app's features.
• Consent (Art. 6(1)(a)): the use of Ada and AI, and notifications.
• Legitimate interests (Art. 6(1)(f)): security, abuse prevention and technical logs.
• Legal obligation (Art. 6(1)(c)): when a law requires us to keep or disclose data.

[LEGAL REVIEW]

• Is an EU representative required (Art. 27 GDPR)?
• If a user voluntarily writes about their health (Art. 9 GDPR): which basis applies?
• Confirm the chosen bases.

8.2 If you live in California (USA)

• Categories of personal information we collect: identifiers (email and user identifier), information you give us in your profile, and content you create in the app.
• Source: you, and Google or Apple if you sign in with them.
• Purpose: providing the service, as described in this policy.
• Sale and "sharing" for cross-context behavioral advertising: We don't sell or "share" personal information, as those terms are defined in the CCPA/CPRA, and we haven't in the last 12 months.
• Your rights:
  • to know what information we hold;
  • to delete and correct it;
  • to not be discriminated against for exercising your rights;
  • to limit the use of sensitive information. We don't use it to infer characteristics about you.
• How to exercise them: through the channels in section 8.

[LEGAL REVIEW] Confirm whether the CCPA/CPRA applies to eien innovations tech E.A.S. (revenue or consumer-volume thresholds). In the meantime, this section stays as a voluntary commitment.

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9. Security

We protect your data with reasonable measures:

• Only you see your content. Every request to our server is verified against your session, and the server only returns data belonging to the account that made the request.
• Your password doesn't go through our servers. Our authentication provider handles it.
• Connections are encrypted between the app and our services. [REVIEW: verify end-to-end HTTPS in production]
• Your session is stored on your phone and you can end it at any time from your profile.

No system is 100% secure. If an incident affects your data, we will let you know and notify the competent authority within the time limits set by law (72 hours, under Art. 17 of Law No. 7593/2025).

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10. Children

Focofly is not directed at children under 13, and we don't knowingly collect data from children under that age. If you know that a child under 13 has given us their data, email hola@eientech.io and we'll delete it.

[LEGAL REVIEW]

• Art. 7 of Law No. 7593/2025 requires the consent of a parent or guardian to process data of minors under 16.
• The GDPR (Art. 8) lets each EU country set the age between 13 and 16.
• Recommendation: set the minimum age at 16 (and align the Terms and the stores' age rating), or implement a parental consent mechanism.
• Today the app doesn't verify age.

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11. Changes to this policy

If we change this policy, we'll update the date and version at the top.

If the change is significant (for example, a new use of your data or a new AI provider), we'll let you know in the app before it takes effect and, where appropriate, ask for your consent again.

Previous versions are available on request.

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12. Governing law

This policy is governed by the laws of the Republic of Paraguay, in particular Law No. 7593/2025 "On the Protection of Personal Data in the Republic of Paraguay" (enacted and published on November 27, 2025). This doesn't take away any rights granted to you by the laws of your country of residence.

This is a translation. In case of discrepancy, the Spanish version prevails. [LEGAL REVIEW]

[LEGAL REVIEW]

• Law No. 7593/2025 enters into force 24 months after its official publication (Art. 57), i.e. at the end of November 2027.
• Until then the previous framework applies: Art. 33 (right to privacy) and Art. 135 (habeas data) of the National Constitution, and Law No. 6534/2020 where applicable.
• Decide whether the policy cites both or adopts the new law early. This draft adopts the new law's standards from now on.
• Source of the law: Biblioteca y Archivo Central del Congreso Nacional, https://www.bacn.gov.py/leyes-paraguayas/12924/ley-n-7593-2025-de-protecci-n-de-datos-personales-en-la-rep-blica-del-paraguay (accessed September 21, 2026).

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13. Contact

eien innovations tech E.A.S. · hola@eientech.io · [TO COMPLETE: registered address]