Privacy Policy

7 February 2023

This Privacy Policy defines the procedure for processing information about Users, including personal data of Users, which "Life Focus Tools", LLC (Spelled as ООО "Лайф Фокус Тулз" in Russian) (hereinafter referred to as the Company) may be obtained during registration/authorization and/or use by Users of any of the Company's software products or website (hereinafter collectively referred to as the Services).

Personal data means any information related directly or indirectly to a specific or identifiable user of any of the Company's Services, as well as information that identifies, relates to, describes, is associated with or can reasonably be associated, directly or indirectly, with a specific consumer or household.

The representative of the Company in accordance with the General Data Protection Regulation (GDPR) for users located in the European Economic Area (EEA) or Switzerland is EcoComputers s.r.o., registered at: U Hájovny 873, 252 43 Průhonice.

I. General provisions

1.1. Relations related to the processing of information, including, but not limited to the collection, use, storage, distribution and protection of information about Users of the Services, are governed by this Policy (hereinafter referred to as the Policy) and other rules posted within the Services, as well as current legislation. Before using the Company's Services, the User is obliged to familiarize himself with this Policy, as well as with all applicable Rules.

1.2. Upon registration, each access and/or actual use of any of the Services, the User agrees to the terms of this Policy, as well as to the terms of the agreements of the Services used by him, in the editions that were in effect at the time of actual use of such Services.

1.3. The User agrees and instructs the Company to perform the following actions:

- processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of User data;

- transfer to partners and affiliates of users' personal data, and their processing by partners and affiliates, on the basis of an order from the Company (by the methods specified in this paragraph), as well as joint processing by partners and affiliates of data with data available to partners and affiliates;

- collecting (receiving) from partners and/or affiliated persons the results of processing User data together with the data at the disposal of partners and affiliated persons, including in the form of integer and/or text values and identifiers.

1.4. In some cases, certain functionality of the Services may be provided not by the Company, but by third parties who act independently of the Company and do not act on behalf of or on behalf of the Company. In this case, Users are obliged to familiarize themselves with the rules for the provision of services and the information/personal data protection policy of such third parties before using the relevant functionality of the Services.

II. Purposes of information collection

2.1. The Company collects and processes only the Information that is necessary to fulfill the Company's obligations to provide the Company's Services.

2.2. The Company may use the Information to:

(a) identify the party to the contract (offer – posted at link to the agreement with the user________) between the User and the Company;

(b) providing services to Users using the Company's Services and further improving the Company's Services, developing new services and services based on feedback/information from Users;

(c) responding to User requests to the support service, informing Users about the capabilities of the Company's Services, sending requests regarding the use of the Company's Services;

(d) marketing;

(e) performing statistical and other research based on depersonalized data;

(g) providing data from cookies to third parties with whom the Company has concluded contracts for the demonstration by third parties of targeted advertising and information materials on the Internet and/or for the purposes of providing other services to Users by third parties in accordance with the procedure established by law.

III. Collected and processed Information

The Company collects and processes the following types of Personal Data:

3.1. Personal data posted by Users about themselves when using the Company's Services, which may include: name, email address, phone number, country of residence, address, age, spending and income data, account balance, etc.

Personal data provided by users voluntarily is processed by the Company to the extent necessary to fulfill obligations.

3.2. Other data necessary for the operation of a particular Service, namely:

((a) data on technical means (devices), technological interaction with the Service (including host IP address, type of User's operating system, browser type, geographical location, Internet service provider);

(b) information automatically obtained when accessing the Services using cookies;

((c) information obtained as a result of User actions in the Services, in particular, information about the addition of any content (if applicable);

(d) generalized analytical information about the use of Internet services.

3.3. The Company does not verify the personal data provided by the User and cannot judge their reliability, as well as whether the User has sufficient legal capacity to provide data. The Company assumes that the personal data provided by the User is reliable and provided to the required extent. By using any of the Services or accessing it, the User confirms that he has reached the acceptable age of using such a Service in accordance with applicable law.

3.4. Processing cookies

Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the User's computer or mobile device. The Company collects and processes cookies in relation to Users visiting the Company's Services.

The following types of cookies are used in the Company's Services:

(a) technical cookies are necessary for the operation of the site and the provision of Services to the User; they allow the Company to identify the User's hardware and software, including the browser type; collect information about how Users interact with the site, which allows you to identify errors and test new features to improve the performance of the Services;

((b) analytical cookies - allow you to recognize Users, count the number and collect information, such as operations performed on sites, including information about visited web pages and content that the User receives; allow you to provide certain functions to facilitate the use of Services, for example, by saving preferences (such as language and location);

(c) tracking files / advertising cookies - collect information about traffic sources, visited pages and advertisements displayed by the User. They allow you to display ads that may be of interest to the User, based on the analysis of information collected about the User. They are also used for statistical and research purposes.

3.5. Cookies are processed by the Company solely for the purpose specified in paragraph 2.2. of this Policy, on the terms and in the manner defined by this Policy, in particular on the basis of data obtained using cookies, the Company develops the most useful functionality for the Services available to the User, conducts statistical research, corrects errors in the Services and tests new features to improve the performance of Services, personalizes them and shows the most relevant information to the User.

3.6. The Company may exchange information obtained through tools such as cookies, registration files and device identifiers with third-party organizations that ensure the operation of automatic data processing technologies of the Services. The Company does not control and does not influence the methods of data processing control of such third-party organizations or how they can be used.

The Company can interact with the following third-party providers to obtain data for the implementation and improvement of the Services:

(1) Amplitude, Inc., - analysis of user behavior on Services. Link to the Privacy Policy: .

(2) Google Analytics Services, LLC: Firebase Crashlytics; Google Analytics for Firebase; Firebase Authentication; Cloud Firestore, - analysis of the use of Services. Links to Privacy Policies: ; .

(3) OneSignal, a U.S. - service for the delivery of Push notifications and automation. Link to the Privacy Policy: .

3.7. Processing of information about the User's location (geo-location).

The Company may receive and process information about the User's location (geo-location) as part of Other data in compliance with the Purpose specified in clause 2.2. of this Policy, namely, to constantly improve the content of the Services, prevent and prevent any errors that may occur when using the Services, to personalize information (including advertising) available to the User in Services, to provide relevant recommendations to the User, as well as to conduct statistical research.

The Company can receive and process information about the User's location (geo-location) of varying accuracy, which depends on the functionality of the Service used, the settings selected by the User, the source of receiving data about the User's location, as well as the need to process location data to provide the functionality of a particular Service to the User and improve the user experience.

At the same time, the Company bases its assumptions about the User's location depending on the settings selected by the User in the browser or on a mobile device based on the User's IP address; information about the location of the device; and/or other information about the User's use of a particular Company Service.

The user can restrict the transmission of information about his location by changing the settings of his browser and/or mobile device.

IV. Terms of the Data processing

4.1. The processing of User Information is carried out by the Company in accordance with the following principles:

1) legality of the purposes and methods of information processing;

2) the integrity of the Company;

3) compliance of the purposes of information processing with the purposes previously defined and declared during its collection, as well as with the Company's powers;

4) compliance of the volume and nature of the processed information, methods of its processing with the purposes of information processing;

5) the inadmissibility of combining databases containing User Information created for incompatible purposes.

4.2. Collecting of Information

The User's personal data is collected during use, any interaction, as well as access to the Company's Services (for example, when launching an application).

4.3. Data Transfer

User data is not transferred to any third parties, except as expressly provided for in this Policy, other applicable rules, as well as applicable legislation.

The Company may transfer User data to third parties, in compliance with the purposes and if there are grounds specified in this Policy. Such third parties may include:

- persons who participate in the provision of services related to the placement and display of information to users (including offers relevant to the interests of Users) about the Company's services and services in programs, products or services owned or controlled by such persons (for example, owners of websites and applications, advertising networks and other persons, etc.);

- third parties in respect of whom the assignment of rights or obligations has been made, or an innovation under the relevant Agreement with the user;

- any authority to which the Company is obliged to provide information in accordance with applicable law upon request.

The Company has the right to provide the User with the opportunity to transfer Credentials to third parties through special technologies (Open ID, etc.), subject to the User's consent to such transfer. At the same time, the Company does not guarantee the completeness and correctness of the transfer of Credentials to the User and is not responsible for the safety of data during the transfer.

In cases provided for by the privacy policies of the relevant Services, the Company may carry out cross-border transfer of Information to the minimum extent necessary for the purposes specified in this Policy to third parties.

It is not allowed to extract and use User data, including for commercial purposes, without the Company's permission.

4.4. Information Storage

The Company stores data in accordance with the requirements of the legislation on personal data on servers that provide reliable data protection.

User data is stored exclusively on electronic media and processed using automated systems, except in cases where non-automated processing of personal data is necessary in connection with compliance with legal requirements.

4.5. Information Retention Periods

The data is stored until the purposes of their processing are achieved, unless otherwise specified in the privacy policy.

The data is stored by the Company during the term of the agreement between the User and the Company on the use of the, and after the termination of such agreement – for the period necessary and established by applicable law.

4.6. Termination of Information processing

Upon achieving the purposes of information processing, the Company terminates data processing in one of the ways provided for by the current legislation.

V. Rights of the User

5.1. The User has the right to receive information about his personal data processed by the Operator.

If the information about the User is incorrect or incomplete, the User can correct and/or supplement the information himself, if the Service allows it, or contact the Company and request correction and/or addition of incorrect information.

5.2. In addition, the user has the rights to:

(a) require the complete deletion of Personal Information;

b) require restrictions on the processing of Personal Information;

c) object to the processing of Personal Information;

5.3. In order to exercise any of the above rights, the User can contact the Company by e-mail (e-mail). The Operator ensures the implementation of the above rights only in relation to the information to which there is access and the storage of which is carried out by the Company. To process the request, the Company must first identify the user.

5.4. When processing information for marketing purposes, the User may request the termination of data processing for such purposes. To exercise this right, you must contact the third-party service providers listed in Section 6 of the Privacy Policy.

VI. Rejection to process personal data

6.1. The User may prevent and/or manage the collection and processing of data related to the use of the Services by following the instructions given below.

Google Analytics. To opt out of tracking Google Analytics data, the User can install and activate the Google Analytics Blocker. The User can also manage and/or delete «cookies» previously set by Google Analytics through the browser settings. Additional information about the practical methods of data processing and the corresponding instructions of Google Analytics can be found at the link (section «Information for visitors to websites and applications where Google Analytics is used»).

6.2. Blocking cookies

Browsers that allow you to refuse to accept cookies.

Internet Explorer (this page links to additional information for different versions of IE — the mobile version is located at )


Blocking all «cookies» can negatively affect the usability of many Services and Websites.

VII. Feedback

7.1. Users have the right to send requests, including requests regarding the use of their personal data provided for in Section 5 of this Privacy Policy, in writing to the address: the company's legal address, or in the form of an electronic document signed with a qualified electronic signature in accordance with applicable law, to the email address:

77.2. In order to exercise the stated right, the Company may request: (1) to provide sufficient information to ensure that the user is the person about whom the Company has collected Personal Data, and (2) to describe the request in sufficient detail so that the Company can understand, evaluate and respond to it. The Company may not respond to requests that do not meet these criteria. The Company will use the Personal Data provided in the request only for verification and execution of the request. The Company will respond to the request within 30 days of its receipt.