Privacy Policy

Effective date: 2026-01-09

1) Who we are

Developer: Cybernetica Ltd (“we”, “us”).
App: Re:Focus - Focus Trainer (“Re:Focus”).
Contact (support + privacy requests): [email protected]

2) What this policy covers

This policy explains what data Re:Focus collects (if any), how it is collected, how it is used, what third parties receive data (if any), and how you can revoke permissions or request deletion.

3) Data we collect (and what we do not collect)

Re:Focus does not require an account. Depending on how you use the app, we may process:

• Camera permission + camera input (on-device): Re:Focus requests access to your front camera to perform eye/face tracking for focus training.
• On-device tracking signals: derived signals used to run sessions (for example, gaze/face-tracking state, calibration progress, and session scoring state). These are processed on-device for core functionality.
• Subscription / purchase status: if you purchase a subscription, Apple processes payment. We may receive subscription entitlement/status information (e.g., active/inactive) via Apple’s StoreKit and our paywall provider (Superwall).
• Support communications: if you email us, we will receive the contents of your message and your email address.

3A) TrueDepth / ARKit Face Tracking (Face Data)

Re:Focus uses ARKit Face Tracking (which uses the TrueDepth camera on supported devices) to process face and eye-tracking signals in real time for focus training. This may include face pose, eye transforms, and limited facial expression signals used to assess tracking quality.

• Face pose: face/head transform.
• Eye tracking: left and right eye transforms.
• Limited facial expression coefficients (tracking-quality checks only): eyeWideLeft and browInnerUp.
• Ambient light estimate (tracking-quality checks only): used to detect low-light conditions that reduce tracking reliability.

We use this data only to provide core functionality (gaze tracking, calibration, feedback, and session scoring).

We do not record, store, or upload photos, videos, depth maps, or face tracking data. Face tracking is processed on-device during a session and discarded when the session ends.

We do not store or upload raw face anchors, eye transforms, gaze points, gaze samples, or any face template/biometric identifier.

We do not use face data to identify you, and we do not perform Face ID-style authentication or create a face template.

We do not share face data with third parties.

4) How we collect data

• From you / your device: when you grant camera permission and use training features.
• From Apple: purchase/subscription events and entitlements provided via StoreKit/App Store.
• From Superwall: data processed to present paywalls and manage subscription flows.
• From you (support): when you email [email protected].

5) How we use data

• Provide core functionality: run focus-training sessions using on-device eye tracking.
• Operate subscriptions/paywalls: show paywalls and determine whether premium features are available.
• Customer support: reply to support requests and troubleshoot issues.

6) Third parties / sharing

We do not sell your personal data. We share limited information only with service providers needed to operate subscriptions/paywalls:

We do not share any TrueDepth/ARKit face tracking data with third parties.

We do not share any TrueDepth/ARKit face tracking data with any third party.

• Apple (App Store / StoreKit): processes payments and provides subscription status/entitlements. Apple’s privacy policy: https://www.apple.com/legal/privacy/
• Superwall: used to present paywalls and manage subscription-related flows. Superwall’s privacy policy: https://superwall.com/privacy

7) Data retention

• On-device tracking/session data: processed on your device for functionality and not stored by us on our servers for training.
• TrueDepth/ARKit face tracking data: processed in memory on-device during a session and not retained after the session ends.
• Support emails: retained only as long as needed to respond and for reasonable record-keeping, then deleted or anonymized where feasible.
• Subscription records: purchase records are maintained by Apple.

8) Your choices, permissions, and deletion requests

• Revoke camera permission: you can grant or revoke camera access at any time in iOS Settings. If you do not grant camera access, focus-training features that rely on eye tracking will not work.
• Request deletion / access: email [email protected] with your request. If your request relates to subscription/paywall data, we may need enough information to locate relevant records. Some records (e.g., App Store purchase history) are controlled by Apple.

We aim to respond to privacy requests within a reasonable timeframe (typically within 30 days).

9) Security

We use reasonable safeguards designed to protect information we process. No method of transmission or storage is 100% secure, so we cannot guarantee absolute security.

10) Changes to this policy

We may update this Privacy Policy from time to time. We will update the “Effective date” above when changes are made. If changes are material, we may provide additional notice within the app or on this page.

11) Contact

Questions or requests: [email protected]