FoCoCo ("we," "us," "our") is a product of Quantum Surprise, Unipessoal Lda, located in Portugal.

We are committed to protecting your privacy, your data, and your trust.

FoCoCo is designed for golfers aged 13+.

This Privacy Policy explains how we collect, use, store, and protect your information when you use the FoCoCo mobile app, WebApp, or website.

The FoCoCo WebApp uses local storage and secure tokens for authentication and performance, not cookies.

1. Who We Are

Quantum Surprise, Unipessoal Lda

NIPC 518139247

Portugal

We act as the Data Controller for all user data under GDPR.

You can contact us anytime: privacy@fococo.ai

2. What We Collect

We only collect the minimum data needed to run FoCoCo safely and effectively.

a) Information You Provide

Email address (to create or restore your account)
Voice input (optional; only when using JustTalk)
Text or tap-based entries (MindCoach routines, reflections, notes)
Newsletter signup (optional)

We never collect:

Name, phone number, address, contacts, photos, videos, or any personal documents.

b) Automatically Collected Data

Used solely to run FoCoCo and improve performance.

Device ID (Firebase)
Crash logs (Crashlytics)
Performance metrics
In-app product interaction
Subscription verification
Search/filter queries (FoCoMap & GolfSync)

c) Location Data

Used only for mapping your round inside FoCoMap.

Precise location (GPS)
Coarse location (automatically inferred)

Location is optional and can be disabled at any time.

d) Voice Data

When enabled, voice data is processed to text. We do not store raw audio.

3. How We Use Your Data

To provide and improve FoCoCo:

Process voice to text
Generate personalized insights
Visualize patterns in FoCoMap
Manage subscription access
Sync your progress across devices
Maintain app reliability and performance

We never sell your data.

We never share it with advertisers.

4. Legal Basis (GDPR)

We process data under:

Contractual necessity (provide the app)
User consent (voice, location, newsletter)
Legitimate interest (app security & performance)

5. How Long We Keep Your Data

Account data: while your account is active
Optional content (notes, voice → text, logs): until deleted by you
Analytics & crash logs: 12-24 months
Backups: 30 days

You may request full deletion anytime: privacy@fococo.ai

6. Your Rights (GDPR)

You can request:

Access to your data
Correction
Deletion
Data export
Restriction of processing
Withdrawal of consent

We respond within 30 days.

7. Data Transfers

If your data is processed outside the EU, we use:

EU Standard Contractual Clauses
GDPR-compliant safeguards

8. Children

FoCoCo is for users aged 13+. We do not knowingly collect data from children under 13.

9. Security

We use:

End-to-end encryption
Secure authentication
Encrypted database storage
Strict access controls

10. Links to Third Parties

We use:

Firebase
RevenueCat (Apple/Google subscription handling)
OpenAI/Gemini/Cartesia (AI processing)

These providers meet strong security and GDPR standards.

11. Governing Law

These terms follow the laws of Portugal, interpreted under Portuguese jurisdiction.

Data protection follows GDPR and applicable EU laws.

Local consumer rights may apply based on your location.

12. Contact

privacy@fococo.ai

info@fococo.ai

support@fococo.ai