Privacy Policy
The Focus on Me application ("the App", "we", "us", "our") is operated by Cubo Software, having its registered office at Via Tagliaferro 12, Scarperia e San Piero, Firenze, Italy, registered with the Trade Register under number 07262550481, tax ID 07262550481 ("the Company", "we").
This policy explains what data we collect, why, how we use it, and what rights you have over it, in line with the General Data Protection Regulation (GDPR — EU 2016/679), the California Consumer Privacy Act (CCPA), and other applicable data protection laws.
1. What data we collect
| Category | Data collected | Purpose |
|---|---|---|
| Account | Email, first name, last name (optional) | Authentication, personalization |
| General location | Country selected at sign-up | Usage statistics, regional adaptation |
| Photos | Your photo and a product photo, sent temporarily for the "try-on" feature (not stored — see Section 3) | Generating the image of the product on you, via AI processing |
| In-app activity | Products viewed, try-ons generated, credits used | Operating the service, preventing abuse |
| Purchases | Purchase confirmation for credit packages (via App Store / Google Play) | Granting purchased credits |
| Technical data | IP address, device type, advertising identifier (if permitted) | Operation, security, advertising |
What we do NOT collect
We do not collect bank card data (payments are processed entirely by Apple/Google), we do not collect permanent biometric data, and we do not sell your data to third parties for direct marketing purposes.
2. Legal basis for processing
Depending on the data and the purpose, we rely on the following legal bases under GDPR:
- Performance of a contract — for account data and try-on processing, necessary to provide the service you requested;
- Consent — for personalized advertising and the use of advertising identifiers;
- Legitimate interest — for basic technical data used to keep the App secure and functioning correctly;
- Legal obligation — for records we are required to keep, such as purchase records for tax purposes.
3. Photos used for "Try-On"
Photos you use for the virtual try-on feature are not stored in the cloud. They live on your device, and are only transmitted, at the moment you request a try-on, to our AI processing service (RunPod) for the sole purpose of generating the result. Specifically:
- your photo and the product photo are sent for processing only when you tap "Try On";
- they are used exclusively to produce the image you requested;
- they are never saved to a database or persistent storage on our side or on RunPod's side — once the result is generated and returned to your device, the submitted photos are deleted;
- they are not used to train AI models, ours or third parties';
- the generated try-on result is returned to your device and is not retained on our servers either.
In short: outside of the brief moment needed to generate your try-on, your photos exist only on your own phone.
4. Third-party services we share data with (sub-processors)
| Service | Role | Data shared |
|---|---|---|
| Supabase | Database, authentication | Email, name, country, account activity |
| RunPod | AI processing of photos for try-on | Photos submitted for processing only, deleted immediately after — not stored |
| Google AdMob | Ad display | Advertising identifier, device technical data (only with consent) |
| Apple App Store / Google Play | Payment processing for credits | Purchase confirmation (we do not see your card details) |
| Awin, TradeDoubler | Affiliate networks for products | Clicks on product links (for commission purposes, not your personal data) |
The App contains links to third-party retailer websites where you can purchase products. Once you leave the App through one of these links, that retailer's own privacy policy applies — we are not responsible for the privacy practices of third-party websites, and encourage you to review their policies before providing any personal information.
5. Advertising and consent
The App displays ads through Google AdMob. Before using advertising identifiers for ad personalization, we ask for your explicit consent (via Apple's App Tracking Transparency prompt and/or Google's consent management platform). You can decline at any time, and the App will continue to work normally, showing less personalized ads instead.
If you change your mind after granting consent, you can withdraw it at any time:
- On iOS: Settings → Privacy & Security → Tracking, and turn off tracking for Focus on Me (or turn off "Allow Apps to Request to Track" globally).
- On Android: Settings → Privacy → Ads, and select "Delete advertising ID" or "Opt out of Ads Personalization", depending on your Android version.
6. How long we keep your data
We retain your account data for as long as your account is active. If you delete your account, the personal data associated with it (email, name, try-on history) is deleted from our systems within 30 days, except where the law requires us to retain certain records longer (e.g. tax records for purchases).
7. Your rights (GDPR)
You have the right to:
- access the data we hold about you;
- request correction of inaccurate data;
- request deletion of your account and associated data;
- request a copy of your data in a portable format;
- withdraw your consent to personalized advertising at any time;
- lodge a complaint with your local data protection authority (in Romania, ANSPDCP) if you believe your rights have been violated.
For any data-related request, contact us at contact@focusonme.fashion.
8. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to:
- know what personal information we collect, use, and disclose about you;
- request deletion of your personal information;
- opt out of the "sale" or "sharing" of personal information — we do not sell your personal information, and any sharing with advertising partners for personalized ads only happens with your consent, which you can withdraw at any time (see Section 5);
- not be discriminated against for exercising any of these rights.
To exercise any of these rights, contact us at contact@focusonme.fashion.
9. Deleting your account
You can request account deletion directly from the App (Profile → Settings → Delete account) or by emailing the address above.
10. Children's privacy
The App is not directed at, or intended for use by, children under 13 years of age (or the relevant minimum age for consent to data processing in your country). Eligibility requirements for creating an account are set out in our Terms and Conditions.
We do not knowingly collect personal data from children under this age. If we become aware that we have inadvertently collected data from a child under the applicable minimum age, we will delete that data as soon as reasonably possible.
If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at contact@focusonme.fashion so we can investigate and delete the relevant data.
For users in the United States, we comply with the Children's Online Privacy Protection Act (COPPA) by not knowingly collecting personal information from children under 13.
11. International transfers
Some of our service providers (Supabase, RunPod, Google) may process data outside the European Union. In these cases, we ensure the transfer is carried out under Standard Contractual Clauses approved by the European Commission or an equivalent safeguard mechanism.
12. Changes to this policy
We may update this policy from time to time. Any significant change will be communicated through the App or by email.
13. Contact
Cubo Software
Via Tagliaferro 12, Scarperia e San Piero, Firenze, Italy
Email: contact@focusonme.fashion