Last updated: 11 September 2026 · version 6
1. Data controller. The data controller is Daniele Cattaneo, reachable at [email protected]. No Data Protection Officer has been appointed, as one is not required under art. 37 GDPR.
2. What data we process.
(a) Account data: the email address you sign in with, via sign-in link or Google account. If you use Google sign-in we receive your email and basic profile identifiers from Google; we use only the email.
(b) App data: the content you voluntarily enter — study or work sessions, focus ratings, exams, grades, goals, weekly plans, reviews, settings and, optionally, the name you choose to display.
(c) Coworking data: if you use coworking we process the time slot you book, the session status (queued, matched, completed, cancelled), the name or nickname you choose to show other participants, required in order to use coworking, the birth year you state once to confirm you are of age (not the full date), the favorites you add (visible only to you) and any reports sent or received. See also section 5.
(d) Support data: if you send a report or support message, the message text, the interface language and — only if you tick the relevant box — your email. If you don't tick it, the submission is anonymous.
(e) Technical data: information strictly necessary to run the service, such as authentication tokens, timestamps and the hosting providers' security logs.
(f) Aggregated traffic statistics: for each page opened we record the page path, the referring page, the browser language, the time of the visit and — only if you arrived through one of our labelled links, for example focus-sea.com/c1 — that link's label. The label belongs to the link, not to you: it is identical for everyone who clicks it, it is never saved on your device, and it disappears from the address bar right away. We use no cookies, generate no identifiers and never link separate visits together: it is not possible to reconstruct one person's path or to identify you. See section 10.
2-bis. If you don't provide the data. Your email is needed to create an account and sign in: without it the service cannot be provided to you. The display name and birth year are needed only for coworking: without them the timer and the rest of the app stay available. All other data is entered by you whenever you want, and not entering it has no consequences.
3. Purposes and legal bases. We process your data to: provide the service, authenticate you and sync your data across devices (art. 6(1)(b) GDPR — performance of a contract); enable the matching and running of the coworking sessions you request (art. 6(1)(b)); answer support requests (art. 6(1)(b)); keep the service secure, prevent abuse and handle reports between users (art. 6(1)(f) — our legitimate interest and that of other users in a safe environment); measure in aggregate form which pages are used (art. 6(1)(f) — legitimate interest in understanding whether the service works, with the lowest possible impact on your privacy); automatically collect the app's technical error messages — what broke, on which screen and with which browser, never what you wrote — in order to fix faults (art. 6(1)(f), legitimate interest in keeping the service working); comply with legal obligations (art. 6(1)(c)). We do not sell your data, we do not use it for advertising, and we carry out no profiling or automated decision-making producing legal effects on you. The only automatic measure in place is the precautionary hold on future bookings after sessions where the other person did not show up: it is temporary, you can lift it yourself or it expires on its own at the time stated in the app, and it produces no legal effects and does not similarly significantly affect you within the meaning of art. 22 GDPR. Any restriction, suspension or closure is instead decided by a person (see section 5).
4. Coworking video calls. Matched sessions take place over video through Jitsi Meet, free software running on a server of ours in Frankfurt (Germany, European Union). The machine is provided by Oracle (see point 6); the video call software is free software and we run it ourselves. There is no third-party video conferencing provider: the call passes through no commercial platform.
How the video travels, precisely. When there are two of you, your devices first try to connect directly: it is the shortest path, and without it the delay grows enough for you to talk over each other. On a direct connection the two devices see each other's IP address, as in any direct link between two computers: it is personal data, we neither store nor display it, and it is the price of a conversation without delay (see point 4-bis). If the direct connection fails — which often happens on mobile networks — audio and video go through our Frankfurt server, which only forwards them: it does not record them, does not store them, does not open them, and in that case the two addresses never meet. In neither case does the call pass through a commercial platform.
One true thing we tell you anyway: our server is in the European Union, but the video call reaches the person you are talking to, wherever they are — including outside the EU, if that is where they live. That is what a video call is, and writing that no data leaves Europe would not be honest. What we can tell you is that what leaves is only what you chose to show them: your image and your voice, for the duration of the call.
We do not record audio or video: on our server recording is not a disabled feature, it is a feature that does not exist. The session's text chat is ephemeral too and is not saved anywhere. The other person can see your image and hear your voice while the call is running, plus the name or nickname you chose to display: we never show them your email or your account name. We recommend not sharing personal information on the call that you don't want known. Recording the call is prohibited by the Terms of Service.
5. Reports and moderation. If you report a session, we process the reason you select, any description you write, the session identifier and the accounts involved. Reports are reviewed by a person: no automated mechanism suspends an account. Following review we may limit, suspend or close access to coworking. If a measure is taken against you, you have the right to challenge it by writing to [email protected], and you will receive a reasoned reply.
6. Recipients of the data. Your data is never sold and is not disclosed to third parties for marketing purposes. We draw a distinction here, because the safeguards are not the same. Processing data on our behalf, as processors under art. 28 GDPR: Supabase (database, authentication, server functions), Cloudflare (site hosting and email routing), Resend (delivery of your sign-in emails) and Oracle (the Frankfurt machine our video call server runs on: it provides the infrastructure, not the video call service). Processing data independently, as its own controller and not on our behalf: Google, only if you choose Google sign-in and limited to authentication. There are no other recipients: the app loads no scripts, fonts, maps or images from third-party servers, uses no external content delivery networks and employs no third-party analytics. We may also disclose data to judicial or competent authorities where legally required.
7. Where the data lives and transfers. The database and authentication are hosted by Supabase in the Frankfurt, Germany (European Union) region. The video call server is also in Frankfurt. Access to app data is protected by row-level security: each account can only read and write its own data. For Supabase, Cloudflare and Oracle, where some technical traffic or support activity may involve infrastructure outside the European Union, the transfer relies on the Chapter V GDPR safeguards set out in the respective data processing agreements. There is no exception, and there used to be one: until 7 September 2026 the video call ran on a third-party provider's United States infrastructure, which we stated plainly and for which we asked your specific consent under art. 49.1.a GDPR. Since the video call runs on a server of ours in the European Union that transfer no longer happens, and that consent has been removed because it no longer has anything to authorise.
8. Retention. Account and app data are kept for as long as your account is active. If you request deletion of your account they are erased without undue delay; residual copies in technical backups are removed within the providers' normal backup cycles, as a rule within 30 days. Coworking session data is kept for as long as needed to show you your history and handle any reports. Reports and the outcome of their review are kept for up to 24 months, so that repeated behaviour can be assessed and claims defended. Anonymous feedback is kept only for as long as it is useful to improve the service. Aggregated traffic statistics are kept for a maximum of 12 months.
9. Your rights. Under arts. 15–22 GDPR you have the right of access, rectification, erasure, restriction, objection and data portability. You can export all your data yourself at any time from Settings → Data, and delete your account and data from Settings → Danger zone. To exercise the other rights write to [email protected]: we reply within one month. You also have the right to lodge a complaint with the supervisory authority of your country; in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it).
9-bis. Right to object. You have the right to object at any time, on grounds relating to your particular situation, to the processing we carry out on the basis of legitimate interest (section 3): security and handling of reports, aggregated traffic statistics, automatic collection of technical errors. To exercise it, just write to [email protected]. We say it here separately because art. 21 GDPR requires this right to be brought to your attention explicitly and separately from any other information.
10. Cookies and local storage. The app uses no cookies, neither technical nor for profiling. It only uses the browser's local storage (localStorage and IndexedDB) needed to run: the local copy of your data, the session token and your preferences, such as language and theme. For every page opened, we also log aggregated visit statistics — which page, the referring page, the browser language, the time — but with no cookies, no identifier saved on your device, and without linking two visits from the same person together: the same principle used by "cookieless" tools like Plausible or Fathom. There are no advertising cookies, no third-party analytics tools and no tracking pixels. That is why no consent banner appears: cookie law is about reading or writing data on your device to track you, and that never happens here.
11. Security. We apply technical and organisational measures appropriate to the risk: encrypted transmission (HTTPS), per-account data access through row-level security, and authentication with no passwords stored by us. No system is absolutely secure: in the event of a personal data breach involving a high risk to your rights, we will inform you under art. 34 GDPR.
12. Minors. The service is reserved for people aged 18 or over. We do not knowingly collect data from minors. If you believe a minor has created an account, write to [email protected] and we will delete it.
13. Changes. We may update this policy. Material changes will be announced in the app with reasonable notice and the date at the top will be updated. If you do not agree with them you can close your account at any time from Settings, at no cost. Changes never apply retroactively to processing that has already taken place.