Effective 2026-04-23. This policy covers the Pure Focus client app at app.purefocusprogram.com. Pure Focus is operated by Manousos Varouxakis (Malta). Contact: privacy@purefocusprogram.com.
The app does not collect payment information. You pay for coaching separately, outside the app. The iOS and Android apps contain no purchase or subscription screens.
We process your data under Article 6(1)(b) - performance of your coaching contract - and, for health data, Article 9(2)(a) - your explicit consent given at account creation.
Solely to deliver your coaching: show your metrics, generate daily briefs, power the AI coach, and flag sessions for your human coach (Manou) to review. We do not sell data. We do not use your data to train AI models.
See /subprocessors for the current list. Anthropic processes AI chat prompts (pseudonymized - your email and name are never sent). Apple Health, Oura, Whoop, and Garmin data is read only with your explicit connection or grant. We do not sell your data. We do not use your data to train AI models.
Biometric events: 3 years after program end. Chat history: 1 year. Photos: until you delete them or your account. Account: until you delete it. Deleted accounts enter a 14-day grace period, then are hard-deleted.
You can export all your data (Article 15) or delete your account (Article 17) from your account settings at any time. You can also request deletion without logging in: see Delete your account. Email privacy@purefocusprogram.com to request correction or restriction.
TLS 1.2+ in transit. SQLite with encrypted off-site backups. Wearable OAuth tokens encrypted at rest (Fernet). You can report vulnerabilities via security.txt.
We use one strictly-necessary cookie (pfa_session) to keep you logged in. No analytics cookies, no ad tracking.
The service is for clients age 18+. We do not knowingly collect data from minors.
Material changes will be emailed 30 days before they take effect.