LAST UPDATED: [DATE] · VERSION 1.0
Draft for review
This document was prepared as a starting point and has not been reviewed by a solicitor. Before launch it needs checking by someone qualified, particularly the sections on special category data, the AI feature and international transfers.
1. Who we are
Soft Focus is operated by [LEGAL ENTITY NAME], [COMPANY NUMBER], registered at [ADDRESS], United Kingdom. For the purposes of UK data protection law we are the data controller for the information described here.
You can reach us at hello@softfocusadhd.com. If we are required to register with the Information Commissioner's Office, our registration number is [ICO REGISTRATION].
2. What we collect
| What | Why |
|---|---|
| Email address | To create your account and let you get back in on a new phone. We use a one-time code rather than a password. |
| Apple or Google account identifier | If you sign in that way instead. We receive an identifier and, where you allow it, an email address. |
| Your first name and your partner's first name | So the app can speak plainly rather than saying "your partner" throughout. |
| Pairing code | An eight-character code that links two accounts together. |
| What you write in the app | Notes, calendar entries, messages to your partner, answers to questions, gratitude notes and mood entries. See sections 3 and 4. |
| Subscription status | Whether you are on the free or premium tier. Payment itself is handled by Apple or Google — we never see your card. |
| Basic technical information | Device type, operating system version and app version, so we can fix crashes. |
We do not collect your card details, your location, your contacts, your photos, or anything from other apps on your phone.
3. What stays on your device
By default, most of what you write never leaves your phone. Your daily prompts, private notes, the things you haven't said, your mood entries and anything you record in Closer are stored locally.
Two things change that:
- Linking with a partner. Some information is then shared deliberately — see the next section.
- Backup. If you create an account and enable backup, an encrypted copy is stored on our servers so you can restore it. You can turn this off and delete the copy at any time.
4. What your partner can see
The short version
Your partner sees only what you deliberately send. They never see your private notes, your mood entries, your list of things unsaid, whether you ticked anything off, or which questions you skipped.
When you link accounts, the following is shared between the two of you:
- Messages you send through the app
- Entries you add to the shared calendar
- Questions you send, and the answers you choose to give
- Gratitude notes you send
- Whether a message or answer has been read
Everything else stays on your own side. This is a deliberate design decision, not an accident: an app that let one partner monitor the other would do more harm than good.
You can unlink at any time from the Plan tab. Unlinking stops any further sharing, though your partner keeps what was already sent to them, in the same way an email you have already sent cannot be recalled.
5. Health and sensitive information
Some of what you enter may amount to health information under UK data protection law — for example recording that you or your partner has ADHD, or logging how you are feeling.
We treat this as special category data. Our lawful basis for handling it is your explicit consent, which you give when you choose to enter it. You can withdraw that consent at any time by deleting the entries or your account.
Soft Focus is not a medical service. Nothing you enter is reviewed by a clinician, nothing constitutes a diagnosis, and we do not share it with any health provider, insurer or employer.
6. The guide, and how AI is used
The guide is powered by a third-party AI service. When you send a message to the guide, that message and the conversation it belongs to are sent to that provider so a reply can be generated.
- We send your question and the conversation so far. We do not send your name, your email, your partner's name or anything else from your account.
- The provider processes it on our instructions under a data processing agreement, and does not use it to train their models.
- Guide conversations are stored on your device and can be cleared at any time from within the guide.
The guide can be wrong. It is not a therapist, it cannot diagnose anyone, and it should not be relied on for medical, legal or financial decisions.
7. Why we're allowed to use it
| Information | Lawful basis |
|---|---|
| Account details and app content | Performance of our contract with you — we cannot provide the app without them. |
| Health and mood information | Your explicit consent (UK GDPR Article 9(2)(a)). |
| Crash and technical data | Our legitimate interest in a working app. |
| Marketing emails | Your consent, given separately and never bundled with signing up. |
8. Who else sees it
We do not sell your data, and we do not allow advertising in Soft Focus. We share information only with the suppliers who help us run it:
- Our hosting and database provider, for accounts and backup
- The AI provider behind the guide, as described above
- Our email provider, for account codes and any marketing you have opted into
- Apple and Google, who handle subscriptions and tell us only whether yours is active
Some of these operate outside the UK. Where that happens we rely on the UK's international data transfer agreement or equivalent safeguards. [CONFIRM SPECIFIC PROVIDERS AND MECHANISMS BEFORE LAUNCH.]
We may also disclose information if we are legally required to, or where it is necessary to protect someone from serious harm.
9. How long we keep it
- While your account is open: for as long as you keep using Soft Focus.
- After you delete your account: we delete your account data within 30 days, other than anything we must keep for legal or accounting reasons.
- If your account is inactive: we will contact you before deleting anything after 24 months of no activity.
- On your device: deleting the app removes everything held locally. That cannot be recovered unless you had backup switched on.
10. Your rights
Under UK data protection law you can ask us to give you a copy of your data, correct it, delete it, restrict how we use it, or object to us using it. You can also ask us to send it to another service, and you can withdraw consent at any time.
Email hello@softfocusadhd.com and we will respond within one month. There is no charge.
If you think we have got something wrong, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would rather you told us first so we can put it right.
11. Age
Soft Focus is for adults. You must be 18 or over to create an account. We do not knowingly collect information from anyone under 18, and will delete it if we discover we have.
12. Changes, and how to reach us
If we change this policy in a way that matters, we will tell you in the app before it takes effect rather than quietly updating this page.
Questions, requests or complaints: hello@softfocusadhd.com, or write to [LEGAL ENTITY NAME], [ADDRESS].