Privacy Policy

1. Who we are and what this Policy covers

This Privacy Policy describes how Focus Pivot ("Focus Pivot", "we", "us" or "our") collects, uses, shares and protects personal information when you use the Focus Pivot website, web application, any mobile applications, and related services (the "Service"), and when you contact us. "Personal information" means information that identifies, relates to or can reasonably be linked to you.

This Policy is part of our Terms of Service. Our Cookie Policy gives more detail about cookies.

2. Information we collect

2.1 Information you give us

• Account information: your name, email address, mobile phone number, date of birth, password and language. We store your password only in a form that cannot be reversed. We also keep the answers you give when setting up your account.
• Financial records you add: wallets and accounts as you name them, transactions (amounts, dates, descriptions, categories, tags and who you paid or were paid by), budgets, scheduled payments, debts and receivables, assets and liabilities, and goals. You add these by typing them in, importing a bank statement file you downloaded, or photographing a document. We do not connect to your bank and never ask for your online banking credentials.
• Files and photos: statement files you import, and photos and documents you upload, such as receipts and invoices, together with the text read from them. Photos may contain metadata added by your device, such as the date, the device model and, if your device records it, the location where the photo was taken.
• People and organizations: contacts and organizations you add or import, and what you record about them, such as names, contact details, birthdays, notes and history.
• Planning and productivity content: habits, week plans, tasks, to-dos, calendar events, projects and events, and notes.
• Messages and invitations: messages you send through the Service, and the email address or phone number of anyone you invite.
• Purchases: your plan, billing period, purchase and payment history, and billing details. Card payments are handled by our payment provider, Stripe. We do not receive or store your full card number. We may receive limited details, such as the card brand, last four digits and expiry date.
• Communications: what you send us when you contact support or answer a survey, and our replies.

2.2 Information collected automatically

• Device and usage information: IP address, browser and operating system type, device identifiers, language, the pages and features you use, actions you take (for example, "created a transaction"), dates and times, referring pages, and error and performance data. We keep a history of significant actions in your account so you and our support team can see what happened and when.
• Cookies and similar technologies: mainly to keep you signed in, protect forms and remember your preferences. See section 10 and our Cookie Policy.

2.3 Information from other sources

• Sign-in providers: if you sign in with Google or Apple, we receive the information you allow that provider to give us. This is usually your name, email address and an account identifier, and may include your profile picture or birthday.
• Services you connect: if you connect Google Contacts or Google Calendar, we receive the contacts or calendar events you authorize, and keep them in sync as the feature describes.
• Payment provider: Stripe tells us whether payments succeeded, failed, were refunded or were disputed, and the status of your subscription.
• Other users: another user may give us your name, email address or phone number to invite you, or may record information about you as one of their contacts or counterparties.

3. How we use information

We use personal information to:

• provide the Service: create and run your account, store and organize your records, calculate balances, budgets, forecasts and reports, and run the features you choose;
• verify your email address or phone number, sign you in, and keep your account and the Service secure, including by detecting and preventing fraud, abuse and unauthorized access;
• process payments, manage subscriptions and trials, and keep accounting and tax records;
• read the files and photos you upload and suggest entries from them (see section 4);
• send you service messages, such as verification codes, security alerts, receipts, reminders you set up, and notices about your plan or our terms;
• with your permission where the law requires it, send you news about Focus Pivot. You can unsubscribe at any time;
• respond to your requests and provide support;
• understand how the Service is used, and fix and improve it, using our own records of activity and errors;
• comply with law, respond to lawful requests, and enforce our Terms; and
• for any other purpose we tell you about when we collect the information, or with your consent.

We do not use your financial records, contacts or other content to target advertising. We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

4. Automated reading and AI

Features such as Photo Inbox and statement import read the files and photos you upload with automated tools, which may include machine-learning or AI models. These tools find dates, amounts, merchants and categories so you do not have to type them. The tools may run on our own systems or be provided by a service provider working on our behalf. A provider receives only the image or file to be read, and may use it only to provide the reading to us.

• Using these features is optional. Nothing is added to your records until you review and apply it.
• Automated readings can be wrong. Check them against the original before you rely on them.
• We do not use your files, photos or records to train AI models.

5. How we share information

We share personal information only as described here:

• Service providers. Companies that process information for us under contracts that limit their use of it to providing services to us. These include cloud hosting and storage, payment processing (Stripe), email delivery, text-message delivery, document and photo reading, error monitoring and logging, and customer support tools.
• Services you connect or choose. When you sign in with Google or Apple, or connect a service such as Google Contacts or Google Calendar, we exchange the information needed for that feature with that provider at your direction. Their use of it is governed by their own privacy policies.
• People you choose. When you send an invitation or a message, we deliver it, with your name, to the person you chose.
• Legal and safety reasons. When we believe in good faith that disclosure is required by law, subpoena or other legal process, or is necessary to protect the rights, property or safety of Focus Pivot, our users or others, including to prevent fraud.
• Business transfers. If Focus Pivot is involved in a merger, acquisition, financing, reorganization, bankruptcy or sale of assets, personal information may be transferred as part of that transaction. It will remain subject to this Policy, or to a policy at least as protective, and we will tell you before it becomes subject to a different policy.
• With your consent. For any other purpose you agree to.

We may also share information that has been aggregated or de-identified so that it can no longer reasonably be linked to you. We will not try to re-identify it.

6. We do not sell or share for advertising

Focus Pivot does not sell personal information. It does not "share" personal information for cross-context behavioral advertising, as those terms are defined under California law, and does not process it for targeted advertising. We have not done so in the past 12 months. That includes the personal information of consumers under 16. We have no third-party advertising, analytics or tracking scripts on our site. If this ever changes, we will update this Policy first, and give you a way to opt out, before it happens.

7. How long we keep information

We keep personal information for as long as we need it for the purposes in this Policy. That depends on how long you have an account, what the law requires us to keep, and whether we need the information to resolve disputes or enforce our agreements.

• While your account is open, we keep your account information and content so the Service can show it to you. You can delete individual records at any time.
• When you close your account in Account Settings, your access ends immediately and you have 14 days to reactivate it. After 14 days, we permanently remove your sign-in details. We also replace the names, contact details and notes in your records with meaningless text, so the remaining entries, such as amounts and dates, can no longer be associated with you through the Service.
• If you ask us to delete your data (see section 12), we erase your account and the records and files in it, except as described below.
• Information we must keep: records we are required to keep by law, such as payment and tax records, and information needed to establish, exercise or defend legal claims, are kept for the period the law requires.
• Backups and logs are kept for limited periods for security and recovery, then deleted or overwritten on a regular schedule.

8. Security

We use administrative, technical and physical safeguards designed to protect personal information. These include encryption of data in transit (HTTPS), one-way protection of passwords, verification codes, limits on repeated sign-in attempts, access controls that limit our staff's access to what their work requires, and records of administrative actions. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Keep your password secret and tell us at once at support@focuspivot.com if you suspect unauthorized access. If a security incident affects your personal information, we will notify you and the authorities as the law requires.

9. Your choices

• Account and profile: view and update your information in Account Settings and your profile.
• Your records: edit or delete records, contacts and photos in the Service at any time.
• Connected services: disconnect Google or other connections in Account Settings, or revoke access in your account with that provider.
• Emails and texts: unsubscribe from marketing emails using the link in each one. Service messages, such as security alerts and receipts, are part of having an account.
• Notifications: choose which notifications you receive in the Service's notification settings.
• Cookies: see section 10.
• Closing your account: see section 7.

10. Cookies, Do Not Track and Global Privacy Control

We use cookies and similar technologies that are necessary to run the Service, such as sign-in, security and the steps of sign-up, and to remember your preferences, such as language. We do not use advertising cookies or cookies that track you across other websites. Our Cookie Policy lists them and explains how to control them.

Do Not Track. Because we do not track you across third-party websites, there is no cross-site tracking for a "Do Not Track" signal to turn off. The Service works the same whether or not your browser sends one.

Global Privacy Control. We do not sell or share personal information, so there is nothing for an opt-out preference signal to opt out of today. If that changes, we will treat a Global Privacy Control signal from your browser as a valid request to opt out of sale and sharing for that browser, and for your account if you are signed in.

11. Children and teens

• Under 13. The Service is not directed to children under 13, and you must be at least 13 to create an account. We do not knowingly collect personal information from children under 13. If we learn that we have, we will delete it and close the account. If you believe a child under 13 has given us personal information, contact us at privacy@focuspivot.com.
• Ages 13 to 17. Users under 18 may use the Service only with the permission of a parent or legal guardian (see our Terms). We do not sell or share their personal information, and we do not use it for targeted advertising.
• Removing content. If you are under 18, you can delete content you posted at any time in the Service, or ask us to remove it by emailing privacy@focuspivot.com. Removal may not guarantee complete erasure in every case, for example where the law requires us to keep information or where someone else has copied it.
• Information about children entered by adults. If you record information about a child, for example as a contact, you are responsible for doing so lawfully. We use that information only to provide the Service to you.

12. Your US state privacy rights

Depending on where you live, including California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia, you may have some or all of the following rights. Each is subject to exceptions under the law that applies to you:

• Know and access: to know what personal information we have collected about you, the categories of sources, the purposes, and the categories of third parties we disclose it to, and to get a copy of the specific pieces of personal information we hold about you;
• Portability: to receive your personal information in a portable, readily usable format;
• Correction: to correct inaccurate personal information;
• Deletion: to have personal information we collected from you deleted;
• Opt out: of the sale or sharing of personal information, targeted advertising, and profiling that produces legal or similarly significant effects. We do none of these, but you may still make the request;
• Limit sensitive personal information: we use sensitive personal information only for the purposes the law permits without offering this right, such as providing the Service and keeping it secure; and
• Non-discrimination: we will not deny you service, charge a different price, or give a different quality of service because you exercised these rights.

How to make a request

Email privacy@focuspivot.com with the subject "Privacy Rights Request". Tell us which right you want to use, and send it from, or include, the email address or phone number on your account. Much of your information can also be viewed, corrected and deleted directly in the Service.

• Verification. To protect you, we verify requests before acting on them. Usually we confirm that you control the email address or phone number on your account. For requests for specific pieces of information or for deletion, we may ask for more. We use the information you give us for verification only for that purpose.
• Authorized agents. You may use an authorized agent to make a request for you. We may ask the agent for proof of your signed permission, and may ask you to verify your identity directly or confirm that you gave the agent permission, unless the agent holds a valid power of attorney.
• Timing. We confirm receipt within 10 business days, and respond within 45 days. Where the law allows, we may extend this by another 45 days and will tell you if we do. We do not charge for requests unless they are manifestly unfounded or excessive.
• Appeals. If we decline your request, in whole or in part, you can appeal by emailing privacy@focuspivot.com with the subject "Privacy Appeal" within 60 days of our decision. Include the request and our response. We will respond within the time the law requires, usually 45 or 60 days. If you are not satisfied with the outcome, you may contact the Attorney General of your state.

13. Additional information for California residents

The California Consumer Privacy Act, as amended ("CCPA"), requires us to describe our practices in specific categories. In the past 12 months we have collected the following categories of personal information, from the sources and for the purposes described in sections 2 and 3. We have disclosed each category for business purposes only to the service providers and recipients described in section 5. We have not sold or shared any category.

We keep each category for as long as described in section 7. We use and disclose sensitive personal information only to provide the Service, keep it secure, and for other purposes permitted under CCPA regulations. We do not use it to infer characteristics about you.

Financial incentives. We do not offer financial incentives in exchange for personal information. Free trials and discounts are not conditioned on giving us more personal information than the Service needs.

"Shine the Light." We do not disclose personal information to third parties for their own direct marketing purposes.

14. Users outside the United States

The Service is intended for users in the United States. If you use it from elsewhere, your information may be processed in the United States, the European Union and other countries where we or our service providers operate. Their data protection laws may differ from those where you live. Where the law requires it, we protect such transfers with appropriate safeguards, such as standard contractual clauses.

If the EU or UK General Data Protection Regulation applies to you, Focus Pivot is the controller of your personal information. We process it to perform our contract with you (providing the Service), for our legitimate interests (security, fraud prevention, and improving the Service), to comply with legal obligations, and with your consent where we ask for it. You can withdraw consent at any time. You have rights to access, correct, delete, restrict, object to processing of, and port your personal information. You also have the right to complain to your data protection supervisory authority. Contact us as described in section 12 to exercise these rights.

15. Other websites and services

The Service may link to, or let you connect to, websites and services operated by others. This Policy does not apply to them. We are not responsible for their privacy practices, so please read their privacy policies.

16. Changes to this Policy

We may update this Policy from time to time. We will post the updated version on this page with a new effective date. If we make a material change, especially one about how we use or disclose personal information we already hold, we will tell you in advance by email or in the Service. Where the law requires your consent, we will ask for it.

17. Contact us

Privacy questions and requests: privacy@focuspivot.com (subject "Privacy Rights Request" for the requests in section 12).
Everything else: support@focuspivot.com.