Last Updated: December 10, 2025
This privacy notice describes how Focus Tree SAS ("Company," "we," "us," or "our") collects, uses, shares, and protects your information when you use our mobile applications, websites, and related services (collectively, the "Services").
Key highlights:
We may collect information you voluntarily provide when using our Services, including:
When you use our Services, we automatically collect certain information, including:
We may receive information about you from third parties, including:
We use the information we collect for various purposes, including to:
We may share your information in the following circumstances:
We share information with third-party vendors, consultants, and service providers who perform services on our behalf, such as hosting, analytics, customer service, marketing, payment processing, and infrastructure providers supporting digital asset features.
We may share information with business partners for various purposes, including to offer you products or services that may be of interest to you, conduct joint marketing initiatives, and for analytics and market research purposes. This may include sharing aggregated, de-identified, or anonymized data with partners who provide market intelligence, analytics, or research services.
We work with third-party advertising companies to display advertisements within our Services and on other platforms. These partners may collect information about your activity on our Services and other websites and applications over time to provide you with more relevant advertising. See Section 4 for more details.
We may share information with analytics partners to help us understand how users interact with our Services. This includes sharing data with companies that provide market research, competitive intelligence, and industry analytics services.
We may disclose information if we believe it is necessary to:
We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for any purpose, including research, analytics, marketing, and commercial purposes. Such information is not subject to the restrictions of this Privacy Policy.
We may share your information with third parties when you give us explicit consent to do so.
Our Services may display advertisements from third-party advertising networks. These networks may use cookies, web beacons, and similar technologies to collect information about your use of our Services and other websites and applications. This information may be used to provide advertisements about goods and services likely to be of interest to you.
Our applications may display third-party hosted offer walls or affiliate offers that allow advertisers to offer rewards or other items in exchange for completing certain actions. When you interact with an offer, you may be redirected to an external site, and a unique identifier may be shared with the provider to credit your account and prevent fraud.
We use analytics services to collect and analyze usage information. These services may use cookies and similar technologies. We may share identifiers and usage data with analytics providers to help us understand usage patterns, user behavior, and market trends.
You may opt out of interest-based advertising through your device settings or through industry opt-out tools such as the Digital Advertising Alliance (DAA) at optout.aboutads.info or the Network Advertising Initiative (NAI) at optout.networkadvertising.org.
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider:
When we no longer need your personal information, we will securely delete or anonymize it.
We implement appropriate technical and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and any credentials related to digital asset features.
Your information may be transferred to, stored, and processed in countries other than your country of residence, including France, the United States, and other countries where we or our service providers operate. These countries may have data protection laws that differ from the laws of your country. By using our Services, you consent to the transfer of your information to these countries. Where required by applicable law, we implement appropriate safeguards for international data transfers.
Depending on your location and applicable law, you may have certain rights regarding your personal information, including the right to:
To exercise these rights, please contact us using the information in Section 16. We will respond to your request in accordance with applicable law.
Limitations on Deletion: Please note that certain information may be exempt from deletion requests, including information we are required to retain for legal or regulatory purposes. Additionally, information recorded on public blockchain networks cannot be modified or deleted due to the inherent immutable nature of blockchain technology. If you have used Digital Asset Features, your blockchain transaction history and wallet addresses will remain on the applicable blockchain network regardless of any deletion request.
Our Services are intended for users aged 13 and older. We do not knowingly collect personal information from children under the age of 13. If you are under 13, you are not permitted to use our Services.
We implement age-screening mechanisms within our Services; however, we rely on users to provide accurate information regarding their age. We do not independently verify the age of our users. If we become aware that we have collected personal information from a child under 13, we will take steps to delete that information promptly. If you believe we have collected information from a child under 13, please contact us immediately.
Certain features of our Services, including those related to digital assets, cryptocurrency, and blockchain functionality ("Digital Asset Features"), are restricted to users aged 18 and older. Users must confirm they meet the applicable age requirement to access these features.
Our Services may include features related to digital assets, including cryptocurrency wallets, digital tokens, non-fungible tokens (NFTs), and related functionality. These features are provided for users aged 18 and older.
Digital Asset Features utilize distributed key management technology provided by third-party infrastructure partners. We do not have access to your private keys and do not have the ability to recover, restore, or access your wallet or digital assets on your behalf. Key components are managed by independent third-party providers over whom we have no control. You are solely responsible for understanding and securing access to your wallet, including any recovery mechanisms. Failure to properly secure your credentials or recovery information may result in permanent and irreversible loss of access to your digital assets.
Digital assets involve significant risks, including but not limited to:
WE DO NOT GUARANTEE THE SECURITY, AVAILABILITY, OR RECOVERABILITY OF ANY DIGITAL ASSETS. YOU ACKNOWLEDGE AND ACCEPT THAT YOU MAY LOSE SOME OR ALL OF YOUR DIGITAL ASSETS, AND WE SHALL HAVE NO LIABILITY FOR ANY SUCH LOSS.
We do not provide investment, financial, tax, or legal advice. Any information provided through our Services regarding digital assets is for informational purposes only. You should consult qualified professionals before making any financial decisions.
Digital Asset Features may involve or integrate with third-party services, including blockchain networks, exchanges, and other providers. Your use of such services is subject to their respective terms and policies. We are not responsible for the actions, availability, or security of third-party services.
Transactions conducted on blockchain networks are public and immutable. Information recorded on a blockchain, including wallet addresses and transaction history, is publicly accessible and cannot be deleted or modified by us or any party.
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
In the preceding twelve (12) months, we may have collected and disclosed the following categories of personal information:
| Category | Examples | Collected | Disclosed for Business Purpose | Sold/Shared |
|---|---|---|---|---|
| A. Identifiers | Email address, username, device identifiers, IP address | YES | YES | YES |
| B. Personal Information (Cal. Civ. Code § 1798.80) | Name, email address | YES | YES | NO |
| C. Protected Classifications | Age range | YES | NO | NO |
| D. Commercial Information | Purchase history, subscription status | YES | YES | NO |
| E. Biometric Information | N/A | NO | NO | NO |
| F. Internet/Network Activity | Usage data, interaction patterns, feature usage | YES | YES | YES |
| G. Geolocation Data | General location based on IP address | YES | YES | YES |
| H. Sensory Data | N/A | NO | NO | NO |
| I. Professional/Employment Info | N/A | NO | NO | NO |
| J. Education Information | Student status (self-reported) | YES | NO | NO |
| K. Inferences | Preferences, characteristics, behavior patterns | YES | YES | YES |
As a California resident, you have the right to:
Under California law, "sale" includes sharing personal information for monetary or other valuable consideration. We may share certain categories of personal information (identifiers, internet activity, geolocation, and inferences) with advertising partners and analytics providers in ways that may constitute a "sale" or "sharing" under California law. To opt out, please contact us at the address below or use any "Do Not Sell or Share My Personal Information" link available in our Services.
To exercise your California privacy rights, please contact us at privacy@focustree.app. We will verify your identity before processing your request.
If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have rights under the General Data Protection Regulation (GDPR) or equivalent laws.
We process your personal information based on the following legal bases:
You have the right to access, rectify, erase, restrict processing, data portability, object to processing, and withdraw consent. To exercise these rights, contact us at privacy@focustree.app. You also have the right to lodge a complaint with your local supervisory authority.
Please note that the right to erasure is subject to limitations, including where data must be retained for legal obligations or where data has been recorded on a public blockchain and cannot be technically modified or deleted.
When we transfer personal information outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.
In connection with any merger, acquisition, reorganization, sale of assets, joint venture, assignment, transfer, financing, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer, sell, or assign any information we have collected, including personal information, to the relevant third party. Such third party will assume the rights and obligations regarding your personal information as described in this Privacy Policy. By using our Services, you acknowledge and consent to such transfers.
We may also share your information with potential acquirers, investors, or partners during due diligence or as part of negotiations regarding such transactions. Any such third party will be required to maintain the confidentiality of your information.
Our Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated version will be indicated by a revised "Last Updated" date. If we make material changes, we may notify you by posting a prominent notice in our Services or by sending you a notification. Your continued use of the Services after any changes indicates your acceptance of the updated Privacy Policy.
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Focus Tree SAS
Email: privacy@focustree.app
General Inquiries: contact@focustree.app
For GDPR-related inquiries, you may also contact our Data Protection Officer at dpo@focustree.app.
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