Privacy Policy

1. Data Controller

Focus Point LLC Andre von Wenzel 21, 39030 Uttenheim, Bolzano - Italy info@focus-point.net

The data controller responsible for data processing under the GDPR is the organization listed above.

2. Collection and Processing of Personal Data

Focus Point collects and processes personal data only to the extent necessary and as follows:

• Registration data: Name, email address and company upon registration. • Usage data: Anonymized information about app usage, including modules visited, time spent and exercises completed. • Technical data: Device information, operating system and IP address for security and optimization purposes.

3. Purpose of Data Processing

Your data is processed for the following purposes:

• Providing and improving the Focus Point service • Generating anonymized analytics and statistics for organizations • Ensuring the security and stability of the application • Fulfilling legal obligations

4. Legal Basis

Processing is carried out on the basis of:

• Art. 6(1)(a) GDPR – User consent • Art. 6(1)(b) GDPR – Performance of a contract • Art. 6(1)(f) GDPR – Legitimate interest in improving the service

5. Storage and Security

Personal data is stored on servers within the European Union. Appropriate technical and organizational measures are implemented to protect your data against unauthorized access, loss or misuse. Data is retained only for as long as necessary for the stated purposes or as required by law.

6. Anonymized Analytics

Focus Point provides organizations exclusively with anonymized usage data. No personal analytics are shared with employers. Individual users cannot be identified.

7. Third-Party Disclosure

Your personal data will not be disclosed to third parties, except:

• When required by law • When necessary to fulfill the contractual purpose • When you have given explicit consent

8. Cookies and Tracking

Focus Point uses only technically necessary cookies. No tracking cookies or third-party trackers are deployed. Session cookies serve solely the functionality of the application and are deleted after the session ends.

9. Your Rights

You have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR) • Right to rectification (Art. 16 GDPR) • Right to erasure (Art. 17 GDPR) • Right to restriction of processing (Art. 18 GDPR) • Right to data portability (Art. 20 GDPR) • Right to object (Art. 21 GDPR)

To exercise any of these rights, please contact us at the address below.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your data violates the GDPR.

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy as needed. Changes will be published on this page. The current version is always accessible.

12. Contact

If you have any questions about data protection, please contact us at:

Focus Point LLC Andre von Wenzel 21, 39030 Uttenheim, Bolzano - Italy info@focus-point.net