Privacy Policy for Tempo Focus
Stoleru Martin PFA ("we," "our," or "us") operates the Tempo Focus mobile application ("Tempo" or "the App"). This Privacy Policy explains how we collect, use, store, and protect your information when you use our App.
Our contact information:
Company: Stoleru Martin PFA
Address: Calea Nationala, nr. 66 Etaj 1, Botosani, 710028, Romania
Email: hey@martinstoleru.com
Website: www.martinstoleru.com
By using Tempo, you agree to this Privacy Policy. If you do not agree, please do not use the App.
1. Data We Collect
1.1 Data Stored on Your Device (Local Data)
The following data is stored only on your device:
- Focus and break sessions: Start time, duration, session type, and labels you assign
- Daily statistics: Aggregated session data for insights and history
- Labels: Custom labels you create for organizing focus sessions
- Settings: Theme, timer durations, cycle preferences, notification settings, app icon choice
- App blocking configuration: The list of apps you choose to block during focus (Family Controls); this is managed by Apple and stored only on your device
iCloud sync: We plan to offer optional iCloud sync for your sessions and statistics in a future update. When available, this data will sync across your devices linked to the same Apple ID. You will be able to enable or disable this feature.
1.2 Analytics Data (Product Interaction)
We use analytics to understand how the App is used and to improve it. This data is sent to our analytics provider (PostHog, hosted in the EU) and may include:
- Events such as: session started, session completed, break completed, onboarding steps, paywall interactions, feature usage (e.g., cycles toggled, cards scrolled)
- Properties associated with events: duration, label name, whether cycles are enabled, step index
- A persistent identifier (distinct ID) that allows us to link events from the same user over time
We do not collect your name, email address, or other directly identifiable information through analytics unless you provide it to us separately (e.g., in feedback).
1.3 Purchase and Subscription Data
When you subscribe to Tempo Pro or make a purchase:
- RevenueCat processes subscriptions on our behalf. RevenueCat receives purchase information from Apple (e.g., product ID, transaction status) to manage your subscription and entitlement status.
- We receive only subscription status (e.g., active, expired) and product identifiers. We do not receive your payment details; those are handled entirely by Apple.
1.4 Data We Do Not Collect
We do not:
- Sell your data
- Share your data with advertisers or ad networks
- Use your data for advertising or cross-app tracking
- Collect your precise location
- Collect your contacts, photos, or other personal content from your device
2. How We Use Your Data
| Purpose | Data Used | Legal Basis |
| Provide and operate the App | Local data, purchase status | Contract performance |
| Improve the App and fix issues | Analytics data | Legitimate interest |
| Manage subscriptions | Purchase data via RevenueCat | Contract performance |
| Respond to your requests | Information you provide (e.g., via email) | Legitimate interest / consent |
3. Third-Party Services
| Service | Purpose | Data Processed | Location |
| PostHog | Product analytics | Product interaction events, distinct ID | EU (Germany) |
| RevenueCat | Subscription management | Purchase history, entitlement status | As per RevenueCat's infrastructure |
| Apple | App distribution, in-app purchases, iCloud (future) | Purchase data, optional sync data | As per Apple's services |
These providers process data on our behalf under agreements that require them to protect your data and use it only for the purposes we specify.
4. Data Retention
- Local data on your device: Kept until you delete the App or clear its data. Uninstalling the App removes this data from your device.
- Analytics data (PostHog): Retained for up to one (1) year, after which it is deleted or anonymized.
- Purchase data (RevenueCat): Retained according to RevenueCat's and Apple's policies, which we rely on for subscription and support purposes.
- Communications with you: Emails and support messages are retained as needed to handle your requests and for legal or regulatory purposes.
5. Data Security
We take reasonable steps to protect your data:
- In transit: All data sent to our services or third parties is transmitted over HTTPS.
- On device: Local data is stored using Apple's secure storage mechanisms (e.g., SwiftData, UserDefaults).
- Access: Only authorized personnel have access to any data we process, and only when necessary.
We do not have formal security certifications. If you have concerns about a specific risk, please contact us.
6. Your Rights (GDPR and Others)
If you are in the European Economic Area (EEA), UK, or other jurisdictions with similar laws, you have the right to:
- Access: Request a copy of the personal data we hold about you
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your personal data ("right to be forgotten")
- Restriction: Request that we limit how we use your data in certain circumstances
- Portability: Request a copy of your data in a structured, machine-readable format
- Object: Object to processing based on legitimate interest
- Withdraw consent: Where processing is based on consent, withdraw it at any time
To exercise these rights, contact us at hey@martinstoleru.com. We will respond within approximately 24 hours and process your request in line with applicable law.
You also have the right to lodge a complaint with your local data protection authority. In Romania, this is the National Supervisory Authority for Personal Data Processing (ANSPDCP).
7. Children's Privacy
Tempo is a general-purpose focus and productivity app. We do not knowingly collect personal data from children under 13 (or under 16 in the EEA) without parental consent.
- If you are under 13 (or 16 in the EEA), please use the App only with your parent or guardian's permission.
- If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at hey@martinstoleru.com. We will delete such data once we have verified the request.
8. International Transfers
- Analytics (PostHog): Data is processed in the EU (Germany). For users outside the EU, this may involve a transfer. PostHog provides appropriate safeguards (e.g., Standard Contractual Clauses) where required.
- Other services: RevenueCat and Apple may process data in various locations. They use measures required by law to protect your data when it is transferred across borders.
9. Changes to This Policy
We may update this Privacy Policy from time to time. When we do:
- We will update the "Last updated" date at the top.
- For material changes, we will notify you in the App (e.g., via a notice or prompt when you next open the App).
- Continued use of the App after the effective date of changes means you accept the updated policy.
10. Contact Us
For any questions about this Privacy Policy or our privacy practices:
Email: hey@martinstoleru.com
Address: Calea Nationala, nr. 66 Etaj 1, Botosani, 710028, Romania
Website: www.martinstoleru.com
This Privacy Policy was last updated on 03 Mar 2026.