The Data Controller responsible for processing personal data collected through the King Focus application is:

ZUMBAT HUB S.R.L.

Viale Abruzzi, 52 — 20131 Milan (MI), Italy
VAT ID / Tax Code: 10928040962
European VAT: IT10928040962
REA: MI-2567601
Email: privacy@kingfocus.app

For any requests related to the processing of your personal data, you can write to the email address above.

2.1 Data Provided Directly by the User

• Name or nickname chosen during registration
• Email address (if registering with email)
• Login data through third-party providers (Apple ID, Google Account) — limited to what is shared by the provider
• Self-reported wellness information: energy level, sleep quality, time since last meal (optional post-session biological check-in)

2.2 Data Generated by App Use

• Results of cognitive exercises and scores (Focus Points)
• History of training sessions
• Progression data: streaks, unlocked badges, difficulty level
• Language preferences and app settings
• Date and time of sessions

2.3 Technical Data Collected Automatically

• Device identifier
• Operating system and app version
• Usage logs and crash data (anonymized)
• In-app purchase data via Apple App Store or Google Play Store (managed directly by those platforms)

3.1 Service Delivery (Art. 6.1.b GDPR — Contract Performance)

• User account creation and management
• Personalization of cognitive training sessions
• Calculation and update of Focus Score and Focus Points
• Management of in-app purchases (Pro Monthly, Pro Lifetime)
• Data synchronization across devices

3.2 Service Improvement (Art. 6.1.f GDPR — Legitimate Interest)

• Aggregated and anonymized analysis of performance to optimize difficulty adaptation algorithms
• Detection and correction of technical errors
• Development of new features

The legitimate interest is balanced with user rights: usage data is processed in aggregated form and does not allow identification of individual users in internal analyses.

3.3 Legal Compliance (Art. 6.1.c GDPR — Legal Obligation)

• Retention of accounting and tax data related to in-app purchases
• Response to requests from competent authorities where required by law

3.4 Direct Marketing (Art. 6.1.a GDPR — Consent)

Sending promotional communications, push notifications, and newsletters, exclusively with explicit consent. Marketing consent is optional and can be withdrawn at any time from app settings or by contacting privacy@kingfocus.app.

• Account and progression data: for the duration of the contractual relationship and for 12 months after account deletion
• Accounting and tax data related to purchases: 10 years in accordance with Italian tax regulations
• Technical logs and crash data: maximum 90 days
• Biological check-in data: for the duration of the account, deletable at any time by the user from settings
• Support communications: 3 years from the closure of the request

After the indicated periods, data is deleted or permanently anonymized.

Personal data may be disclosed to the following categories of recipients, appointed as data processors pursuant to Art. 28 GDPR:

5.1 Technical Service Providers

• Supabase Inc. — database hosting and authentication (USA, with adequate safeguards via Standard Contractual Clauses)
• RevenueCat Inc. — management of in-app purchases and subscriptions (USA, with adequate safeguards via Standard Contractual Clauses)
• Apple Inc. — iOS distribution and App Store purchase management
• Google LLC — Android distribution and Google Play purchase management

5.2 Analytics Providers

Data transmitted to analytics tools is anonymized or pseudonymized before transmission.

Data is not sold, transferred, or shared with third parties for commercial profiling purposes.

Some of the providers listed in section 5 are based in the United States of America. Data transfers to such providers occur with adequate safeguards under Chapter V of the GDPR, in particular through:

• Standard Contractual Clauses approved by the European Commission
• Adequacy certifications where applicable

Upon request, the Data Controller will provide a copy of the adopted safeguards.

Pursuant to Articles 15-22 of the GDPR, you have the right to:

• Access — obtain confirmation that data concerning you is being processed and receive a copy thereof
• Rectification — request correction of inaccurate data or completion of incomplete data
• Erasure ("right to be forgotten") — request deletion of your data in cases provided for by Art. 17 GDPR
• Restriction — request restriction of processing in cases provided for by Art. 18 GDPR
• Portability — receive data provided in structured, machine-readable format
• Objection — object to processing based on legitimate interest or for direct marketing purposes
• Consent Withdrawal — withdraw consent at any time without prejudice to the lawfulness of prior processing

To exercise your rights, contact privacy@kingfocus.app. We will respond within 30 days of receiving your request.

You also have the right to lodge a complaint with the Data Protection Authority (https://edpb.ec.europa.eu/), or your national supervisory authority.

King Focus is an application intended for users aged 16 or older. We do not knowingly collect personal data of minors under 16 years of age. If you believe a minor has provided personal data through the app, please contact us immediately at privacy@kingfocus.app. We will delete such data at the earliest opportunity.

We adopt appropriate technical and organizational measures to protect personal data from unauthorized access, loss, destruction, or accidental disclosure, including:

• Encryption of data in transit using TLS/HTTPS protocol
• Encryption of data at rest
• Access to data limited to authorized personnel and strictly necessary providers
• Periodic backup procedures
• Continuous monitoring to detect and respond to potential breaches

The Data Controller reserves the right to update this policy at any time, particularly in case of regulatory changes or service architecture modifications. Significant changes will be communicated to users via in-app notification or email at least 14 days before taking effect.

The updated version is always available within the application in the Settings > Privacy section and on kingfocus.app/privacy.

For any questions or requests regarding the processing of your personal data:

Email: zumbat.software@gmail.com
Mail: ZUMBAT HUB S.R.L., Viale Abruzzi 52, 20131 Milan (MI)