Privacy Policy

Focused Pupa Privacy Policy

Owner and data controller: Focused Pupa Teknoloji ve Yazılım Hizmetleri Anonim Şirketi 

Email: [email protected]

Definition and Legal References

Personal Data

Any information that, directly, indirectly or in combination with other information, makes it possible to identify a natural person.

Usage Data

Information that enables the use of Focused Pupa and is automatically collected may include: IP addresses or domain names of computers used by users using Focused Pupa, URI (Uniform Resource Identifier) addresses, time of the request, method used to send the request to the server, received file in response size, numerical code indicating the response status of the server (success, error and others), country of origin, features of the browser and operating system used by the user, various time details per visit (for example: Application and operating system of the device with special reference to the order of the visited pages and/or other parameters related to the user's IT environment.


The person using the Focused Pupa application and submitting data to the application, unless otherwise specified.

Data Subject

The natural person to whom the Personal Data refers.

Datenverarbeiter (oder Data Controller))

The natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller as described in this privacy statement.

Data Controller (or Owner)

The natural or legal person, public authority, institution or other body that determines, alone or together with others, the purposes and means of processing personal data, including the security measures regarding the operation and use of the Focused Pupa application. The data controller owns the Focused Pupa application, unless stated otherwise.

Focused Pupa (or this App)

Mobile software in which the user's personal data is collected and processed.


As specified in the Website, application and contracts, it indicates the activities and transactions offered by Focused Pupa that enable the user to use the application.


Cookies are trackers consisting of small sets of data stored in the user's browser.


Tracker refers to any technology (such as cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting) that enables users to be tracked, for example by accessing or storing information on the user's device.

Legal Information

This confidentiality agreement has been prepared based on the provisions of many legislations. (EU) 2016/679 (General Data Protection Regulation) 13/14.

Types of Data Collected

The Focused Pupa App collects the following types of personal data: Cookies, Usage Data, Unique Device Identifiers for Advertising (e.g. Google Advertising ID or IDFA), Geolocation, Camera Authorisation, Storage Authorisation, Photo Library Authorisation, Device Information, Geography/Region, Number of User Sessions, Session Duration, In-App Purchases, Application Updates, Initial Launches, Operating Systems, User Name, Picture, User's School Information, User's Gender Information, User's Email Address.

Full details of the personal data collected will be provided in the specific sections of this Privacy Policy or in the disclosure texts shared prior to the collection of the data.

Personal data can be provided manually by the user or usage data can be retrieved automatically when using Focused Pupa (Android version). Unless otherwise specified, all data requested by Focused Pupa (Android version) is mandatory and failure to provide such data may prevent Focused Pupa (Android version) from providing its services.

The provision of some data (user name, picture, information about the user's school, information about the user's gender, the user's e-mail address and others) is at the user's own discretion. In cases where this data is not provided, the user may continue to use the application. 

Users who wish to ascertain which personal data are mandatory can contact the owner of the application.

Any use of cookies or other tracking tools by Focused Pupa's app owners or third party services used by Focused Pupa is for the purpose of, among other things, providing the service requested by the user. 

Users are responsible for all third party personal data obtained, published or disclosed through Focused Pupa and confirm that the third party's consent has been obtained.

The application owner shall take appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of data.

Data processing is carried out using computers and/or IT-enabled tools in accordance with company procedures and modes closely related to the stated purposes. In some cases, the application owner may appoint third parties as data processors. For example: Focused Pupa (management, sales, marketing, legal, system administration) or external parties (e.g. third party technical service providers, postmen, hosting providers, IT companies, communication agencies). An updated list of these processors can be requested by the user at any time.

Under certain legal provisions, the owner may be permitted to process personal data without relying on consent or one of the following legal bases until the user objects to such processing ("opt-out"). In any case, the app owner will be happy to help you determine which specific legal bases apply to the data processing, in particular whether the provision of personal data is required by law or contract or necessary for the conclusion of a contract.

The data is processed at the offices where the application is developed and at other locations where the parties involved in the data processing are located.

Depending on the user's location, data transfers may involve the transfer of user data to a country other than their home country. Users can check the personal data processing details section to learn more about where such transferred data is processed.

Users also have the right to obtain information about the legal basis of data transfers to a country outside the European Union or to an international organisation governed by international law or established by two or more countries, such as the UN, and the security measures taken. If such a transfer is made by the owner of the application to protect their data, users can obtain further information by reviewing the relevant sections of this document or by contacting the owner of the application using the information provided in the "Contact Us" section.

Personal data are processed and stored for as long as required by the purpose for which they were collected. Therefore: Personal data collected for purposes related to the performance of a contract between the owner of the application and the user will be stored until said contract is fully performed. In all cases where the user consents to such processing, the application owner is permitted to retain personal data for a longer period of time. Personal data collected for the App Owner's legitimate interests will be retained for as long as necessary to fulfil those purposes. Users can find specific information on the app owner's legitimate interests in the relevant sections of this document or by contacting the app owner. Unless such consent is revoked. In addition, the application owner may be required to retain personal data for a longer period of time if this is necessary to comply with a legal obligation or by order of the authorities. After the retention period has expired, personal data is deleted. Therefore, the right of access, the right of erasure, the right of rectification and the right of data portability cannot be enforced after the retention period has expired.

Purposes of Data Processing

User data includes the app's ability to provide services for their intended purpose, to comply with its legal obligations, to respond to enforcement requests, to protect its rights and interests (or the interests of its users or third parties), to detect malicious or fraudulent activity and also includes: advertising, hosting and back-end infrastructure, access to third-party accounts, managing contacts and sending messages, infrastructure monitoring, device permissions to access personal data, user database management, analytics and social features.

Focused Pupa may collect the information required to register with apps that provide login information such as Facebook and Google for user login. 

This service allows Focused Pupa to connect to a user account found in other apps. The requested permissions can be: Basic information = by default contains certain user data such as name, picture, gender and locale. Some user links such as friends are also available. If the user has made more of their data public, more information is available. Friends list = provides access to the friends list of the user who also uses the application in question. Device permissions to access personal data = Focused Pupa can request certain permissions that allow the user to access device data as described below.

By default, these permissions must be granted by the user before the relevant information can be accessed. Once granted, consent can be revoked by the user at any time. To revoke these permissions, users can refer to the device settings or request support via the contact information provided in this document. The exact procedure for checking app permissions may depend on the user's device and software. Please note that revoking such permissions may affect the proper functioning of Focused Pupa.

If the user grants one of the permissions listed below, the relevant personal data can be processed (i.e. accessed, modified or removed) by Focused Pupa.

Camera Permission

Used to access the camera or take pictures and videos from the unit.

Photo Library Permission

Provides access to the user's photo library.

Storage Permission

It is used to access shared external storage, including reading and adding items.

Detailed Information on the Processing of Personal Data

Personal data is collected for the following purposes and using the following services:

Access to third party accounts

This type of service allows Focused Pupa to access and perform actions on the data in your account in a third-party service. These services are not activated automatically, they require explicit authorisation by the user.

Access to Facebook, Google and other accounts

This service allows Focused Pupa to connect to the user account provided by Facebook, Google and others and to process related data.

Device permissions for access to personal data

Focused Pupa asks users for specific permissions that allow the user to access device data as described below.

Focused Pupa requests certain permissions from users that allow the user to access device data as described herein and in this document. Personal data processed: Camera permission; Photo library permission; Storage permission.

Server and back-end infrastructure

This type of service is intended to provide a pre-built infrastructure to run certain functions or parts of Focused Pupa and to host the data and files that enable Focused Pupa to run and be deployed. Some of these services are operated through geographically dispersed servers, which makes it difficult to determine the actual location where personal data is stored.

Monitoring the infrastructure

This type of service enables Focused Pupa to monitor the use and behaviour of its components so that performance, operation, maintenance and troubleshooting can be improved. The personal data processed depends on the characteristics and use of these services, whose function is to filter Focused Pupa's activities.

Manage contacts and send messages

This type of service allows a database of email contacts, telephone contacts or other contact information to be managed in order to communicate with the user. These services may also collect data about when the user interacted with the message, for example by clicking on links included in the message, and the date and time the user viewed the message.

Social functions

Focused Pupa users have the right to view other users' public information such as focus time, PupaCoin total, class and school information, usernames, profile pictures, inspirational quotes. Users can engage in activities that require interaction with other users such as making friends, inviting, sending messages. 

User database management

This type of service allows the application to create user profiles based on an email address, personal data or other information provided by the user to the Focused Pupa application, as well as monitor user activity through analytics. This personal data can also be matched with publicly available information about the user (e.g. social network profiles) and used to create private profiles that they can view and use to improve the app. It may also enable the sending of scheduled messages to the user, e.g. emails based on specific actions performed on Focused Pupa.

Immediate and scheduled notifications

Focused Pupa may send instant notifications to the user to achieve the purposes stated in this Privacy Policy. In most cases, users can opt-out of receiving push notifications and change settings by accessing device settings, such as mobile phone notification settings. Users should be aware that disabling push notifications may affect the use of Focused Pupa.

User rights

Users may exercise certain rights in relation to their data processed by the application owner. In particular, users have the right to.

Users have the right to withdraw their consent to the elements they have previously allowed to process their personal data.

Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. 

Users have the right to be informed about whether the data are processed by the application holder, to be informed about certain aspects of the processing and to obtain a copy of the data processed.

Users have the right to verify the accuracy of their data and to request that it be updated or corrected.

Users have the right to restrict the processing of their data under certain conditions. In this case, the application owner will not process their data for any purpose other than storing it.

Users have the right to have their personal data deleted or removed under certain conditions.

Users shall have the right to receive their structured data in a commonly used and machine-readable format and, where technically possible, to transmit it without hindrance to another controller. This provision applies where the data is processed by automated means and the processing is based on the user's consent, a contract of which the user is an integral part or pre-contractual obligations. Users have the right to submit a request to the competent data protection authorities.

Details of the right to object to data processing

In cases where personal data are processed for a public interest, for the use of an official authority granted to the app owner or to protect the app owner's legitimate interests, users may object to this processing by providing a justification for it specific situation. 

Users are informed that if their personal data are processed for direct marketing purposes, they may object to this processing at any time without giving reasons. To find out whether the app owner processes personal data for direct marketing purposes, users can consult the relevant sections of this document.

Users may submit their requests to exercise their rights to the app owner via the contact information provided in this document. These requests can be made free of charge and will be processed by the app owner as soon as possible.

Cookie Policy

Focused Pupa uses cookies (cokies). For more information, please see the User Cookie Policy.

Legal Measures

The user's personal data may be used by the application owner for judicial purposes.

The user declares that he/she is aware that the app owner may be asked to disclose his/her personal data at the request of the authorities.

System Maintenance

For operational and maintenance purposes, Focused Pupa and third party services may collect files (system logs) that record interaction with Focused Pupa (system logs) or use other personal data (e.g. IP address) for this purpose.

Further details on the collection or processing of personal data can be requested by users. Please refer to the contact information at the beginning of this document.

The application owner reserves the right to change this privacy policy at any time by notifying its users on this page and possibly within the Focused Pupa application and/or, to the extent technically and legally possible, by sending notifications to users about any communications. Users are strongly advised to check this page regularly.

If the changes concern the processing activities carried out on the basis of the user's consent, a new consent of the user shall be obtained if necessary.