FocUS App Privacy Policy

Last Updated: [Jan. 9, 2026]

This Privacy Policy explains how Dallas Hughston LLC ("Company," "we," "us," or "our") collects, uses, processes, stores, shares, and protects personal data when you access or use the FOCUS mobile application, associated websites, dashboards, and related services (collectively, the "Services").

This policy is designed to meet the requirements of applicable U.S. privacy laws and the General Data Protection Regulation (GDPR) of the European Union. It also specifically addresses the use of activity and health-related data obtained through third-party integrations, including Garmin.

Our philosophy is simple: we exist to help users align their daily behavior with what matters most—not to exploit personal data. Data is used to support awareness, coaching, and accountability, never advertising or resale.

1. Scope and Applicability

This Privacy Policy applies to all users of the Services, including:

• Individual clients

• Independent coaches using the platform

• Visitors to our websites or dashboards

This policy governs data processed by Dallas Hughston LLC acting as a data controller (under GDPR terminology) or a business (under U.S. privacy laws). Independent coaches may act as separate and independent data recipients as described below.

This policy does not apply to third-party websites, applications, or services that may be linked to or integrated with the Services but are governed by their own privacy policies.

2. Definitions

For clarity, the following definitions apply:

• Personal Data: Any information relating to an identified or identifiable individual.

• Activity Data: Non-medical health and fitness-related information such as steps, workouts, or activity duration.

• Processing: Any operation performed on personal data, including collection, storage, analysis, or disclosure.

• Coach: An independent individual or entity providing coaching services through the platform.

• Client: An individual receiving coaching or using the Services for personal development.

3. Information We Collect

We collect information in three primary ways: (1) information you provide directly, (2) information collected automatically, and (3) information collected through authorized third-party integrations.

3.1 Information You Provide Directly

You may provide the following categories of information:

• Name and contact details (such as email address)

• Account credentials and authentication data

• Profile information

• Goals, intentions, values, and statements of meaning

• Messages and communications with coaches

• Survey responses, reflections, and feedback

Providing this information is voluntary; however, certain features of the Services may not function without it.

3.2 Activity and Health-Related Data (Garmin Integration)

If you choose to connect your Garmin account, we may collect activity-related data only after explicit user authorization, including:

• Step counts

• Activity duration and frequency

• Workout summaries

• Intensity levels

• Time-based activity trends

We do not collect precise GPS location data unless explicitly disclosed to and authorized by the user. We do not collect raw biometric identifiers or clinical health records.

Garmin data is used exclusively to support coaching insights, behavioral awareness, accountability, and progress visualization.

3.3 Device, Usage, and Technical Data

We may automatically collect certain technical information, including:

• Device type, operating system, and app version

• IP address and general location (city/state level)

• Log files, crash reports, and performance diagnostics

• Interaction data such as feature usage frequency

This data is used to maintain security, reliability, and performance.

4. Legal Bases for Processing (GDPR)

For users located in the European Economic Area (EEA), we process personal data under the following legal bases:

• Consent: When you connect third-party integrations such as Garmin

• Contractual necessity: To provide the Services you request

• Legitimate interests: To improve functionality, security, and user experience

• Legal obligation: To comply with applicable laws

You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5. How We Use Personal Data

We use personal data for the following purposes:

5.1 Core Service Delivery

• Creating and managing user accounts

• Enabling coaching and accountability features

• Displaying insights related to focus, alignment, and consistency

5.2 Coaching and Behavioral Insights

• Comparing stated goals with observed behavior patterns

• Supporting coaches in delivering personalized guidance

• Generating aggregate or individual metrics (e.g., focus scores)

5.3 Platform Improvement

• Monitoring system performance

• Developing new features

• Debugging and resolving technical issues

5.4 Legal, Safety, and Compliance

• Enforcing terms and policies

• Preventing fraud or misuse

• Responding to lawful requests

We do not use personal or activity data for advertising, profiling for marketing, or sale to third parties.

6. Sharing and Disclosure of Data

We share personal data only in limited, transparent circumstances:

6.1 Independent Coaches (Independent Data Recipients)

If you engage with a coach through the Services, certain information (including activity insights, progress indicators, and communications) may be shared with that coach.

Coaches are independent data recipients, not employees or agents of Dallas Hughston LLC. Coaches are responsible for their own data handling practices and are required to comply with applicable privacy laws.

6.2 Service Providers

We may share data with vetted service providers that support our operations, including:

• Cloud hosting providers

• Analytics services (non-advertising)

• Customer support platforms

These providers process data solely on our instructions and are bound by confidentiality and security obligations.

6.3 Legal and Regulatory Disclosure

We may disclose personal data if required to do so by law, court order, or governmental authority, or to protect the rights, safety, and security of users or the Company.

7. International Data Transfers

Personal data may be transferred to and processed in the United States or other jurisdictions. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses to protect international data transfers.

8. Data Retention

We retain personal data only for as long as necessary to:

• Provide the Services

• Fulfill coaching and accountability purposes

• Comply with legal and regulatory obligations

Data is deleted or anonymized when no longer required.

9. Data Security

We implement reasonable administrative, technical, and organizational safeguards, including:

• Encrypted data transmission

• Secure access controls

• Monitoring for unauthorized access

While no system is completely secure, we take data protection seriously and continuously improve our safeguards.

10. User Rights (U.S. and EU)

Depending on your location, you may have the right to:

• Access your personal data

• Correct inaccurate data

• Request deletion

• Restrict or object to processing

• Data portability (GDPR)

• Withdraw consent at any time

Requests may be submitted using the contact information below.

11. Children’s Privacy

The Services are not intended for children under 13. We do not knowingly collect personal data from children.

12. Third-Party Integrations (Garmin)

The Services integrate with Garmin APIs. Garmin data is accessed only with user authorization and handled in accordance with this Privacy Policy and Garmin’s API terms.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted with an updated effective date.

14. Contact Information

If you have questions or wish to exercise your rights, contact:

Dallas Hughston LLC
Email: [dallas@mymindset.com]

By using the Services, you acknowledge that you have read and understood this Privacy Policy.