FOCUS+Privacy Policy
Last updated: 2026-05-21
Who we are
SWAND AB (org. nr [FILL_ORG_NR]) operates FOCUS+ at focus-plus.space. We are the data controller for all personal data collected through this site. Contact: hello@swandapp.com.
What data we collect
- Email address — when you join the waitlist or buy a product. Used to deliver the product, send onboarding and educational emails, and notify you of updates.
- First name (optional) — when provided via the opt-in form. Used to personalize emails.
- Purchase data — when you buy via Payhip: name, billing email, country, transaction ID, product purchased, amount, currency. We never see your card details — those go directly to Payhip.
- Technical data — IP address, browser type, device type, referrer, pages visited. Used for analytics and fraud prevention.
- Cookie preferences — your consent choice stored in your browser's localStorage.
Why we collect it (legal basis)
| Data | Purpose | Legal basis (GDPR) |
|---|
| Email + first name | Send the product and related emails | Contract (Art. 6(1)(b)) + Consent (Art. 6(1)(a)) |
| Purchase data | Fulfill the purchase, comply with tax law | Contract + Legal obligation (Art. 6(1)(c)) |
| Technical data | Analytics, security | Legitimate interest (Art. 6(1)(f)) |
Who we share it with (sub-processors)
We use the following third parties to deliver the service. Each is bound by a Data Processing Agreement.
We do not sell data. We do not share data with advertisers.
International transfers
Some sub-processors are in the United States. Transfers are protected under the EU-US Data Privacy Framework or Standard Contractual Clauses, depending on the processor.
How long we keep it
- Email and first name: until you unsubscribe + 30 days, then deleted.
- Purchase data: 7 years (Swedish bookkeeping law / Bokföringslagen).
- Technical data: 90 days, then aggregated and anonymized.
Your rights
Under GDPR you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Delete your data ("right to be forgotten") — note that bookkeeping records may need to be retained
- Restrict processing
- Receive your data in a portable format
- Object to processing based on legitimate interest
- Withdraw consent at any time
To exercise any right, email hello@swandapp.com. We respond within 30 days. You can also file a complaint with the Swedish Authority for Privacy Protection (IMY) at imy.se.
Changes
We will update this policy when our practices change. The "Last updated" date at the top reflects the most recent revision. Material changes will be announced via email to active subscribers.