PRIVACY POLICY AND DATA PROCESSING AGREEMENT

Effective Date: April 18, 2026
Applicability: Global, with specific provisions for European Economic Area (EEA) residents.

1. INTRODUCTION AND LEGAL FRAMEWORK

Welcome to the AI Focus Timer & Music ADHD mobile application (the “App”), developed and operated by WRS Group SRL (“we,” “us,” “our,” or the “Company”). We operate under the umbrella of the Open Foresight academic framework.

This Privacy Policy forms an integral part of our Terms of Service. It has been drafted in strict compliance with:

The General Data Protection Regulation (EU) 2016/679 (“GDPR”)
The Romanian Law No. 190/2018 implementing the GDPR
The ePrivacy Directive 2002/58/EC
The Artificial Intelligence Act (EU) 2024/1689 (“AI Act”)

2. IDENTITY OF THE DATA CONTROLLER

WRS Group SRL
EUID: ROONRC.J2023000854053
Address: Luceafărului Building 4B, Office 3, Calea Aradului Nr. 4, Sc. B, ap.3, Oradea, Bihor County 410223, Romania
Data Protection Contact: contact@openforesight.eu

3. CATEGORIES OF PERSONAL DATA PROCESSED

In adherence to the principle of “Data Minimization” (Art. 5(1)(c) GDPR), we process only the data strictly necessary for the App’s functionality and the underlying academic research:

Identity & Authentication Data: Email address, anonymized user ID tokens provided by Apple Inc. or Google LLC.
Cognitive & Behavioral Metrics: User-reported generic “Anxiety Levels” (scaled 1-10) used purely for algorithmic calibration. Disclaimer: We do not process “Special Categories of Personal Data” (Art. 9 GDPR) such as clinical medical diagnoses.
Task Inputs (User Prompts): Text inputs submitted by the user strictly for deconstruction by the AI.
Telemetry & Local Data: Device identifiers, OS version, session lengths, and interaction timestamps. This includes data stored locally on your device (via MMKV) necessary for offline functionality, compliant with the ePrivacy Directive.
Financial Data: Handled exclusively by Apple Inc. We do not process, store, or have access to your credit card information.

4. LEGAL BASES AND PURPOSES OF PROCESSING (Art. 6 GDPR)

A. Contractual Necessity (Art. 6(1)(b)):

To create and manage your account.
To provide the AI Task Slicing service and deliver generated audio layers.

B. Legitimate Interests (Art. 6(1)(f)):

To ensure network and information security.
To analyze behavioral usage patterns for App optimization.

C. Scientific Research Purposes (Art. 89 GDPR):

Data collected via the App may be aggregated, pseudonymized, and utilized for longitudinal academic research within the Open Foresight PhD methodology, analyzing cognitive learning improvement and digital task paralysis.

5. PROVISIONS UNDER THE EU ARTIFICIAL INTELLIGENCE ACT

Role Classification: WRS Group SRL acts exclusively as a “Deployer” of general-purpose AI models via API, not as a “Provider” or developer of foundational AI models.
Risk Classification: The App is classified as a “Minimal Risk” AI system. It is not an employment, biometric, or law enforcement tool.
No Legal Decisions: The App does not engage in “Automated Individual Decision-Making” (Art. 22 GDPR). AI outputs are strictly advisory, non-binding task recommendations.
User Ban on Sensitive Data: Users are strictly prohibited from inputting Protected Health Information (PHI) or Personally Identifiable Information (PII) into the AI prompt interfaces. By using the App, you indemnify WRS Group SRL against any liability arising from your unauthorized inclusion of sensitive data in AI prompts.

6. RECIPIENTS OF PERSONAL DATA AND INTERNATIONAL TRANSFERS

WRS Group SRL does not sell your data. Data may be shared with the following categories of processors under strict Data Processing Agreements (DPAs):

Cloud Infrastructure: Google Cloud/Firebase (EU servers primarily).
AI Service Providers: Proprietary AI API providers.
Subscription Management: RevenueCat Inc.

Cross-Border Transfers: If data is transferred outside the EEA (e.g., to servers in the USA), such transfers are safeguarded by the EU Standard Contractual Clauses (SCCs), ensuring a level of protection essentially equivalent to that guaranteed within the EU.

7. DATA RETENTION, ANONYMIZATION, AND RESEARCH EXEMPTIONS

Account Data: Retained until you request deletion.
Research & Analytics Data: In accordance with the scientific research derogations under GDPR, we may transform usage logs and task data into fully anonymized, aggregated datasets. Once anonymized, this information falls outside the scope of the GDPR and will be retained indefinitely by WRS Group SRL for ongoing Open Foresight research.

8. YOUR RIGHTS AS A DATA SUBJECT (Art. 15-21 GDPR)

Subject to legal limitations and the exemptions afforded to scientific research, you have the right to:

Access: Request confirmation of data processing and a copy of your data.
Rectification: Correct inaccurate personal data.
Erasure: Request deletion of your account. “Right to be forgotten” requests may be partially denied if the deletion seriously impairs the achievement of our scientific research objectives (Art. 17(3)(d) GDPR).
Restriction: Limit how we process your data.
Data Portability: Receive your data in a structured, machine-readable format.
Object: Object to processing based on legitimate interests.

To exercise these rights, please contact contact@openforesight.eu. You also maintain the right to lodge a complaint with the Romanian Data Protection Authority (ANSPDCP).

9. CHILDREN’S PRIVACY

The App is not intended for individuals under the age of 16 without parental consent. We do not knowingly collect personal data from children. If we become aware of such data collection, we will securely delete it.

10. AMENDMENTS

We reserve the right to amend this Privacy Policy to reflect evolving legal, technical, or business developments. Substantive changes will be communicated via an in-app notification. Your continued use of the App signifies your acceptance of the updated policy.

Privacy Policy