FocusSort is local-first by design. Your photos never leave your Mac. We collect zero data by default. Only if you opt into analytics do we collect anonymous, aggregated usage data — never your photos, file names, or anything identifying. We never sell, rent, or share your data. You have full rights over your information at all times.
Table of Contents
- 1. Who We Are & Legal Controller
- 2. What Data We Collect
- 3. What We Never Collect
- 4. How Analytics & Telemetry Works
- 5. Crash Reporting & Feedback
- 6. Freemius Payment Processing
- 7. Anti-Fingerprinting & Aggregation
- 8. Legal Basis for Processing (GDPR)
- 9. Data Retention Schedules
- 10. Your Privacy Rights
- 11. Children's Privacy (COPPA)
- 12. Data Security & Encryption
- 13. Subprocessors & Third Parties
- 14. International Data Transfers
- 15. California Privacy Rights (CCPA/CPRA)
- 16. Other International Regulations
- 17. Changes to This Policy
- 18. Contact & Data Request Procedures
1 Who We Are & Legal Controller
Developer: FocusSort is developed and operated by Scott Jones, an individual developer based in Rochester, New York, USA.
Data Controller: Scott Jones is the data controller for all processing of your data under GDPR, CCPA, and similar privacy laws — meaning Scott Jones determines how and why data is collected and processed.
Contact Information:
- Email: privacy@focussort.com
- Location: Rochester, New York, USA
2 What Data We Collect
FocusSort processes data in distinct categories based on your choices:
(a) By Default: Zero Collection
When you first install and use FocusSort, the app collects and transmits zero data. The Software is entirely offline and does not require an account, login, or network access to use core features.
(b) If You Enable Analytics: Anonymous Usage Data Only
If you opt into analytics in Settings → Privacy → Analytics, we collect only the following anonymous data:
- Feature usage: Which features you use (e.g., "duplicates feature opened") — not what you do with results
- Performance metrics: Time measurements (e.g., "startup: 2.3s", "duplicate scan: 45s") — to identify performance regressions
- Library size ranges: Bucketed photo counts (e.g., "100K–500K photos") — never exact numbers
- Error types: When features fail (e.g., "failed to parse HEIC file") — to prioritize bug fixes
- Hardware categories: Processor family & RAM (e.g., "Apple Silicon M4 Pro, 32 GB") — for performance analysis
- OS information: macOS version number only (e.g., "macOS 15.2")
- Session metadata: Bucketed session durations and event counts — not precise timestamps with timezone
All data is collected in a local SQLite database and sent to our server in encrypted batches every 24 hours.
(c) If You Submit Feedback: User-Selected Information Only
If you use the in-app "Send Feedback" feature, you control what information is included. We do not automatically attach any data, logs, or system information. You see exactly what will be sent before confirming.
(d) Crash Reports: Diagnostic Data Only
If the Software crashes, a dialog asks whether you want to submit a crash report. Submission is always optional. If you choose to submit, the report includes: the crash stack trace and exception details, macOS version and hardware model, session breadcrumbs (recent actions — no personal data or file content), and memory usage at crash time.
3 What We Never Collect
Regardless of your analytics or feature settings, FocusSort definitively does not collect:
- Your photos, images, or any image content
- Thumbnails or image previews
- File names, folder names, or file paths
- GPS coordinates, location data, or location inferred from metadata
- Search queries or collection names you create
- Your name, email address, Apple ID, or account credentials
- Camera serial numbers or identifying EXIF metadata
- Content classification results (Studio tier — all results stay 100% local)
- Facial recognition data, face embeddings, or people groupings
- Quality scores for individual photos
- Exact photo counts or library size (ranges only)
- Precise timestamps with timezone information
- Your IP address (stripped before storage if transmitted)
- Device identifiers (UDID, hardware serial number, etc.)
- Biometric data of any kind
4 How Analytics & Telemetry Works
Data Flow
- Events are recorded locally in a SQLite database on your Mac — no server involvement at this stage
- Every 24 hours, all pending events are sent in a single encrypted batch over HTTPS/TLS 1.3
- Each app session uses a random, session-specific ID that is never reused and has no persistent connection to you
- If you enable "Enhanced Analytics" (optional), an additional random UUID (install ID) is generated for tracking data across app updates — it has no connection to your Apple ID, device serial number, or identity
- If the server is unreachable, events remain on your device until the next 24-hour cycle
Transparency & Control
- View the exact JSON-formatted data pending submission in Settings → Privacy → View Pending Data
- Delete all pending data without sending it at any time
- Disable analytics immediately in Settings; all pending unsent data is deleted automatically upon disabling
5 Crash Reporting & Feedback Data
Crash Reports: Optional and user-initiated. Transmitted over HTTPS/TLS 1.3. Contain only the diagnostic information needed to fix the crash — no Content, personal data, or file paths.
Feedback Submissions: You control what is sent. No data is automatically attached or transmitted without your explicit confirmation.
Retention: Crash reports and feedback are retained for up to 90 days, then permanently deleted.
6 Freemius Payment Processing
FocusSort uses Freemius, Inc. (freemius.com) for payment processing, subscription management, and license activation.
Data Handled by Freemius (Not by Us)
- Payment card information
- Billing name and address
- Email address (for purchase receipts)
- Subscription status and renewal dates
- License activation keys
Your payment information is governed by Freemius's Privacy Policy. For questions about payment data, contact Freemius directly at freemius.com/contact.
7 Anti-Fingerprinting & Data Aggregation
To prevent re-identification through unique combinations of data, we apply strict aggregation and bucketing to all analytics:
- Photo counts: Rounded to ranges (1K, 10K, 50K, 100K, 500K, 1M+)
- Storage size: Rounded to TB ranges (1TB, 2TB, 5TB, 10TB+)
- Session durations: Bucketed (0–1s, 1–5s, 5–10s, 10–60s, 60s+)
- Event counts: Bucketed (1, 2–5, 6–10, 11–50, 51–100, 100+)
- Timestamps: UTC date only — no time-of-day or timezone information
- Performance metrics: Rounded to nearest 100ms or 1 second
Even with all available data points combined, you cannot be uniquely identified or re-identified across sessions.
8 Legal Basis for Processing (GDPR)
Under the GDPR, our processing is based on the following legal grounds:
- Analytics data: Article 6(1)(a) — Your explicit, freely-given, informed opt-in consent. Analytics is never enabled by default. You can withdraw consent at any time.
- Crash reports: Article 6(1)(f) — Our legitimate interest in diagnosing crashes to improve stability and user experience.
- Feedback data: Article 6(1)(a) — Voluntary submission by you; you choose what to send.
9 Data Retention Schedules
- Basic Analytics events: Automatically deleted from our server after 90 days
- Enhanced Analytics events: Automatically deleted after 180 days
- Aggregated analytics summaries: Retained up to 2 years (contain no individual-level data)
- Crash reports: Retained up to 90 days, then permanently deleted
- Feedback submissions: Retained up to 90 days, then permanently deleted
- Deletion requests: Processed and permanently deleted within 72 hours of request
After the retention period, data is permanently and irreversibly deleted.
10 Your Privacy Rights
To exercise any right below, email privacy@focussort.com:
- Right to know: Request what data we have collected about you. We respond within 45 days.
- Right to access: Enhanced Analytics users can download all their data as JSON in Settings → Privacy → Download My Data.
- Right to delete: Request permanent deletion of all your data. We delete within 72 hours and provide written confirmation.
- Right to withdraw consent: Disable analytics at any time in Settings. Takes effect immediately; pending data is deleted automatically.
- Right to portability: Export your Enhanced Analytics data as JSON for transfer to another service.
- Right to object: Object to analytics processing at any time by disabling it in Settings.
- Right to rectification: If any data about you is incorrect, contact us and we will correct or delete it.
- Right to non-discrimination: The app works identically whether analytics is on or off. No features are restricted, no experience is degraded, and no prices differ based on your privacy choices.
11 Children's Privacy (COPPA/CalOPPA)
FocusSort is not directed toward users under 13. To comply with the Children's Online Privacy Protection Act (COPPA) and California's child privacy laws:
- If we become aware we have collected analytics data from a user under 13, we will delete it immediately
- If macOS parental controls are detected, analytics defaults to disabled
- We do not knowingly collect any data from users under 13
- For users aged 13–17, we apply the same protections as adult users: opt-in only, no sale, no sharing
If a parent or guardian believes FocusSort has collected data from a child under 13, please contact privacy@focussort.com immediately.
12 Data Security & Encryption
On Your Mac: Your photos and library data are stored on your local drive under standard macOS file permissions. FocusSort does not encrypt your photos at rest — that is handled by macOS FileVault or full-disk encryption at your discretion.
In Transit: All analytics data, crash reports, and feedback are transmitted over HTTPS with TLS 1.3 encryption, preventing eavesdropping in transit.
On Our Server: Analytics data is stored on Cloudflare's infrastructure with encryption at rest. Access is restricted to the developer and protected by multi-factor authentication. We do not store your IP address.
Limitations: While we take reasonable security measures, no system is 100% secure. We are not responsible for unauthorized access caused by your actions, compromised devices, or network interception outside our control.
13 Subprocessors & Third Parties
Cloudflare: Analytics data is processed and stored on Cloudflare's global edge network. Cloudflare acts as a data processor on our behalf. See Cloudflare's Privacy Policy.
Freemius: As described in Section 6, Freemius processes payment and subscription data. Freemius is a data processor for payment information only.
14 International Data Transfers
Analytics data may be processed and stored on Cloudflare's edge network, which operates globally across multiple regions. For international transfers, we rely on:
- Your consent: By enabling analytics, you consent to processing in the United States and on Cloudflare's global network
- Aggregated data: All analytics data is heavily aggregated — no individual-level personal data is transferred
- Data minimization: We never transfer your photos, file content, or identifying information
If you are in the EU, EEA, or UK and object to international data transfers, you can disable analytics in Settings to prevent any transmission.
15 California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the CCPA and CPRA:
- Right to know: Request what personal information we have collected about you in the past 12 months. We respond within 45 days.
- Right to delete: Request deletion of your personal information, except as required by law. We delete within 45 days and confirm.
- Right to opt out of sales: We do not sell personal information under any circumstances.
- Right to correct: Request correction of inaccurate personal information.
- Right to limit use: We process only anonymized analytics data, which is not "sensitive personal information" under CCPA.
- Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights.
To submit a California Privacy Request, email privacy@focussort.com with the subject line "California Privacy Request," your name, and the specific right you are exercising.
16 Other International Privacy Regulations
This Privacy Policy is designed to be consistent with the following frameworks:
- GDPR — EU, EEA, UK
- CCPA/CPRA — California
- LGPD — Brazil
- PIPEDA — Canada
- POPIA — South Africa
- APPI — Japan
You have the same privacy rights under all applicable laws in your jurisdiction. If your local law provides additional protections beyond what is stated here, those protections apply.
17 Changes to This Policy
Material Changes affecting your privacy rights or how we process data will be communicated via a prominent in-app notice, email notification (if you've provided contact information), and a notice on this website. Major changes affecting data collection will require you to re-accept the policy before analytics continues.
Minor Changes (clarifications, typos, new compliance sections that don't change your rights) will be reflected with an updated date without separate notice.
18 Contact & Data Request Procedures
For all privacy questions, data requests, or concerns:
Email: privacy@focussort.com
Location: Rochester, New York, USA
Include "Privacy Request" or "Data Subject Access Request" in the subject line. We respond to all requests within 45 days.
FocusSort is designed by a photographer, for photographers. Your photos are yours. Your privacy matters. We believe in transparency, user control, and minimal data collection.