FoCoCo is operated by Quantum Surprise, Unipessoal Lda, NIPC 518 139 247, with registered office at Caminho dos Picoitos 798x, Santo Estêvão, Tavira, 8800-506, Portugal. We are the controller of personal data described in this Policy.
Privacy contact: privacy@fococo.ai | Support: support@fococo.ai
This Policy applies to fococo.ai, fococo.app, the FoCoCo iOS and Android apps, CoachTalk, GameTrust, round capture, performance insights, voice features, subscriptions, support and related services.
1. Who may use FoCoCo
FoCoCo is available only to people aged 16 or older. We do not knowingly offer the service to, or collect personal data from, anyone under 16. If we learn that an account belongs to a person under 16, we may suspend or delete it and remove associated personal data, subject to legal retention duties.
2. Personal data we collect
2.1 Account and profile data
- Name, email address, country, preferred language and account identifiers.
- Age confirmation and, where voluntarily provided, golf profile information such as handicap, home club, playing goals and preferences.
- Authentication and security information, including login events and account recovery records.
2.2 Golf and performance data
- Round information, scores, course and tee details, captured moments, notes, routines, reflections and performance inputs.
- Focus, Confidence and Control inputs, GameTrust activity, CoachTalk conversations, completed sessions and related progress information.
- Patterns, summaries, recommendations and other insights created from information you provide.
2.3 Voice and location data
- Microphone input and transcripts when you choose to use voice features. Raw audio is processed only as needed to transcribe or provide the requested feature and is not retained by FoCoCo longer than necessary for that processing, unless you deliberately save a recording or we must preserve it for security, support or legal reasons.
- Precise or approximate location when you enable location-based golf features. Location permission can be changed in your device settings. FoCoCo does not use location for advertising.
2.4 Payment, device and usage data
- Subscription status, purchase identifiers, billing country and transaction records. Apple, Google and Stripe process payment-card details; FoCoCo does not receive full card numbers.
- Device type, operating system, app version, IP address, crash information, security events and service interactions.
- Cookie and analytics information where you have consented, as described in the Cookie Policy.
2.5 Support and communications
- Messages, attachments and information you send to support.
- Email preferences and records of transactional or marketing communications.
3. How and why we use personal data
| Purpose | Examples | Legal basis |
|---|---|---|
| Provide the service | Create your account; capture rounds; deliver CoachTalk, GameTrust, insights, sessions and cross-device access | Performance of our contract |
| Personalize coaching | Use your prior activity, stated goals and relevant history to make coaching more useful and consistent | Performance of our contract |
| Voice and location features | Transcribe speech and provide location-enabled functionality you request | Performance of our contract; device permission where required |
| Payments and records | Manage subscriptions, verify entitlement, issue invoices and maintain tax records | Contract and legal obligation |
| Security and abuse prevention | Authenticate users, protect accounts, investigate misuse and maintain service integrity | Legitimate interests and legal obligation |
| Product reliability | Diagnose errors, monitor performance and improve usability | Legitimate interests; consent where cookies or similar device access require it |
| Marketing | Send product news and offers where you have opted in | Consent |
| Legal compliance | Respond to lawful requests, exercise or defend legal claims and meet regulatory duties | Legal obligation and legitimate interests |
4. How FoCoCo remembers and personalizes your game
FoCoCo is designed to remember relevant information so it can coach you consistently over time. This may include conversation history, round history, goals, routines, recurring patterns, previous recommendations and whether a recommended session helped.
- The information is used to provide your own personalized experience.
- You can review and correct profile information and may request access, export or deletion of your data.
- Deleting your account permanently removes or de-identifies personal coaching history, subject to limited legal and backup retention.
- FoCoCo does not use your private conversations, voice transcripts or identifiable performance data to train general-purpose AI models. Contracted AI providers may process relevant inputs only to generate the feature you requested and under their data-processing commitments.
5. Automated processing and AI
FoCoCo uses AI to organize inputs, identify patterns and generate coaching responses and performance insights. AI output may be incomplete or inaccurate and should be considered alongside your own judgment. FoCoCo does not use solely automated processing to make decisions that produce legal or similarly significant effects about you.
6. When we share personal data
We do not sell personal data or private conversations. We share data only as necessary with:
- Cloud hosting, authentication, database, analytics, email, voice, AI, payment, customer-support and security providers acting for us.
- Apple, Google or Stripe in connection with purchases and subscription management.
- Professional advisers, auditors, insurers or authorities where necessary and lawful.
- A purchaser or successor in a merger, financing, reorganization or sale, subject to confidentiality, applicable law and notice where required.
A current subprocessor list should be maintained at https://www.fococo.ai/subprocessors. FoCoCo will not provide a coach, academy, federation or other organization with your identifiable coaching data unless you deliberately connect to that party and choose the information to share. Any future sharing feature will include clear controls and can be revoked prospectively.
7. Aggregated and anonymized information
FoCoCo may create statistics and insights that are aggregated or anonymized so they are not reasonably capable of identifying an individual. We may use that information to improve FoCoCo, measure performance and understand golf-performance patterns. We do not license or sell identifiable personal data or private conversations. If FoCoCo later introduces optional contribution to commercial benchmarking or research products, we will provide a clear explanation and choice before using data for that purpose.
8. International transfers
Some providers may process data outside Portugal or the European Economic Area. Where required, we use recognized safeguards such as an adequacy decision, the European Commission Standard Contractual Clauses and supplementary security measures.
9. Retention
| Data | Typical retention |
|---|---|
| Active account and golf history | For the life of the account, unless deleted sooner |
| Draft rounds | Until completed, deleted, or automatically removed after a reasonable inactivity period |
| CoachTalk and personalization history | For the life of the account, unless deleted with the account or earlier where controls are available |
| Raw voice audio | Only for the time needed to process the request, unless deliberately saved or temporarily preserved for a documented support/security reason |
| Transcripts and captured moments | For the life of the account or until deleted with associated content |
| Security and technical logs | Normally up to 12 months, longer where needed to investigate abuse or comply with law |
| Support records | Normally up to 3 years after closure of the request |
| Marketing records | Until consent is withdrawn, plus a suppression record so we respect the opt-out |
| Transaction and tax records | For the period required by Portuguese tax, accounting and consumer law |
| Deletion backups | Removed through the ordinary backup cycle, normally within 90 days |
10. Your rights
Subject to applicable law, you may request access, correction, deletion, restriction, portability or objection, and may withdraw consent at any time without affecting earlier lawful processing. You may also complain to the Comissão Nacional de Proteção de Dados (CNPD) or your local supervisory authority.
Requests: privacy@fococo.ai. We may need to verify your identity. We normally respond within one month, subject to lawful extensions for complex requests.
11. Security
We use technical and organizational measures appropriate to the nature and risks of the data, including encryption in transit, protected cloud storage, access controls, logging, security monitoring and incident procedures. No service can guarantee absolute security.
12. Cookies and device permissions
Website cookies and similar technologies are described in the Cookie Policy. Mobile permissions are requested contextually and should be limited to features you choose to use. You can change permissions in your device settings, although some features may then be unavailable.
13. Changes to this Policy
We may update this Policy as FoCoCo changes or the law requires. We will post the updated version and notify users of material changes. Where new processing requires consent, we will request it before the processing begins.
14. Contact
Quantum Surprise, Unipessoal Lda
NIPC 518 139 247
Caminho dos Picoitos 798x, Santo Estêvão, Tavira, 8800-506, Portugal
privacy@fococo.ai