Privacy Policy

Effective date: May 21, 2025

Who we are

Where to Focus (wheretofocus.com) is a productivity application developed and operated by TCB, informacijske storitve, Ljubomir Marković s.p., Goriška cesta 51, 3320 Velenje, Slovenia. Tax ID: 90939514. Contact: info@tcb.si.

What data we collect

We collect only what's necessary to run the application.

At registration

  • Email address (required to create an account)
  • Password (stored in encrypted form — bcrypt)

During use

  • Time zone (to display your schedule correctly)
  • Content you create: life paths, values, daily plans, activities, and reflections

Reflections, daily insights, and value orientations are personal content stored solely to provide the service to you. We do not read, analyse, or process this content beyond what is technically necessary to display it back to you. No automated profiling or behavioural analysis is performed on your content.

Session data

  • Login cookies (session cookies) — retained only for the duration of your active session

What we don't collect

  • Payment information
  • Data from third-party services (no social login or integrations)
  • Analytics trackers (we don't use external analytics tools at this time)
  • Location data

Why we collect it

We do not process your data for marketing, profiling, or sale to third parties.

Purpose Legal basis (GDPR)
Creating and managing your account Performance of a contract (Art. 6(1)(b))
Maintaining your session while logged in Performance of a contract (Art. 6(1)(b))
Storing your content Performance of a contract (Art. 6(1)(b))
Security and abuse prevention Legitimate interest (Art. 6(1)(f))
Sending transactional emails (confirmation, password reset) Performance of a contract (Art. 6(1)(b))
Sending the newsletter Consent (Art. 6(1)(a))

Cookies

We use only functional session cookies necessary for login to work. These cookies don't track your activity outside the application and are deleted when you log out or close your browser.

We don't use analytics, advertising, or third-party cookies.

Data processors

Cloudflare

We use Cloudflare (Cloudflare, Inc., USA) for security and application delivery. Cloudflare processes your IP address to determine your approximate country of origin and to protect against malicious use. This processing happens server-side and is not stored beyond your session. Cloudflare is certified under standards compliant with GDPR.

Newsletter

During registration you may opt in to receive our newsletter. Your email address is stored for this purpose based on your consent (Art. 6(1)(a) GDPR). You can withdraw consent at any time in your account settings.

Data retention

We retain your data for as long as your account is active. If you request account deletion, all associated personal data is removed within 30 days. Data is stored on secure servers within the EU.

Your rights

Under the GDPR, you have the right to:

  • Access — request a copy of the data we hold about you
  • Rectification — correct inaccurate data directly in your account settings
  • Erasure — request deletion of your account and all associated data
  • Portability — request an export of your data in a standard format
  • Restriction — request that we limit processing in certain circumstances
  • Objection — object to processing based on legitimate interest

To exercise any of these rights, contact us at info@tcb.si. We respond within 30 days.

You may also lodge a complaint with the Slovenian Information Commissioner (ip-rs.si) or the supervisory authority in your country of residence.

Security

Passwords are stored using secure hashing (bcrypt). All data in transit between your browser and our servers is protected by HTTPS. Database access is restricted and monitored.

Changes to this policy

We'll notify you by email before making significant changes. The effective date at the top of this document always reflects the latest version.

Contact

For privacy-related questions: info@tcb.si — TCB, informacijske storitve, Ljubomir Marković s.p., Goriška cesta 51, 3320 Velenje, Slovenia.