Privacy Policy

This policy explains how Dras Labs LLC (“Dras Labs,” “we,” “us”) handles information through the Focal Keys keyboard, the Focal Keys companion app and focalkeys.com (together, the “Services”). It's written to be read, not skimmed past.

1. Who we are

Focal Keys is a product of Dras Labs LLC, a New Jersey limited liability company. Dras Labs is responsible for the information described in this policy. You can reach us at support@focalkeys.com.

2. What we process and why

We use this information only for the purposes listed above: providing and securing the Services, applying fair-use limits, answering you, and keeping records the law requires. If we ever want to use it for something new, we'll update this policy first and, where the law requires, ask for your consent.

3. What we don't collect

• Your keystrokes, or anything you type that you haven't asked us to polish.
• Anything you copy that you don't send to us by tapping. Links in copied messages are removed before anything is sent.
• Passwords. iOS always uses its own keyboard in password fields.
• Your name, contacts, photos, location, health data or advertising identifier.
• Information from other apps, beyond the message you choose to send.

4. How the keyboard works

Custom keyboards on iPhone need a setting that iOS calls Allow Full Access before they can connect to the internet. Focal Keys uses it to reach our server: to send the text you choose when you tap Reply for me, Polish mine or Write an opener, and, once you've agreed in the app, to send a small wake-up request when the keyboard opens so replies come faster. The wake-up request contains no message text and no device code. iOS may also ask whether Focal Keys can paste; that lets the keyboard pick up the message you just copied so it can show “Replying to.” None of your text is sent until you tap.

The keyboard works for normal typing without Full Access. You can turn Full Access off anytime in Settings › General › Keyboard › Keyboards › Focal Keys.

5. How AI is used

Your permission comes first. Before the first suggestion, the app asks for your permission to send text to our AI provider and names that provider. Without your permission, Focal Keys makes no AI requests. You can withdraw permission anytime in the app's Privacy & AI settings.

Who our AI provider is. Suggestions are currently created by Google's Gemini models, through Google Cloud's Vertex AI service. Under Google Cloud's terms, Google doesn't use your messages to train its models. We've turned off Google's caching of prompts. Google may log requests for a limited time only to detect abuse, and then deletes them. Requests reach Google from our server, so Google receives only what's described in section 2, not your IP address or device code.

Changing providers. We may move to, or add, other AI providers in the future, such as OpenAI or Anthropic. We'll only use a provider whose business terms forbid training on your content. Before your messages go to a new provider, we'll update this policy and the in-app permission screen and, where needed, ask for your permission again.

Tools we use to build Focal Keys. Like many developers, we use AI tools, including Claude by Anthropic, ChatGPT by OpenAI and Google's Gemini, to help us write code, copy and designs. These tools never receive your messages or any personal information from the Services.

Suggestions are AI-generated. They can be wrong or a poor fit. Always read a suggestion before you send it; you decide what's sent. We don't use your messages to build a profile of you or to make decisions about you.

6. Other people's messages and sensitive information

The message you send is usually written by someone else, your match. We process it only to create your suggestion and keep none of it afterward. Please only send messages you're comfortable having processed this way.

Dating conversations can reveal sensitive information, such as someone's sexual orientation, sex life, health or religion. We don't look for, infer or keep this information. If a message contains it, it's processed only to create your suggestion, with the permission you gave in the app, and we never keep it.

7. Who we share information with

We share information only with service providers that help us run Focal Keys, and only what each one needs:

• Google Cloud and Firebase (Google LLC): hosting, our servers and the database that holds the anonymous usage counts and consent records.
• Our AI provider, currently Google (Gemini): creates suggestions, as described in section 5.
• Cloudflare: hosts focalkeys.com, protects it from attacks and forwards emails sent to support@focalkeys.com.
• Google (Gmail, Google Workspace, Forms and Sheets): our email, and where waitlist sign-ups are kept.
• Google Fonts: provides the fonts on focalkeys.com, so your browser contacts Google when it loads them.
• Apple: TestFlight, the App Store and any subscriptions.

These providers may use the information only to provide their services to us. We may also disclose information if the law requires it, to protect someone's safety, to investigate abuse of the Services, or as part of a merger or sale of our business, in which case this policy's promises would continue to apply.

We don't sell personal information, we don't “share” it for cross-context behavioral advertising (as California law uses that term), we don't use it for targeted advertising, and we don't give it to data brokers. We don't use it for profiling that has legal or similarly significant effects.

8. How long we keep information

• Messages, drafts, hints and other context sent with a request: never kept by us. Our AI provider may log them for a limited time only to detect abuse (section 5).
• Anonymous usage counts: deleted automatically within 30 days.
• Server and website logs (IP address and technical details, never message, draft or hint text): kept for up to 30 days, then deleted.
• Consent records (including any withdrawal): kept for up to 3 years from when you agreed, so we can show what you agreed to.
• Waitlist emails: kept until launch and for 12 months after, or until you ask us to remove yours.
• Support emails: kept for up to 2 years, then deleted, unless we need them longer to resolve an issue or meet a legal obligation.

9. Your choices and rights

Choices everyone has

• Withdraw AI permission in the app's Privacy & AI settings. Focal Keys then stops making AI requests.
• Turn off Full Access, or remove the keyboard, in Settings › General › Keyboard › Keyboards.
• Delete the app. Your tone and settings are stored on your device and go with it.
• Leave the waitlist or stop our emails by using the opt-out link or emailing us.

Privacy rights

Depending on where you live, including California, New Jersey, Virginia, Colorado, Connecticut, Texas and other states with privacy laws, you may have the right to:

• know what personal information we hold about you and get a copy of it;
• correct information that's wrong;
• delete your personal information;
• withdraw consent you've given, including for sensitive information;
• opt out of the sale of personal information, targeted advertising and certain profiling (we don't do any of these);
• appeal if we turn down your request; and
• use these rights without being treated differently.

We give these choices to everyone, wherever you live. To make a request, email support@focalkeys.com with the subject “Privacy request.” Because there are no accounts, we may ask for something that lets us find your information, such as the email you signed up with. Usage counts and consent records aren't linked to your name or email, so we usually can't match them to you; usage counts are deleted automatically within 30 days. We'll reply within 30 days. If you use an authorized agent, we may ask for proof that they act for you.

If we turn down your request, you can appeal by replying with the subject “Privacy appeal.” We'll answer within 45 days and explain our decision. If you're still not satisfied, you can contact your state attorney general.

California residents: we don't disclose personal information to third parties for their own direct marketing.

10. Cookies, tracking and Do Not Track

focalkeys.com doesn't use analytics, advertising or tracking cookies, and the app doesn't track you across other companies' apps or websites. Cloudflare may set a strictly necessary security cookie to protect the site from attacks. Because we don't track you, “Do Not Track” and Global Privacy Control signals don't change how we handle your information; we'd honor them anyway. If we ever add analytics or ads, we'll update this policy first and ask for consent where the law requires.

11. Age

Focal Keys is only for people 18 and older, and the Services aren't directed at children. We don't knowingly collect personal information from anyone under 18. If you believe someone under 18 has given us information, email us and we'll delete it.

12. Security

We encrypt data in transit, limit who can access our systems, keep what we hold to the minimum and never write message content to logs. No system is perfectly secure, but holding as little as possible is our strongest protection. If a security incident affects your personal information, we'll notify you and the authorities as the law requires.

13. Where information is processed

Focal Keys is run from the United States, and information is processed in the US. Some of our providers, such as Google and Cloudflare, may process it briefly in other countries where they operate, under their own security commitments. If you use the Services from outside the US, you understand your information will be processed in the US, where privacy laws may differ from those where you live.

14. Changes to this policy

We'll post any change here and update the version and date above. If a change is meaningful, for example a new AI provider or a new kind of information, we'll tell you in the app before it applies and ask for your permission again where needed. Earlier versions are available on request.

15. Contact us

Dras Labs LLC
Email: support@focalkeys.com