1. Who We Are

FocusAI Limited operates the FocusAI service at focusai.co.nz. We are a New Zealand registered company with our principal place of business at Havelock North, Hawke’s Bay, New Zealand 4130.

We are the ‘agency’ responsible for your personal information as defined under the New Zealand Privacy Act 2020. For questions or requests relating to your privacy, contact us at contact@focusai.co.nz.

2. What Information We Collect

2.1 Information you provide

• Email address (when you sign up for a free or paid account)
• Payment information (processed securely by our payment provider — we do not store card details)
• Content you enter into the FocusAI tool (your written prompts and concerns)

2.2 Information collected automatically

• IP address and general location data
• Browser type and device information
• Pages visited, time on site, and usage patterns (via analytics cookies)
• Cookie data (see our Cookie Policy for details)

2.3 Information we do not collect

We do not knowingly collect personal information from anyone under the age of 18. We do not collect sensitive personal information such as health records, financial account details, or government identification numbers.

3. How We Use Your Information

We collect and use your personal information only for the following purposes:

• To provide and operate the FocusAI service
• To send you service-related emails, including your daily clarity prompts (Pro subscribers)
• To process subscription payments
• To improve and develop the service
• To comply with our legal obligations
• To respond to enquiries or support requests

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

4. Legal Basis for Processing

Under the New Zealand Privacy Act 2020, we collect and use your information on the following grounds:

• Performance of a contract — to deliver the service you have signed up for
• Legitimate interests — to improve our service and protect our business
• Legal obligation — where required by New Zealand law
• Consent — for optional communications such as marketing emails

5. How We Share Your Information

5.1 Third-party service providers

We share limited personal information with trusted third-party providers who help us operate the service:

• Anthropic (AI infrastructure) — your prompts are processed by Anthropic’s API to generate responses
• MailerLite (email platform) — your email address is stored for delivery of subscription emails
• Payment processor (Stripe or equivalent) — payment information is handled directly by our payment provider
• Hosting provider (Dreamhost) — website and data hosting

5.2 Legal requirements

We may disclose your information where required to do so by law, court order, or government authority.

6. International Data Transfers

Some of our third-party service providers operate outside of New Zealand. Where your data is transferred internationally, we take reasonable steps to ensure it is protected to a standard comparable to the New Zealand Privacy Act 2020.

If you are located in the European Union or United Kingdom, you may have additional rights under GDPR or the UK GDPR. Please contact us to exercise those rights.

7. Data Retention

• Account information — retained for the duration of your account plus 12 months after closure
• Payment records — retained for 7 years as required by New Zealand tax law
• Tool input/prompts — not retained beyond the session unless required for service delivery
• Email communications — retained for 24 months

8. Your Rights

Under the New Zealand Privacy Act 2020, you have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information (subject to legal retention obligations)
• Withdraw consent for optional processing (such as marketing emails)
• Lodge a complaint with the New Zealand Privacy Commissioner at privacy.org.nz

To exercise any of these rights, contact us at contact@focusai.co.nz. We will respond within 20 working days as required by the Privacy Act 2020.

9. Security

We take reasonable steps to protect your personal information from unauthorised access, loss, or misuse. This includes encrypted data transmission (HTTPS), access controls, and working only with reputable third-party providers.

10. Children’s Privacy

FocusAI is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or by posting a notice on the website. Continued use of the service after changes are posted constitutes acceptance.

12. Contact Us

Last updated: 20 April 2026. Prepared for FocusAI Limited under the New Zealand Privacy Act 2020. Recommended for review by a qualified New Zealand solicitor before publication.