FocalPrivacy Policy
Last updated
Focal (for iPhone) and Focal Film Lab (for Mac) work without an account and don't send anything to the developer. Your photos stay on your device and in your Photos library. The looks and lenses you design sync between your devices through your own iCloud account. This policy explains what the apps access and why.
In short
| What | Where it goes | Can the developer see it? |
|---|---|---|
| Your photos | Your Photos library, in a “Focal” album | No |
| Originals kept for developing again | Inside the app on your iPhone | No |
| Camera frames in the viewfinder | Developed in memory on your device, never stored or sent | No |
| Your looks, lenses and groups | Your devices, synced through your own iCloud account | No |
| Settings (format, grid, RAW…) | Only on your device | No |
Who is responsible
Focal and Focal Film Lab are developed by Marco Lüthi, the controller responsible for data processing under the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
Marco Lüthi
Gutstrasse 172
8055 Zürich
Switzerland
hi@luthi-mar.co
Permissions the apps ask for
- Camera (Focal), to show the viewfinder and take photos. Focal can't work without it.
- Photos (Focal, optional), to save your developed photos to the library and show the photos you took with Focal in the app. With limited access, Focal still sees the photos it created.
- Photos, add only (Focal Film Lab), to save photos you develop on the Mac to your library.
- Files you choose (Focal Film Lab), to open the photos you add and to save exports and .cube files where you pick.
You can change each permission at any time in Settings. Neither app uses your location.
Your photos
The viewfinder's frames are developed in memory as you compose and are discarded. When you take a photo, Focal saves the developed photo (and, if you shoot RAW or ProRAW, the DNG with it) to your Photos library, in an album called “Focal”. Photos keep the metadata the camera writes, such as the date and exposure settings.
So that you can develop a shot again later, Focal keeps its ungraded original and the settings it was developed with inside the app on your iPhone. When a photo is deleted from your library, Focal removes its original too. Deleting the app deletes all originals; the photos in your library stay.
Once a photo is in your Photos library, it is managed by iOS or macOS like any other photo. If you use iCloud Photos, Apple syncs it under its own privacy policy (apple.com/legal/privacy).
Looks synced through iCloud
The looks, lenses and groups you create or change, in Focal Film Lab or in Focal, are stored with Apple's CloudKit in the private database of your own iCloud account, so they appear on all your devices signed in to it. The developer has no access to this database. If iCloud is off, they stay on the device. Photos are not part of this sync.
Settings
Your choices, such as the capture format, grid and the last film and lens, are stored on your device. They may be included in your device backups, depending on your own iCloud or computer backup settings.
Photographing other people
Focal captures what the camera sees, which may include other people. Please respect their privacy and the laws that apply where you photograph.
Legal basis
Where the GDPR applies, the processing described above happens on your devices or in your own iCloud account and is necessary to provide the features you use (Art. 6(1)(b) GDPR). Camera and Photos access are based on your choice to grant them, which you can withdraw at any time in Settings. Under the Swiss FADP, we process personal data only as described here and in line with its principles.
What the apps do not do
- No account, sign-up or login.
- No uploading to the developer: your photos, originals and settings are never sent to the developer or to any server of the developer.
- No advertising, analytics, crash-reporting or tracking SDKs.
- No tracking across apps or websites, and no selling or sharing of data with data brokers.
This website
This website is a static site without cookies, analytics or tracking. Fonts are served from this website itself, so your browser does not contact third-party font services. When you visit a page, the hosting provider Vercel Inc. (based in the United States, with data centres worldwide) automatically records technical access data in server logs: your IP address, date and time, the requested page, referrer and browser type. This is needed to deliver the site and keep it secure (legitimate interest, Art. 6(1)(f) GDPR). The logs are deleted after a short period. Links to the App Store take you to Apple, where Apple's privacy policy applies.
Your rights
You have the right to request access to your personal data and to have it corrected or deleted, to object to or restrict processing, and to data portability. Because the apps store your data on your device and do not identify you, the developer usually holds no personal data about you. Most of it you can delete yourself by deleting the app.
To exercise your rights, email hi@luthi-mar.co. You can also lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in the EU the data protection authority of your country.
International transfers
Apple may process data in the United States and other countries. Apple describes the safeguards it uses for these transfers, such as the Data Privacy Framework and standard contractual clauses, in its privacy policy. This website is hosted by Vercel Inc., based in the United States; its server logs are transferred under the same kind of safeguards.
Children
Focal and Focal Film Lab are not directed at children.
Changes to this policy
If the apps start handling data differently, this page will be updated before the change ships, and the date at the top will change.