By downloading and using the TypingDNA “Focus” Application (the “App” or “Focus”), You consent to Us collecting and further processing certain Personal Information (as defined below) You provide to Us (directly or indirectly) through the use of the App.
TypingDNA Inc. (referred to as “TypingDNA”, “We” or “Us”) control the purpose for which, and the manner in which, Personal Information (as defined below) about individuals using the App are processed. We are therefore the data controller under applicable data privacy laws with respect to Personal Information collected from You through Your use of the App or otherwise processed by us in relation to the App. Our contact details are set out at the end of this privacy policy (“Privacy Policy”).
This Privacy Policy outlines the categories of Personal Information We collect from You and further process about You, the purposes for which Your Personal Information might be used and the safeguards We put in place in the course of our relationship with You to protect Your Personal Information.
By using the App, You expressly consent to our processing of Your Personal Information (as defined below) as described in this Privacy Policy, and to being bound by the provisions hereof.
Who We are
We are a technology company developing passive authentication and typing biometrics technologies. Further information about Us and the technologies we have developed is available here: https://www.typingdna.com/.
The App
The TypingDNA Focus App is a mood prediction app based on typing biometrics that allows users to see their predicted mood and typing activity. The App is a mood prediction, mood tracker, typing analyzer, productivity and health & fitness application which may be downloaded to Your device (PC, Mac, or mobile) and used to provide You with valuable information about when and how You use Your device when You type.
We have designed the App primarily to:
Focus relies on (built-in) typing biometrics proprietary technology and analyzes how You type so that You can discover when You are most focused, tired, or stressed, as well as other moods, mental states or emotions. It gives You insights based on Your typing behaviour, which will include weekly trends, daily activity breakdown, engage window, focus levels, and immediate analysis of Your mood, among other things. This way, You can use Focus to know when You are most focused, better plan Your daily activities, and improve Your productivity.
!!! Just so that we are clear from the very beginning, while Focus relies on typing biometrics proprietary technology to analyze Your typing activity on Your device, We do not track Your activity on Your devices remotely, and the App works (once downloaded on Your device) without any form of interaction between You and Us, with the exception of eventual updates and App initialization when the App starts, and at sign up/sign in where We communicate with our servers in order to be able to activate Your account and unlock premium features in the App. The technology already embedded in Focus allows it to analyze Your typing biometrics data directly on Your device, without any transfer of Your typing biometrics data to Us. We do not process or track or otherwise have access to Your activity on Your device. However, with Your prior consent, We will collect anonymous statistical data from the App that can help Us improve the App and give You better predictions.
For avoidance of doubt, We DO NOT keylog/log Your typed text in the cloud through the Focus App. We only record Your typing biometrics on the device only to run our prediction algorithms on the device as well. For better clarity, separately, We do have a different research app (called Public Research app), that runs in browser only, where We allow anyone who opts in for it to help Us build better algorithms by typing in a chat window/answering some questions.
How Focus works
You may download the App from the TypingDNA website, at https://www.typingdna.com/focus. The App is provided free of charge for non-commercial use only, in accordance with PolyForm Strict License 1.0.0, linked here: https://polyformproject.org/licenses/strict/1.0.0/. All You need to be able to download and use Focus is a valid/active Google email account. For the time being, sign-up to Focus is possible only with a Google email account.
Some App functions, such as specific/premium mood predictions, may be unlocked through one of the following methods:
Participate in our Public Research – alternatively, You can unlock the additional functionalities of Focus by helping us improve the App and the technology behind it. To do so, You may agree to contribute to Our Public Research, which is available here: https://public-research.typingdna.com/. To unlock the available features, You will be required to complete a certain target/objective (i.e. quantity of typing on Our Public Research website). Such target will be communicated to You once You choose this option.
We are currently running a research and development programme (the Public Research programme), seeking to identify certain behavioural metrics in the way people type, depending on a variety of stimuli they are subjected to, or circumstances they may find themselves in. The purpose of the Research Study is to identify particular typing patterns defined as behavioural patterns and data that can be related to typing, touch and pointer input (including, but not limited to, speed of typing, pressure applied, intervals between keystrokes, telemetry information, typing rhythms, touch and swipe pattern etc) depending on various emotions participants feel at a given moment, the research is also used to develop and further improve our typing biometrics technologies for any potential use, including but not limited to user authentication.
Please note that Public Research is subject to a different Privacy Policy. You can consult the applicable Privacy Policy here: https://public-research.typingdna.com/privacypolicy.
If You decide to use this option, please remember to use the same Google email account as You use for signing-up to Focus for signing up to the Public Research, as this is the only way We will be able to verify that You have met Your typing target and unlock the additional features of Focus.
Anonymous and Aggregate/Statistic Information
When We use the phrase “Anonymous Information” in this Privacy Policy, We mean information rendered anonymous in such a way that it cannot or can no longer be used to personally identify an individual. This information is not Personal Information within the meaning of the data privacy legislation.
To improve the functionalities of the App, We may monitor the use of the App by collecting aggregate information. No personally identifiable data is collected in this process. Typically, We collect information about the number of users of the App, the most frequently accessed features or functions of the App, actual user activity data, typing activity data and mood data that is only statistical (i.e. how many characters per minute the user types, what predictions our algorithms made for moods, but not for whom, and not the actual text being typed. That text and typing biometrics data never leaves the device, to improve the usability, performance and effectiveness of the App.
We may also store such aggregate or statistical data about Your use of the App, Your typing activity and mood.
Source of Personal Information Collection
We require that You submit certain Personal Information about yourself, such as Your Google email address, when You first download the App to Your device and on each subsequent use of the App. We receive additional Personal Information about You (consisting in Your Google account username and, if available, profile picture) from Google.
Purposes and legal basis of processing of Personal Information
We collect and use the Personal Information mentioned above when You first download the App on Your device and on each subsequent use of the App. We process such Personal Information exclusively for the purposes of providing the App and services related to the App.
We may use Your Google email address also to respond to any correspondence or to respond to Your requests to provide support or information You have requested.
We use Your Personal Information:
We will limit Personal Information that We collect and further process about You only to what is limited for the purposes of processing mentioned above (or other limited purposes which are consistent with the primary purposes mentioned above). We will not use Your Personal Information in a manner which is incompatible with the purposes for which it has been initially collected and/or authorized by You, unless We obtain Your prior consent.
We collect, process, use and, as applicable, disclose Personal Information related to you on the basis of the following legal grounds under the General Data Protection Regulation (“GDPR”):
Your consent (Art. 6(1) letter (a) GDPR): by choosing to use the App, You consent to Your Personal Information being collected and processed by us for the purposes and as regulated in this Privacy Policy. You may vary or fully revoke Your consent at any time, by sending an email to dataprivacy@typingdna.com. Withdrawal of consent will have an effect only for the future and does not affect the legitimacy of Personal Information processed until that date. Please note that You will be unable to use all or part of the App if You do not provide consent to the processing of Your Personal Information. We further note that We may continue to use any part of Your Personal Information for which We may have other legal grounds for processing in accordance with the applicable law.
By using the App, You agree to the terms of this Privacy Policy. This Privacy Policy is a legally binding agreement between You and Us.
We may use Your Personal Information based on Your explicit consent for the following purposes: (i) to provide You with the App (including any related apps, services and functionalities thereof); (ii) to improve the quality of the App and user experience; (iii) to fulfil any request You make in relation to the App; (iv) to communicate with You; (v) or as otherwise directed by You.
our legitimate interests (Art. 6 (1) letter (f) GDPR): To the extent necessary, We may also process Your Personal Information to protect legitimate interests of our own and/or of third parties (such as to resolve disputes and/or troubleshoot problems). When We process Your Personal Data to meet Our legitimate interests, We balance our legitimate interests against Your fundamental rights and freedoms and We implement appropriate safeguards to ensure that Your interests, rights and freedoms do not override Our legitimate interests. For more information about this, please contact Us at dataprivacy@typingdna.com.
Recipients of Personal Information
We may disclose Your Personal Information: (a) to third party vendors/suppliers who help Us provide the App; (b) as required by law, such as to comply with a subpoena or otherwise in response to a lawful request by public authorities (including to meet national security or law enforcement requirements), or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; (c) to a parent company, investor, subsidiary, joint venture, or other companies under common control with us (collectively, “Affiliates”), in the event we have such Affiliates now or in the future, in which case We will require our Affiliates to honour this Privacy Policy, or (d) to a company that merges with us, acquires us, or purchases our assets, or a successor in interest in bankruptcy, in which case such company may continue to process Your Personal Information as set forth in this Privacy Policy. We may also disclose Your Personal Information to our partners assisting us in the processing of such data for the purposes of the App (to the extent feasible for the purposes of the App, We may anonymise such data before disclosing it to Our business partners). We will implement appropriate data processing agreements to ensure that such recipients of Your Personal Information process such data in accordance with the relevant data protection laws.
We will share Your Personal Information with third parties only in the ways that are described in this Privacy Policy, only to the extent necessary as per the applicable purpose of the disclosure and in strict compliance with applicable data privacy laws (including by observing the requirement to conclude compliant data processing agreements with any third party processor carrying out their tasks on Our behalf and upon Our instructions). We do not otherwise share or sell Your Personal Information with or to third parties. We may use and disclose Anonymous Information without restriction.
We do not and will not share, disclose, sell, rent, or otherwise provide Your Personal Information to other companies for the marketing of their own products or services.
If You do not want Us to disclose your Personal Information to a third party, please write to Us at dataprivacy@typingdna.com in this sense. We will take all measures which may be feasible to give effect to such request, but may continue to disclose Your Personal Information to a third party acting as an agent/data processor performing tasks on our behalf and under our instructions, only to the extent strictly required for such operations.
Transfer of Personal Information
Third parties to which We may disclose Your Personal Information may be located within the European Union and elsewhere in the world (including the United States). As a result, Your Personal Information may be transferred to countries whose data protection laws may be less stringent than the laws in Your country.
We will ensure that suitable safeguards are in place to protect Your Personal Information and that the transfer of Your Personal Information complies with applicable data protection laws.
Where required by applicable data protection laws, We will ensure that service providers (including other associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant data exporter. You can obtain a copy of any standard contractual clauses in place, which relate to transfers of Your Personal Information by contacting dataprivacy@typingdna.com, although some details may be redacted for confidentiality reasons.
Rights with regard to Personal Information
You have a number of rights under the GDPR in relation to Your Personal Information, as follows:
the right of access pursuant to Art. 15 GDPR: You have the right to obtain from Us confirmation as to whether or not Personal Information concerning You is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Information and the manner in which, and the purposes for which We process Your Personal Information so that You can verify its accuracy and the lawfulness of the processing;
Please note that once We transform Your Personal Information into Anonymous Information, We will no longer be able to provide you with a copy of any such data which was initially provided by You as Personal Information.
TypingDNA SRL has been appointed as TypingDNA Inc’s representative in the European Union. If You are located in the European Union, you may refer any complaints/disputes related to the processing of Your Personal Information hereunder the competent data protection supervisory authority in Romania (see above). We encourage You to resolve any concerns/complaints with respect to the processing of Your Personal Information for the purposes, or in the context, of the App directly with Us first.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), Our interests (e.g. the maintenance of legal privilege) or rights and freedoms of others, as provided by the GDPR.
While We will make good faith efforts to provide You with access to Your Personal Information, We may deny or limited access to such Personal Information where: this would interfere with the execution or enforcement of the law or with private causes of action (including the prevention, investigation or detection of offences or the right to a fair trial); the legitimate rights and interest of others would be violated through such disclosure; this would prejudice the confidentiality necessary in monitoring, inspection or regulatory functions connected with sound management, or in future or ongoing negotiations involving Us. We will of course endeavour to offer You an adequate explanation of the necessity, and reason for, restricting access in the circumstances mentioned above.
If You exercise any of these rights, we will check your entitlement and respond without undue delay, but not later than within a month. In complex cases or at times of receiving numerous requests, this period may be extended by two further months of which we will inform you.
To review or update Your Personal Information including user information to ensure it is accurate, please write to us at dataprivacy@typingdna.com informing Us of any changes that may need to be made in respect of Your Personal Information and We will update such information on Your behalf and in Our systems.
If You no longer want to use the App, please uninstall the App from Your device. If You want Us to delete Your Personal Data from Our systems, please write to Us at dataprivacy@typingdna.com. You will no longer be able to use the App afterwards, unless You download and install it again on Your device (and, in the process, agree to this Privacy Policy). Certain information is necessary in order for Us to provide the App; therefore, if You delete such necessary information You will no longer be able to use the App.
Please remember, however, if We have already disclosed some of this information to third parties, We may not be able to access that information any longer or force the deletion or modification of any such information by the parties to whom We have made those disclosures. We will of course comply with any legal obligation We may have to notify them of Your request.
Please note that even though You may request the deletion of Your Personal Information by Us, We may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to keep this information and not delete it, or to keep this information for a certain time, in which case We will comply with Your account deletion request only after We have fulfilled such requirements. When You request deletion of Your account information, Personal Information will be deleted from the active database, but (limited) Personal Information may remain in Our archives where legally permitted.
Please note that any processing of Your Personal Information prior to the deletion of Your account will remain valid under the legal grounds then prevailing.
You can exercise any of Your rights as stated above, by sending Us a request to dataprivacy@typingdna.com. We will endeavour to respond to any such request as soon as possible, and in any event within the legal deadline.
Information Security
The security of Your Personal Information is important to Us. We use appropriate technical and organizational methods to protect the Personal Information submitted to, or otherwise processed by, Us, both during transmission and once We receive it from loss, misuse or unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
We take great care in implementing and maintaining the security of the App and of Your Personal Information. We have put in place appropriate technical and organizational measures to protect Your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and against all other unlawful forms of processing, in accordance with the law. In addition, We employ industry standard procedures and controls to ensure the safety of Your personal data, such as: secure network typology which includes Firewall systems; encrypted communication, authentication and access control, external and internal audit tests, etc.
Other than Your Google account information (email address, Google username and, if available, profile picture), We do not collect or process any other Personal Information about You for the purposes of providing the App. The App works exclusively on Your device, and there is no transfer of information between Your device and Us. The App does not require interaction between You and Us in order for the App to work.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of Your Personal Information. We do not use vulnerability scanning and/or scanning to PCI standards. We do not use cookies.
Changes to the Privacy Policy
We may update this Privacy Policy to reflect changes to Our practices. If We make any material changes, We may notify You by email (sent to the email address specified in Your account) prior to the change becoming effective. We encourage You to review the latest information on Our privacy practices. Continued use of the App following notice of such changes will indicate Your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Any changes to this Privacy Policy may affect Our use or disclosure of Personal Information collected prior to the changes. If You do not agree to any of the changes, You should notify Us prior to the effective date of the changes that You wish to terminate Your account with Us.
Retention Period
We endeavour to ensure that Personal Information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. We retain the Personal Information collected about You for the purposes of the App only for as long as You continue to use the App and the App is installed on Your devices. This does not prevent us from processing Your Personal Information for longer periods of time, to the extent such processing reasonably serves other purposes, including for statistical analysis.
Once We anonymise Your Personal Data, such data will no longer constitute ‘personal data’ within the meaning of personal data protection laws. We may retain such anonymised data and use it for further analysis and research and development purposes, without restrictions.
Some Personal Information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons. We will generally retain Your Personal Information only so long as it is required for purposes for which it was collected. Where Your Personal Information is no longer required, We will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
Subject to the principles set out in the above paragraph, We will delete Your account data the earlier of (i) Your express request to dataprotection@typingdna.com; or (b) 10 years after your last use of the App.
Representation of TypingDNA Inc. for the purposes of data privacy regulations
For the purposes of Art. 27 GDPR, TypingDNA SRL is hereby appointed as the representative of TypingDNA Inc. in the territory of the European Union and may be addressed, in addition to or instead of, TypingDNA Inc. by, in particular, supervisory authorities and data subjects located in the European Union, on all issues related to personal data processing performed by Us, for the purposes of ensuring compliance with the GDPR.
TypingDNA SRL is a Romanian limited liability company, headquartered in Romania, Oradea, Str. Santului 2E, 1st floor, registered with the Trade Registry under no. J5/1153/2016, unique registration code 36172414.
Questions about this Privacy Policy & Exercising your rights as a Data subject
If You have questions or comments about this Privacy Policy, or wish to exercise any of Your data subject rights under the GDPR, or otherwise make any request as specified further in this Privacy Policy, please contact Us at:
If You are dissatisfied with Our use of your Personal Information or Our response to any exercise of Your rights under the GDPR, You have the right to complain to the data protection authority:
https://www.dataprotection.ro/
In order to ensure timely resolution, We encourage You to reach out to us first with respect to any queries, questions or complaints You may have in relation to Our processing of Your Personal Information. We will endeavour to respond as soon as practicable.
Date: October 2022
