Privacy policy
1. Data controller
Hoolu is published by FOCUS TESTING LTD, a private limited company registered in England and Wales under number 15429929, whose registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom ("we", "us").
Contact for any privacy question: focus.target.app@gmail.com.
2. Microphone: what Hoolu hears
Hoolu uses the microphone to recognise two sounds: a double clap and a whistle. When listening is on:
- the sound is analysed on your phone only, in short windows of about one second, by sound-recognition models built into the app;
- it is never recorded, stored, sent to us or to anyone else, and never used to recognise speech, voices or people;
- Android shows a permanent notification while Hoolu is listening, and you can stop listening at any time from the app or the notification;
- during the Quiet hours you choose in the settings, Hoolu never rings; to turn the microphone off completely, stop listening.
The microphone permission is used for nothing else. Legal basis: performance of the service you ask for (Article 6(1)(b) UK GDPR / GDPR).
3. Motion guard
When you arm Motion guard, Hoolu reads your phone's motion sensor (accelerometer) to detect that the phone is being moved, and sounds an alert. These readings are processed on your phone only and are never stored or sent.
4. Data stored on your device
Hoolu stores the following on your device only: your settings (sounds, volume, ring duration, flash, vibration, sensitivity, quiet hours, Motion guard options, language, appearance, Ad campaign measurement), whether you completed the introduction, the last known status of your Hoolu Premium subscription (so the app opens without waiting for the store), and the number of times Hoolu helped you find your phone (used only to choose when to suggest rating the app). If you choose Make it my ringtone, the selected sound is copied to your device's ringtones.
This data never leaves your device and is erased when you uninstall the app or clear its data.
5. Measuring our own ad campaigns (Meta)
Hoolu shows no ads. We do advertise Hoolu on Facebook and Instagram, and to know whether these ads work and to show them to people likely to be interested, Hoolu uses the Meta SDK (Meta Platforms Ireland Limited / Meta Platforms, Inc.). It starts when you first open the app; there is no consent form.
- From the app: that Hoolu was installed and opened, and that a free trial was started (plan and currency), together with an anonymous identifier created by the Meta SDK, your device's advertising identifier and technical information about your device (model, system version, app version, language, screen size, time zone).
- From RevenueCat (section 6): when a subscription is paid, for example at the end of the free trial or at renewal (product, price, currency), linked to the same anonymous identifier and advertising identifier.
- Meta uses this data to attribute installs and purchases to our ads, to measure and optimise our campaigns, and, under its own terms, to improve the delivery of ads. It never receives what Hoolu hears, your settings, or your name, email address or phone number.
- Your right to object: turn off Settings › App › Ad campaign measurement (on by default). From then on Hoolu sends nothing more to Meta, stops collecting the advertising identifier for Meta and removes the Meta anonymous identifier from RevenueCat; on the next launches the Meta SDK is not started at all. Turning it back on resumes measurement. You can also reset or delete your advertising ID in your device settings.
- Legal basis: our legitimate interest in measuring the effectiveness of our advertising (Article 6(1)(f) UK GDPR / GDPR). We limited the data to what this measurement needs and you can object at any time, as described above. Retention: as set by Meta (see the Meta Privacy Policy).
6. Hoolu Premium and purchases (RevenueCat)
Hoolu Premium gives full access to the app, after a free trial, as a yearly subscription; without it, the app only shows the subscription screen. It is purchased through Google Play or the App Store. RevenueCat, Inc. manages subscription status with a random anonymous identifier, together with the purchase history sent by the store (product, date, price, trial and renewal status). While Ad campaign measurement is on (section 5), RevenueCat also receives the Meta anonymous identifier, your advertising identifier, your device identifier and IP address, so that it can report paid subscriptions to Meta. We never see your name, email or payment details.
Legal basis: performance of the contract; for reporting to Meta, as in section 5. Retention: as long as needed to provide Premium and meet our accounting obligations. See the RevenueCat privacy policy.
7. Ratings and sharing
When Hoolu suggests rating it, the rating window is shown by Google Play or the App Store, under their own policies; we only see the public reviews. When you share Hoolu, your device's share sheet sends a link to the app to whoever you choose; we receive nothing.
8. Device permissions
| Permission | Why |
|---|---|
| Microphone | Recognise a double clap or a whistle, on the device only (section 2). |
| Notifications, full-screen alerts | Show that Hoolu is listening or guarding, and show the alert over the lock screen when your phone rings. |
| Run in the background, ignore battery optimisation, keep awake | Keep listening while your screen is off, so your phone can ring when you look for it. |
| Run at startup | If Hoolu was listening when your phone restarted, show a notification offering to turn it back on (Android does not let apps restart the microphone on their own). |
| Vibration, flashlight | Vibrate and flash when your phone rings. The flashlight is used as a light only: no image is captured. |
| Modify system settings | Only if you choose Make it my ringtone, to set a Hoolu sound as your ringtone. |
| Internet | Purchases and subscription status (section 6), ad campaign measurement (section 5). |
| Advertising ID | Read by the Meta SDK to measure our ad campaigns, only while Ad campaign measurement is on (section 5). Hoolu shows no ads. |
You can withdraw any permission in your device settings; only the related feature will stop working.
9. Summary table
| Data | Where | Shared with | Retention |
|---|---|---|---|
| Sound picked up by the microphone, motion sensor readings | Your device, in memory, for about one second | Nobody | Never stored |
| Settings, find counter | Your device | Nobody | Until uninstall |
| Install, app opened, free trial started, paid subscriptions; Meta anonymous ID, advertising ID, device information | Meta | Meta (unless you turn off Ad campaign measurement) | Per Meta's policy |
| Purchase status and history, anonymous ID, device identifiers | RevenueCat | RevenueCat, Google Play / App Store, Meta (paid subscriptions, unless you turn off Ad campaign measurement) | While needed, plus legal obligations |
10. International transfers
Meta, RevenueCat, Google (Google Play) and Apple (App Store) may process data outside the UK and the European Economic Area, in particular in the United States. These transfers rely on the EU-US Data Privacy Framework and its UK extension, or on standard contractual clauses (and the UK addendum).
11. Your rights
Under the UK GDPR and the EU GDPR, you have the right to access, rectify and erase your data, to restrict or object to its processing, and to data portability. You can object at any time to the measurement of our ad campaigns, which relies on our legitimate interest.
Hoolu has no account and we do not know who you are. The simplest ways to exercise these rights are in the app and on your device: Settings › App › Ad campaign measurement to object to ad campaign measurement, your device settings to reset or delete your advertising ID, and uninstalling the app to erase the data on your device. For anything else, write to focus.target.app@gmail.com; we answer within one month.
You can complain to the UK Information Commissioner's Office (ico.org.uk) or to the data protection authority of the EU country where you live.
12. Children
Hoolu is meant for a general audience and is not directed at children under 13. We do not knowingly collect personal data from children. If you believe a child has used Hoolu in a way that sent data to the partners named above, write to us and we will help you delete it.
13. Additional information for Brazil and Mexico
This section adds to the rest of this policy if you live in Brazil or in Mexico. The data controller and its contact details are given in section 1; the data, the purposes and the recipients are described in sections 2 to 7.
Brazil
- Legal bases. Under the Lei Geral de Proteção de Dados (LGPD, Law No. 13,709/2018), we rely on: the performance of the service you request, for recognising claps and whistles, Motion guard and purchases (Article 7, V); and our legitimate interest, for measuring our ad campaigns (Article 7, IX). Hoolu shows no ads. You can object to ad campaign measurement at any time in Settings › App › Ad campaign measurement, or limit it by resetting or deleting the advertising identifier in your device settings.
- Your rights. Article 18 of the LGPD gives you the right to obtain confirmation that we process your data, to access it, to have it corrected, to have unnecessary or excessive data anonymised, blocked or deleted, to data portability, to information about whom we share data with, and to object to processing based on our legitimate interest. Write to focus.target.app@gmail.com, which is also the contact of our data protection officer (encarregado); we reply within 15 days. You can also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD, gov.br/anpd).
- International transfers. The providers named in sections 5 and 6 may process data in the United States. These transfers are necessary to provide the service you request, or rely on the contractual safeguards offered by these providers (Article 33 of the LGPD).
Mexico
- Privacy notice. For the purposes of the Ley Federal de Protección de Datos Personales en Posesión de los Particulares, this policy is our comprehensive privacy notice (aviso de privacidad integral) and the controller (responsable) is the company named in section 1, at the address given there. We process no sensitive personal data: sound and motion readings never leave your device.
- Purposes. Primary purposes, necessary for the service: recognising claps and whistles, Motion guard and managing purchases. Secondary purpose, which is not necessary: measuring our own ad campaigns (Hoolu shows no ads). You can refuse it at any time, without losing access to the app, by turning off Settings › App › Ad campaign measurement, or limit it by resetting or deleting the advertising identifier in your device settings.
- ARCO rights. You can exercise your rights of access, rectification, cancellation and opposition (ARCO), object to ad campaign measurement, or limit the use or disclosure of your data by writing to focus.target.app@gmail.com. We reply within 20 business days and, where the request is justified, act on it within the following 15 business days.
14. Security
Hoolu is designed so that the most sensitive data, what your microphone and sensors pick up, never leaves your phone. The rest is limited to what ad campaign measurement and purchases require, and is handled by the providers named above.
15. Changes
We may update this policy when the app changes. Any material change will be shown in the app, and the date at the top of this page shows the latest version.