Privacy Policy

Effective as of March 11, 2026.

This Privacy Policy describes how Hashedlab LLC (d/b/a "FocusLM," "we," "us" or "our"), 30 North Gould Street, Sheridan, WY 82801, United States, processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, the FocusLM application, and other activities described in this Privacy Policy (collectively, the "Service")). We may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

FocusLM is an AI product that builds structured, self-configuring memory. You describe a problem you want to work through; an agent interviews you, designs a memory structure for it, and files the material you provide as organized, searchable notes, so you receive grounded, project-specific help over time. The Service includes onboarding interviews, memory design and storage, structured ingestion of the content you provide, and related features.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area.

1. Personal Information We Collect

We may collect personal information from or about you from a variety of sources. Below, we describe the various manners in which we may collect such personal information. We may combine your personal information that we obtain from various sources.

1.1 Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
Account data, such as the username and password that you may set to establish an online account on the Service, and any other information that you add to your account profile, including your website, job title, location, and length of time as a FocusLM user.
Demographic data, such as your city, state, country of residence, and postal code.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Financial data, such as your financial account numbers or payment card information, including corporate payment card information. Payment card information is collected and processed directly by our payment processor (Stripe) and is not stored on our servers.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Project and memory content, such as the problem you describe during onboarding, your messages to the assistant, the materials you upload or add to a project (documents, images, audio you dictate, and other files), the structured memory the Service builds from them, and any other content you generate, transmit, or make available on the Service, together with associated metadata (such as how, when and by whom a piece of content was added, and how it has been organized or edited). This content may include personal or sensitive information you choose to record about yourself or others; you control what you add.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2 Third-party sources

We may obtain personal information about you from other sources, such as:

Single sign-on providers. If you sign in using a third-party service such as Google, we receive basic profile information (such as your name, email address, and profile picture) that the provider makes available based on your settings. Our use and disclosure of information received from Google's APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. You can review Google's privacy policy at www.google.com/policies/privacy.
Public and other sources, such as publicly available sources, where relevant to providing or securing the Service.

1.3 Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, Media Access Control ("MAC") address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data, based on your IP address at a city/country level.
Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) — we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

2. How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

2.1 Service delivery and operations

We may use your personal information to:

Provide, operate and improve the Service and our business.
Attribute user contributions or user-generated content.
Personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service.
Establish and maintain your user account on the Service.
Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.
Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages.
Understand your needs and interests, and personalize your experience with the Service and our communications.
Provide support for the Service, and respond to your requests, questions and feedback.

2.2 AI processing

The Service uses artificial intelligence to run the onboarding interview, design and update your project's memory structure, file the material you provide, generate short captions and (on request) images, and answer your questions grounded in your project's memory. We use third-party large language model (LLM) providers (currently Anthropic and OpenAI) for this processing, under terms that: (a) protect your content in a manner substantially consistent with this Policy; (b) provide that the provider will not use your content to train its models; and (c) acknowledge your ownership of the outputs generated from your prompts.

Your project content is processed by these AI models solely to deliver the Service features you request, and we do not use your content to train general-purpose AI models. Depending on the provider, AI processing may take place outside the European Economic Area, including in the United States, subject to appropriate safeguards (see International Data Transfer).

2.3 Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

We use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.

2.4 Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. We will not attempt to reidentify any such data.

2.5 Marketing and advertising

We and our service providers may use your personal information for marketing purposes:

Direct marketing. We may send you direct marketing communications about FocusLM and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Your Choices section below.

2.6 Compliance and protection

We may use your personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities.
Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims).
Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
Enforce the Terms of Service that govern the Service.
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.7 With your consent

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

2.8 Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Specific retention periods:

Active account data: retained for as long as the account is active.
Personal data after account deletion: deleted within 30 days.
Billing and financial records: retained as required by applicable tax and accounting law.
Application and activity logs: 90 days.
AI processing debug logs: 30 days.
Backup archives: 90 days.

When we no longer require the personal information we have collected about you, we may either delete it or anonymize it. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, generative AI or large language model (LLM) providers, information technology, customer support, email delivery, marketing, analytics, and website analytics). We select third party LLMs used in the provision of the Service that are provided pursuant to policies: (a) protecting Your Content in a manner substantially consistent with the terms of this Policy; (b) that the provider will not use Your Content to train the LLM; and (c) that acknowledge the user's ownership of outputs from the LLM's processing of prompts.
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe. Stripe may use your payment data in accordance with its privacy policy: https://stripe.com/privacy.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments, financing, or the sale, transfer or merger of all or part of our business, assets or shares). We may also disclose your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
People you share with. A project's memory and related content are private to the project. If you invite others to a project or share it with members of your workspace, the content you have added becomes visible to those people according to the access you grant. We are not responsible for how the people you share with use that information.

We do not sell your personal information to third parties.

4. Your Choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies and other tracking technologies. For information about cookies and other tracking technologies employed by the Service and how to control them, see our Cookie Policy.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

5. Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

6. Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

7. International Data Transfer

We are headquartered in the United States. We use hosting and infrastructure providers and third-party LLM providers (Anthropic and OpenAI); depending on the provider, your information may be processed in the United States and other countries.

Your personal information may be transferred to locations outside of your state, province, or country, including to the United States, where privacy laws may not be as protective as those in your jurisdiction. Where we transfer personal information outside the European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission or reliance on the EU-US Data Privacy Framework where applicable.

8. Children

The Service is not intended for use by anyone under 18 years of age. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

9. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

10. How to Contact Us

Hashedlab LLC
30 North Gould Street
Sheridan, WY 82801, United States
Phone: +1 (307) 533-0148

Email: privacy@focuslm.ai

For data protection inquiries, data subject requests, or complaints, please email privacy@focuslm.ai.

11. Notice to European Users

General

The information provided in this section applies to individuals in the European Economic Area, whose personal information Hashedlab LLC processes subject to the General Data Protection Regulation (GDPR).

References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" as defined in the GDPR — i.e., information about individuals from which they are either directly identified or can be identified.

Controller

Hashedlab LLC is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the EU General Data Protection Regulation (GDPR). See the How to Contact Us section above for our contact details.

Data Protection Contact

For questions or concerns regarding data protection, you may contact us at: privacy@focuslm.ai.

Legal Bases for Processing

The GDPR requires us to ensure that we have a "legal basis" for each purpose for which we use your personal information. Our legal bases are listed below.

Purpose	Legal Basis
Service delivery and operations	Contractual Necessity — performance of the contract we have with you
AI processing	Contractual Necessity — necessary to provide the Service features you request
Service improvement and analytics	Legitimate Interest — improving our Service and understanding user activity
Research and development	Legitimate Interest — analyzing and developing new products and services
Marketing (direct)	Consent, where required by applicable law; otherwise Legitimate Interest
Compliance and protection	Compliance with Law; Legitimate Interest in protecting rights, property, and safety

Your Rights Under GDPR

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Portability. Port a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests. You also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising these rights. You may submit requests by email to privacy@focuslm.ai or by postal mail to our address above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part), we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Right to Lodge a Complaint

If you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

European Economic Area: You may lodge a complaint with the data protection authority in your country of residence. A directory of EU/EEA authorities is available via the European Data Protection Board: https://www.edpb.europa.eu/home_en

No Automated Decision-Making

As part of the Service, we do not engage in automated decision-making and/or profiling which produces legal or similarly significant effects.

Security Breach Procedures

We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.

Data Processing Outside the EEA

Your personal information may be stored and processed in the United States and other countries, including by our third-party LLM providers (Anthropic and OpenAI). Where we transfer the personal information of individuals in the EEA outside the EEA, we ensure appropriate safeguards are in place as described in the International Data Transfer section above.

12. Notice to US Residents

In states where residents are allowed additional individual rights under applicable privacy laws (including California, Virginia, Colorado, Connecticut, and other states with comprehensive privacy legislation), we are committed to honoring those rights for such residents, including requests that may limit how we use and share your data, or requests to delete or correct inaccurate data, consistent with applicable law.

Note that applicable law may exempt certain personal information from such requests. To submit a request based on local law, please contact us at privacy@focuslm.ai. We will respond to your request as required by law. If any circumstances cause a material delay in our response, you will be promptly notified.

We do not sell your personal information.

See also our Terms of Service and Cookie Policy.