LAST UPDATED: DECEMBER 12, 2025

FOCUS TIGER SERVICES

1 GENERAL

This Focus Tiger privacy policy (“Privacy Policy”) describes how SILTA Education Oy (“we”, “us”, “our” or the “Controller”) processes data subjects’ (“you”, “your” or the “data subject”) personal data in connection with the following services (together referred to as the “Focus Tiger Services” and, individually, as a “Focus Tiger Service”):

1. Focus Tiger Online Training Program – Our web-based training platform for end-users of our enterprise customers (e.g., employees of our enterprise customer). It is also possible to use a demo version of the Focus Tiger Online Training Program for a short period of time to test it before subscribing;

2. Focus Tiger App for Slack – A productivity coaching app available within the Slack workspace;

3. Focus Tiger Microsoft Teams App – A productivity coaching app available within the Microsoft Teams workspace; and

4. Focus Tiger Dashboard – Our web-based platform for representatives of our enterprise customers. The Focus Tiger Dashboard provides an overview of the end-users’ use of Focus Tiger Services. The statics visible to the representative of our enterprise customer are always aggregated. Therefore, individual end-users cannot be identified based on the statistics available on the Dashboard.

This Privacy Policy describes what personal data is collected and for what purposes the personal data is processed when you use one or more of the Focus Tiger Services listed above. This Privacy Policy also describes to whom the personal data is disclosed or transferred, and how you, as a data subject, can exercise your rights in relation to processing of your personal data. In addition, the Privacy Policy defines the obligations that are complied with regarding processing of personal data.

This Privacy Policy is applicable to the Focus Tiger Services defined above. The Controller processes personal data according to the applicable data protection legislation. Data protection legislation shall mean the General Data Protection Regulation (EU 2016/679) (“GDPR”) and applicable national data protection laws, such as the Finnish Data Protection Act (1050/2018, as amended). Terms which are not defined in this Privacy Policy shall have the same meaning as in the relevant applicable data protection legislation.

2. CONTROLLER’S CONTACT INFORMATION

SILTA Education Oy (Business ID: 3241267-5).
Office address: Haartmaninkatu 4, Building 14, FI-00290 Helsinki, Finland
Postal address: Kadetintie 3 B 21, FI-00330, Helsinki, Finland
Email address: pertti@focustiger.io

3 DATA SUBJECTS

3.1 Focus Tiger Online Training Program
The data subjects are participants of the Focus Tiger Online Training Program. Additionally, a data subject may also be a user of the demo version of the Focus Tiger Online Training Program.

3.2 Focus Tiger App for Slack
The data subjects are the users of the Focus Tiger App for Slack (i.e., the end-users who have the Focus Tiger App for Slack installed in their Slack workspace).

3.3 Focus Tiger Microsoft Teams App
The data subjects are the users of the Focus Tiger Microsoft Teams App (i.e., the end-users who have the Focus Tiger Microsoft Teams App installed in their Microsoft Teams workspace).

3.4 Focus Tiger Dashboard
The data subjects are the representatives of our enterprise customers for whom a Focus Tiger Dashboard account has been created, as well as the end-users (e.g., employees) of such enterprise customers who use one or more of the Focus Tiger Services.

4 PROCESSED PERSONAL DATA

4.1 Focus Tiger Online Training Program
The following personal data is processed in connection with Focus Tiger Online Training Program:

  • name
  • email
  • user and login information: e.g., username and password or single sign-on credentials, screen name and user language;
  • Information on the use of the Focus Tiger Online Training Program;
  • Other information concerning the user and the user account which are formed on the basis of the information that the user (i.e., data subject) has provided when using the services;
  • Consent given for marketing and contacting and the subject matter of the consent;
  • Other information received from the data subject or on the basis of his/her consent or authorization that is necessary for the execution of the service he/she has requested;
  • “Dig Deeper” -answers;
    • You as the data subject, have the option to participate to the exercises, where you can ask for feedback on your answers. Your answers will be anonymized after completing the exercise and receiving feedback, after which the answers you have given cannot be identifiable to you in any way;
  • Focus Tiger AI neuroscientist -chatbot discussions;
    • You can have discussions with the chatbot for support and guidance related to the Focus Tiger Online Training Program. The chatbot discussions will not be stored after an individual session or used for any other purposes than providing the service. However, you can choose to save the discussions in your own files;
  • Customer feedback and communication between the Controller and the data subject; and
  • Data generated in the context of using the Focus Tiger Online Training Program:
    • browsing data;
    • the web page, from which the application and/or services was accessed, the individual device and/or cookie identification and other relevant browsing and IP address data.

4.2 Focus Tiger App for Slack

The personal data we process in connection with the Focus Tiger App for Slack can be divided into (i) personal data generated by the Focus Tiger Services and (ii) personal data collected from Slack through Slack API permissions.
Personal data generated by Focus Tiger Services includes:

  • Functional data: Information collected for the operation of the Focus Tiger App for Slack, including:
    • Daily goals you set
    • Goal completion status and timestamps
    • Your productivity streak count
    • Scheduled reminder preferences and time zone
  • Interaction and usage data: Data related to how the user interacts with the Focus Tiger App for Slack, including onboarding events (e.g., button clicks and responses) collected for analytics purposes
  • Installation and authentication data: Information necessary for secure app installation and authentication, such as OAuth tokens

When you use the Focus Tiger App for Slack, we also collect and process personal data through specific Slack API permissions. We use Slack’s Granular Permissions and apply the principle of least privilege, requesting only the personal data that is strictly necessary for the stated purposes of processing.

Personal data collected via Slack API permissions includes:

  • Slack profile information (such as display name, time zone, and user ID)
  • The content and metadata of direct messages you send to Focus Tiger bot and the direct messages sent to you by Focus Tiger bot

For clarity, we do not access or process your Slack direct messages or channel conversations except for the messages exchanged directly between you and Focus Tiger bot.

4.3 Focus Tiger Microsoft Teams App

The personal data we process in connection with the Focus Tiger Microsoft Teams App can be divided into (i) personal data generated by the Focus Tiger Services and (ii) personal data collected from Microsoft Teams through Microsoft Teams API permissions.

Personal data generated by Focus Tiger Services includes:

  • Functional Data: Information collected for the operation of Focus Tiger Microsoft Teams App, including:
    • Daily goals you set
    • Goal completion status and timestamps
    • Your productivity streak count
    • Scheduled reminder preferences and time zone
  • Interaction and usage data: Data related to how the user interacts with the Focus Tiger Microsoft Teams App, including onboarding events (e.g., button clicks and responses) collected for analytics purposes
  • Installation and Authentication Data: Information necessary for secure app installation and authentication, such as OAuth tokens

When you use the Focus Tiger Microsoft Teams App, we also collect and process personal data through specific Microsoft Teams API permissions. We request only the personal data that is strictly necessary for the stated purposes of processing.
Personal data collected via Microsoft Teams API permissions includes:

  • Microsoft Teams profile information (such as display name, email address, user ID, and tenant ID)
  • The content and metadata of direct messages you send to the Focus Tiger bot and the direct messages sent to you by the Focus Tiger bot

For clarity, we do not access or process your Microsoft Teams direct messages or channel conversations, except for the messages exchanged directly between you and Focus Tiger bot.

4.4 Focus Tiger Dashboard

We process the following personal data in connection with Focus Tiger Dashboard:

  • Company representative contact and login information, including name, email, phone number, and login credentials or other identifiers used to access the service (e.g., username/password or single sign-on credentials)
  • Interaction and usage data of company representatives and end-users, including data on how the Focus Tiger Services are used for the purpose of generating statistics
  • Cookies, IP-addresses, location (country and city), browser, referral-address

5 PURPOSE AND LEGAL BASIS OF PROCESSING

The processing of personal data in connection with Focus Tiger Services does not involve any automated decision-making. Where the processing is based on legitimate interest, you are entitled to request further information regarding the applicable legitimate interest by contacting us using the contact details set out in Section 2 of this Privacy Policy. Further information on the purposes and legal bases of the processing for each Focus Tiger Service is described below.

5.1 Focus Tiger Online Training Program

In connection with Focus Tiger Online Training Program, we process personal data for the following purposes:

  • providing and developing the Focus Tiger Online Training Program (including data analysis)
  • feedback, support and assistance during the Focus Tiger Online Training Program
  • IT support during the Focus Tiger Online Training Program
  • marketing and contacting purposes (for those who have given their consent for marketing or contacting purposes)

The processing of personal data in connection with the Focus Tiger Online Training Program is generally carried out on the basis of our legitimate interests, namely: to provide the services pursuant to the agreement concluded with our enterprise customer, to manage and maintain the quality and security of our services, and to develop and improve our services in accordance with applicable legislation.

In certain situations, processing may also be based on your consent, but only to the extent that you have provided consent explicitly covering the relevant processing.

5.2 Focus Tiger App for Slack

In connection with Focus Tiger App for Slack, we process personal data for the following purposes:

  • to provide the Focus Tiger App for Slack service and operate its functionalities, including:
    • Helping you set, track, and complete daily goals, and sending scheduled reminders
    • Personalizing, sending, and delivering messages, greetings, and reminders
    • Providing encouragement, tracking your consistency, and supporting habit-building
  • To develop the Focus Tiger App for Slack, including understanding how it is used and improving its functionality. For analytics in the Focus Tiger Dashboard, the data will be aggregated.
  • To manage and maintain the quality of the Focus Tiger App for Slack, including maintaining service quality, troubleshooting issues, and ensuring security.

The processing of personal data in connection with the Focus Tiger App for Slack is generally carried out on the basis of our legitimate interests, namely: to provide the services pursuant to the agreement concluded with our enterprise customer, to manage and maintain the quality and security of our services, and to develop and improve our services in accordance with applicable legislation.

In certain situations, processing may also be based on your consent, but only to the extent that you have provided consent explicitly covering the relevant processing.

5.3 Focus Tiger Microsoft Teams App

In connection with Focus Tiger Microsoft Teams App, we process personal data for the following purposes:

  • To provide the Focus Tiger Microsoft Teams App service and operate its functionalities, including:
    • Helping you set, track, and complete daily goals, and sending scheduled reminders
    • Personalizing, sending, and delivering messages, greetings, and reminders
    • Providing encouragement, tracking your consistency, and supporting habit-building
  • To develop the Focus Tiger Microsoft Teams App, including understanding how it is used and improving its functionality. For analytics in the Focus Tiger Dashboard, the data will be aggregated.
  • To manage and maintain the quality of the Focus Tiger Microsoft Teams App, including maintaining service quality, troubleshooting issues, and ensuring security.

The processing of personal data in connection with the Focus Tiger Microsoft Teams App is generally carried out on the basis of our legitimate interests, namely: to provide the services pursuant to the agreement concluded with our enterprise customer, to manage and maintain the quality and security of our services, and to develop and improve our services in accordance with applicable legislation.

In certain situations, processing may also be based on your consent, but only to the extent that you have provided consent explicitly covering the relevant processing.

5.4 Focus Tiger Dashboard

In connection with the Focus Tiger Platform, we process personal data for the following purposes:

  • Providing and developing the Focus Tiger Dashboard, including operating and improving its functionalities and generating statistics.
  • To manage and maintain the quality of the Focus Tiger Dashboard, including maintaining service quality, troubleshooting issues, and ensuring security.

The processing of personal data in connection with the Focus Tiger Dashboard is generally carried out on the basis of our legitimate interests, namely: to provide the services pursuant to the agreement concluded with our enterprise customer, to manage and maintain the quality and security of our services, and to develop and improve our services in accordance with applicable legislation.

In certain situations, processing may also be based on your consent, but only to the extent that you have provided consent explicitly covering the relevant processing.

6 COLLECTING PERSONAL DATA

The data collected in Focus Tiger Services is mainly received from the data subject him/herself. Such data comprises information given by the data subject in connection with the use of and/or registration for the Focus Tiger Services, in connection with the installation of Focus Tiger App for Slack and/or Focus Tiger Microsoft Teams App and/or in connection with other forms of contact with the Controller. The Controller also collects data by technical means when the data subject uses the Focus Tiger Services.

The Controller may also receive data collected from a third-party customer procuring the Focus Tiger Services (e.g., employer of the data subject), as well as from third-party service providers in connection with the Focus Tiger App for Slack and the Focus Tiger Microsoft Teams App, as detailed in Sections 4.2 and 4.3 of this Privacy Policy.

In addition, personal data is collected through cookies in compliance with relevant applicable legislation.

7 COOKIES

The Controller uses cookies to enable the technical execution of the Focus Tiger Services and to monitor use of them. Cookies are small text files, which the internet browser saves on the user’s or visitor’s device. A detailed description of the Controller’s cookie policy can be found on the Controller’s website.

Certain cookies may be necessary for the proper operation of the Focus Tiger Services. The user or the visitor may opt-out of the use of cookies by referring to the browser settings in accordance with the instruction of the browser provider. Some functionalities of the Focus Tiger Services may not function properly if the user chooses to decline or opt-out of the use of cookies. The decline or opt-out of the use of cookies may also otherwise adversely affect the Focus Tiger Services user experience.

Use of cookies is further defined in a separate cookie policy, which can be found on the Controller’s website.

8 DATA PROCESSORS AND OTHER RECIPIENTS

As a rule, the personal data collected in the Focus Tiger Services is not transferred to third parties. However, data may be transferred in the following situations:

Information collected in the Focus Tiger Services may be disclosed to third parties on the basis of legal requests by competent authorities, or in accordance with other legal requirements or the data subject´s consent.

The Controller may use processors and sub-processors for the processing of the personal data in the Focus Tiger Services for the purposes set out in Section 5. In such cases the Controller shall use contractual clauses to ensure compliance with data protection legislation.

9 TRANSFERS OUTSIDE OF THE EU OR EEA

The Controller does not transfer personal data outside of the European Union (EU) or the European Economic Area (EEA). Should a transfer of personal data outside the EU or the EEA become necessary in the future, we shall ensure that the conditions for such transfers set out in the GDPR are complied with. Personal data shall be transferred only to third countries in respect of which the European Commission has determined that an adequate level of data protection exists (for example, pursuant to the EU–U.S. Data Privacy Framework or another applicable adequacy decision), or where the transfer outside the EU or EEA is subject to the European Commission’s Standard Contractual Clauses and, where required, appropriate supplementary technical and organizational safeguards have been implemented.

Where an international transfer of personal data is based on the European Commission’s Standard Contractual Clauses, you, as a data subject, shall have the right to obtain a copy of the applicable clauses by contacting us at the address indicated in Section 2 of this Privacy Policy.

10 RETENTION

Personal data is retained for as long as necessary for the Controller to utilize the personal data for the purposes defined in Section 5.
Retention period of Focus Tiger Online Training Program data:

Your personal data shall be deleted within six (6) months after the end of the Focus Tiger Online Training Program or the test period of its demo version.

Retention period of Focus Tiger App for Slack data:

When you or your workspace administrator uninstalls the Focus Tiger App for Slack, your personal data will be deleted within 14 days. Alternatively, if you do not use the Focus Tiger App for Slack for 12 consecutive months, you will be notified that your account will be deleted due to inactivity unless you interact with the Focus Tiger App for Slack during 30 days of such notification. If no interaction occurs, your personal data will be deleted within 14 days.

Retention period of Focus Tiger Microsoft Teams App data:

Your personal data shall be deleted during 14 days after the uninstallation, deactivation, or removal of the Focus Tiger Microsoft Teams App.

Retention period of Focus Tiger Dashboard data:

Your personal data shall be retained up to six (6) months following the termination of the agreement with the respective enterprise customer.

The Controller shall, however, keep the personal data beyond the above-mentioned term, if applicable legislation requires the Controller to store the personal data for a longer period or if the data subject has consented to e.g., storing and using of their contact information for marketing or contacting purposes.

11 DATA SECURITY

The Focus Tiger Services’ data security and confidentiality, integrity and availability are ensured with appropriate technical and organisational measures.

Only our personnel or third parties authorised by us, whose tasks require processing personal data, shall have the right to access said personal data. The stored personal data is protected with personal user IDs and passwords. Personnel and partners shall be required to commit to necessary protection and confidentiality obligations regarding any personal data.

12 DATA SUBJECT RIGHTS

Data subjects have the rights defined in the applicable data protection legislation. Notice that use of said rights is always evaluated in regard to each case separately.

Data subjects must send their requests concerning their rights to the following email: pertti@focustiger.io

The Controller does not charge any fees for data subject requests. However, if the data subject’s requests are apparently unfounded or unreasonable, such as for example if they are presented repeatedly, the Controller may charge the data subject a reasonable fee based on the administrative costs of processing such request.

12.1 Right to access and rectification

Data subjects have the right to access the personal data relating to him/her. The data subjects also have the right to correct or complete incorrect, imprecise, incomplete, outdated, or unnecessary personal data.

12.2 Right to deletion

Data subjects may ask to delete their personal data from the systems e.g. if the personal data is no longer necessary for the purposes for which it was collected.

12.3 Right to withdraw consent

In case the processing of personal data is based on the data subject’s consent, the data subjects have the right to withdraw their consent to such processing at any time.

12.4 Right to restriction of processing

The data subjects may in certain situations have the right to request that the Controller restrict the processing of their personal data.

12.5 Right to object

The data subjects may object to certain processing of personal data including for example processing of personal data for other purposes than purposes necessary for the performance of a contract or for compliance with a legal obligation. The data subject may also object to further processing of personal data after the data subject has given consent to processing. With regards to direct marketing, the data subject can unsubscribe from any direct marketing messages to prohibit the Controller from using the data subject’s personal data for such purposes.

12.6 Right to data portability

The data subject has the right to request that the Controller provides the personal data regarding the data subject in question in a structured and commonly used electronic form. The data subject may also request that the personal data is transferred to another controller if this is technically feasible.

12.7 Lodging a complaint

If you, as the data subject, consider the processing of personal data does not comply with applicable data protection legislation, you may lodge a complaint with the local national supervisory authority (in Finland, the Office of the Data Protection Ombudsman).

13 CHANGES TO THIS PRIVACY POLICY

We develop our services continuously and need to update this Privacy Policy accordingly from time to time. Changes to this Privacy Policy may also be needed due to changes in the legislation. The latest version of this Privacy Policy can be found on our website.