Orion GLE Ltd (“we”, “us”, “our”) provides VOW Focus. This Privacy Policy explains how we collect,
use, and protect personal data when you use our app and services.
1. Who We Are
Orion GLE Ltd is the data controller for VOW Focus.
2. Data We Process
We may process:
- App usage and profile data (session durations, points, levels, streak/progress, settings)
- Purchase and entitlement information from Apple for in-app purchases
- Support communications you send to us
- Technical / service data required for reliability and security
3. Why We Process Data
We process data to:
- Provide core app functionality and save your progress
- Process purchases and restore purchases
- Maintain service security and prevent misuse
- Respond to support and legal rights requests
4. Legal Bases (UK GDPR)
Depending on context, we rely on:
- Contract performance
- Legitimate interests
- Legal obligations
- Consent (where required, for example direct marketing)
5. Sharing
We do not sell personal data.
We may share limited data with service providers / processors needed to operate VOW Focus
(for example Apple for in-app purchases).
6. International Transfers
If data is processed outside the UK, we use lawful transfer mechanisms and safeguards where required.
7. Retention
Typical retention periods:
- App progress / settings: while account or app use is active; removed on valid deletion request (unless legally required otherwise)
- Purchase / accounting records: up to 6 years
- Support records: up to 24 months from last interaction
- Security logs: typically 30 to 90 days (longer if incident-related)
8. Your Rights
You may have rights to:
- Access your data
- Correct inaccurate data
- Request deletion
- Restrict processing
- Object to processing
- Request portability
To make a request, email support@oriongle.co.uk.
Subject line suggestion: “GDPR Request”
9. Marketing
Where direct marketing is used, we provide opt-in / opt-out controls and unsubscribe options.
10. Data Breaches
We maintain incident response procedures and notify regulators or users where legally required.
11. Complaints
Please contact us first at support@oriongle.co.uk.
You also have the right to complain to the UK Information Commissioner’s Office (ICO).
12. Changes to This Policy
We may update this policy from time to time. The latest version will be published on this page and in-app.