Legal & Compliance
AEI Digital Solutions is an independent software studio operated by Adrian Eugen Ionescu. We develop and distribute applications, including Heads Down.
Data controller: AEI Digital Solutions
Contact: [email protected]
None. Heads Down has no user accounts, no sign-in, no analytics SDKs, no advertising SDKs, and makes no network requests with your data. The information below exists only inside the app on your device:
| Data | Where it's stored | Purpose |
|---|---|---|
| Focus statistics (minutes, blocks, streaks, program progress) | Your phone only | Your in-app progress and rewards |
| App settings (coach voice, sensitivity, program level) | Your phone only | Remembering your preferences |
We never collect: your name, email address, IP address, device identifier, location, contacts, usage analytics, or any personal data whatsoever.
Heads Down uses your phone's motion sensor (accelerometer) to detect whether the phone is lying face down during a focus session. Readings are processed live, on the device, and are never stored or transmitted. The sensor is only read while a session is running and the app is open.
All app data is stored in the app's private storage area on your phone. Deleting the app deletes this data. No copy is held by AEI Digital Solutions.
If you use your phone's own backup service (Apple iCloud Backup or Google Backup), your device may include Heads Down's local data in those backups. Those backups are governed by your agreement with Apple or Google, under your own account — we have no access to them.
Because Heads Down transmits no personal data, no remote processing takes place. The only processing is local storage of your statistics and preferences on your own device, which is necessary to provide the core functionality (legitimate interest, Art. 6(1)(f) GDPR).
You remain in full control of your data at all times: it is on your device. You can erase everything by deleting the app. If you have any privacy question or request (access, rectification, erasure, restriction, portability, objection), contact us at [email protected] — we will respond within 30 days.
Heads Down uses no third-party services. No data is shared with anyone.
Heads Down is not directed at children under the age of 13 and collects no personal data from anyone, including children.
We may update this policy from time to time — for example, if a future version adds an optional online feature. The current version is always available at this URL, and the "Last updated" date above will change accordingly. Any future feature that transmits data will be strictly opt-in and described here first.
AEI Digital Solutions
[email protected]
If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. In Romania, this is the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP).