Legal · Version 1.0 · Last updated October 26, 2026

Privacy Policy

This policy explains how Dras Labs LLC (“Dras Labs,” “we,” “us”) handles information through the Focal Keys keyboard, the Focal Keys companion app and focalkeys.com (together, the “Services”). It's written to be read, not skimmed past.

The short version

1. Who we are

Focal Keys is a product of Dras Labs LLC, a New Jersey limited liability company. Dras Labs is responsible for the information described in this policy. You can reach us at [email protected].

2. What we process and why

InformationWhenWhy, and what happens to it
A message you copied, or a draft you typedOnly when you tap Reply for me or Polish mineSent over an encrypted connection to our server and our AI provider to create one suggestion. Links in copied messages are removed before anything is sent. We don't store it, write it to our logs or use it for training. See section 5 for how our AI provider handles it.
A hint you typeWhen you add one and tap Reply for me or Polish mine, or when you tap Write an openerSent with your request to guide the suggestion. For Write an opener, the hint is what the opener is based on. Handled exactly like your message.
Other context sent with a requestWith each requestSome requests may also include recent suggestions, so Try again gives you something new, and earlier messages you copied, for context. Handled exactly like your message: used for that one suggestion and never kept by us.
Your settings: tone and the Flirty optionWhen you choose themKept on your device and sent with each request so the suggestion matches your style.
Anonymous device code and daily usage countWith each requestA random code created by the app (one-way scrambled before it's stored), plus how many suggestions it requested that day. Used to apply daily limits and prevent abuse. Deleted automatically within 30 days. It isn't linked to your name, email or Apple Account.
Consent recordWhen you agree in the app, or withdraw your agreementThat you agreed, the versions of the Privacy Policy and Terms you agreed to, and the time, linked to the scrambled device code. If you withdraw consent in the app's Privacy & AI settings, we record the withdrawal too. Used to show we asked before sending anything to AI.
Technical data: your device's IP address and technical details such as the time of a request and whether it workedAutomatically, with each request and website visitNeeded to deliver requests, fix problems and keep the service secure. Our server's logs keep this for up to 30 days. They never contain message, draft or hint text.
Wake-up requestWhen the keyboard opens, only after you've agreed in the appA small request that gets our server ready so replies come faster. It contains no message text and no device code. Like any request, our server logs your device's IP address with it, for up to 30 days.
Your email addressWhen you join the waitlist or email usUsed only to send beta invites and Focal Keys news, or to answer you. Every news email has an unsubscribe link.
Anything you send to supportWhen you email usUsed to help you. Please don't include your matches' messages or screenshots of their profiles.
Beta dataIf you test through Apple's TestFlightApple shares crash reports, basic usage and any feedback or screenshots you choose to send, under Apple's own privacy policy.
Purchase statusOnly if we offer paid plans and you subscribePayments are handled by Apple. We receive whether your subscription is active, never your payment details.

We use this information only for the purposes listed above: providing and securing the Services, applying fair-use limits, answering you, and keeping records the law requires. If we ever want to use it for something new, we'll update this policy first and, where the law requires, ask for your consent.

3. What we don't collect

4. How the keyboard works

Custom keyboards on iPhone need a setting that iOS calls Allow Full Access before they can connect to the internet. Focal Keys uses it to reach our server: to send the text you choose when you tap Reply for me, Polish mine or Write an opener, and, once you've agreed in the app, to send a small wake-up request when the keyboard opens so replies come faster. The wake-up request contains no message text and no device code. iOS may also ask whether Focal Keys can paste; that lets the keyboard pick up the message you just copied so it can show “Replying to.” None of your text is sent until you tap.

The keyboard works for normal typing without Full Access. You can turn Full Access off anytime in Settings › General › Keyboard › Keyboards › Focal Keys.

5. How AI is used

Your permission comes first. Before the first suggestion, the app asks for your permission to send text to our AI provider and names that provider. Without your permission, Focal Keys makes no AI requests. You can withdraw permission anytime in the app's Privacy & AI settings.

Who our AI provider is. Suggestions are currently created by Google's Gemini models, through Google Cloud's Vertex AI service. Under Google Cloud's terms, Google doesn't use your messages to train its models. We've turned off Google's caching of prompts. Google may log requests for a limited time only to detect abuse, and then deletes them. Requests reach Google from our server, so Google receives only what's described in section 2, not your IP address or device code.

Changing providers. We may move to, or add, other AI providers in the future, such as OpenAI or Anthropic. We'll only use a provider whose business terms forbid training on your content. Before your messages go to a new provider, we'll update this policy and the in-app permission screen and, where needed, ask for your permission again.

Tools we use to build Focal Keys. Like many developers, we use AI tools, including Claude by Anthropic, ChatGPT by OpenAI and Google's Gemini, to help us write code, copy and designs. These tools never receive your messages or any personal information from the Services.

Suggestions are AI-generated. They can be wrong or a poor fit. Always read a suggestion before you send it; you decide what's sent. We don't use your messages to build a profile of you or to make decisions about you.

6. Other people's messages and sensitive information

The message you send is usually written by someone else, your match. We process it only to create your suggestion and keep none of it afterward. Please only send messages you're comfortable having processed this way.

Dating conversations can reveal sensitive information, such as someone's sexual orientation, sex life, health or religion. We don't look for, infer or keep this information. If a message contains it, it's processed only to create your suggestion, with the permission you gave in the app, and we never keep it.

7. Who we share information with

We share information only with service providers that help us run Focal Keys, and only what each one needs:

These providers may use the information only to provide their services to us. We may also disclose information if the law requires it, to protect someone's safety, to investigate abuse of the Services, or as part of a merger or sale of our business, in which case this policy's promises would continue to apply.

We don't sell personal information, we don't “share” it for cross-context behavioral advertising (as California law uses that term), we don't use it for targeted advertising, and we don't give it to data brokers. We don't use it for profiling that has legal or similarly significant effects.

8. How long we keep information

9. Your choices and rights

Choices everyone has

Privacy rights

Depending on where you live, including California, New Jersey, Virginia, Colorado, Connecticut, Texas and other states with privacy laws, you may have the right to:

We give these choices to everyone, wherever you live. To make a request, email [email protected] with the subject “Privacy request.” Because there are no accounts, we may ask for something that lets us find your information, such as the email you signed up with. Usage counts and consent records aren't linked to your name or email, so we usually can't match them to you; usage counts are deleted automatically within 30 days. We'll reply within 30 days. If you use an authorized agent, we may ask for proof that they act for you.

If we turn down your request, you can appeal by replying with the subject “Privacy appeal.” We'll answer within 45 days and explain our decision. If you're still not satisfied, you can contact your state attorney general.

California residents: we don't disclose personal information to third parties for their own direct marketing.

10. Cookies, tracking and Do Not Track

focalkeys.com doesn't use analytics, advertising or tracking cookies, and the app doesn't track you across other companies' apps or websites. Cloudflare may set a strictly necessary security cookie to protect the site from attacks. Because we don't track you, “Do Not Track” and Global Privacy Control signals don't change how we handle your information; we'd honor them anyway. If we ever add analytics or ads, we'll update this policy first and ask for consent where the law requires.

11. Age

Focal Keys is only for people 18 and older, and the Services aren't directed at children. We don't knowingly collect personal information from anyone under 18. If you believe someone under 18 has given us information, email us and we'll delete it.

12. Security

We encrypt data in transit, limit who can access our systems, keep what we hold to the minimum and never write message content to logs. No system is perfectly secure, but holding as little as possible is our strongest protection. If a security incident affects your personal information, we'll notify you and the authorities as the law requires.

13. Where information is processed

Focal Keys is run from the United States, and information is processed in the US. Some of our providers, such as Google and Cloudflare, may process it briefly in other countries where they operate, under their own security commitments. If you use the Services from outside the US, you understand your information will be processed in the US, where privacy laws may differ from those where you live.

14. Changes to this policy

We'll post any change here and update the version and date above. If a change is meaningful, for example a new AI provider or a new kind of information, we'll tell you in the app before it applies and ask for your permission again where needed. Earlier versions are available on request.

15. Contact us

Dras Labs LLC
Email: [email protected]