LAST UPDATED: JANUARY 31st, 2025

Effective Date: January 31st, 2025

1. Introduction

Welcome to Focus on Clients (“we,” “us,” “our”). This Privacy Policy explains how FOCUS ON DIGITAL DESIGN LIMITED (registered in England & Wales) collects, uses, stores, discloses, and protects your personal information when you interact with us, including through our website www.focusonclients.com (“Website”), services, and SMS/text messaging programs.

We process personal data in compliance with applicable privacy laws, including the UK General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications Regulations (PECR) in the UK, and the Telephone Consumer Protection Act (TCPA) and related industry guidelines in the United States.

By using our Website or services, or providing your information to us, you agree to the terms of this Privacy Policy.

2. Who We Are

Controller: FOCUS ON DIGITAL DESIGN LIMITED

Brand: Focus on Clients

Company Address: Twelve Quays House, Egerton Wharf, Wirral, England, CH41 1LD5

Contact Email:[email protected]

We determine how and why personal data is processed.

3. Personal Data We Collect

We may collect the following types of data:

Identity & Contact Data: name, email, postal address, telephone/mobile number.

SMS Consent & Messaging Data: records of opt-in consent for SMS, messaging preferences, unsubscribe status.

Usage & Analytics: website interactions (e.g., IP address, pages visited).

Other Data: as required to provide services.

We do not store full payment card data; payment is processed by third parties.

4. How We Use Your Personal Data

We use your information for:

4.1 To Provide and Manage Services: processing registrations, service delivery, account support.

4.2 SMS/Text Messaging:

We may send SMS/text messages for marketing, promotions, service alerts, and transactional communications if you have provided valid consent. For SMS sent to the United States, we rely on express written consent before sending promotional messages. For UK recipients, consent is collected in accordance with UK GDPR and PECR requirements.

SMS may include promotional offers, updates, or alerts.

4.3 Legal Compliance: enforce legal obligations, protect rights, and cooperate with regulators.

4.4 Business Improvement: analytics, research, and service enhancements.

5. SMS Consent and Messaging

UK Recipients

For UK recipients, we obtain informed, specific, freely given, and unambiguous consent prior to sending marketing SMS, in line with UK GDPR and PECR consent standards. You will be told what types of messages you will receive and can opt out at any time.

US Recipients

For SMS recipients in the United States, we require express written consent before sending promotional text messages, consistent with the TCPA and A2P 10DLC requirements. This consent must be provided through clear affirmative action (e.g., an unchecked checkbox).

Message and data rates may apply. Standard carrier charges may be incurred.

6. Opt-Out and Withdrawal of Consent

You may withdraw consent or opt out of SMS marketing at any time:

Reply STOP, UNSUBSCRIBE, or similar instructions included in the message. Follow instructions in any communication we send.

We process opt-outs promptly and will not send further marketing texts once consent is withdrawn. Transactional messages necessary for service delivery may still be sent where required.

7. Legal Basis for Processing

We rely on the following legal bases:

Consent: where you have explicitly agreed to receive marketing SMS. Contractual necessity: for delivering services you requested. Legitimate interests: for internal business operations, analytics, and fraud prevention.

8. Sharing Your Personal Data

We do not sell or rent personal data.

We may share your data with:

Service Providers (e.g., SMS platforms such as GoHighLevel, analytics, hosting). Legal Authorities if required by law.

Third parties are bound by contractual obligations to protect your information.

9. International Transfers

Some third-party service providers may process data outside the UK or EU. We ensure appropriate safeguards are in place (e.g., approved transfer mechanisms).

10. Data Retention

We retain personal data only as long as necessary: to fulfil the purposes outlined in this policy, to comply with legal obligations, or to resolve disputes.

11. Your Rights

Under applicable laws, you may have rights including:

Access to your personal data Correction of inaccurate data Data deletion Restriction or objection to processing Withdrawal of consent

To exercise these rights, contact us at [email protected]

For UK users, you have the right to complain to the Information Commissioner’s Office (ICO) if you believe your data rights have been violated.

12. Security

We implement appropriate measures to safeguard personal data from unauthorized access, loss, or misuse.

13. Children

Our services are not intended for children under 16. If we learn data has been collected from a child without consent, we will delete it.

14. Changes to This Policy

We may update this policy. The new version will be posted on our Website with a revised effective date.

15. Contact Us

FOCUS ON DIGITAL DESIGN LIMITED

Email: [email protected]

Address: Twelve Quays House, Egerton Wharf, Wirral, England, CH41 1LD5