Privacy policy.

This policy explains what personal data Focal Creative collects when you use this website or get in touch, why it's collected, how it's used, and what rights you have over it.

Who we are

Focal Creative is the trading name of James Curd, a sole trader based in the United Kingdom. For the purposes of UK data protection law, James Curd is the "data controller" responsible for your personal data.

Address for service: CityCoast Centre, North Street, Portslade, East Sussex BN41 1DG.

Contact: james@focalcreative.uk

What data we collect

We collect personal data in the following ways:

• When you fill in the "Start a project" form — name, email address, phone number (if provided), business name, and any project details or notes you choose to share. The form also runs Cloudflare Turnstile, a bot protection service, which processes technical information about your device and browser to verify you're human and prevent spam.
• When you email us directly — your email address, name (if given), and the contents of your message.
• Automatically, via Umami analytics — aggregated information about how the site is used, such as which pages are viewed, which site referred you, and rough device and browser type. Umami is a privacy-focused analytics tool: it sets no cookies, does not track you across other websites, and does not store your IP address or build any profile that could identify you.
• Via Google Fonts — this site loads typefaces from Google's servers, which may involve your device connecting to Google and sharing your IP address as a technical requirement of loading the font files.

We do not knowingly collect payment card details, government ID numbers, or other special category data through this website.

How we use your data

We use the data collected for the following purposes:

• To respond to your enquiry and discuss your project.
• To prepare quotes, proposals and, where a project goes ahead, to deliver the agreed work.
• To keep basic records of enquiries and client correspondence.
• To understand how visitors use the site in aggregate, so we can improve it.
• To meet our own legal, accounting and tax obligations.

Our legal basis for processing

Under UK GDPR, we rely on the following legal bases:

• Legitimate interests — for responding to enquiries, keeping business records, and understanding site usage via analytics, where this doesn't override your rights and interests.
• Contract — where processing is necessary to prepare for or perform a contract with you (e.g. delivering a website build).
• Consent — where we ask for it explicitly, and you're free to withdraw it at any time. We don't currently rely on consent for anything on this website, since we set no cookies and run no tracking.
• Legal obligation — for record-keeping required by UK tax and accounting law.

Cookies and similar technologies

This site does not set any cookies. Our analytics tool, Umami, measures site usage without cookies and without storing personal data, so there is no cookie banner to click through and nothing for you to consent to or withdraw.

To reduce spam, our forms include a hidden field that automated bots tend to fill in and people never see. This checks nothing about you and processes no personal data — it simply lets us discard obvious bot submissions.

Who we share your data with

We don't sell your personal data. We may share it with:

• Service providers who help us run this site and our business — our hosting provider, our email provider (Brevo, used to deliver enquiry notifications), Umami for analytics, Google Fonts for typefaces, and Cloudflare Turnstile for bot protection on our forms. These providers only process data on our instructions and for the purposes described here. For more details on how Cloudflare Turnstile processes your data, see the Turnstile Privacy Addendum.
• Professional advisers such as an accountant, where necessary for our legal and tax obligations.
• Authorities where we're required to by law, such as to comply with a legal obligation or protect our legal rights.

International transfers

Some of the third parties we use (such as Google, for fonts) may process data outside the UK, including in the United States. Where this happens, we rely on safeguards recognised under UK GDPR, such as the UK's international data transfer addendum or the provider's own standard contractual clauses, to ensure your data stays protected.

How long we keep your data

We keep enquiry and client data for as long as necessary to deal with your enquiry, deliver any agreed project, and meet our legal obligations — UK tax law generally requires business records to be kept for 6 years. Enquiry records older than that are deleted on a routine basis. Analytics data is aggregated and contains nothing that identifies you.

Your rights

Under UK GDPR, you have the right to:

• Ask what personal data we hold about you, and get a copy of it (right of access).
• Ask us to correct inaccurate or incomplete data (right to rectification).
• Ask us to delete your data, where there's no good reason for us to keep it (right to erasure).
• Ask us to restrict or object to certain processing.
• Ask for your data in a portable format, where technically feasible.
• Withdraw consent at any time, where we're relying on consent (this won't affect processing carried out before you withdrew it).

To exercise any of these rights, email james@focalcreative.uk. We'll respond within one month, as required by law.

If you're unhappy with how we've handled your data, you also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), though we'd appreciate the chance to put things right first.

Keeping your data secure

We take reasonable technical and organisational steps to protect your personal data against unauthorised access, loss or misuse, including restricting who can access enquiry records and using reputable, secure third-party providers for hosting and email.

Children's privacy

This site and our services are intended for business use by adults. We don't knowingly collect personal data from children.

Changes to this policy

We may update this policy from time to time, for example if we start using a new tool or service that processes personal data. The "last updated" date at the top of this page will always reflect the most recent version. We'd encourage you to check back occasionally.

Contact us

If you have any questions about this policy or how your data is handled, email james@focalcreative.uk.