Privacy Policy

Last updated: May 16, 2025

Data Controller

Focusark.com (“we”, “us”, “our”) is operated by Sergey Petrov, a private individual registered at Tbilisi, Georgia. We act as the data controller under all applicable privacy laws (GDPR, CCPA/CPRA, PIPEDA, UK GDPR, APP, COPPA).
For any questions or to exercise your rights, please contact us at
[email protected].

Information We Collect

• Personal Identifiers: name, email address (when you subscribe or contact us).
• Technical Data: IP address, browser type/version, device information, operating system.
• Usage Data: pages visited, time spent on pages, click-throughs, referral URLs.
• Cookies & Tracking: see Section 5 below.

How We Collect Data

• Directly: via newsletter subscription forms, contact forms and comments.
• Automatically: through analytics and security services (Google Analytics, Microsoft Clarity, Cloudflare).
• Cookies & Similar Technologies: to recognise returning visitors and understand usage patterns.

Purposes of Processing

We use your data to:

• Provide, maintain and improve our website and services
• Send you newsletters or marketing communications, but only if you have explicitly opted-in.n.
• Analyze and understand usage trends and preferences to optimize content.
• Protect our website against malicious activity and unauthorized access.
• Comply with legal obligations and enforce our Terms of Use.

Cookies and Tracking Technologies

We implement a consent banner allowing you to manage cookie categories. Our cookies fall into:

• Necessary Cookies: required for core website functionality (e.g. security, login).
• Preference Cookies: remember your language or display settings.
• Statistics Cookies: collect anonymous usage data (Google Analytics, Microsoft Clarity).
• Marketing Cookies: track clicks on affiliate links (Impact, ShareASale, CJ Affiliate) and ad networks.

You can change or withdraw your consent at any time via the banner or browser settings. For more details, see our Cookie Policy.

Third-Party Services & Processors

We share data with and rely on the following processors, all bound by Data Processing Agreements (DPA):.

Data Retention

We retain personal data according to the following criteria:

• Security Logs (IP, login attempts): retained for 90 days, then automatically deleted.
• Subscription and Contact Data: retained until you unsubscribe or request deletion, then permanently erased.
• Anonymized Analytics Data: retained up to 2 years for trend analysis, then aggregated or deleted.
• Backups: stored securely for up to 30 days, then rotated out.

International Data Transfers

Your information may be transferred to and stored on servers located outside your country (e.g., USA, Georgia). We ensure adequate safeguards such as Standard Contractual Clauses.

Note: the EU–US Privacy Shield was invalidated in July 2020; we rely on SCCs and other approved mechanisms.

Your Rights

Under GDPR & UK GDPR (EU/UK Residents)

You have the right to access, rectify, erase, restrict processing, data portability, object to processing, and withdraw consent at any time.

Under CCPA/CPRA (California Residents)

“Do Not Sell My Personal Information”: We do not sell your personal data. “Sale” under CCPA is defined broadly, but by default we do not sell or share personal information for money. If this changes, we will update this policy and provide a clear opt-out mechanism here.

Sensitive Personal Data: We do not collect Sensitive Personal Data as defined by CCPA, such as racial or ethnic origin, religious beliefs, health data, or precise geolocation.

Right to Know & Delete: You can request access to the personal data we hold about you or request its deletion by contacting us at [email protected]. We will verify your request and respond within 45 days.

Under PIPEDA (Canada)

Right to access and amend your personal information.

Under APP (Australia)

Right to access and correct personal information.

Under COPPA (Children’s Privacy)

We do not knowingly collect data from children under 13. If you are a parent and believe your child’s data has been collected, please contact us to have it deleted.

Security Measures

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption (TLS) in transit.
• Web application firewall and DDoS protection via Cloudflare.
• Wordfence Security and Limit Login Attempts Reloaded for intrusion prevention.
• Regular security audits and updates of plugins and server software.

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. The “Last updated” date at the top will indicate when changes occur. We encourage you to review this page periodically.

Contact Information

If you have any questions, concerns or requests regarding this policy or your personal data, please write to us at:

Email: [email protected]
Controller: Sergey Petrov, Tbilisi, Georgia