Privacy Policy
Last updated: October 23, 2026
This Privacy Policy explains how Focal Identity (“we”, “us”, “our”) collects, uses, shares and protects your personal information when you visit https://focalidentity.com, contact us, or use our web design and digital marketing services. It also explains the rights you have over your information.
Where the law requires your consent for something, we ask for it separately. We do not sell your personal information.
1. Who we are
Focal Identity is a web design and digital marketing studio based in Lusaka, Zambia. We work with clients in Zambia, the United Kingdom and the United States. We are responsible for the personal information described in this policy.
- Business: Focal Identity [CONFIRM: registered business name and registration number]
- Address: Plot 10, Makeni Road, Near Makeni School of Nursing, Makeni, Lusaka, Zambia
- Email: info@focalidentity.com
- Phone and WhatsApp: +260 979 605 396
Members of our team and associates, including our marketing specialist based in the United States, may handle personal information to help us deliver our services. They are bound by confidentiality duties.
2. Laws that apply
We handle personal information in line with Zambia’s Data Protection Act, 2021. Where they apply to you, we also follow the UK GDPR and the Data Protection Act 2018, the EU GDPR, and the privacy laws of individual US states.
3. Information we collect
Information you give us
- Enquiries: your name, email address, phone or WhatsApp number, country, the service you are interested in, your budget range, and anything you write in your message.
- Messages: what you send us by email, WhatsApp, phone or video call.
- Newsletter: your email address if you subscribe.
- Clients: business and billing details, logos, text, photos, and other material you supply for your project, plus access to the accounts we need to do the work (for example your website, hosting, domain, social media or advertising accounts).
- Payments: invoice details and payment references. We do not store full card numbers. [CONFIRM: payment methods you accept and any payment provider you use.]
Information collected automatically
When you visit our website we may collect your IP address, browser type and version, device type, operating system, the pages you view, the time and date of your visit, how long you stay, the website that referred you, and your approximate location (derived from your IP address).
Information stored in your browser
If you choose a currency on our pricing sections, we save that choice in your browser so the site shows the same currency on your next visit. This choice stays on your device and is not used to identify you.
4. Cookies and similar technologies
Cookies are small files placed on your device. We use:
- Essential cookies that keep the website working and secure.
- Preference storage that remembers choices such as your currency.
- Analytics from tools such as Google Analytics and Google Search Console, which help us understand how the site is used so we can improve it.
Where the law requires it, we use non-essential cookies only with your consent, and you can change your mind at any time using our cookie settings (where available) or your browser settings. If you block cookies, some parts of the site may not work properly.
5. How we use your information
- To reply to your enquiries, prepare quotes and discuss your project.
- To provide our services, manage contracts and invoices, and give support and maintenance.
- To send you our newsletter and similar updates, where you have asked for them or the law allows.
- To run, secure and improve our website and services, including analysing how the site is used.
- To meet legal, tax and accounting obligations, and to protect our legal rights.
- In connection with a sale, merger or transfer of our business, if that ever happens.
Where UK or EU law applies, our legal bases are: performing a contract or taking steps before entering one; our legitimate interests in running and improving our business; your consent (for example for the newsletter and non-essential cookies); and complying with legal obligations.
6. Marketing messages
We only send marketing emails where the law allows, and only with your consent where consent is required. You can unsubscribe at any time using the link in any email or by contacting us. We do not send marketing text messages. We use WhatsApp to reply to messages you start, and we do not add you to broadcast lists without your permission.
7. Client projects and account access
If you become a client, we may need access to your website, hosting, domain, social media or advertising accounts. We use that access only to do the agreed work, we keep access details in a secure password manager, and we ask you to share them through a secure method rather than by email, WhatsApp or the contact form. Your accounts stay in your name, and we remove our access when the project or support plan ends.
If your website collects information about your own customers, you are responsible for how it is used. Where we handle that information for you, we do so only on your instructions and under our agreement with you.
8. Who we share information with
We share personal information only where needed and only with:
- Service providers that help us run our business, such as website hosting, email and form handling, analytics, video calls and messaging (including WhatsApp), and accounting or payment services.
- Our team and associates who work with us on your project.
- Professional advisers such as lawyers and accountants.
- Authorities when the law requires it or to protect rights, safety or property.
- A buyer or successor if our business is sold or reorganised, and we will tell you if that affects your information.
- Anyone else, with your consent.
We do not sell your personal information or share it for advertising by other companies.
9. Transfers outside your country
Your information may be processed in Zambia, the United States and other countries where our service providers operate. These countries may have different data protection laws from yours. Where the law requires it, we use appropriate safeguards, such as contract terms with our providers, to protect your information.
10. How long we keep information
- Enquiries that do not become projects: up to 24 months.
- Client records and correspondence: for the length of our working relationship and for a period afterwards to deal with follow-up questions and disputes.
- Invoices and financial records: for as long as the law requires. [CONFIRM: retention period.]
- Newsletter subscribers: until you unsubscribe.
- Analytics and server logs: up to 24 months.
When we no longer need information, we delete or anonymise it. Copies may stay in encrypted backups for a short time until they are overwritten.
11. Your rights
Depending on where you live, you may have the right to:
- ask for a copy of the personal information we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information;
- ask us to restrict how we use it, or object to certain uses;
- ask for your information in a portable format;
- withdraw your consent at any time, without affecting what we did before you withdrew it.
To use any of these rights, email info@focalidentity.com. We may need to confirm who you are first, and we will reply within the time the law requires. We cannot always delete everything, for example where we must keep records by law, but we will explain if that is the case.
If you are unhappy with how we handle your information, please contact us first so we can try to put it right. You also have the right to complain to the Office of the Data Protection Commissioner in Zambia, to the Information Commissioner’s Office if you are in the United Kingdom, or to the data protection authority where you live.
12. Security
We take reasonable steps to protect your information, including using secure hosting, access controls and regular software updates. No method of sending or storing information online is completely secure, so we cannot guarantee absolute security. Please do not send passwords or payment card details through the contact form.
13. Children
Our website and services are not aimed at anyone under 16, and we do not knowingly collect their personal information. If you think a child has given us their information, please contact us and we will delete it.
14. Links to other websites
Our website may link to other websites and apps, such as WhatsApp, social media pages and client websites, which we do not control. We are not responsible for their privacy practices, so please read their policies.
15. Changes to this policy
We may update this policy from time to time. We will post the new version on this page and change the “Last updated” date. If the changes are significant, we will tell you by email or with a notice on the website.
16. Contact us
If you have questions about this policy or how we handle your information, contact us:
- By email: info@focalidentity.com
- By WhatsApp or phone: +260 979 605 396
- By post: Focal Identity, Plot 10, Makeni Road, Near Makeni School of Nursing, Makeni, Lusaka, Zambia
