PRIVACY
POLICY

Controller and Scope

This Privacy Policy applies to the website focusprofit.pro (the "Site") operated by FocusProfit. It covers all personal data collected through the Site — application forms, analytics, and any future subscription features.

By using the Site, you acknowledge that your data may be processed as described in this Policy.

What Data We Collect

We collect personal data through three channels:

• Application form: name, Telegram handle or other contact details, and preferred markets you select. This information is stored on a secured server in the /leads/ directory and is used solely to process your request.
• Web analytics: technical data such as IP address, cookie identifiers, browser type, device information, and on-site behaviour, collected via Google Analytics 4 after you accept analytics cookies through our cookie-consent banner (see Section 6, "Cookies and Analytics", for what is collected before you make a choice).
• Market review subscriptions (planned): email address, to be collected when we launch the review mailing list. This data is not collected yet.

Purposes and Legal Bases

• Processing your application and contacting you — to fulfil your request. Legal basis: performance of a contract or pre-contractual steps taken at your request (GDPR Art. 6(1)(b)), and your consent (Art. 6(1)(a)).
• Site analytics and improvement — understanding how visitors use the Site so we can make it better. Two distinct legal bases apply, depending on what is actually processed (see Section 6, "Cookies and Analytics", for the technical detail):
  • Minimal, cookieless measurement before you choose — Google Analytics 4 sends anonymised, cookieless pings (no cookies, no identifiers) in Google Consent Mode while awaiting your choice. Legal basis: legitimate interest (GDPR Art. 6(1)(f)), narrowly scoped to this minimal, non-identifying signal only.
  • Full cookie-based tracking after you accept — the full cookie-based mode of Google Analytics 4. Legal basis: your consent (GDPR Art. 6(1)(a)), given through the cookie-consent banner. These analytics cookies are set only after you accept; if you decline, no analytics cookies are placed.
• Market review mailings (future) — sending periodic analytical content to subscribers. Legal basis: your consent (GDPR Art. 6(1)(a)).

Storage and Retention

Data is stored on a secured server (Hetzner, Germany). Application data is retained for 1 year.

Analytics data is retained according to the settings of the respective third-party service (Google Analytics 4).

Third-Party Transfers

We share data with the following service providers only to the extent necessary:

• Mailgun — transactional email delivery. Privacy policy: mailgun.com/legal/privacy-policy
• Google Analytics 4 — web analytics. Privacy policy: policies.google.com/privacy

We do not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes.

Cookies and Analytics

The Site uses cookies placed by Google Analytics 4 to collect anonymous behavioural data (pages visited, session duration, referrer). No cookies are used for advertising targeting.

These analytics cookies are set only after you give consent via the cookie banner shown on your first visit. Until you accept, Google Analytics 4 loads but operates in Google Consent Mode, sending only anonymised, cookieless pings with no cookies or identifiers attached — it switches to full cookie-based tracking only once you accept.

You can withdraw your consent at any time — reopen the consent banner using the link below and choose "Decline". Your choice is stored in your browser, and the banner will automatically ask again after 6 months. You can also disable cookies in your browser settings, or opt out of analytics tracking directly via the providers:

• Google Analytics: tools.google.com/dlpage/gaoptout

Manage cookie preferences

Your Rights

Depending on applicable law, you have the right to:

• Access (Art. 15) — request a copy of the personal data we hold about you.
• Rectification (Art. 16) — request correction of inaccurate or incomplete data.
• Erasure (Art. 17) — request deletion of your data ("right to be forgotten").
• Restriction of processing (Art. 18) — request that we limit how we process your data in certain circumstances.
• Portability (Art. 20) — receive your data in a structured, commonly used, machine-readable format.
• Objection (Art. 21) — object to the processing of your personal data on grounds relating to your particular situation.
• Withdrawal of consent (Art. 7(3)) — revoke consent at any time, without affecting the lawfulness of processing carried out before withdrawal. For analytics cookies you can do this directly via the consent banner (see Section 6).
• Complaint — lodge a complaint with the relevant supervisory authority in your jurisdiction.

To exercise any of these rights, contact us at the address listed in Section 8.

Contact for Privacy Requests

For any questions or requests regarding your personal data, please contact us at:
info@focusprofit.pro

We aim to respond to all legitimate requests within 30 days.

Effective Date

This Privacy Policy was first published on 14 June 2026 and was last updated on 12 July 2026.

We may update this Policy from time to time. Significant changes will be reflected in the "last updated" date above.