Who we are
Focalplex Inc. (“Focalplex”, “we”, “us”) is a digital marketing company based at Suite 903, 300 Antibes Drive, Toronto, Ontario, M2R 3N8, Canada. We are responsible for the personal information described in this policy. You can reach us at info@focalplex.com.
What this policy covers
This policy covers our website, focalplex.com, and the advertising campaigns we run on platforms such as Meta (Facebook and Instagram), Taboola and Outbrain, including the software we use to manage those campaigns and measure their results. It does not cover the article pages our ads link to, which are operated by our publishing partner under its own privacy policy, or the advertising platforms themselves, which have their own policies.
Information we collect
When you visit focalplex.com
Our website uses no analytics and no tracking or advertising cookies. Our hosting provider may keep standard technical server logs, such as the time of a request and the page requested, to operate and secure the service.
When you contact us
If you use our contact form or email us, we receive the name, email address and message you provide. The contact form is processed by our form provider, Formspree, on our behalf.
When you click one of our ads
Clicks on our ads pass briefly through our click-measurement service before reaching the article page. For each click we record:
- the date and time of the click and the ad, ad set and campaign it came from;
- the click identifier that the advertising platform adds to the link, such as Meta’s fbclid;
- your browser’s user agent and the country the click came from;
- a one-way cryptographic hash of your IP address, used to detect fraudulent and automated traffic. We do not store your IP address itself;
- a random reference number we assign to the click.
Our click-measurement service does not set cookies and does not collect your name, email address or any other contact details.
When you interact with the article page
If you search or click a sponsored result on the article page, our publishing partner informs us by a server-to-server message that references our random click number, together with the search term and the estimated revenue. We match this to the recorded click.
How we use information
- to measure and improve the performance of our advertising campaigns;
- to detect and prevent fraudulent, automated or otherwise invalid traffic;
- to reconcile our reports and billing with our advertising and publishing partners;
- to answer your enquiries when you contact us.
We do not sell personal information, and we do not use it to build profiles of individuals.
How we share information
- Advertising platforms. To let a platform measure and optimise the ads it delivered, we report conversions back to it. For Meta, we send each conversion through the Meta Conversions API with the platform’s own click identifier, your browser’s user agent, our random click reference, the conversion value and the address of the page. For Taboola and Outbrain, we send the platform’s click identifier and the conversion value. We do not send your IP address or contact details to any platform.
- Our publishing partner. The article pages our ads link to are operated by our partner, which receives the random click reference and the ad’s identifiers in the link, and processes your visit under its own privacy policy.
- Service providers. We use Amazon Web Services and Hetzner to host our website and systems, and Formspree for our contact form. They process information only on our instructions.
- Legal reasons. We may disclose information if required by law or to protect our rights, users or partners.
Our Meta app
We operate a Meta business app, “AdFront”, which uses the Meta Marketing API only to manage our own advertising accounts and to send the conversion events described above. It does not offer Facebook Login and does not collect profile information from Facebook or Instagram users.
Legal bases (EEA, UK and Switzerland)
Where the GDPR or a similar law applies, we process click and conversion information on the basis of our legitimate interests in measuring our advertising, preventing fraud and reconciling billing, and we process enquiries to take steps you ask for. Where the law requires consent, we rely on the consent collected by the platform or partner concerned.
How long we keep information
We keep click and conversion records only as long as needed for campaign reporting, billing reconciliation with our partners and fraud prevention, and then delete or anonymise them. We keep enquiries as long as needed to handle them and for our business records.
Where information is processed
We and our service providers process information in Canada, the European Union and the United States. Where information moves between countries, we rely on the safeguards the applicable law provides.
Your rights
Depending on where you live, you may have the right to access, correct or delete your personal information, to object to or restrict its processing, and to receive a copy of it. To exercise these rights, email info@focalplex.com. You may also complain to your data protection authority; in Canada, that is the Office of the Privacy Commissioner of Canada.
How to request deletion of your data
Email info@focalplex.com with the subject “Data deletion request”. Because our click records do not contain your name or email address, please include what helps us find them: the approximate date and time you clicked one of our ads, the platform where you saw it (for example Facebook or Instagram) and, if you can, the link you were taken to. We will delete the matching records and confirm within 30 days.
Information held by Meta itself, such as your activity on Facebook and Instagram, is managed through your Meta account settings, including “Your activity off Meta technologies”.
Children
Our website and advertising are not directed to children under 16, and we do not knowingly collect their personal information.
Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last changed.
Contact
Focalplex Inc., Suite 903, 300 Antibes Drive, Toronto, Ontario, M2R 3N8, Canada · info@focalplex.com