LEGAL INFORMATION
Privacy Policy
Effective and last updated: 7 November 2026. This policy explains how we collect, use, share and protect your personal data on focus.az and through our contact channels.
Notice (7 November 2026): this policy was updated — Instagram Direct messages, the message archive and the data deletion procedure were added.
1. Data controller
Your personal data is controlled and processed by Focus Bureau (individual entrepreneur, Baku, Azerbaijan). • Email: bureau@focus.az We process your data in line with the Law of the Republic of Azerbaijan "On Personal Data".
2. What data we collect
• Contact and request forms: first and last name, email, phone number, company and position (optional), what you tell us about your project, and the date and time of your consent. • WhatsApp: your phone number, profile name and the content of the conversation. • Instagram Direct: your Instagram user ID, profile name and the content of the messages you send us. • Chatbot: the conversation text, its time and any contact details you choose to share in it. • Careers (CV): name, contact details, CV, portfolio links and cover letter. • Technical data: IP address, browser and device type, pages viewed and cookie identifiers — analytics and marketing cookies only with your consent. • Traffic source: on your first visit we keep the UTM parameters in the URL (utm_source, utm_medium, utm_campaign, utm_content, utm_term), the ad click ID (fbclid, gclid) and the referring site in your browser’s session storage; they are attached as a “source” to the form you submit (request, contact, custom package, careers). This data is deleted when the browser session ends. • Behaviour analytics (Microsoft Clarity): only with your analytics consent we record your clicks, scrolling and cursor movements; what you type into forms (name, phone, email, message, etc.) is masked and not recorded.
3. Purposes and legal basis
• To answer your request and prepare a quote — based on your request and the consent given in the form. • To conclude and perform a contract — if you become a client. • To select candidates for vacancies — based on the consent you give when sending a CV. • To reply to WhatsApp and Instagram messages, pass your request to our team and check service quality — based on your request. • We combine requests that the same person sends through different channels (form, WhatsApp, Instagram, chatbot) so that we can reply without asking you again. We do not use this for advertising profiling. • Site statistics and ad measurement — only with your cookie consent. • To meet tax and accounting obligations — as required by law. We do not sell your data or use it for purposes not listed in this policy.
4. Third parties
We share your data only to the extent needed to provide our services: • Meta Platforms (Facebook, Instagram) — measuring ad results via Meta Pixel (with consent). • WhatsApp (Meta) — delivering the messages you send us on WhatsApp. • Instagram (Meta) — delivering the messages you send us on Instagram Direct and sending our replies. • Google — site usage statistics via Google Analytics (with consent); receiving and storing form and CV submissions via Google Apps Script / Google Workspace. • Microsoft — behaviour analytics on the site via Microsoft Clarity (with consent). • Cloudflare — storing and delivering the site’s media files (videos, images); encrypted storage of system backups and the message archive. • Hosting provider — the server where the site is hosted. • Chatbot technology provider — processing chatbot conversations (automation platform and AI model). • Customer relationship management (CRM) platform — storing requests and conversations. • Automation and cloud hosting provider — processing requests and notifications. • Telegram — internal notifications to our team about your requests. • AI model provider — preparing WhatsApp, Instagram and chatbot replies. These parties process your data under their own privacy policies and the safeguards agreed with us.
4.1. Site statistics (Google Analytics and Google Search Console)
To understand how our website is used and to improve it, we use Google Analytics 4 and Google Search Console. Google Analytics runs only with your consent (your cookie choices). These services collect aggregated information such as page views, number of sessions, general geography, device type, the channel through which the site was found, search queries, impressions and clicks, and the number of clicks on WhatsApp, phone and form buttons. This information is not used to identify you personally; the name, phone number, email or message you type into a form is not sent to Google Analytics. We receive this aggregated statistics through Google’s APIs in read-only mode and store it in our internal reporting system. Statistics are kept for at most 14 months. Data processor: Google Ireland Limited. You can stop the collection by turning off analytics in your cookie choices or by using Google’s “Google Analytics Opt-out” add-on. If you have questions, write to bureau@focus.az.
5. International transfers
Servers of Meta, Google, Microsoft, Cloudflare and our hosting and chatbot providers may be located outside Azerbaijan (including the United States and the European Union). Such transfers take place only with your consent or where necessary to answer your request, and only where the provider has appropriate technical and organisational safeguards.
6. CVs and job applications
A CV sent via the Careers page is used only for candidate selection and is seen only by staff involved in hiring. If your application is unsuccessful, we keep your CV for 12 months for future vacancies and then delete it. If you withdraw your consent, your CV is deleted within 30 days.
7. Chatbot
The chatbot on our site is AI-powered and gives automated answers — its answers do not create contractual obligations. Please do not share sensitive data (health, financial, ID details, etc.) with the chatbot. Conversations are kept for 90 days to check service quality and to follow up on your request.
8. Retention periods
• Contact form and email requests — 24 months after the last message. • WhatsApp and Instagram conversations — 24 months after the last message (the first 90 days in our working system, then in a closed archive that only authorised staff can access). • Client contracts and financial records — for the period required by tax law (at least 5 years). • CVs — 12 months. • Chatbot conversations — 90 days. • Google Analytics statistics — 14 months. • Microsoft Clarity recordings — up to 30 days (Microsoft’s default period). • Traffic source — deleted when the browser session ends; the source note submitted with a form is kept for as long as that request. • Consent records — 3 years after consent is withdrawn (as evidence). • System backups — daily for 90 days, monthly for 12 months. If you ask us to delete your data, copies in backups are not deleted separately; they are removed automatically when their retention period ends (12 months at the latest); if a backup is restored, your data is deleted again. When the period ends, data is deleted or anonymised.
9. Your rights
• Access your data and receive a copy. • Ask us to correct inaccurate or incomplete data. • Ask us to delete your data or restrict its processing. • Withdraw your consent at any time — this does not affect processing carried out before withdrawal. You can change cookie consent via the "Cookie settings" link in the footer. • Object to processing for analytics and direct marketing. • If you believe your rights have been violated, lodge a complaint with the competent state authority of the Republic of Azerbaijan or a court. Send your requests to bureau@focus.az — we reply within 30 days.
Deleting your data
If you contacted Focus Bureau via WhatsApp, Instagram Direct, our website form or chatbot, you can ask us to delete your data. How to request deletion • Email bureau@focus.az with the subject “Data deletion request”, or • write “Delete my data” in the same channel you used to contact us (WhatsApp or Instagram Direct). Please mention the channel you used (phone number or Instagram username) so we can find your data. What we delete Your lead record (name, phone number or Instagram ID), your conversations with us, and archived copies of this data. Timeline We delete your data within 30 days of receiving your request and confirm through the same channel. Copies in system backups are removed automatically within 12 months at the latest; if a backup is restored, your data is deleted again. What may be kept Data we are legally required to keep (for example contracts and payment records) is kept for the period required by law. Technical logs that contain no personal data are not deleted. You can remove permissions you gave via Instagram or Facebook at any time in your Meta account under “Apps and websites”.
10. Security
The site is protected by HTTPS (SSL), access to data is limited to authorised people who need it for their work, and we use strong passwords and access controls in the services we rely on.
11. Changes to this policy
When this policy changes, the new version is published on this page and the date above is updated. We announce significant changes with a separate notice on the site. Latest change (7 November 2026): Instagram Direct, the message archive, system backups and the data deletion section were added.