Who We Are
FocusLatex is operated by JIUXIAN TRADING CO., LIMITED (九闲商贸有限公司) ("FocusLatex", "we", "us" or "our"). For applicable data protection laws, we are generally the controller or data user responsible for the personal data described in this Policy.
Registered business address: Room D07, 8/F, Kai Tak Factory Building, Stage II, 99 King Fuk Street, San Po Kong, Hong Kong
Privacy contact: support@focuslatex.com
Our products are manufactured and orders are initially fulfilled in Nanjing, Jiangsu, People's Republic of China. We sell and ship internationally, subject to the destinations and restrictions stated in our Shipping Policy.
Scope of This Policy
This Privacy & Cookie Policy explains how we collect, use, disclose, transfer, retain and protect personal data when you:
- visit or use our website;
- create or use an account;
- place, pay for or receive an order;
- request standard-size made-to-order, made-to-measure or fully custom products;
- upload measurements, design files or reference images;
- contact customer service, request after-sales support or exercise a privacy right; or
- receive marketing communications or interact with our advertisements.
This Policy should be read together with our Terms of Service, Shipping Policy, Return, Refund & Cancellation Policy and any just-in-time notice shown when information is collected.
Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data.
3.1 Identity, contact and account data
This may include your name, email address, telephone number, billing and shipping addresses, country or region, account username, password in protected or hashed form, communication preferences and account history.
3.2 Order, transaction and delivery data
This may include products ordered, size and configuration selections, order value, currency, discount information, transaction identifier, payment status, limited payment-method details, billing information, fraud-screening result, customs information, delivery instructions, tracking events, signature or proof of delivery, and return, repair, remake, cancellation or refund records.
Payment card information is generally collected and processed directly by our payment providers or through their embedded payment technology. Depending on the checkout integration, we may receive limited information such as the card brand, last four digits, transaction reference and payment status. We do not use card security codes for our own independent purposes and do not intentionally retain them after authorisation.
3.3 Customisation data
For made-to-measure and fully custom orders, we may collect body measurements, sex or gender information where relevant to pattern construction, fit preferences, written requirements, sketches, design files and reference images. Please provide only information genuinely needed for us to quote, design, manufacture or support your product.
Reference images may identify you and may reveal sensitive aspects of your body or private life. Only an account holder aged 18 or over may create an account, place an order or submit a reference image. Only an adult account holder aged 18 or over may submit an image containing nudity, sexual content or intimate body areas, and only through a channel that FocusLatex has expressly approved for that purpose.
Do not upload an image unless you own it or have the lawful authority and permission of every identifiable person in it. Do not upload identification documents, images of children, illegal material, or content that is not necessary for the order. By deliberately submitting sensitive reference material after reading this notice, you ask us to process it only for the customisation, fulfilment and related support purposes described in this Policy. Where applicable law requires a separate form of explicit consent, we will request it before processing.
3.4 Communications and support data
This may include emails, chat messages, enquiry details, order notes, complaints, survey responses, photos or videos supplied to show a quality or delivery issue, and records of our response.
3.5 Marketing and preference data
This may include whether you subscribed or unsubscribed, your preferred language, campaign interactions, abandoned-cart activity and inferred interests based on your interactions with our website and marketing, subject to applicable consent and opt-out rules.
3.6 Device, usage and technical data
When you use our website, we and our service providers may collect IP address, device and browser type, operating system, language, time zone, approximate location derived from IP address, referring page, pages and products viewed, searches, clicks, session information, error logs, cookie identifiers, advertising identifiers and security events.
3.7 Data received from third parties
We may receive personal data from payment providers, fraud-prevention providers, logistics providers, local delivery partners, advertising and analytics providers, customer-support tools, social-media platforms, and persons who place an order or contact us on your behalf.
If you provide another person's data, you must be authorised to do so and must give that person any notice required by law.
Whether Providing Data Is Required
Providing marketing information, optional profile information and non-essential cookies is voluntary. Information marked as required at checkout or during customisation is needed to create an account, enter into or perform a contract, make or deliver a product, process payment, comply with customs or legal requirements, or resolve a request. If required information is not provided, we may be unable to accept, manufacture, deliver or support the order.
How and Why We Use Personal Data
We use personal data only where we have an appropriate purpose and, where required, a lawful basis.
| Purpose | Typical data | Lawful basis where applicable |
|---|---|---|
| Operate accounts, carts and checkout | Account, contact, device and order data | Contract; legitimate interests in operating our store |
| Accept payment and prevent fraud | Transaction, contact, device and fraud data | Contract; legal obligation; legitimate interests in preventing fraud |
| Design and manufacture custom products | Measurements, sex or gender where relevant, designs, requirements and reference images | Contract; consent or explicit consent where legally required for sensitive data |
| Pack, ship, clear customs and deliver orders | Name, address, telephone, order and customs data | Contract; legal obligation |
| Provide service, repairs, remakes, refunds and dispute handling | Order, communications, images, videos and delivery records | Contract; legal obligation; legitimate interests in resolving claims |
| Maintain security and prevent misuse | Account, device, usage and transaction data | Legal obligation; legitimate interests in protecting customers and our business |
| Keep tax, accounting and legal records | Order, transaction and communications data | Legal obligation; legitimate interests in establishing or defending legal claims |
| Improve our website, products and service | Usage, order, feedback and support data | Legitimate interests; consent where required for analytics cookies |
| Send newsletters, offers and abandoned-cart messages | Contact, preference, cart and interaction data | Consent where required; otherwise legitimate interests where permitted by law |
| Measure and personalise advertising | Cookie, device, usage and marketing data | Consent where required; otherwise subject to applicable notice and opt-out rights |
| Respond to privacy requests and regulators | Identity, contact, request and verification data | Legal obligation; legitimate interests in verifying and documenting requests |
Where we rely on legitimate interests, we consider whether our interests are proportionate and whether your rights and expectations override them. Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing already lawfully completed.
Custom Measurements and Reference Images
We restrict the use of customisation data to personnel and service providers who need it for quotation, design, pattern preparation, manufacturing, quality review, customer service, after-sales support or dispute handling. Because our manufacturing and fulfilment operations are in Nanjing, authorised personnel there may access the complete order file, including customisation materials and necessary customer and delivery information.
We do not use private reference images for public advertising, social media, training promotional models or unrelated product development unless we first obtain a separate, specific permission. We do not permit personnel to copy or retain such images for personal use.
You may request deletion of a reference image before the ordinary retention period ends. We will comply unless continued retention is reasonably necessary to complete your order, provide requested support, investigate misuse, establish or defend a legal claim, or meet a legal obligation. Deleting an image during design or production may prevent us from completing the order and does not by itself create a right to cancel or receive a refund.
Cookies and Similar Technologies
Cookies are small files or identifiers stored on or accessed from your browser or device. We may also use pixels, tags, local storage, software development kits and similar technologies. Some are set by us and others by third parties.
7.1 Cookie categories
| Category | Purpose | Typical examples |
|---|---|---|
| Strictly necessary | Security, network management, cart, checkout, account login, payment and consent preferences | WordPress/WooCommerce session, cart and authentication cookies |
| Functional | Remember language, region, display and other optional preferences | Preference and localisation cookies |
| Analytics | Understand visits, performance, navigation and errors | Analytics and performance tools, if enabled |
| Advertising | Measure campaigns, limit repetition, create audiences and personalise or retarget advertisements | Advertising pixels and conversion tags, if enabled |
The actual providers, cookie names, purposes and durations may change as we configure the website. The current list should be displayed in our cookie settings panel or cookie table when the website launches.
7.2 Your cookie choices
Our cookie interface is intended to let you accept, reject or manage cookies by category. You can also delete or block cookies through your browser. Blocking strictly necessary cookies may prevent the cart, checkout, account or security features from working.
Where applicable law requires prior consent, non-essential analytics, functional or advertising technologies should not be activated until you consent. You may withdraw consent through the cookie settings link made available on the website. Where applicable law permits a technology to operate without prior consent, you may still have a right to opt out of targeted advertising, sale or sharing, or certain profiling.
We intend to recognise legally required browser-based preference signals, such as Global Privacy Control, where they apply to our processing. Cookie choices are browser- and device-specific, so you may need to repeat them on another device or after clearing cookies.
Direct Marketing
We may send promotional emails and abandoned-cart reminders where permitted by law. You may unsubscribe using the link in a marketing email or by contacting us. We may still send non-marketing messages necessary for an order, account, safety notice, policy change or customer-service request.
We do not use custom measurements or private reference images to target advertisements.
How We Disclose Personal Data
We may disclose personal data only as reasonably necessary to the following categories of recipients:
- website hosting, WordPress/WooCommerce, information-technology and security providers;
- payment gateways, acquirers, card networks, PayPal, Antom and fraud-prevention providers;
- our authorised manufacturing, order-management and fulfilment personnel in Nanjing;
- freight forwarders, customs agents, DHL, UPS, FedEx, Yanwen, cross-border logistics providers and local last-mile carriers, as applicable;
- email, customer-support, analytics, advertising and cookie-consent providers that we actually enable;
- accountants, auditors, insurers, banks, legal advisers and other professional advisers;
- regulators, courts, law-enforcement bodies, customs authorities or other persons where disclosure is required or legally permitted; and
- a buyer, investor or successor in connection with a proposed or completed merger, restructuring, financing, sale or transfer of all or part of our business, subject to appropriate confidentiality measures.
We require service providers to use personal data only for authorised services and to protect it, subject to their independent legal obligations. Payment providers, carriers and other recipients may sometimes act as independent controllers or data users under their own privacy notices.
We do not sell personal data for money. Certain advertising or analytics disclosures may, under some United States state privacy laws, be treated as a "sale", "sharing" or targeted advertising even when no money changes hands. Where those laws apply, you may use our cookie settings or contact us to exercise the relevant opt-out right.
International Data Transfers
We operate from Hong Kong, manufacture and initially fulfil orders in mainland China, serve customers internationally, and use service providers that may operate in other countries. Your personal data may therefore be accessed, processed or stored outside the country where you live, including in Hong Kong, mainland China, the United States and the countries where our service providers or logistics partners operate.
Privacy laws in those locations may differ from those in your jurisdiction. Where required, we use recognised safeguards for restricted transfers, which may include adequacy decisions, approved contractual clauses, data-transfer agreements, supplementary technical and organisational measures, or another lawful transfer mechanism. You may contact us for information about safeguards relevant to your data, subject to necessary confidentiality redactions.
Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including contractual, operational, tax, accounting, fraud-prevention, dispute and legal requirements.
| Data category | General retention approach |
|---|---|
| Orders, transactions, tax and accounting records | Generally up to 7 years after the relevant transaction, or longer if law or an active dispute requires |
| Customer account | While active; then deleted or anonymised after a reasonable inactivity period, subject to records we must retain separately |
| Customer-service and complaint records | Generally up to 3 years after the matter closes, or longer for an active claim |
| Measurements, sex or gender information, designs, requirements and reference images | Generally up to 3 years after order completion, unless deleted earlier upon a valid request or retained longer for an active dispute or legal duty |
| Marketing subscription data | Until you unsubscribe or object, plus a limited suppression record so we can respect your choice |
| Cookie and analytics data | According to the duration shown in the cookie settings or the relevant provider's controls |
| Privacy-request records | As needed to verify compliance and defend or establish legal rights |
When data is no longer needed, we delete, anonymise or securely isolate it, subject to backup cycles and technical limitations. Aggregated or irreversibly anonymised information may be retained for longer because it no longer identifies you.
Data Security
We use reasonable administrative, technical and physical safeguards designed to protect personal data against accidental loss and unauthorised access, use, alteration or disclosure. These measures may include access controls, authentication, encryption in transit where appropriate, staff confidentiality obligations, backups, logging and vendor review.
No website, transmission or storage system is completely secure. You are responsible for using a strong, unique password and keeping your account credentials confidential. If you believe your account or data has been compromised, contact us promptly at support@focuslatex.com.
If a personal-data incident occurs, we will investigate and make notifications to affected persons or authorities where required by applicable law.
Your Privacy Rights
Depending on where you live and subject to legal conditions and exceptions, you may have rights to:
- be informed about how your personal data is used;
- request access to or a copy of your personal data;
- request correction of inaccurate or incomplete data;
- request deletion of data;
- restrict or object to certain processing;
- withdraw consent at any time;
- receive certain data in a portable format;
- opt out of direct marketing, targeted advertising, sale or sharing of personal data, or certain profiling;
- appeal our response where applicable; and
- complain to a competent privacy or data-protection authority.
Hong Kong data subjects may request access to and correction of their personal data under the Personal Data (Privacy) Ordinance. EEA and UK residents may also have the rights provided by the GDPR or UK GDPR. Residents of California and other applicable United States states may have additional rights, including rights concerning access, deletion, correction and certain sale, sharing, targeted-advertising or profiling activities. We will not unlawfully discriminate against you for exercising a privacy right.
To exercise a right, email support@focuslatex.com and describe your request. We may ask for information reasonably necessary to verify your identity and authority. An authorised agent may submit a request where local law permits, but we may require proof of authority and direct verification. We will respond within the period required by applicable law. Some rights are not absolute; for example, we may retain information needed to complete a transaction, comply with law, prevent fraud, or establish or defend legal claims.
Children and Young People
Our account, ordering and customisation services are intended only for adults aged 18 or over. We do not knowingly permit a person under 18 to create or use an account, place an order or submit personal data through an order or customisation process. A person under 18 must not submit reference images or other custom-order material.
If we learn that personal data was submitted by a person under 18, or that an age representation was false, we may delete the information, suspend the relevant account, refuse or cancel an affected order as permitted by law, and take other appropriate steps. A parent or guardian who believes a person under 18 has provided personal data contrary to this Policy should contact us promptly.
Third-Party Websites and Services
Our website may link to third-party websites, social-media services or payment pages. Their privacy practices are governed by their own notices. We are not responsible for a third party's independent processing, and we encourage you to review its privacy information before providing data.
Changes to This Policy
We may update this Policy to reflect changes in our services, technology, vendors or legal obligations. We will post the updated version and revise the "Last updated" date. Where required, we will provide additional notice or obtain consent before a material change takes effect.
Governing Law and Mandatory Privacy Rights
This Policy is governed by the laws of Spain, without limiting any mandatory privacy, data-protection or consumer right that applies in your place of residence, including the GDPR where applicable. Please first contact support@focuslatex.com so that we can try to resolve a concern in good faith. Subject to mandatory law, disputes relating to this Policy are subject to the courts of Spain. This does not limit any non-waivable right to complain to a competent data-protection authority or bring proceedings elsewhere.
Contact Us
Questions, privacy requests and complaints may be sent to:
JIUXIAN TRADING CO., LIMITED (九闲商贸有限公司)
Trading as FocusLatex
Room D07, 8/F, Kai Tak Factory Building, Stage II
99 King Fuk Street, San Po Kong, Hong Kong
Email: support@focuslatex.com