Privacy Policy Notice

The policy: This privacy policy notice is served by Onfocus Tech Ltd with Registered Address of Cheltenham Film Studios, Hatherley Lane, Cheltenham, Gloucestershire, United Kingdom, GL51 6PN under the website www.funkyfreebies.co.uk. The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website. If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.

Effective date: 29 September 2026

Policy key definitions:

  • "I", "our", "us", or "we" refer to the business, Onfocus Tech Ltd.
  • "you", "the user" refer to the person(s) using this website.
  • GDPR means General Data Protection Act.
  • PECR means Privacy & Electronic Communications Regulation.
  • ICO means Information Commissioner's Office.
  • Cookies mean small files stored on a users computer or device.

Key principles of GDPR:

Our privacy policy embodies the following key principles; (a) Lawfulness, fairness and transparency, (b) Purpose limitation, (c) Data minimisation, (d) Accuracy, (e) Storage limitation, (f) Integrity and confidence, (g) Accountability.

Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

  • We are registered with the ICO under the Data Protection Register, our registration number is: ZA447038.
  • Lawful basis: Consent
    Where our purpose for processing is: Personalised email marketing
    Which is necessary because: You have asked to be sent emails with new offers, freebies and deals. This was via our website subscription form which contained an explanation that you would receive emails, was affirmed by your click on the button and had a clear link to this privacy policy.
    We process your information in the following ways: Your email address, the answers you gave on the signup form, and a record of your consent (the wording you agreed to, when, and the IP address and browser it came from) are stored in our own subscriber database, hosted on Microsoft Azure. We then send emails to you on a regular basis. Our emails may contain advertising on behalf of our clients of products or services in the categories: Automotive, Entertainment, Finance, Gambling, Health & Fitness, Insurance, Learning, Lifestyle, Retail, Travel, Utilities.
    Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
    Sharing your information: We do not sell or share your information with third parties for their own use. Our emails are sent through Postmark, which processes your email address and email activity on our behalf and under our instructions only.
  • Lawful basis: Legitimate interests
    Where our purpose for processing is: Advertising
    Which is necessary because: To allow us to publish a website with the best offers & perform as a profitable company.
    We process your information in the following ways: We re-target users by placing cookies from Google.
    Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
    Sharing your information: We do not share your information with third parties.
  • Lawful basis: Legitimate interests
    Where our purpose for processing is: Analytics
    Which is necessary because: To allow us assess the most popular offers and optimise our website.
    We process your information in the following ways: Usage data is recording using Google services, although no personally identifiable information is included. This includes the use of AMP Client ID to help identify you between website visits.
    Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
    Sharing your information: We do not share your information with third parties.

If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

Your individual rights

Under the GDPR your rights are as follows. You can read more about your rights in details here;

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO www.ico.org.uk if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR.

To act on any of your rights, please contact us via email to data-protection@onfocus.tech

Internet cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.

Some cookies are required to enjoy and use the full functionality of this website.

Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser provides controls to block and delete cookies on your device - please see your web browser options.

Data security and protection

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

Fair & Transparent Privacy Explained

We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

Sponsored links, affiliate tracking & commissions

Our website contains adverts, sponsored and affiliate links on some pages. These are typically served through our advertising partners including but not limited to Google AdSense, eBay Partner Network, Amazon Affiliates, or are self served through our own means. We only use trusted advertising partners who each have high standards of user privacy and security. However we do not control the actual adverts seen / displayed by our advertising partners. Our ad partners may collect data and use cookies for ad personalisation and measurement. Where ad preferences are requested as 'non-personalised' cookies may still be used for frequency capping, aggregated ad reporting and to combat fraud and abuse.

Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. You can read more about cookies on this website above. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you.

We use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.

If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website.

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Your subscription is held in our own database, and our emails are sent through Postmark, an email delivery service that acts as our processor.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. You can withdraw your consent at any time using the unsubscribe link in any of our emails. To change your preferences, or to access, correct or delete the information we hold about you, email data-protection@onfocus.tech.

Changes to this privacy policy

We may update this Privacy Policy Notice from time to time to reflect changes in our services, legal requirements, or data practices. The latest version will always be published on our website with an updated effective date.

Resources & further information