1. Who We Are
ftdboost Limited is a company registered in Malta (registration number: C 101385, VAT: MT28925804), with registered address at Triq il-Mahsel, Sea Star Court, Flat 3, MSK 3648 Marsaskala, Malta. We operate 24hrpage.com.
Contact: hello@24hrpage.com
ftdboost Limited has not appointed a Data Protection Officer, as the nature and scale of our data processing does not meet the threshold requiring mandatory appointment under Article 37 GDPR.
2. Data We Collect
We collect personal data in two distinct contexts.
A. From clients who place an order
When you submit our intake form, we collect your name, business name, email address, phone number, business address, opening hours, services, and any other details you provide in connection with your order.
B. From prospective clients we contact proactively (Article 14 notice)
We also collect publicly available business contact information, including business name, address, phone number, and email address, from publicly available business directory listings. We use this information to build speculative preview pages demonstrating what a professional website could look like for your business, and to make initial contact with businesses that appear to have no existing website.
If you are reading this policy because you received a call, message, or email from us, or because you discovered a preview page we created for your business, this paragraph applies to you. This notice is provided at the point of first contact in fulfilment of our obligations under Article 14 GDPR. You have the right to object to this processing at any time (see Section 9). You can also request removal of your preview page at any time by emailing hello@24hrpage.com.
3. Preview Pages
As part of our outreach activity, we create speculative preview pages for local businesses using publicly available information such as business name, location, phone number, and business category. These pages are hosted on preview.24hrpage.com and are intended to demonstrate the value of a professional website.
Preview pages are unofficial. They are not commissioned or approved by the businesses they feature. Each preview page carries a prominent disclaimer to this effect. Any business can request immediate removal of their preview page by emailing hello@24hrpage.com with the subject line "Remove my page" and we will action the request within 24 hours.
4. How We Use Your Data
For clients who have placed an order, we use your data to build and deliver your webpage, to communicate with you about your order, to send invoices and manage the care plan subscription, and to comply with our legal obligations.
For prospective clients we have contacted proactively, we use your contact information solely to make initial contact about our services and to host a preview page. We do not share this data with third parties for marketing purposes, and we do not contact you again after you object.
5. Legal Basis
For clients who have placed an order, processing is based on the performance of a contract (Art. 6(1)(b) GDPR) and, where applicable, compliance with a legal obligation (Art. 6(1)(c) GDPR).
For prospective clients contacted proactively, processing is based on our legitimate interests (Art. 6(1)(f) GDPR). Our legitimate interest is in marketing our web services to local businesses that demonstrably lack an online presence. We have assessed that this interest is not overridden by the rights and interests of the businesses we contact, given that: the data used is limited to publicly available contact information; the preview pages demonstrate a genuine potential benefit; every communication includes a clear opt-out; and we immediately cease all contact upon any objection. A full Legitimate Interests Assessment is maintained by ftdboost Limited and is available on request.
6. Third-Party Processors
We use the following third-party service provider who processes personal data on our behalf as a data processor:
Netlify (netlify.com) provides website hosting and infrastructure for 24hrpage.com and all published client websites. Netlify is a US-based company certified under the EU-US Data Privacy Framework (including the UK Extension) and additionally operates under Standard Contractual Clauses adopted pursuant to Commission Implementing Decision 2021/914. Both are recognised transfer mechanisms under Article 46 GDPR.
No personal data is sold to third parties or shared for advertising purposes.
7. International Transfers
Netlify is based in the United States. When personal data is processed by Netlify, it may be transferred to and stored on servers located outside the European Economic Area. These transfers are governed by Standard Contractual Clauses under Commission Implementing Decision 2021/914 and Netlify's EU-US Data Privacy Framework certification. Copies of applicable transfer documentation are available on request by emailing hello@24hrpage.com.
8. Automated Decision-Making
We do not carry out automated decision-making or profiling in relation to any personal data we process. No decisions with legal or similarly significant effects on individuals are made by automated means.
9. Your Rights
Under GDPR you have the right to access, correct, delete, or restrict processing of your personal data, and the right to data portability. To exercise any of these rights, contact us at hello@24hrpage.com. We will respond to all data subject rights requests within one month of receipt. In complex cases we may extend this period by a further two months, in which case we will notify you within the first month.
Right to object to direct marketing. Where we contact you for direct marketing purposes, you have an absolute right under Article 21(2) GDPR to object at any time. This right is unconditional: we are not permitted to refuse or override it. To exercise it, reply to any message you receive from us, or email hello@24hrpage.com with your name and the words "stop contact." We will cease all marketing contact immediately and delete your details from our outreach records within 5 business days.
You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (IDPC), which is the supervisory authority for Malta. The IDPC can be contacted at idpc.org.mt.
10. Retention
For clients who have placed an order, we retain your data for as long as necessary to fulfil your order and for 7 years thereafter for tax and accounting purposes under Maltese law, after which it is securely deleted.
For prospective clients we have contacted but who have not placed an order, we retain contact details for a maximum of 12 months from the date of first contact, or until you object, whichever is sooner. Upon objection we delete your details from our outreach records within 5 business days.
Preview pages for businesses that have not commissioned a website are removed within 24 hours of a removal request.
11. Cookies
24hrpage.com uses only essential functional cookies necessary for the website to operate correctly. These include session management tokens used to maintain form state and security. No advertising cookies, tracking cookies, or third-party analytics cookies are used. No consent is required for essential functional cookies under the ePrivacy rules transposed in Malta.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Where changes are material, we will notify affected individuals by email before the change takes effect. The date at the top of this policy reflects when it was last updated.