California Privacy Rights

Last Updated: February 10, 2025

I. California Shine the Light Disclosure

Focus Technology does not share personal information of California residents with third parties for their own direct marketing purposes.

II. California Do Not Track Disclosure

Focus Technology does not recognize or respond to your browser’s Do Not Track signals.

III. California Consumer Privacy Act (“CCPA”) Notice

This Privacy Notice applies to California Residents only and is effective January 1, 2020. The purpose of this Privacy Notice is to provide California residents information disclosure, and sale of personal information and of the rights of California Residents regarding their personal information. This Privacy Notice shall be reviewed annually and updated as required.

A. Focus Technology Collection Practice.

Focus Technology’s collection practice (including the preceding 12 months) is described below:

Categories of Personal Information Collected/Disclosed Examples Business Purpose Third Parties Categories for Disclosure Sources for Collection Categories
Identifiers name, email address and telephone number. For Focus Technology to provide its services and perform our business agreements or fulfill the purpose for which personal information was provided. Security Compliance and Legal Service Providers Business Partners California Resident directly Our Customers Advertising networks Social networks Operating Systems and Platforms Service Providers Business Partners
Commercial Information Your interaction with Focus Technology and the commercial services provided For Focus Technology to provide its services and perform our business agreements or fulfill the purpose for which personal information was provided. Security Compliance and Legal Service Providers Business Partners California Resident directly Focus Technology and its affiliated companies directly Our Customers Advertising networks Social networks Operating Systems and Platforms Service Providers Business Partners
Geolocation Information, and Internet activity IP address and physical location and Focus Technology ability to access a consumer’s visit and history in interacting with our website to provide our service offering. Providing information, products or services from Focus Technology and perform our business agreements or fulfill the purpose for which personal information was provided Security Compliance and Legal Service Providers Business Partners California Resident directly Focus Technology and its affiliated companies directly Our Customers Advertising networks Social networks Operating Systems and Platforms Service Providers Business Partners
Job Applicant and Employment Information Your resume, and information related to employment. Administer job applicant tracking and administer employment and perform our business agreements Security Compliance and Legal Service Providers California Resident directly Social Networks Advertising Networks Operating systems and platforms Service Providers

B. Sale of California Resident Personal Information

Focus Technology does not sell and has not sold California Resident personal information in the preceding twelve (12) months.

C. Access and/or Deletion Requests

A California Resident, or its authorized agent, can request access to the personal information Focus Technology collects about them over a 12 month period preceding the request, as well as request Focus Technology to delete personal information concerning them regardless of time period. In connection with an access request, Focus Technology is required to disclose the following information: (i) The categories of California Resident personal information Focus Technology sells or discloses for a business purpose; (ii)The categories of California Resident personal information Focus Technology collects; (iii) The categories of sources for California Resident personal information Focus Technology collects; (iv) Focus Technology business purpose for collecting or selling California Resident personal information; (v) The categories of third parties with whom Focus Technology sold or disclosed for a business purpose California Resident personal information; and (vi) The specific pieces of personal information Focus Technology collected about the California Resident.

A California Resident, or its authorized agent, can request that Focus Technology delete any personal information about them, including notifying any third party to delete the personal information of the California Resident whom Focus Technology shared personal information with.

As both access and deletion requests from a California Resident are subject to certain exemptions under CCPA, Focus Technology may deny certain aspects of access and deletion requests from a California Resident.

D. Verification

In order for Focus Technology to process an access and/or deletion request from a California Resident, Focus Technology must first verify the California Resident’s identity and /or the identity of the agent representing the California Resident. To verify a California Resident’s identity, Focus Technology will attempt to match data already maintained by Focus Technology within its business about the California Resident. If Focus Technology cannot verify the identity of a California Resident on the basis of the initial submission from the California Resident, Focus Technology may request additional information or utilize a third-party identity verification service identity. Anagent acting on behalf of a California Resident must submit a power of attorney in accordance with California Probate Code in order for the California Resident’s request to be processed otherwise a California Resident must verify their identify directly with Focus Technology and must confirm directly with Focus Technology that the agent has been authorized to act on the California Resident’s behalf in writing.

A California Resident, or its authorized agent, will submit an access or deletion request to Focus Technology through one of the following means: (i) calling Focus Technology at the following toll free telephone number: 877-303-0480 (ii) emailing us to the attention of our CEO, Christopher Caprio, at ccaprio@focustsi.com; or (iii) filling out and submitting the Focus Technology online form located here.

Focus Technology will acknowledge a California Resident or its agent’s request within 10 business days of receipt and provide information to the California Resident concerning how the request will be processed and expected timeframe to process. FocusTechnology will respond to a California Resident’s request within forty-five (45) days of receipt, unless Focus Technology requires additional time up to process the request, up to an additional 45 days, which Focus Technology will inform the California Resident of the additional time period to answer the request and the reason additional time is necessary.

Focus Technology will deliver its written response via mail or electronically to the California Resident. Responses to California Residents electronically are portable and in a readily useable format. Focus Technology does not charge a fee to process or respond to a California Resident’s request unless the request occurs more than twice in a twelve (12) month period for any individual California Resident.

E. Non-Discrimination.

Focus Technology does not discriminate against California Residents for exercising any of their CCPA rights.

F. Privacy Notice Amendments

Focus Technology reserves the right to amend this California Privacy Rights Policy at its discretion and at any time. When we make changes to this California Privacy Rights Policy, we will publish the date this California Privacy Rights Policy is last updated. By continuing to interact with our business, you agree to the revised California Privacy Rights Policy.

G. Contact Information.

For questions or comments about this California Consumer Privacy Act Notice, or to obtain alternate formats of this California Consumer Privacy Act Notice available to California Residents with disabilities, please do not hesitate to contact Focus Technology by writing us at Focus Technology Solutions, Inc., Attn: Legal, 10 Post Office Square, Suite 1005, Boston, MA 02109. or send us an e-mail to the attention of our CEO, Christopher Caprio, at ccaprio@focustsi.com or call us at 877-303-0480.