Focus Technology: Privacy Statement

Protecting your personal information is important to us.  Focus Technology’s privacy statement informs you of how: (i) we collect, use, share, maintain, protect and disclose your personal information when you interact with our website or business (ii) use your personal information (iii) sell and/or share your personal information with third parties; and (iv) your available rights and choices in connection with your personal information.  You consent to our collection and use of your personal information as described herein.

Collection:

We collect personal  information from you that you choose to provide to us.

  • By way of example, you may contact us on our website requesting more information about our services and provide us your contact information, including but not limited to, name, email address and telephone number.

We collect personal information for job opportunities with us.

  • By way of example, when you apply for a job opportunity with us, you may be required to submit personal information, including but not limited to, name, telephone, resume, and mailing address.

We collect personal information as part of our commercial business function.

  • By way of example, including but not limited to, through providing IT outsourcing support services through our commercial business relationship with our customers, through alliances with our third party networks, and through investment opportunities. 

We collect personal information as part of our function as an employer.

  • By way of example, we collect personal information from our employees and contractors, including but not limited to, employment authorization, tax identification, and payroll and benefits administration.

We collect personal information about you from other third party sources.

  • By way of example, we may collect personal information about you from: (i) our corporate parents, subsidiaries or affiliates; or (ii) through our third party networks;  or (iii) through social media; or (iv) through investment opportunities; or (v) through our service providers and other customers that we have a business relationship /agreement.

We collect personal information through automatic data collection processes.

  • Our collection of information through automatic data technology collection tools on our website is limited to the use of collecting user statistics from Google Analytic. Google Analytics’ collection process may include collection of your personal information, including your IP address.  You may opt out of Google Analytics collection of your personal information, by visiting the Google Analytics Opt-Out Browser Add-on located here: https://tools.google.com/dlpage/gaoptout.

Use:

We may use your personal information for our legitimate business purposes, including but not limited to: (a) provide, maintain and administer our website, (b) for performance of our services or business agreements; (c) detect fraud and illegal activities; (d) monitor abuse; (e) protect yours/ours/third party rights, property, or safety; (f) investment opportunities and due diligence; (g) comply with law; h) enforce compliance with our terms of use, privacy statement and related policies; (i) communicating with you; and (j) perform out any other purposes described to you at the time that we collect your information.

Sale and Sharing:

We do not sell your personal information to a third party or share your personal information except as described in this Privacy Policy.  We may share your personal information with our third-party service providers who support our business operations.  We may share your personal information to an affiliate or successor entity as part of sale or reorganization transaction.  We may share your personal information  as necessary to comply with law, enforce our rights or protect the rights of others, and protect your security. We may share your personal information to perform our business agreements. We may also share your personal information with your consent.

Data Rights and Choices:

You may be afforded certain privacy rights depending on your jurisdiction and as permitted by law, including rights to (i) request and access what personal information we collect about you, (ii) the right to receive a copy of the information we collect about you, (iii) the right to update and/or correct your personal information, (iv) the right to have your personal information deleted,  (v) the right to restrict, opt out or object to our processing and/or sharing of your personal information with third parties, and (vi) the right to withdraw your consent; provided that withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. These rights may be limited by applicable law. For instance,  we may need to retain or share certain personal information for legitimate business purposes, to complete transactions you have requested, to comply with our legal obligations, and for other purposes as required or permitted by law.

In the event we send you marketing correspondence, you will also have the ability to opt out of future receipt of such communication directly within the correspondence.

Should you have any questions or comments about our Privacy Statement or want to exercise your privacy rights, please send us an e-mail to the attention of our CFO, Christopher Caprio, at ccaprio@focustsi.com,  or contact us at our mailing address at: Focus Technology Solutions, Inc., Attn: Legal, 99 High Street, Suite 3110, Boston, MA 02210. Please be aware that your request does not guarantee complete access or removal of your personal information as the law may not permit or require removal in certain circumstances.

Security and Data Retention:

We care about the security of your personal information and apply industry standard technical and organizational measures designed to protect your personal information that is under our control in for both the receipt and transmission of your personal information.  Notwithstanding the foregoing, we cannot guaranty your security and any information you provide us is at your own risk. 

We may retain your personal information for our legitimate business needs including, but not limited to, not communicate with you if you have asked us not to, to detect and prevent abuse of our website, illegal activities, to administer business agreements with you and third parties, and comply with applicable legal, tax or accounting requirements. When we have no legitimate business need to retain your information, we will either delete it in accordance with our internal policies  or take reasonable steps to de-identify your personal information in accordance with applicable law.

Third Party Websites:

Our Privacy Statement does not apply to information that you have provided or made accessible to third parties.   For example,  we utilize Twitter, Linkedin and Facebook so that you may comment on or like the information we share with you on our website.  Disclosure of your personal information to these third parties is subject to the relevant third party’s privacy policy.  We are not responsible for a third party’s use of your personal information as provided for in this Privacy Statement.

Children’s Personal Information:

Our website is directed to adults. We do not knowingly collect personal information on our website from children under the age of 13 or equivalent minimum age in the applicable jurisdiction.

Deidentified Personal Information:

Any personal information that we collect from you that is deidentified to remove and/or anonymize your personal information is not subject to any restrictions under this Privacy Statement.

Changes:

We may update this Privacy Statement in our sole discretion so you are encouraged to review it. When we make changes to this Privacy Statement, we will publish the date this Privacy Policy is last updated. By continuing to interact with our business, you agree to the revised Privacy Policy.

Contact:

If you have any questions or concerns about our Privacy Statement, please send us an e-mail to the attention of our CFO, Christopher Caprio, at ccaprio@focustsi.com,  or write us at our mailing address:
Focus Technology Solutions, Inc.,
Attn: Legal, 99 High Street,
Suite 3110, Boston, MA 02210.

Last Updated: October 12, 2020

©1998-2020 Focus Technology. All Rights Reserved.

Focus Technology: Terms of Use

These Terms of Use govern your use of our website. By accessing or using our website, you agree to these Terms of Use.

Disclaimer.  Our website  is for informational purposes only and does not convey legal, accounting, tax or other professional advice of any kind. Our website is provided on an “as is” and “as available” basis.  To the fullest extent permitted by law, we disclaim any and all, representations, endorsements, guarantees, and warranties, whether express or implied or statutory, including without limitation, the implied warranties of merchantability and fitness for a particular purpose, title and non-infringement of third-party rights.

Usage. We have the right to control access, hours of use, and any other information related to your use of our website and its content.  We may change, suspend, limit access or discontinue our website or its content at any time in our sole discretion without prior notice or liability.

Intellectual Property.  This website and all the information it contains is owned by and the property of Focus Technology and/or our third party content providers as applicable, and is protected from unauthorized copying and dissemination by US copyright law, trademark law, international conventions, and other intellectual property laws.  Nothing contained on this website should be construed as granting, any license or right to use this website or its content, without the prior written permission of Focus Technology or such third party content provider as applicable. You agree that your use of this Site will not infringe the rights of third parties. You agree that we are free to use on  an unrestricted basis any suggestions, ideas, comments or other submissions concerning our business, whether through this website or otherwise.

Limitation of Liability. Except to the extent contrary to applicable law, the liability of Focus Technology liability shall be limited to the fullest extent provided by law, and in no event will Focus Technology or it parents, affiliates, owners, officers, directors, shareholders or employees be liable for any direct, indirect, punitive, incidental, special or consequential damages arising out of or relating to these Terms of Use, whether based on warranty, contract, tort, or any other legal theory, even if advised of the possibility of any such damages.  Your sole remedy for dissatisfaction with this website is to stop using the website.

Indemnification. To the greatest extent permitted by law, you shall indemnify, defend and hold harmless Focus Technology and it parents, affiliates, owners, officers, directors, shareholders and employees for any and all claims, losses, liabilities, and expenses arising from your use of our website or your alleged or actual violation of these Terms of Use.

Third Party Sites. Our website may contain links to and/or third party sites as applicable.  We are not responsible for the contents of any third party site. The inclusion of any third party site does not imply our endorsement. These third parties may have their own terms and policies, and your use of them will be governed by those terms and policies.

Privacy Statement. Focus Technology’s Privacy Statement  is incorporated herein.

California Privacy Rights.  If you are a California resident, Focus Technology’s California Privacy Rights Statement is incorporated herein.

Code of Conduct. You agree that you will not use our website to: (1) collect, sell, share, or harvest information about other users; (2) Transmit any virus or other item or process to the website that in any way affects the use, or service of the website; (3) post any material on the website that is offensive to any other person and we reserve the sole right to determine what is offensive; (4) Post or store on the site any content that violates or infringes third party rights; (5) Copy, duplicate or otherwise modify our website or information on our website; (6) Engage in any action which we determine  is detrimental to the use and enjoyment of our website or use our website for any unlawful or defamatory means; or (7) Violate or attempt to violate security of our website.  We will investigate occurrences of possible violations and will cooperate with all applicable law enforcement authorities.

Compliance. You shall comply with all current or future laws, rules and regulations which govern or apply to the operation and use of this website. We make no representation that that our website or its content are appropriate or available for use in any particular jurisdiction.  You are prohibited from any use of this website or its content that is illegal, gives rise to liability or otherwise violates any applicable local, state, national or international law or regulation or that violates these terms.

Force Majeure.  Focus Technology shall have no obligation or liability in connection with an event beyond its reasonable control,  including, but not limited to, connectivity issues, computer viruses, unauthorized access, theft, operator errors, severe weather, earthquakes or natural disasters, pandemics, strikes or other labor problems, wars, terrorist activities or governmental restrictions.

Governing Law. This Terms of Use shall be governed by and construed in accordance with the laws of the State of Massachusetts, except with regard to its conflicts or choice of law rules.  Use of this website is unauthorized in any jurisdiction that does not give full effect to all provisions of these Terms of Use.

Entire Agreement. All rights not expressly granted herein are reserved by Focus Technology. This Agreement contains the entire agreement concerning your use of our website and its subject matter and supersedes all prior agreements. Neither the course or conduct between Focus Technology and you nor trade practice shall act to modify any provision of these Terms of Use.

Changes. We may modify these Terms of Use in our sole discretion.  You should periodically check these Terms of Use for changes. When we make changes to these Terms of Use, we will publish the date these terms of use are last updated. By continuing to use our website, you agree to the revised Terms of Use.

Contact. Any legal notice to us shall be given by courier to : Focus Technology Solutions, Inc., Attn: Legal, 99 High Street, Suite 3110, Boston, MA 02210. If you have any questions about these Terms of Use, please write us at the address listed above in this provision or send us an e-mail to the attention of our CFO, Christopher Caprio, at ccaprio@focustsi.com

Last Updated: October 12, 2020

©1998-2020 Focus Technology. All Rights Reserved.

CALIFORNIA PRIVACY RIGHTS

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 concerning Focus Technology’s practices regarding the collection, use, 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 that complies with the requirements of CCPA to verify a California Resident’s identity.  An agent 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 CFO, 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.  Focus Technology 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, 99 Hight Street, Suite 3110, Boston, MA 02210 or send us an e-mail to the attention of our CFO, Christopher Caprio, at ccaprio@focustsi.com or call us at 877-303-0480.

Last Updated: October 12, 2020

©1998-2020 Focus Technology. All Rights Reserved.

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