Privacy Statement

Last Updated: February 10, 2025

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 personalinformation 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 personalinformation. 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 anyprocessing 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 beaware 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 CEO, Christopher Caprio, at ccaprio@focustsi.com, or write us at our mailing address: Focus Technology Solutions, Inc., Attn: Legal, 10 Post Office Square, Suite 1005, Boston, MA 02109.