Customer Personal Information We Collect Directly:

In order to operate our Website or serve our Customers, Focus USA will collect various information, including:

• Business professional information including your name, role or title, company email, company name, and company website URL.
• Correspondence, which may include any personal information provided during an email correspondence or customer service engagement.
• Billing, payment, and administrative finance information.
• Information about visitors to our Website and how our Customers use our Services, including time spent on our applications, behavioral activity, and metadata associated with software interactions. Please see ‘Cookies and Other Tracking Technologies’ below for more information.
• Applications for employment, including any associated information.

End Consumer Personal Information Our Customers Provide Through Our Business Services:

When our Customers use our Business Services, they may enable Focus USA to process various types of personal information on their existing customers, or end consumers (“End Consumers”). Below, we provide a list of the commonly processed personal information of End Consumers. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.

• Contact information such as name, role or title, employer, business email address, and business phone number.
• Lists of email addresses and information associated with email correspondence.
• Lists of phone numbers. (Note: Focus USA does not provide telemarketing services.)
• Proprietary information about their business relationships, including historical transactions, engagements, communications, and notes about correspondence.
• We also collect information on business activities, including engagement rates, number of leads generated, which campaigns are functioning best, conversion rates, and trends.

We do not intentionally collect any personal information from children under the age of 16. If you believe we have obtained personal information associated with children under the age of 16, please contact us at privacy@focus-usa.com, and we will delete it.

Subject to the terms of our client agreements, we may use personal information for the following purposes:

• To provide our Business Services, including:
  • Identifying and enabling engagement with prospective customers through our data acquisition and enrichment services;
  • Synchronizing data between disparate data sources, such as matching email addresses with postal addresses;
  • Providing data correction, data hygiene, and assisting with fulfillment of marketing campaigns;
  • Creating compelling and relevant content for sales and marketing outreach; and
  • Measuring marketing, advertising, sales and communications performance.
• Customer support, including email and chat.
• To improve our Services, for example, we may modify our Website user interface based on user behavior.
• To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.
• Aggregated or anonymous information about the various types of information, integrations, metadata and performance metrics to ensure our Services are serving their intended purposes and for product improvements.
• For any legal purpose necessary, including IP protection, or if Focus USA is required to process information as a result of a court order or other legal or regulatory proceeding.

Our Services provide Customers with the ability to synchronize certain external software or data applications with Focus USA, which may include the transfer of personal information. Some of the types of applications are:

• Cloud Or Other Storage Services.
• Customer Support.
• Customer Relationship Management.
• Call Centers.
• Email Service Providers.

Subject to client agreements, we may disclose Customer or End Consumer information in order to:

• Protect the legal rights of our company, our employees, our agents, and our affiliates.
• Protect the safety and security of those who access and use our Services.
• Detect and protect against fraud.
• Comply with law or legal process.
• Complete a legal transaction related to the sale of our business or any assets.

Focus USA may share aggregate or anonymous information for any purpose. This means that the information we share does not identify specific individuals, or is combined with other data to protect your privacy.

With respect to our Business Services (versus our Data Broker Activities which are subject to a separate privacy policy here), we provide our Customers with the right to exercise the following choices with our use of your personal information:

• Access the personal information we maintain about you.
• Delete the personal information we maintain about you. Please note that we reserve the right to retain any information necessary to comply with our legal obligations, including financial reporting.
• Correct inaccurate personal information we maintain about you.
• Opt out of certain uses of your personal information, notably:
  • Marketing Emails: To opt out of marketing e-mail communications, you may click the ‘unsubscribe’ link in the marketing emails.
  • Tailored Advertising Using Cookies: Refer to our list of advertising services below for company-specific choices, or visit http://optout.aboutads.info to exercise an industry-wide opt-out. In addition, you may reject or delete cookies through your browser settings.

You can exercise these rights by contacting us at privacy@focus-usa.com or through your account representative. Please do not contact us at this email address for consumer data broker-related opt-out requests, but rather visit our Privacy Center.

If you are a current or former employee of one of our Business Services Customers, and you would like to fulfill your rights to the personal information we maintain about you on behalf of our Customer, please contact a representative of that Customer rather than email us with your request. We cannot provide personal information about a specific individual on behalf of a Customer without their express written instructions.

Like many companies, we use cookies, pixels, and other tracking technologies to collect information about your browsing activities, your interactions with our Website or emails, and to serve tailored ads on our advertisers behalf through other websites. There are a number of ways to opt out of having your online activity and device data collected through these Services for our advertising purposes, which we summarize below.

1. Tailored advertising using your email address. If Focus USA has collected your email address, it may be used for tailored advertising on other websites, including through social media such as LinkedIn. To opt out of this use, please email us at the email address above.
2. Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info.
3. With Each of Our Vendors Individually. The following advertising or marketing service partners offer opt-out features that let you opt-out of use of your information for interest-based advertising or profiling:

Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure. Choose an account password that is hard for others to guess and don’t reveal it to third parties. If you use a shared public computer, do not opt to have your login ID or password remembered and be sure to log out of your account when you finish.

We will retain Customer personal information, including End Consumer information, according to the terms of our written agreements, and then for a minimum of five years in accordance with our Customer retention policy.

Certain U.S. states have enacted comprehensive privacy laws that create additional privacy obligations for businesses and provide their residents with additional privacy rights, including: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

While most of these privacy rights are associated with our Data Broker Activities which are referenced in our Data Broker Privacy Notice, the following state-specific rights may apply to our Website and Business Services.

Additional Privacy Rights:

In addition to the rights granted above, if you are a resident of a state with enhanced privacy rights, you may also have the right to:

1. Opt out of the “sale” or “sharing” of your personal information for the purpose of cross-context behavioral or targeted advertising. Please visit our ‘Cookies and Other Tracking Technologies’ section above to exercise your rights.
2. Sensitive Personal Information. Focus USA does not collect or ‘sell’ sensitive personal information associated with our Website or Business Services. Please review our Data Broker Privacy Notice for more information about potential sensitive personal information associated with consumers.
3. Portability. Any information we provide to you as part of a ‘Right To Know’ or ‘Access’ request will be in a readily usable format.

Focus USA does not ‘sell’ any personal information associated with our Business Service Customers other than through the use of Cookies as referenced above. If you would like to exercise your consumer rights related to the ‘sale’ of your personal information in association with our Data Broker Activities, visit the ‘Your Privacy Choices’ webform.

Appeal:

If we deny your privacy request, you may appeal that decision by emailing us at privacy@focus-usa.com. If you are still unsatisfied with our response, you may have the right to file a complaint with your state attorney general.

Focus USA exclusively operates and stores personal information in the United States. While we welcome international business customers to use our Business Services, we do not intentionally collect, use, or sell personal information associated with individuals whose residence is outside of the United States.

The Services may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of any other site that collects personally identifiable information.

We may update this Privacy Policy from time to time as we update or expand our Services. If we make material changes, we will post the updated Privacy Policy on this page with a ‘Last Updated’ effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

If you have any questions about our privacy or security practices, or if you are a Focus USA Customer and would like to request access to or correction of your personal information, you can contact us by email at privacy@focus-usa.com or at:

Focus USA Privacy Office
PO BOX 1782
Paramus, NJ 07653-1782