PRIVACY POLICY
Last Updated: March 26, 2025
INTRODUCTION
Focus Connect LLC (“FocusConnect,” “we,” “our,” or “us”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit www.focusconnect.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Privacy Policy applies to information we collect:
- On this Website
- In email, text, and other electronic messages between you and this Website
- When you interact with our advertising and applications on third-party websites and services
Please read this Privacy Policy carefully to understand our policies and practices regarding your information. By accessing or using this Website, you agree to this Privacy Policy. If you do not agree with our policies and practices, you may choose not to use our Website. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy section below).
INFORMATION WE COLLECT
We collect several types of information from and about users of our Website, including:
Personal Information
Personal information is information that identifies you as an individual or relates to an identifiable individual. We may collect:
- Contact information (name, email address, postal address, telephone number)
- In order to utilize various features of the Website, FocusConnect may require you to submit certain personally-identifiable information, such as your name, telephone number, mailing address, e-mail address, and/or other information which is specific to you. You can choose whether or not to provide us this information but doing so may diminish your experience with the Website, as certain functions may be unavailable or may not work as intended.
- Location information
- In order to for you to utilize various features of the Website, FocusConnect may need to collect information concerning your location. Some devices permit users to disable this feature, but doing so may diminish your experience with the Website, as certain functions may be unavailable or may not work as intended.
- Communication preferences
Non-Personal Information
- Browser and device information
- IP address
- Unique Device Identifier (UDI)
- Operating system
- Page views and Website navigation
- Aggregated or anonymized usage statistics
Information Collection Methods
Information You Provide Directly: We collect information that you provide directly when you:
- Complete forms or surveys
- Correspond with us
- Sign up for newsletters or marketing communications
- Submit feedback or customer service requests
Automated Collection Methods: We also collect information about your visits through:
- Cookies and similar technologies
- Web beacons
- Log files
- Google Analytics and similar services
FocusConnect may obtain certain generic information about you when you use the Website. This may include your IP address, Unique Device Identifier (“UDI”) and arrival time. The UDI reveals nothing personal about the user other than the UDI from which the user has accessed the Website. We may use this information to examine aggregate Website traffic, but FocusConnect does not collect or evaluate this information regarding individuals.
FocusConnect may use “cookies” to track use of the Website. You can manage your cookie preferences through your browser settings. A cookie is a small alphanumeric identifier that your browser stores on your computer’s hard drive when you visit the Website. Consequently, we can enhance your future use of the Website by identifying features of the Website that you have used previously. You can remove or disable cookies at any time.
The Website may also contain electronic images known as “clear gifs” or “web beacons.” Web beacons collect limited information such as the time and date of a page view, and a description of the webpage on which the web beacon resides. Web beacons do not contain any personally identifiable information and are used by FocusConnect solely to monitor use of the Website.
HOW WE USE YOUR INFORMATION
We may use information we collect for the following purposes:
Business Purposes
- Providing you with products, services, or information you request
- Responding to your inquiries and customer service requests
- Personalizing your experience and delivering content relevant to your interests
- Improving our Website, products, and services
- Developing new products, services, or features
- Protecting the security and integrity of our Website and business
- Conducting data analytics and research
- Complying with legal obligations
Marketing Purposes
- Sending marketing communications about our products and services
- Providing news and information we think will be of interest to you
- Conducting surveys and collecting feedback
- Communicating about promotions, events, or other initiatives
You may opt out of receiving marketing communications from us by following the unsubscribe instructions included in each promotional email, adjusting your communication preferences in your account settings, or contacting us as described in the “Contact Us” section below.
LEGAL BASIS FOR PROCESSING (FOR EEA USERS)
If you are in the European Economic Area (EEA), we process your personal information based on one or more of the following legal grounds:
- Performance of a Contract: To perform our contractual obligations to you, including providing our services and processing transactions.
- Legitimate Interests: For our legitimate interests, such as improving our services, marketing, preventing fraud, and ensuring the security of our systems, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.
- Compliance with Legal Obligations: To comply with laws, regulations, court orders, or other legal obligations.
- Consent: Based on your consent, such as for sending marketing communications or tracking your Website usage via cookies. Where we rely on consent, you have the right to withdraw your consent at any time.
DATA SHARING AND DISCLOSURE
We may share your personal information in the following circumstances:
Service Providers
We share information with third-party service providers who perform services on our behalf, such as:
- Data analytics
- Email delivery
- Customer service
- Hosting services
- Marketing assistance
These service providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
Legal Requirements and Business Transfers
We may disclose information:
- To comply with any court order, law, or legal process, including responding to government or regulatory requests
- To enforce or apply our Terms of Use and other agreements
- To protect the rights, property, or safety of FocusConnect, our customers, or others
- In connection with a business transaction such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FocusConnect’s assets
Categories of Third Parties
The categories of third parties with whom we may share personal information include:
- Marketing and advertising partners
- Professional service providers (e.g., consultants, lawyers, accountants)
DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider:
- The amount, nature, and sensitivity of the personal information
- The potential risk of harm from unauthorized use or disclosure of your personal information
- The purposes for which we process your personal information and whether we can achieve those purposes through other means
- Applicable legal requirements
When we no longer need your personal information, we will securely delete or anonymize it. If this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
DATA SECURITY
We have implemented appropriate technical and organizational measures designed to protect the security of your personal information. However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We utilize the following security measures:
- SSL encryption for data transmission
- Access controls for sensitive data
- Regular security assessments
- Employee security training
- Multi-factor authentication for administrative access
- System monitoring and logging
In the event of a data breach that compromises your personal information, we will notify you and relevant authorities as required by applicable law.
YOUR PRIVACY RIGHTS
Depending on your location, you may have certain rights regarding your personal information:
For All Users
- Access: You can request access to your personal information we hold.
- Correction: You can request correction of inaccurate personal information.
- Opt-out: You can opt out of marketing communications.
For California Residents
California’s Online Privacy Protection Act requires us to disclose how we respond to “do not track” requests and other similar mechanisms. Our current policy is that we do not recognize “do not track” requests from Internet browsers and similar devices.
Additional, pursuant to California’s “Shine the Light” law, California residents who provide personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us (once per calendar year) information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2015 will receive information regarding 2014 sharing activities).
To obtain this information with respect to FocusConnect, please send an e-mail to (privacy@focusconnect.com) with “Request for California Privacy Information” in the subject line and in the body of your message. We will respond to your e-mail address with the requested information. Please note that only certain information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
INTERNATIONAL DATA TRANSFERS
We are based in the United States and process information on servers located in the United States. If you are located outside the United States, your information may be transferred to, stored, and processed in a country that may not provide the same level of data protection as your home country.
Because the Website is accessible globally, you agree to comply with all local rules regarding online conduct. Specifically, you agree to adhere to all applicable laws regarding the transmission of technical data exported to or from the United States or the nation in which you reside.
Additionally, for users visiting us from a country within the European Union, please note that FocusConnect may transfer your personally identifiable data outside the European Union for use for any of the above-described purposes. By using the Website and providing FocusConnect with your personal data, you consent to such transfer of your personal data.
CHILDREN’S PRIVACY
Our Website is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from a child under 13, please contact us.
Parents should be aware that in addition to governing our use of personal information, this Privacy Policy will also apply to information that is voluntarily given by children (or others) that may be used by third parties to generate unsolicited communications. FocusConnect encourages all parents to teach their children regarding protection of their personal data and responsible use of the Internet.
THIRD-PARTY WEBSITES AND SERVICES
Our Website may contain links to third-party websites and services. This Privacy Policy does not apply to those websites and services. We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third-party websites you visit.
CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email (if you have provided one) or by posting a notice on our Website prior to the change becoming effective. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.
GOVERNING LAW AND JURISDICTION
This Privacy Policy is governed by the laws of the State of Colorado, without regard to its conflict of law provisions. You agree to submit to the personal and exclusive jurisdiction of the courts located in Denver, Colorado for any disputes arising out of this Privacy Policy or your use of the Website.
CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
By Email: privacy@focusconnect.com
By Mail:
FocusConnect
5155 Clarkson St.
Denver, CO 80216
Attn: Privacy Officer
YOUR CHOICES
You have several choices regarding how we use your information:
- Configure your browser to reject cookies
- Opt out of marketing communications
- Request access to or deletion of your data
- Update your account information
- Disable location services on your device
We will respond to your requests within the timeframe required by applicable law.