Throughout this Policy, the terms “we,” “us,” and “our” refer to Focus Finance and the terms “you” and “your” refer to any visitor to or user of the Focus Finance site or the Online Services.
Team Focus respects the privacy of its users.
Our goal is to provide you with a personalized Internet experience that delivers the information, resources and services that are most relevant and helpful to you. In order to achieve this goal, we sometimes collect information during your visits to understand what differentiates you from other users.
In order to demonstrate our commitment to your privacy, we have prepared this statement disclosing the privacy practices for the Focus Finance site. Additional terms and conditions, if any, regarding the collection and use of your information may also be provided to you before you sign up for a particular service.
What Information is Collected
Focus Finance may collect certain information from and about its users in two ways: 1) directly from the user and from our web server logs and 2) user-supplied information. When you submit a form we may ask you for your name, email address and some other personal information. The more accurate information you volunteer, the better we are able to customize your Focus Finance experience. The PII we may collect includes, but is not limited to, contact information (i.e. name, e-mail address, postal address, telephone number), employee identification numbers, government-issued identification numbers (i.e. social security numbers or driver’s license numbers), billing information (i.e., credit card or bank account information), as well as other information such as demographic data (i.e. gender and date of birth) and information specific to the type of insurance product requested or purchased, subject to the terms of this Policy, so that we can: (i) allow users with a username and password to access specialized portions of the Online Services; (ii) process payments; (iii) contact you to respond to inquiries related to the Online Services and/or related to purchasing products and services offered by or through Focus Finance; (iv) review, consider, and/or process applications and supplemental documentation submitted through the Online Services, and (v) communicate with you to provide you with relevant information about Focus Finance and the products and services it offers, including but not limited to, pricing, special promotions and discounts. In all of these cases, we will collect PII from you only if you voluntarily submit such information to us. Further, you agree that we may contact you based on the information you provide.
We may obtain information, including PII, from third parties and sources other than the Focus Finance site or the Online Services, such as our partners, vendors and credit reporting agencies. If we combine or associate information from other sources with PII that we collect through the Focus Finance site or the Online Services, we will treat the combined information as PII in accordance with this Policy.
The Website Is Not Intended For Use By Individuals Under 18 Years of Age
No one under the age of 18 may provide any personal information on or through the Focus Finance site or the Online Services. We do not knowingly collect personal information, including PII, from anyone under 18. If you are under 18, do not: (i) use or provide any information on the Focus Finance site or the Online Services or, on or through any of the features available on the Focus Finance site or the Online Services; (ii) use any interactive features on the Focus Finance site or Online Services; or (iii) provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information, including PII from an individual under 18 without verification of parental consent, we will take appropriate steps to delete that information. If you are a parent or guardian and believe we might have any information from or about an individual under 18, please contact us via email at TFIGPrivacyOffice@teamfocusins.com.
To the extent a minor has posted such content on the Focus Finance site or the Online Services, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Policy. If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section of this Policy. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
When you visit an internet website, you disclose certain information about yourself, such as your internet [Protocol] (IP) address, the time of your visit and the referring location (e.g., the site or page that offered a link to a Focus Finance page). Focus Finance, like many other sites, records this basic information about visits to its site. You should remember that whenever you voluntarily disclose PII online, your information can be collected and used by others. Although Focus Finance tries to protect your PII, Focus Finance cannot ensure or warrant the security of any PII you transmit to us, and you do so at your own risk. You are also solely responsible for maintaining the secrecy of any passwords you set up and/or any account information.
How and When Information is Used
We use information in different ways, depending on the type of information: 1) User-supplied information: This information is used for purposes such as personalization and verification; and 2) Web server logs: This information helps us identify which areas of our site are of interest to our visitors. Focus Finance also collects the Internet [Protocol] (IP) addresses of its visitors for the purposes of system administration.
How We Protect Your Information
The privacy and protection of your PII is vitally important to us. Focus Finance does not make PII available to any third parties without your permission. Any user statistics that we may provide to prospective partners regarding your Focus Finance usage are provided in the aggregate only and do not include any personally identifiable information about any individual user.
Your access to some services and content is password protected. We recommend that you do not divulge your password to anyone. Focus Finance will never ask you for your password in an unsolicited phone call or in an unsolicited email. You should not disclose your username and password to others.
In addition, if applicable, you should remember to sign out of your Focus Finance account or service at the end of each session. You may also wish to close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or internet cafe.
No data transmission over the internet can be guaranteed to be 100% secure. Accordingly, despite our efforts to protect your PII, Focus Finance cannot ensure or warrant the security of any information you transmit to us. You transmit all such information at your own risk. However, once we receive your transmission, we make our best effort to ensure its security on our systems.
Who Has Access to the Information?
Except as described in this Policy, or as otherwise permitted by law, Focus Finance will reasonably attempt to ensure that it will not willfully disclose any PII or other individually identifiable information about its users to any third party without first receiving that user’s permission through your opting in or otherwise agreeing to the disclosure of such information.
Links to Other Sites
We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Google, Apple, Microsoft and Facebook or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any PII you disclose through or in connection with the Apps or our Social Media Pages.
Retention of Information
We only retain your PII for as long as we need it to fulfill the purposes for which we have initially collected it, or such longer period as may be required by applicable law pertaining to records retention for our industry. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are located outside the United States, we may transfer, process and store PII we collect from you through the Online Services in centralized databases and with service providers located in the United States.
We comply with the US-EU Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Customers in the European Union member countries and Switzerland. We have certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this Policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.
The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield.
We may provide PII to third parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, we may store such PII in the facilities operated by third parties. Such third parties must agree to use such PII only for the purposes for which they have been engaged by us and they must either:
- Comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of PII; or
Data Controller and Data Processor
We process PII as both a processor and a controller as defined in the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”). For those located in the European Union, all processing of PII performed in accordance with privacy rights and regulations in accordance with the GDPR.
For those located in the United States, we process data solely in data centers located in the US. We have adopted reasonable physical, technical and organizational safeguards that substantially mirror the European Union safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the data in our possession. Our policy is to protect and safeguard any PII we obtain in accordance with United States state or federal laws governing the protection of personal information and data. Accordingly, we adhere to practices and policies that aim to safeguard the data.
Lawful basis for the processing
Generally, we process PII provided by visitors through the Focus Finance site or the Online Services on the basis of consent.
We may also process PII on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for us to comply with our legal obligations.
At any point while we are in possession of, or processing your PII, you, the data subject, have the following rights:
- Right of access: You have the right to request a copy of the data we hold about you. Please contact us at TFIGPrivacyOffice@teamfocusins.com if you wish to access the personal information we hold about you.
- Right of rectification: You have the right to correct data we hold about you that is inaccurate or incomplete. If that data has been passed on to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact us at TFIGPrivacyOffice@teamfocusins.com if you need us to rectify any of your information.
- Right to be forgotten: This is sometimes called the ‘right to erasure.’ In certain circumstances, you can ask for the data we hold about you to be erased from our records. If you want us to erase some or all of your PII, and we do not have a legal reason to continue to process or hold it, please contact us at TFIGPrivacyOffice@teamfocusins.com.
- Right to restriction of processing: You have the right to ask us to restrict how we process your data. This means we are permitted the store your data, but not further process it. We will keep just enough data to make sure we respect your request in the future. If you want the us to restrict the processing of your data, please contact us at TFIGPrivacyOffice@teamfocusins.com.
- Right of portability: We are required to allow you to obtain and reuse your PII for your own purposes across multiple services in a safe and secure way without affecting the usability of your PII. If you want information on how to port your data to another organization, please contact us at TFIGPrivacyOffice@teamfocusins.com. Please note that this right only applies to PII that you have provided to us as the Data Controller and that this data must be held by us by either your consent or for the performance of a contract.
- Right to object: You have the right to object to us processing your PII, even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation) and the processing for the purposes of statistics. If you wish to object to the processing of your PII, please contact us at TFIGPrivacyOffice@teamfocusins.com.
- Right to object to automated processing, including profiling: You have the right not to be subject to the legal effects of automated processing or profiling. If you wish to object to the processing of your PII, please contact us at TFIGPrivacyOffice@teamfocusins.com.
- Right to review: In the event we refuse your request under any of the above rights, we will provide you with a reason as to why. You will also have the right to lodge a complaint, as outlined below.
- Right to withdraw consent: If you have given us your consent to process your PII but change your mind later, you have the right to withdraw your consent at any time and we must stop processing your data upon request. If you wish to withdraw your consent, please contact us at TFIGPrivacyOffice@teamfocusins.com.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Should we determine that you are not entitled to exercise that right, we will provide you with the reason(s) for the denial. Also, please note that the erasure of your data may be subject to our records retention policy or applicable law. Should the data you seek to have erased fall within an area where we are under a legal requirement to retain such data for a certain period of time, we will retain that data in accordance with our legal obligations.
You may decline to share certain PII with us, in which case we may not be able to provide to you some of the features and functionality of the Focus Finance site or the Online Services.
At any time, you may object to the processing of your PII, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at TFIGPrivacyOffice@teamfocusins.com. You also have a right to lodge a complaint with data protection authorities.
Electronic Communications and Opting in and Opting Out
When you communicate with us electronically, via e-mail or otherwise, you consent to our use of the information you have provided, and you further consent to receive electronic communications from us. If you would prefer not to receive such communications, you can opt out of/unsubscribe to our e-mail lists by clicking on the “opt out”/“unsubscribe” line at the bottom of the e-mail you receive from us. You should be aware, however, that (i) it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request, and (ii) we are unable to have your information removed from the records of any third party who has been provided with your information in accordance with this Policy. Further, if you elect to opt-out of receiving commercial email from us or otherwise modify the nature or frequency of communications you receive from us; it may take up to thirty (30) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Online Services.
Cookies and Other Technologies
Additionally, we may use IP address information to count and track aggregate visits to the Focus Finance site, to help diagnose problems with our server, and to administer the Focus Finance site or the Online Services. We do not link IP addresses to anything personally identifiable, so while a particular user’s session can be tracked, the user remains completely anonymous.
Reviewing, Correcting or Requesting that We Discontinue use of Your PII
If you would like to review the current details of your PII or the PII submitted by you, or if you would like us to either change, or discontinue use of, your PII or other PII submitted by you, please contact us at: TFIGPrivacyOffice@teamfocusins.com.
Please note that while any changes you make will be reflected within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain PII with us, in which case we may not be able to provide to you some of the features and functionality of the Focus Finance site or the Online Services.
At any time, you may object to the processing of your PII, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at: TFIGPrivacyOffice@teamfocusins.com. You also have a right to lodge a complaint with data protection authorities.
We welcome any questions or comments you have about the Focus Finance site or the Online Services.
Changes to the Policy
We encourage you to review the Policy not just the first time you visit the Focus Finance site or utilize the Online Services but periodically afterwards since we may modify the Policy from time to time. The date of the last update of the Policy will always be posted below:
This Policy was Last Revised on July 31, 2020.
If we make any substantive changes to our Policy in the future with regard to how we use PII, we will incorporate those changes here. Your continued use of the Online Services after the changes are posted constitutes your agreement to the changes, both with regard to information we have previously collected from you and with regard to information we collect from you in the future. If you do not agree to the changes, please discontinue use of the Online Services. Lastly, if Focus Finance is sold or merged with another company, your PII and any other PII submitted by you may be included as part of the sale. In this case, your PII and the PII submitted by you will be maintained in the same manner as described in this Policy unless you are notified that this Policy has been changed.
How to Contact Us
P.O. Box 45-9003
Sunrise, FL 33345-9003.