- Personal data that users of our services (“Customers“) ask us to process on their behalf (“Processor data“), which will include any personal data that customers provide to us to transcribe, caption, translate, or otherwise process for them. When Focus Forward processes personal data on behalf of a customer, Focus Forward is the “processor” of the data under applicable law, and the customer is the “controller”.
- Data, including personal data, that we process for our own business (“controller data”), other than for our human resources and recruiting operations. This includes, for example, the information we collect through the site and the names and contact information of our customers and vendors. Under applicable law, Focus Forward is the “controller” of such data.
Our collection, use, and disclosure of processor data:
We receive information from or on behalf of our customers and their users. Because of the nature of the services, this information may contain any type of personal data, including names, contact information, and other identifying information.
Subject to our contractual obligations with our customers, and depending on the particular services, we use and disclose processor data as follows:
- Providing Services: to provide, maintain, and improve the services, including by analyzing the services and addressing security and business continuity issues.
- Protecting Us and Others: to enforce the legal terms that govern the services.
- Compliance with Laws: to comply with law, and where we deem disclosure appropriate to protect rights, safety and property (for example, for national security or law enforcement).
- Business Transfers: as part of an actual or contemplated business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization.
- Consistent with Customer Requirements: for other purposes requested or permitted by our customers or their users, or as reasonably required to perform our business.
Subject to our contractual obligations with our customers, and depending on the particular services, we share processor data as follows:
- Business Transfers: as we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including during negotiations of such an event, processor data may be part of the transferred assets.
- Agents, Consultants and Related Third Parties: Focus Forward, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases.
- Legal Requirements: Focus Forward may disclose processor data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Focus Forward, (iii) act in urgent circumstances to protect the personal safety of the general public, or (iv) protect against legal liability.
- Consistent with customer requirements: Focus Forward will disclose processor data for other purposes requested or permitted by our customers or users, or as reasonably required to perform our business.
Our collection, use, and disclosure of controller data:
When you interact with us through the site or the services, or become a customer or are a vendor, we may collect personal data and other information from you. As further described below, and depending on how you interact with us, we may collect the following categories of personal information:
- Identifiers (such as name and email address);
- Commercial information (such as transaction data);
- Internet or other network or device activity (such as browsing history and log data);
- Location information (such as general location information inferred from an ip address);
- Financial data (such as credit card information);
- Sensory information (such as audio or visual information);
- Professional or employment related data;
- Legally protected classifications (such as gender and marital status if you disclose such information to us); and
- Other information that identifies or can be reasonably associated with you.
Personal Data that We Collect from Third Parties: we collect personal data from third parties, such as lead generation firms.
Automatically Collected Data: When you interact with Focus Forward through the Site or Services, we receive and store certain automatically collected information collected passively using various technologies. Focus Forward may store such information itself or such information may be included in databases owned and maintained by Focus Forward affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve the users of the Services, Focus Forward often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Focus Forward may share this data with its affiliates, agents and business partners. Focus Forward may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
In operating our Site, we may also use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. (e.g., Internet Explorer; Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari).Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Online Analytics: We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in above may be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, providing certain features to you, and other purposes. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
We use controller data for business and commercial purposes as follows:
- Providing Services: To provide, maintain, and improve the Services, including by analyzing the Services and addressing security and business continuity issues. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. Also, if you provide personal data in order to obtain access to the Services, we will use your personal data to provide you with access to such services and to monitor your use of such services.
- Communications: To communicate with you regarding the Services or to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. Note however that as user of the Service you cannot opt-out of some administrative communications that are reasonably necessary to the Service, such as billing or service notifications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
- Protecting Us and Others: To enforce the legal terms that govern the Services.
- Compliance with Laws: To comply with law, and where we deem disclosure appropriate to protect rights, safety and property (for example, for national security or law enforcement).
- Business Transfers: As part of an actual or contemplated business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization.
- Consistent with Customer Requirements: For other purposes requested or permitted by our Customers or their users, or as reasonably required to perform our business.
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose personal data. To the extent those laws apply, our legal grounds for processing Controller Data are as follows:
- Legitimate interests: In most cases, we handle Controller Data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Protecting our Services, business, personnel and property
- Customer service
- Analyzing and improving our business
- Managing legal issues
- We may also process Controller Data for the same legitimate interests of our customers and business partners
- To honor our contractual commitments to the individual: Some of our processing of Controller Data is to meet our contractual obligations to individuals, or to take steps at customers’ request in anticipation of entering into a contract with them.
- Consent: Where required by law, and in some other cases, we handle Controller Data on the basis of consent. Where legally required (e.g., for the use of fingerprints for security purposes in certain jurisdictions), this is explicit consent.
- Legal compliance: We need to use and disclose Controller Data in certain ways to comply with our legal obligations.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including during negotiations of such an event, Controller Data may be part of the transferred assets.
- Agents, Consultants and Related Third Parties: Focus Forward, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, shipping and fulfillment and processing payments.
- Legal Requirements: Focus Forward may disclose Controller Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Focus Forward, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Focus Forward is not in the business of selling Controller Data. There are, however, certain circumstances in which we share the categories of personal information identified as Controller Data with certain categories of third parties without further notice to you, as follows:
Your EU Rights and Choices:
We offer the options described below for exercising rights and choices under applicable law, which are subject to important limits or exceptions under applicable law.
- For Processor Data: To exercise rights or choices with respect to Processor Data, please make your request directly to the Customer for whom we process the personal data.
- For Controller Data:
- To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted via this Site or Services.
- The law of your jurisdiction (for example, within the European Economic Area) may give you additional rights to request access to and rectification or erasure of certain of your personal data we hold. In some cases, you may be entitled to receive a copy of the personal data you provided to us in portable form or to request that we transmit it to a third party. The law may also give you the right to request restrictions on the processing of your personal data, to object to processing of your personal data, or to withdraw consent for the processing of your personal data (which will not affect the legality of any processing that happened before your request takes effect). You may contact us as described below to make these requests.
- For example, residents of the European Economic Area and certain other jurisdictions may have a right to opt out of our processing of Controller Data for direct marketing purposes. You can exercise this right by contacting us as described below. Our marketing emails and certain other communications include unsubscribe instructions, which you can use to limit or stop the relevant communications. Opt-out processes may take some time to complete, consistent with applicable law. Certain communications (such as certain billing-related communications or emergency service messages) are not subject to opt-out.
- You may contact us with any concern or complaint regarding our privacy practices, and you also may lodge a complaint with the relevant governmental authority.
Additional California Privacy Notice
This Additional California Privacy Notice applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.
As described above, in the preceding twelve months, we or our service providers may have collected the following categories of personal information for business or commercial purposes: (1) identifiers (such as name and email address); (2) commercial information (such as transaction data); (3) Internet or other network or device activity (such as browsing history and log data); (4) location information (such as general location information inferred from an IP address); (5) financial data (such as credit card information); (6) sensory information (such as customer service recordings ); (7) professional or employment related data; (8) legally protected classifications (such as gender and marital status if you disclose such information to us); and (9) other information that identifies or can be reasonably associated with you.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) third parties such as lead generation firms.
As further described above, we collect the categories of personal information identified above for the following business and commercial purposes: (1) to provide the Services; (2) to communicate with you regarding the Services or to tell you about services we believe will be of interest to you; (3) to protect us and others, including enforcing the legal terms that govern the Services; (4) to comply with laws; (5) to facilitate any business transfers for an actual or contemplated sale involving our assets; and (6) as consistent with customer requirements.
California law may permit California residents to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information (such as information we collect about our employees or job applicants, or information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services) may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services. If you ask us to delete it, you may no longer be able to access or use the Services.
If you would like to exercise any of these rights, please submit a request through this form or at email@example.com. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
California residents may opt out of the “sale” of their personal information. Focus Forward does not “sell” your personal information as we understand that term to be defined by the California Consumer Privacy Act (“CCPA”) and its implementing regulations. However, some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. If you take the position that any of those relationships involve a “sale” within the meaning of the CCPA, then you may consider Focus Forward to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on the Focus Forward site), and “commercial information” (like the fact that a browser visited a page directed to people who are considering obtaining services from us) to those sorts of companies. While Focus Forward does not believe these are “sales” as that term is defined under the CCPA, you can opt out of this activity by following the directions in the Tailored Online Advertising section above.
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by firstname.lastname@example.org. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Links to Other Web Sites / Services:
Other Terms and Conditions:
Your access to and use of this Site is subject to any other agreements in place between us, including our Terms of Service located at: .
Contacting Focus Forward:
You may contact us as follows:
- mailing us at 950 West Valley Road, Suite 2700, Wayne, PA 19087
- calling us at 215-367-4000
- emailing us at email@example.com