Your privacy is very important to us, and we will treat all of your data and information with care and respect. This Privacy Policy describes the details of how we collect, use, and/or disseminate the information you provide, including your Personal Data. We reserve the right to change this Policy at any time and urge you to review our Policy regularly to familiarize yourself with any changes.

By visiting our website, using our online products/services, downloading/installing and/or using our application on a mobile phone, and/or by voluntarily submitting Personal Data to us via online forms, advertisement responses, mobile applications, and/or electronic mail, you are accepting the practices described in this Privacy Policy. If you do not wish us to use your Personal Data, please opt-out as described below.

If you have any questions or concerns about our use of your Personal Data, please contact us using the contact details provided below.

Who We Are ?

We develop and license an online marketing system that allows its users to manage and promote client programs and opportunities of their choice (the "System"). The System is operated and managed by FocalPoint, LLC., located in the State of New Jersey in the United States.

Because each account is controlled by an independent representative, we cannot guarantee how the System and your Personal Data will be managed by these representatives.

Key Terms

An individual who subscribes to the FocalPoint System is referred to as a "Member" of the System. The Member's targeted audience is the "Subscriber" or “Contact.” "Users" or "you" include Members and Subscribers, as well as anyone visiting this site.

"Personal Data" means any information that identifies or can be used to identify a user directly or indirectly. Examples of Personal Data include, but are not limited to, first and last name, email address, phone number, or other demographic information.

To cater to Users of our site, we may be required to collect, use, and share certain information, including Personal Data. The type of information we collect, together with a description of how we use and/or share it, is described below.

Information Collection and Use
Information You Provide to Us

Personal Data about you may be collected when you register for our service, contact our customer service representatives, send us an email, integrate with another service or website, or communicate with us in any way.

We also act as the Processor of Personal Data about Customers, which is stored and processed by and on behalf of our Members. We only process Personal Data where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products, and System, ensuring the security of the System, and to support our marketing activities.

Registration

In order to use the system, a Member may first complete the registration form. During registration, the Member will be required to give contact information (such as name and email address). We may use this information to contact the Member about services on our site for which the Member has expressed interest. The Member may also be asked for demographic information (such as information about the Member‘s industry, gender, or the company they represent), so we can provide a more personalized experience on our site. If a Member chooses to enroll in our service, in certain circumstances the law may require us to collect the Members social security number or if a company, their EIN number. These numbers will be collected only if they are required to comply with IRS requirements.

A Member registering for a paid account will also be required to provide financial information (such as a credit card number and expiration date). This information is used for billing purposes and to fill the Member’s order. If we have trouble processing an order, the information is used to contact the Member.

Order

If you are placing an order on our system, we will request information from you on our order form. You must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number and expiration date). This information is used for billing purposes to fill your order and, if we have trouble processing your order, to contact you.

Information We Process on a Member's Behalf

If you are a Member, we will use Personal Data that we gather about you to provide the requested services. In addition, if you have a free trial account, then we will use the Personal Data gathered about you to share more information about our business in an attempt to convince you to make a purchase from us or our associated companies.

If you have a paid account, we will use your Personal Data to bill and collect money owed to us by you.

If You are a Subscriber, this site and the person/affiliate who sent you to this site will be granted access to your contact information (name, phone number, and email) so that they can communicate with you in an attempt to "sell" various products, services, and memberships to you.

We may also use your Personal Data to send you system alert messages, communicate with you about your account and provide customer support, enforce compliance with ours Terms and Conditions of Service, to protect the rights and safety of our Members and third parties, to meet legal requirements, and to otherwise carry out legitimate business purposes necessary to operate the System.

Information We Collect Automatically

We store information that we automatically collect through cookies, log files, clear gifs, and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information such as device information and applications you use to access the System is tied to your Personal Data to provide offers and improve the content of the site for the user. This profile is used to tailor a user's visit to our site, and to direct pertinent marketing promotions to them. We may share your profile with other third parties as detailed in this policy. Your profile is shared together with your Personal Data. YOUR CREDIT CARD, SOCIAL SECURITY NUMBER OR EIN, AND OTHER PRIVATE FINANCIAL INFORMATION IS NEVER SHARED WITH ANY OUTSIDE THIRD PARTY UNLESS REQUIRED BY LAW OR FOR BILLING PURPOSES.

Cookies, click through and pixel tags

FocalPoint's website may use "cookies" and other technologies to help us understand which parts of our websites are the most popular, where our visitors are going, how much time is spent there and study traffic patterns on our website. This information can include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), operating system, date/time stamp, and referring/exit pages.

We may use cookies to understand and save your preferences for future visits and keep track of advertisements or who may have referred you to our site.

FocalPoint and/or its Members may also use 3rd party vendor remarketing tracking pixels, or cookies. This means we may continue to show ads to you across the internet. The techniques our partners employ does not collect Personal Data such as your name, email address, postal address, or telephone number.

If you prefer not to enable cookies, please check the help section of your preferred internet browser for instructions on how you can disable cookies. Please note that certain features of the FocalPoint website may not be available when cookies are disabled.

This information, which does not identify individual users, may be used to analyze trends, to administer the site, to track users' movements around FocalPoint's sites and to gather miscellaneous demographic information about our visitors as a whole. While cookies may be used to display ads based on prior visits, FocalPoint will not collect information to market directly to that person.

In some of our email messages we use a "click-through" url link to content on the FocalPoint website. When customers click one of these url's, they pass through our web servers before arriving at the destination. FocalPoint may track this click-through data to help us measure interest in methods customers prefer to retrieve information and messages. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.

FocalPoint may use pixel tags, which are tiny graphic images to tell us what parts of our website customers have visited.

Log Files

Like most standard Web site servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track users movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses are only tied to Personal Data provided by a user when necessary to enable our Web-based service.

Clear Gifs (Web Beacons, Web Bugs, CSS, and similar functionality)

We may employ or our third-party advertising company(ies) may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective.

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are tied to users Personal Data. Clear Gifs can "work with" existing cookies on a computer if they are both from the same Web site or advertising company. That means, for example, that if a person visited www.companyX.com, which uses an advertising company’s clear gif, the Web site or advertising company would match the clear gifs identifier and the advertising company’s cookie ID number, to show the past online behavior for that computer. This collected information would then be given to the advertising company or Web site.

In addition, we may use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.

Usage Data

We may collect usage data about you whenever you interact with the System, which may include the dates and times that you access the System and your browsing activities (such as what portions of the System are used). We also collect information regarding the performance of the System, including metrics related to the deliverability of emails and other communications you send through the System. This information allows us to improve the content and operation of the System, and facilitate research and analysis of the System.

Communications from the Site
Special Offers and Updates

We send all new Members a welcome email. Established Members may occasionally receive information on products, services, special deals, and a newsletter.

Service Announcements

On rare occasions it is necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance we might send Members an email. Members might not be able to opt-out of these communications, although they can deactivate their account. However, these communications are not promotional in nature.

Customer Service

We also communicate with Members and others who contact us with questions and concerns on a regular basis to provide requested services, in regard to issues relating to their account, and to otherwise respond to inquiries. We reply via email or phone, in accordance with your wishes.

Sharing with Third Parties
Aggregate Information (non-personally identifiable)

We may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Data.

Advertising

We may use the Personal Data a Member has voluntarily provided to us to cause information, offers, products, and/or services that appear to us to be consistent with the Member's expressed interests to be directed to a Member. This is accomplished by using your information to direct to you information, offers, products, and/or services from us. A Member's Personal Data may, therefore, ultimately be used by us for marketing purposes.

You may choose to opt-out of receiving such marketing by following the unsubscribe instructions sent with every email or by contacting us as set forth below.

We will not sell your Personal Data to a third-party.

Third Party Intermediaries

We may use a credit card processing company to bill users for services. These companies only use your information for billing purposes and, to the extent they store your credit card or other private financial information, do so in a secure industry-standard fashion.

Service Providers

We partner with other third parties to provide specific services. When the user signs up for these particular services, we share names and Personal Data only to the extent that it is necessary for the third party to provide these services. These third parties are not allowed to use your Personal Data except for the purpose of providing these services and for purposes referenced in their privacy policies.

Approved Lead Vendors

We may allow carefully-screened Approved Lead Vendors to be listed in a Member's back office. Under certain circumstances, we may share a Member's contact information with one or more of these Approved Lead Vendors. They may use this information to contact a Member via telephone, email or direct mail to inform a Member about an upcoming lead special, conference call or other promotional opportunity which could potentially benefit a Member.

Business Transitions

In the event we go through a significant business transition, such as a merger, being acquired by another company, or selling a major portion of its assets, your Personal Data will, in most instances, be part of the assets transferred. We will strive to notify you via email prior to a change of ownership or control of their Personal Data, consistent with our notification of changes section.

Legal Proceedings

Please note that FocalPoint may be required by law or litigation to disclose your personal information. FocalPoint's internal policies call for the release of required information in the cases of subpoena, court orders and order of local, state and federal government.

Data Protection Rights
Choice/Opt-out

Users who no longer wish to have their Personal Data collected or processed may opt-out of receiving further communications by following the unsubscribe instructions sent with every email, by contacting the Member who is the Controller of their Personal Data, or by contacting us as set forth below. Members who no longer wish to have their Personal Data collected or processed must unsubscribe from our service.

Users who wish to remove cookies may do so by following directions provided in their internet browser's "help" directory. If you reject cookies, you may still use our site, but your ability to use some areas of the site may be limited.

Correction of Personal Data

We take all reasonable steps to ensure that the information we collect is reliable for its intended use, accurate, complete and up-to-date. As a Member, you can manage your individual account and profile settings in your back office or you may contact us directly by emailing us the address below. If a Subscriber or visitor to the site wishes to exercise any of these rights, they should contact you directly or contact us as described below.

Additional Rights

You may object to the processing of Personal Data, ask to restrict processing of your Personal Data, ask us to delete your Personal Data or request portability of your Personal Data. Members may do so by contacting us using the contact details provided below. If your Subscribers wish to exercise any of these rights, they should contact you directly or contact us as described below.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Children's Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children's Online Privacy Protection Act); we do not knowingly collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older. If a child under 13 submits personal information to FocalPoint and we learn that personal information is the information of a child under 13, we will attempt to delete the information as soon as possible.

Telecommunications Privacy

Protecting the privacy of your telecommunications information is important to us. When users make phone calls to or from telecommunication services provided by us, we may track information about the name, phone number, and other information about the call. We do not share this information, unless required to do so by law. We may use this information in the aggregate to analyze trends or to improve the service. By contacting us via telephone you are allowing us to contact you even if your phone number is on any legal DNC (do not call) lists.

Security

We use industry-standard good practices to protect our users Personal Data. When users submit Personal Data via the site, we strive to ensure that Personal Data is protected both online and off-line. However, please be aware that no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure. When our registration/order form asks users to enter financial or other sensitive Personal Data (such as a credit card number and/or a social security number), that information is encrypted and is protected with industry-standard technology.

While we use industry-standard technology to protect sensitive information online, we also work to protect user-information off-line. All of our users information, not just the Personal Data mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to Personal Data. All employees are kept up-to-date on our security and privacy practices. Finally, the servers that store Personal Data are in a secure environment, in a secure facility.

Supplementation of Information

In order for this site to properly fulfill its obligation to users, it may be necessary for us to supplement the Personal Data we receive with information from 3rd party sources.

Notification of Changes

We will post any changes to this privacy statement in places that we deem appropriate. We will use Personal Data in accordance with the privacy policy under which the Personal Data was collected.

If, however, we are going to use users Personal Data in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether we use their Personal Data in this different manner.

However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their Personal Data be used in this new manner. If we make any material changes in our privacy practices that do not affect Personal Data already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice, we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

This policy was last modified on 05/25/2018.

FocalPoint

200 Centennial Ave, Suite 200 #248
Piscataway, NJ 08854

CustomerCare@FocalPointSystem.com FocalPoint Sales:       (800) 363-5519 (Extension 1) Outside US/Canada:  (732) 582-0199 (Extension 1)