PRIVACY POLICY – YOUR PRIVACY RIGHTS

Effective Date: 05/16/2022

This Privacy Policy ("Policy") describes how Focal Point, LLC ("Focal Point," "we," or "us") treats personal information we collect about you through our websites, applications, and platforms where the Policy is located (the “Platform”). This policy does not apply to our treatment of employee personal information.

If you are a California resident, please click here to view our CALIFORNIA PRIVACY NOTICE.

If you are a Nevada resident, please click here to view our NEVADA PRIVACY NOTICE.

This Platform is intended for use by individuals who are located in the United States.

Focal Point collects personal information from you and about you. Here are some examples of the personal information we may collect:

• Identifying Information. For example, we may collect your name, business or personal address, unique personal identifiers, professional organization ID numbers, online identifiers, telephone number and email address. We may also collect your mobile phone number.
  
• Payment Information. For example, we may collect your billing address and shipping address in connection with a purchase.
  
• Account Information. If you create an account with us, we may collect your account log-in and password.
  
• Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
  
• Employment Information. For example, this may include the name and address of your employer. If you apply for a job with us, we may also collect the personal information you include in your application and your employment history. We may also collect information about your education history.
  
• Information You Post or Submit. We may collect personal information you post in a public space on our Platform. We may collect personal information that you submit when you contact our customer service team. We may also collect personal information when you enter a promotion or contest.
  
• Demographic Information. We may collect demographic information such as your birthdate, age, and zip code.
  
• Course Information. We may collect information about the continuing education courses for which you register and your performance during these courses.
  
• Commercial Information. We may collect personal information that could identify you and relates to the products or services in which you are interested, or have considered or purchased. We may also collect personal information about your purchasing habits, or consuming history or tendencies.
  
• Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your browser information, device identifier, IP address or mobile operating system.
  
• Location Information. For example, we may collect information about the city or state where you are located. We may also collect geographic information based on your IP address.
  
• Internet Information. If you use our website, we may collect information about the browser you are using or your browsing or search history. We might look at what site you came from, or what site you visit when you leave us. We may also collect information about how you interact with an advertisement.

Focal Point collects your personal information in different ways. Below are some examples of how we may collect your personal information.

• Directly From You. For example, when you:
  • Register for an account.
  • Request information about our products or services.
  • Sign up to receive promotional communications.
  • Participate in one of our promotional sweepstakes or contests.
  • Complete a survey.
  • Register for a tour of our facilities.
  • Sign up for or complete a course that we offer.
  • Submit a request to, or engage with, our field or customer service team.
  • Interact with our social media pages.
  • Apply for a job through our Platform.
    
• Passively. For example, when you:
  • Visit and navigate our Platform on any device.
  • Enable location-based features on our Platform.
    

We may also collect personal information about users over time and across different websites, apps and devices when you use the Platform. Third parties also collect personal information this way on our Platform.

• From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
  • Our business partners, including online advertising networks, analytics vendors, and third parties that promote our products via their own platforms. If you participate in a course that we sponsor, the company that provides or hosts the course may share your personal information with us.
  • Social media sites or job posting sites, including Facebook, Twitter, LinkedIn, Pinterest, Glassdoor, YouTube and Instagram.
  • Companies that provide personal information to supplement what we already know about you. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.
    
• By Combining Information. For example, we may:
  • Combine personal information that we collect offline with personal information we collect through our Platform.
  • Combine personal information we collect about you from the different devices you use to access our Platform.
  • Combine personal information we get from third parties with information we already have about you.

Examples of how we may use your personal information include:

• To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or your request to complete a course that we offer.
  
• To Improve Our Products and Services. We may use your personal information to make our Platform, products and services better. We may also use your personal information to customize your experience with us.
  
• To Understand Your Interests. For example, we may use your personal information to better understand what products interest you.
  
• To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion. It may also include processing your request for a tour of our facilities.
  
• To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
  
• To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use this personal information to evaluate your application.
  
• For Marketing Purposes. We may provide you with information about new products and special offers. We might use your personal information to serve you ads about products and offers. We might tell you about new features or updates. These might be third party offers or products we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message. We and our partners may engage in interest-based advertising using information gathered across multiple websites, devices, or other platforms. For more information about your choices related to these communications, see the Choices section below.
  
• For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform or investigating a potential fraud.
  
• As Otherwise Permitted By Law or As We May Notify You.

We may share your personal information in the following ways:

• Internally. We may share your personal information with our affiliates and subsidiaries.
  
• On Our Platform. For example, we may publically display personal information you post on our social media sites or submit through our customer reviews feature. We may also display personal information you submit in connection with a promotion.
  
• With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include merchandise vendors. It may also include companies that send emails on our behalf or help us run our Platform.
  
• With Our Business Partners. For example, this may include a third party that co-sponsors a contest or promotion. We may also share personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers. We may also share personal information with companies that help us learn more about our customers.
  
• With Third Parties for Marketing Purposes. This may include third parties in whose products or services we believe you may be interested. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
  
• With Any Successors to All or Part of Our Business or One of Our Brands. For example, if Focal Point merges with, acquires or is acquired, or sells a brand or part of its business to another business entity. This may include an asset sale, corporate reorganization or other change of control. We may sell or transfer our customer personal information as an asset or as part of a larger transaction action.
  
• To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating a potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share personal information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
  
• For Other Reasons We May Describe to You At the Time of Collection.

You have certain choices about how we use your personal information. Certain choices you make are browser and device specific.

Marketing Communications:

• You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can follow the instructions contained in the communication.
  

Cookies & Other Tracking Technologies:

• Your browser may give you the ability to control cookies or other tracking tools. How you do so depend on the type of tool. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
  

Our Do Not Track Policy:

• Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

The California Consumer Privacy Act (“CCPA”) requires us to make specific disclosures about how we collect, use and share the personal information of California residents who are subject to CCPA (“California Consumer Personal Information”). CCPA also grants such California residents certain rights related to their personal information.

This section of our Privacy Policy explains our online and offline collection of California Consumer Personal Information, and includes instructions for California residents who wish to exercise their rights under CCPA. Note that this section does not apply to the personal information of California residents that we collect in the employment context or in certain business transactions.

• We are required under CCPA to tell you which categories of California Consumer Personal Information we collect, and which of these categories we disclose for “business purposes” or for “sale” purposes as these terms are defined under CCPA.
  • In the past 12 months, we have collected the following categories of California Consumer Personal Information: identifiers; categories of personal information described in subdivision (e) of Section 1798.80; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; audio, electronic and visual information; professional or employment-related information; non-public education information; and inferences drawn from the categories in this paragraph.
    
• We may disclose any of the above categories of California Consumer Personal Information for “business purposes” as this term is defined in CCPA.
  
• As of the date of this Policy, we do not knowingly “sell” California Consumer Personal Information as this term is defined in CCPA.
  
• How we may collect, use and share California Consumer Personal Information:
  • We may collect California Consumer Personal Information as described in the “HOW WE COLLECT YOUR PERSONAL INFORMATION” section of this Policy. We may also collect your personal information if you provide it to us during a trade show or other in-person event
  • We may use the California Consumer Personal Information we collect as described in the “HOW WE USE YOUR PERSONAL INFORMATION" section of this Policy.
  • We may share California Consumer Personal Information we collect as described in the “HOW WE SHARE YOUR PERSONAL INFORMATION" section of this Policy.
    
• California resident rights under CCPA. Subject to certain exclusions included in CCPA, and as relevant to our operations, California residents may exercise the rights listed below. We may take steps to verify your identity, as permitted or required under CCPA, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.
  • Deletion. This means that you can request that we delete any personal information about you which we have collected from you.
  • Notice. This means that you can request that we disclose the categories of personal information we have collected about you; the categories of sources from which such personal information is collected; the categories of personal information we have “sold” or disclosed for a business purpose; the categories of third parties to whom the personal information was “sold” or disclosed for a business purpose; and the specific pieces of personal information we have collected about you in the last 12 months.
  • Equal prices and services. This means that we are prohibited from discriminating against you if you exercise your rights under CCPA.
    
• Agents that you have authorized to act on your behalf may also submit CCPA requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
  
• California residents who wish to exercise their rights under this section can call us at 773.247.9494 or email us at info@focalpointlights.com. Please indicate you are a California resident making a “CCPA” request.
  

Cal. Civ. Code 1798.83 (the “Shine the Light” law) grants our California resident customers the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at info@focalpointlights.com or call us at 773.247.9494. Please indicate that you are a California resident making a "California Shine the Light" inquiry.

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A username and password are needed to access certain areas of the Focal Point Platform. It is your responsibility to protect your username and password.

Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

Our Platform may contain links to other third party sites that are not governed by this Policy. This includes third party sites that offer continuing education courses or other resources and content which you can access through our Platform. If you click on a link to a third party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third party sites.

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at info@focalpointlights.com or by telephone at 773.247.9494. You may also write to us at the following address:

Focal Point, LLC
ATTN: Vice President of Human Resources
4141 S. Pulaski Road
Chicago, IL 60632

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.