Privacy notice

1. Who we are and how to contact us

Client Focus LLC is a limited liability company organized under the laws of the Commonwealth of Virginia, with its principal office at 44355 Premier Plaza #110, Ashburn, VA 20147, United States. Client Focus also operates an engineering and operations center in Hyderabad, Telangana, India. For the purposes of data protection law, Client Focus LLC is the controller of personal data described in this notice unless stated otherwise. Questions, requests and complaints concerning this notice may be directed to info@clientfocusllc.com, by telephone at (888) 613-7190, or by post to the address above, marked for the attention of the Privacy and Compliance Office.

2. Scope of this notice

This notice applies to personal data that Client Focus collects through clientfocusllc.com and related web properties, through correspondence, meetings and events, through recruitment, and in the course of establishing and managing client, supplier and partner relationships. It does not apply to data that Client Focus processes on behalf of clients under a service agreement, which is addressed in section 11.

3. Personal data we collect

Client Focus collects the following categories of personal data:

• (a)Identity and contact data, such as name, organization, job title, business email address, business telephone number and postal address, provided when an inquiry is submitted, a briefing is requested, or a business card is exchanged.
• (b)Correspondence data, including the content of messages sent to Client Focus and records of meetings and calls.
• (c)Relationship data, such as the services discussed, the status of a proposal, and contract and billing details for clients and suppliers.
• (d)Recruitment data, including resumes, application correspondence and interview notes, for candidates who apply for a position.
• (e)Technical data collected automatically when the website is visited, including IP address, browser type and version, device type, operating system, referring page, pages viewed and timestamps.
• (f)Cookie preference data, recording the choice made in the cookie preference control.

Client Focus does not intentionally collect special categories of personal data through this website and asks that such data not be submitted through the inquiry form.

4. How we obtain personal data

Personal data is obtained directly from the individual, from the organization the individual represents, from publicly available professional sources such as company websites and professional networking services, and automatically from the individual's device when the website is used.

5. Purposes and legal bases for processing

Client Focus processes personal data for the following purposes and, where the GDPR or UK GDPR applies, on the following legal bases:

• (a)To respond to inquiries and requests for briefings: performance of steps prior to entering into a contract, or legitimate interests in responding to business correspondence.
• (b)To negotiate, enter into and perform contracts with clients and suppliers, including invoicing and account management: performance of a contract and legitimate interests.
• (c)To operate, secure and improve the website, including the detection and prevention of fraud and abuse: legitimate interests in maintaining secure and reliable systems.
• (d)To measure website usage through optional analytics cookies: consent, given through the cookie preference control.
• (e)To send business communications about Client Focus services, insights and events to existing contacts: legitimate interests, with the ability to object at any time.
• (f)To consider candidates for employment: performance of steps prior to entering into a contract and legitimate interests in recruitment.
• (g)To comply with legal obligations, including tax, accounting, sanctions screening and regulatory requirements: compliance with a legal obligation.
• (h)To establish, exercise or defend legal claims: legitimate interests.

Client Focus does not sell personal data and does not use personal data for automated decision-making that produces legal or similarly significant effects.

6. Cookies and similar technologies

The website uses strictly necessary cookies to deliver pages securely, remember cookie preferences and protect forms against abuse. These cookies do not require consent. Optional analytics cookies, which measure aggregate usage of the website, are set only when the visitor selects "Accept all" in the cookie preference control. The default selection is "Accept necessary only". Preferences may be changed at any time through the "Cookie preferences" link in the footer. The website does not use advertising cookies and does not respond to targeted advertising across third-party sites. Browser-level "Do Not Track" and Global Privacy Control signals are honored by treating them as a selection of necessary cookies only.

7. Sharing of personal data

Client Focus shares personal data only as follows:

• (a)With service providers that process data on Client Focus's instructions under written contracts, such as website hosting, email, customer relationship management, document management and professional services platforms.
• (b)With professional advisers, including lawyers, auditors, insurers and accountants, where necessary for the advice or service provided.
• (c)With affiliates of Client Focus, including its engineering and operations center in India, for the purposes described in this notice.
• (d)With regulators, courts, law enforcement and other authorities where disclosure is required by law or is necessary to protect the rights, property or safety of Client Focus, its clients or others.
• (e)With a successor entity in the event of a merger, acquisition, reorganization or sale of assets, subject to this notice.

8. International transfers

Client Focus operates in the United States and India, and personal data may be transferred to and processed in either country. Where personal data originating in the European Economic Area, the United Kingdom or Switzerland is transferred to a country that has not been found to provide adequate protection, Client Focus relies on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism, and applies supplementary measures where appropriate. A copy of the relevant safeguards may be requested through the contact details in section 1.

9. Retention

Client Focus retains personal data for no longer than is necessary for the purposes for which it was collected. As a general rule: inquiry and correspondence data is retained for 24 months after the last contact; client and supplier contract data is retained for the duration of the relationship and for 7 years thereafter to meet accounting and legal obligations; recruitment data for unsuccessful candidates is retained for 12 months after the decision unless the candidate agrees to a longer period; technical log data is retained for 12 months; and cookie preference data is retained for 12 months. Data may be retained for longer where required by law or for the establishment, exercise or defense of legal claims.

10. Security

Client Focus operates an information security management system certified to ISO/IEC 27001. Personal data is protected by technical and organizational measures that include encryption in transit and at rest, role-based access on a least-privilege basis, multi-factor authentication, logging and monitoring, secure development practices, supplier assessment, staff training and tested incident response procedures. No method of transmission or storage is entirely secure, and Client Focus cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to individuals, Client Focus will notify the relevant authorities and affected individuals as required by law.

11. Client operational data

In delivering engineering, network operations and security operations services, Client Focus processes data on behalf of clients, including monitoring records, transaction metadata, incident evidence and system logs. For that data, the client is the controller and Client Focus acts as a processor under the data processing terms of the applicable service agreement. Those terms, not this notice, govern the purposes, retention, sub-processing and security of client operational data. Individuals whose data is contained in client operational data should direct requests to the relevant client.

12. Your rights

Depending on the jurisdiction, individuals may have the right to: request access to the personal data Client Focus holds about them; request correction of inaccurate or incomplete data; request erasure of data in certain circumstances; object to processing based on legitimate interests; request restriction of processing; receive a copy of data provided to Client Focus in a portable format; withdraw consent at any time where processing is based on consent; and lodge a complaint with a supervisory authority. Residents of Virginia may also have rights under the Virginia Consumer Data Protection Act to confirm whether personal data is being processed and to appeal a decision on a request. To exercise any right, contact Client Focus using the details in section 1. Client Focus will verify the identity of the requester and respond within the period required by law, which is generally 30 days, extendable where permitted. Individuals in the EEA or the United Kingdom may complain to the supervisory authority in their country of residence, and individuals in India may approach the Data Protection Board of India.

13. Children

The website and the services of Client Focus are directed at businesses and their representatives. Client Focus does not knowingly collect personal data from individuals under 18 years of age. If Client Focus becomes aware that such data has been collected, it will delete it.

14. Third-party websites

The website contains links to third-party websites, including thecroc.ai and professional networking services. Client Focus is not responsible for the privacy practices of those sites, and this notice does not apply to them.

15. Changes to this notice

Client Focus reviews this notice at least annually and updates it when its practices or the law change. The effective date at the top of the page indicates when the current version took effect. Material changes will be highlighted on this page for 30 days after they take effect.