Legal

Focustech Privacy Policy

Last updated: March 3, 2023

We at Focustech (the Focustech entities listed in Section 11 below, referred to here as “we”, “us” or “our”) respect and protect the privacy of those who explore our Services (“Users”) and Users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).

This Privacy Policy describes how we collect, use, and share personal information when you explore, sign up for or access our “Services”, which include the services offered on our websites, including myfocustech.com, If you reside outside of the UK and the European Economic Area (the “EEA”), accessing and using our Services means that you accept this Privacy Policy and its terms. 

It is important that you understand how we use your information. You should read this page in full, but below are the key highlights and some helpful links:

• Our goal is to simplify your crypto experience. If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services.

• We collect and use your information in order to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations.

• We share your information with other Focustech companies, as well as trusted third parties and service providers, in order to offer our Services and fulfill legal requirements.
• To learn more, explore Section 3. How And Why We Share Your Information.

• We offer privacy tools for you to request access to or deletion of information we hold about you. You can use these tools by visiting your Privacy Rights Dashboard. Depending on where you live, you may also have other privacy rights under law.

• If you have any questions, please contact us on our Support Portal or at dpo@focustech.com. See Section 9. How to Contact Us With Questions for more information.

1. WHAT INFORMATION WE COLLECT

We collect the following personal information and documentation:

Information You Provide to Us

Information Collected Automatically

Information we obtain from Affiliates and third parties

2. HOW WE USE YOUR INFORMATION

We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use them, and for legal compliance, loss prevention, and anti-fraud purposes. Learn more about how we use your personal information and our legal basis for each such data use:

Data use necessary to perform our contract with you

Data use to comply with our legal obligations

Data use for our Legitimate Interests

Data use based on your consent

Data use to protect your or others’ vital interests

3. HOW AND WHY WE SHARE YOUR INFORMATION

We work with service providers, partners and other third parties to help us provide our Services, and as a result we need to share certain information with these third parties.  Here’s how:

Affiliates

Linked Third Party Websites

TRUST

Professional advisors, industry partners, authorities and regulators

Asset Transfer or Company Acquisition

Third-Party Service Providers

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your information as needed to provide our Services, comply with legal obligations, or protect our or others’ interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Customers, and Users.

We retain biometric information (as part of our retention of Supplemental Identification Information) for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third party identity verification service providers retain this information for as long as set out in their applicable notices/policies. 

In line with these considerations, we delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your information (which you can initiate through your Privacy Rights Dashboard).

5. CHILDREN’S PERSONAL INFORMATION

The Sites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information through the Sites or Services. If a User or Customer submitting personal information is suspected of being younger than 18 years of age, Focustech will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.

6. INTERNATIONAL TRANSFERS

To facilitate our global operations, Focustech, its Affiliates, third-party partners, and service providers may transfer, store, and process your personal information throughout the world, including Ireland, Germany, Singapore, the UK, the US, and the Philippines. See here for more information. 

If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information (collectively, “European Personal Data”).

• We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of European Personal Data to third countries, including from our EU operating entities to Focustech, Inc. in the United States. For a copy of the Standard Contractual Clauses, please contact dpo@focustech.com. 

We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law. For example, because Focustech operates and provides its  Services globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Services (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing personal information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).

7. YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. You can make privacy rights requests relating to your personal information by logging into your account and going to your Privacy Rights Dashboard. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Focustech has absolute discretion in providing you with these rights.

• Right to access and portability: 
• You may request that we provide you a copy of your personal information held by us through your Privacy Rights Dashboard, or by submitting a request via our Support Portal. 

• Right to rectification: 
• You may request us to rectify or update any of your personal information held by Focustech that is incomplete or inaccurate by logging in to your account and clicking the Profile or My Account tab.

• Right to deletion/erasure: 
• You may request to erase your personal information, subject to applicable law. If you close your Focustech Account, we will retain or delete information associated with your account as described in Section 4. How Long We Keep Your Personal Information.

• Right to withdraw your consent: 
• To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. The lawfulness of Focustech’s processing before you withdraw your consent will not be affected by such withdrawal.

• Right to object to or restrict processing: 
• You may have  the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your personal information where permitted or required by applicable law. You can opt-out of receiving marketing communications from Focustech through your account settings or by submitting a request via our Support Portal.  

• Right to non-discrimination: We will not discriminate against you for exercising any of your rights provided to you under law.

• Right to lodge a complaint:  
• If you reside in the EEA, Switzerland, or the UK, you have the right to lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state. In the UK, the relevant data protection authority is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, +44 (0303) 123 1113, email: casework@ico.org.uk. In Ireland, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: info@dataprotection.ie or by using the following online form: Forms for Data Protection.
• If you reside in Australia or the Philippines, you may lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country. In Australia, the relevant data protection authority is the Office of the Australian Information Commissioner, and complaints may be made through their website at www.oaic.gov.au. In the Philippines, the relevant data protection authority is the National Privacy Commission, email: complaints@privacy.gov.ph.

To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.