Focus USA Data Broker Privacy Notice

Data Broker Privacy Notice

Last Updated: April 18, 2025

This privacy notice applies exclusively to Focus USA’s Data Broker Activities. To review Focus USA’s Business Services and website privacy practices, see the Business Services Privacy Policy.

Focus USA is a publicly registered data broker in compliance with various state privacy and data broker laws, including California, Nevada, Oregon, Texas, and Vermont. This means that Focus USA sells, or rather ‘licenses’, personal information that we did not directly collect from individuals. In this Data Broker Privacy Notice, we provide information about how we collect, process, and license personal information for our Customers or partners to use with their advertising, marketing, and communications efforts. Most importantly, we provide you with choices to exercise your privacy rights under applicable laws by following the instructions below.

Please note that Focus USA does not sell, license, or otherwise provide children’s data under the age of eighteen (18), or data that would be used to make material decisions about an individual’s reputation or determine creditworthiness, employment, or housing. Our Customers are primarily businesses or advertising services that use licensed data to sell consumer products or services or otherwise attempt to reach large groups of recipients with advertisements.

Your Privacy Choices

As of the date of the posting of this notice, the following states have specific data privacy rights: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia. If you would like to exercise your rights under applicable privacy or data broker laws, you may do so by visiting our Privacy Center.

These rights may include:

Receiving a copy of the personal information (or ‘personal data’) we maintain about you (a.k.a. the right to ‘Know’ or ‘Access’).
Correcting any inaccuracies in your personal information we maintain about you.
Requesting the deletion of the personal information we maintain about you.
Requesting that we cease to ‘sell’ or ‘share’ your personal information for third-party targeted or cross-contextual behavioral advertising purposes (a.k.a. the right to ‘Opt-Out’).

For requests to access, correct, or delete your personal information, please be prepared to provide information that will help us verify your identity and note that Focus USA reserves the right to refuse any request that may not be available under the laws of your personal jurisdiction, or if we can not verify your identity. We also reserve the right to require additional legal information from any business or individual purporting to be an ‘agent’ of another person, unless we are prohibited by law or regulation from doing so. See ‘Privacy Choices’ below for more information, including how to appeal any decisions related to your privacy rights.

Source	Description
Publicly accessible information	In accordance with local laws or website terms, we receive personal information from public records, business professionals, websites, directories, online forums, or other sources where the information is publicly accessible.
Website visitors	We may receive information associated with visitors to websites through the use of cookies or other tracking technologies. In order to receive this information, we contractually require these websites to offer their visitors a choice to opt out from any such ‘sales’ or ‘sharing’/targeted advertising activities.
Market research surveys	We license information from market research companies that conduct email, phone, online, or other surveys that may include the contact information as well as survey respondent information that helps us segment the overall population into the categories listed below.
Third party businesses, including not for profits or non profits	Various companies may license data to us that includes event attendance, sweepstakes or contest entries, or requests for information. The categories of third parties from which we collect personal data include: Affiliates Data resellers Advertising networks Banks/credit unions Collection agencies Credit reporting agencies Fintech companies Government (not public record) Insurance carriers Marketing companies
Combined and inferred information	We may infer some data using the personal information from the sources listed above. These inferences may relate to individuals, households, or geographic areas. Like the data we collect from other sources, inferences are used in our Customer’s marketing efforts to reach certain audiences. These inferences may include categories deemed to be ‘sensitive’ under various privacy laws (see below). However, this typically does not mean that Focus USA can correlate any inferred sensitive category with an individual’s (or household’s) specific behaviors, transactions, or conditions.

How We Collect Personal Information

Focus USA collects or licenses personal information from a variety of sources depending on the purpose for its use.

The Categories of Personal Information We Sell, Share or License (including in the preceding twelve months)

Category	Description
Personal identifiers and online identifiers	Directly identifiable information such as name, phone number, postal address, plain text or ‘hashed’ email address Internet, hardware, or software identifiers such as cookie IDs, CTV IDs, IP address, mobile advertising identification number (MAID), synthetic ‘probabilistic’ identifiers based on a combination of browser or other device-specific attributes
Demographic data (i.e. background)	Age (precise, estimates, or ranges) Gender Known or inferred racial or ethnic background Religion
Commercial records	Personal property or automotive purchases, leases, liens or other information associated with a property or automotive transaction Buying activities or interests based on commercial or transaction information
Internet or other similar network activity (i.e. website activities, browsing data)	Specific website or mobile application visitation or engagement activities Categories of websites visited or applications utilized (i.e. cross-contextual)
Course geolocation data (from postal or IP address, not device-specific information)	Census or other geographic information based on postal address or Internet Protocol (IP) address
Professional or employment-related information	Previous, prospective, and current employment information including roles and titles Education information, including certifications Authored or otherwise publicly affiliated research, papers, memos, or speaking materials
Inferences made about you	Categories of product or service interests
Information used to verify your identity (exclusively to process state-specific data subject rights)	Government identifiers such as Social Security Number, driver’s license number, passport number, state identification card number

The Categories of ‘Sensitive’ Personal Information We Sell, Share or License

Focus USA does not collect or sell ‘sensitive’ personal information associated with our data broker activities, as defined by U.S. state privacy laws.

Categories of Third Parties with Which Personal Information is Sold or Shared

Advertising and Marketing Services Agriculture, Forestry, and Fishing (e.g., farm cooperatives) Automotive (e.g., car manufacturers and dealerships) Business Services/Agency (e.g., data brokers) Communications (e.g., wireless carriers) Construction (e.g., real estate development companies) Consumer Packaged Goods (e.g., companies that sell personal and household products) Education (e.g., colleges and universities) Energy and Utilities (e.g., electric and gas companies) Entertainment (e.g., movie and television studios and streaming services) Financial Services (e.g., banks and investment companies) Gift and incentive marketing companies Government (e.g., state and federal agencies and political parties, and candidates) Health and wellness (e.g., hospitals) Insurance (e.g., insurance carriers)	Manufacturing (e.g., consumer product manufacturers) Media and Publishing (e.g., magazines, retail catalogs) Non-Profit (e.g., charitable organizations) Parenting (e.g., magazines) Real Estate (e.g., real estate brokerage companies) Retail (e.g., department stores, hardware stores) Services-Non Professional (e.g., consulting firms) Services-Professional (e.g., advertising agencies and financial planners) Social networks or services Sports (e.g., professional sports teams) Technology (for example, software and hardware providers, social media platforms) Transportation (e.g., railway companies, airlines, rental car companies) Travel and Tourism (e.g., cruise lines, hotels, online travel services)

Advertising and Marketing Services
Agriculture, Forestry, and Fishing (e.g., farm cooperatives)
Automotive (e.g., car manufacturers and dealerships)
Business Services/Agency (e.g., data brokers)
Communications (e.g., wireless carriers)
Construction (e.g., real estate development companies)
Consumer Packaged Goods (e.g., companies that sell personal and household products)
Education (e.g., colleges and universities)
Energy and Utilities (e.g., electric and gas companies)
Entertainment (e.g., movie and television studios and streaming services)
Financial Services (e.g., banks and investment companies)
Gift and incentive marketing companies
Government (e.g., state and federal agencies and political parties, and candidates)
Health and wellness (e.g., hospitals)
Insurance (e.g., insurance carriers)

Manufacturing (e.g., consumer product manufacturers)
Media and Publishing (e.g., magazines, retail catalogs)
Non-Profit (e.g., charitable organizations)
Parenting (e.g., magazines)
Real Estate (e.g., real estate brokerage companies)
Retail (e.g., department stores, hardware stores)
Services-Non Professional (e.g., consulting firms)
Services-Professional (e.g., advertising agencies and financial planners)
Social networks or services
Sports (e.g., professional sports teams)
Technology (for example, software and hardware providers, social media platforms)
Transportation (e.g., railway companies, airlines, rental car companies)
Travel and Tourism (e.g., cruise lines, hotels, online travel services)

The Purposes For Our Customers Use of Sold or Licensed Personal Information

Advertising and marketing, including direct marketing and interest-based, targeted or ‘cross-context behavioral’ advertising Sales and fundraising Business and professional communications Market research about consumer interests and behaviors Fraud and identify theft prevention and protection Product research and development

Categories of Personal information Disclosed To Service Providers or Contractors For A Business Purpose

Cloud computing and storage vendors Security service providers or contractors Consultants Measurement and analytics providers Advertising and marketing service providers

We also may disclose any of the personal data we process for the following purposes:

Legal Purposes: We may disclose personal information in order to comply with legal process or a regulatory investigation, enforce our legal terms or contracts, protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public, including against fraud or security incidents.
In the Event of a Corporate Transaction: We may disclose personal information in the event of a corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all our assets, or for purposes of due diligence connected with any such transaction.
With Service Providers: As noted above, we may disclose any personal information with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain, and improve our services.

Retention of Sold or Licensed Personal Information

Focus USA regularly refreshes and retains the personal information it sells or licenses. Records of sold or licensed data is deleted after twelve (12) months from the last date of ts use. Please note that following a request to delete your personal information, Focus USA may retain a record of the deletion request for the necessary purpose of ensuring that the information remains deleted and is not used for any other purpose.

Privacy Choices

As noted, if you would like to exercise your rights under applicable privacy or data broker laws, you may do so by visiting our Privacy Center.

For requests to access, correct, or delete your personal information, please be prepared to provide information that will help us verify your identity and note that Focus USA reserves the right to refuse any request that may not be available under the laws of your personal jurisdiction, or if we can not verify your identity. Any information we provide to you as part of a right To ‘Know’ or ‘Access’ request will be in a readily usable format (a.k.a. for ‘portability’ purposes).

If you are an ‘authorized agent’, you must provide in your web form submission a copy of the authorization signed by the authorizing consumer in order for you to exercise rights on their behalf.

**If you would like to provide us with a bulk data transfer on behalf of many users, you may review our bulk opt-out documentation here: https://www.focus-usa.com/docs/optout-api/.

Appeal Your Privacy Rights

If we deny your privacy request after your submission through our Privacy Center, you may appeal that decision by emailing us at privacy@focus-usa.com. Please do not attempt to contact us at this email address if you have not visited and filled out a request through our Privacy Center. If you are still unsatisfied with our response, you may have the right to file a complaint with your state Attorney General or their Division of Consumer Affairs.

International Visitors

Focus USA primarily operates and stores personal information in the United States. While we welcome international business customers to use our Business Services, we do not intentionally collect, use, or sell personal information associated with individual consumers whose residence is outside of the United States.

California Annual User Rights Request Metrics

California law requires certain businesses to compile and disclose metrics on an annual basis regarding their compliance with California privacy law and consumer rights requests. Focus USA reports the following metrics for the period of January 1, 2024 through December 31, 2024.

Requests	Delete	Correction	To Know or Access	Opt-out of sale or sharing
Personal identifiers and online identifiers	8,419	0	0	8,419
Demographic data (i.e. background)	8,419	0	0	8,419
Commercial records	n/a	n/a	n/a	n/a
Internet or other similar network activity (i.e. website activities, browsing data)	n/a	n/a	n/a	n/a
Course geolocation data (from postal or IP address, not device-specific information)	8,419	0	0	8,419
Professional or employment-related information	n/a	n/a	n/a	n/a
Inferences made about you	n/a	n/a	n/a	n/a
Information used to verify your identity (exclusively to process state-specific data subject rights)	n/a	n/a	n/a	n/a

Texas Required Data Broker Disclosure

The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

Changes to this Data Broker Privacy Notice

We may update this Data Broker Privacy Notice from time to time. If we make material changes, we will post the update on this page with a ‘Last Updated’ effective date of the revisions. We encourage you to look for updates and changes to this Data Broker Privacy Notice by checking this page.