Privacy Policy

This Privacy Policy describes how Focus Cloud Americas LLC ("Focus Cloud," "we," "us," or "our"), collects, uses, discloses, retains and protects personal information in connection with our staffing, recruitment, consulting and related services and our US website.

This Privacy Policy applies to candidates, job applicants, prospective candidates, contractors and consultants, client and prospective-client contacts, referees, business contacts and visitors to our US website.

1. Who We Are

Focus Cloud Americas LLC is a specialist staffing, recruitment and consulting business supporting organizations and professionals across enterprise technology ecosystems.

Our US business provides permanent recruitment, temporary and contract staffing and related consulting and talent services.

US entity: Focus Cloud Americas LLC

US address: 2700 Post Oak Blvd., FL 21, Houston, TX 77056

Privacy enquiries: info@focuscloud.org

Focus Cloud operates internationally. Our US and UK operations use shared technology systems and authorized personnel within the Focus Cloud Group may access information held within those systems where required for legitimate business and operational purposes.

2. Personal Information We Collect

The personal information we collect depends on your relationship with Focus Cloud and how you interact with us.

Candidates, Applicants, Contractors and Consultants

We may collect:

• Name and contact information
• Resume/CV and professional profile information
• Employment and work history
• Education, qualifications and certifications
• Skills and professional experience
• Current and previous job titles
• Employment preferences
• Compensation, salary and rate information
• Availability and location
• References and referee information
• Identification and work-authorization information where required
• Information required for onboarding, contracting or payroll where applicable
• Information obtained during interviews or recruitment processes
• Communications with our consultants
• Information concerning assignments, engagements and placements
• Information required to comply with legal, regulatory or contractual obligations

Certain information may constitute sensitive personal information under applicable state law. Where we need such information, we will collect and use it only where reasonably necessary and as permitted by applicable law.

Clients, Prospective Clients and Business Contacts

We may collect:

• Name
• Job title
• Employer or organization
• Business contact information
• Communications with Focus Cloud
• Recruitment, staffing or consulting requirements
• Contract and commercial information
• Information concerning your interactions with our services and personnel

Website Visitors

When you use our website, we and our technology providers may collect:

• IP address
• Device and browser information
• Pages visited
• Time spent on pages
• Referral information
• Website interaction information
• Cookie and similar technology identifiers
• Advertising and analytics information

Additional information about these technologies is provided in our separate US Cookie Policy.

3. Where We Obtain Personal Information

We may obtain personal information:

• Directly from you
• Through applications, registrations and communications with us
• From clients or prospective employers
• From agents or representatives acting on your behalf
• From referees and professional contacts
• Through referrals and recommendations
• From publicly available professional sources
• From professional networking platforms such as LinkedIn
• From job boards
• From social media and other publicly available online sources
• Through technology ecosystem events, meetings and professional introductions
• Through sourcing and recruitment tools

We currently use sourcing tools, including Zoominfo and Lusha to assist our recruitment teams in identifying potentially suitable professionals using information available from professional and publicly accessible sources.

We may contact individuals who have not previously registered with Focus Cloud where we reasonably believe their professional background may be relevant to an opportunity or to our recruitment and staffing services, subject to applicable law and their communication preferences.

4. How We Use Personal Information

We may use personal information to:

• Identify candidates for employment, contract and consulting opportunities
• Match skills, experience, qualifications and preferences with opportunities
• Communicate with candidates about relevant opportunities
• Evaluate candidate suitability
• Present candidate information to clients in connection with potential opportunities
• Arrange and manage interviews
• Verify information and conduct appropriate checks
• Obtain and manage references
• Manage placements, contracts and consulting engagements
• Onboard contractors and consultants
• Administer contractor management and payroll processes where applicable
• Provide recruitment, staffing and consulting services to clients
• Manage client and prospective-client relationships
• Respond to inquiries and requests
• Conduct business development
• Improve our services
• Operate, secure and improve our website
• Measure website and marketing performance
• Conduct recruitment and business marketing
• Maintain business and financial records
• Prevent fraud, abuse and security incidents
• Establish, exercise or defend legal claims
• Comply with applicable federal, state and local laws and regulatory requirements

We may also use information for other purposes that are compatible with the reason it was collected or as otherwise permitted by law.

5. Recruitment Technology, Artificial Intelligence and Candidate Matching

We use technology to support our recruitment and internal operations.

This includes Microsoft 365 Copilot and Autometry, together with software tools that may assist our consultants by generating candidate matches, rankings or other indicators.

These technologies are used to support our recruitment professionals rather than replace professional judgment.

Where candidate-matching or scoring technology is used, its output is reviewed by members of our team. Focus Cloud does not make decisions that significantly affect a candidate solely on the basis of an automated score or ranking.

We will use these technologies in accordance with applicable federal, state and local requirements governing employment, privacy, discrimination and automated decision-making.

6. Systems and Service Providers

Our US business uses shared Focus Cloud Group technology infrastructure.

Personal information may be stored or processed using systems including:

• Bullhorn – recruitment CRM
• ETZ – contractor management and payroll
• Workday – HR and consulting services management
• Xero – accounting
• Microsoft 365 – email, documents and collaboration

We also use website and business technology providers including:

• Google LLC – Google Analytics 4 and Google Tag Manager
• Microsoft Corporation – Microsoft Clarity
• LinkedIn – LinkedIn Insight Tag
• ZoomInfo Technologies LLC – ZoomInfo WebSights

These and other vendors may process personal information on our behalf or in connection with services they provide to us.

We expect service providers handling personal information on our behalf to protect that information appropriately and use it in accordance with their contractual obligations and applicable law.

7. Website Analytics, Advertising and Business Intelligence

Subject to your cookie choices and applicable law, we use website technologies to understand how visitors interact with our website and to measure and improve our marketing.

These include Google Analytics 4, Google Tag Manager, Microsoft Clarity and LinkedIn Insight Tag.

Microsoft Clarity may provide interaction analytics such as session recordings, heatmaps, clicks and scrolling behavior.

We also use ZoomInfo WebSights, which uses IP address and firmographic information to help identify organizations visiting our website and support our business-development activity.

More information is available in our US Cookie Policy, including information about managing cookie preferences.

8. How We Disclose Personal Information

We may disclose personal information where reasonably necessary for our business and services, including to:

Clients and Prospective Employers

Candidate information may be disclosed to organizations considering candidates for employment, contract assignments or consulting engagements.

Focus Cloud Group Companies

Because Focus Cloud operates internationally using shared systems, information may be accessed by authorized Focus Cloud Group personnel, including personnel located outside the United States, where necessary to provide services, operate the business, administer systems, support candidates and clients, or meet legal and compliance requirements.

Technology and Service Providers

We may disclose information to providers supporting:

• Recruitment systems
• Contractor management
• Payroll and onboarding
• IT and cloud infrastructure
• Accounting
• Communications
• Website hosting
• Analytics
• Marketing
• Business intelligence
• Verification and referencing
• Professional advisers and other business operations

Legal and Regulatory Purposes

We may disclose information where required or permitted by law, including to comply with legal process, protect legal rights, investigate suspected fraud or misconduct, enforce agreements, protect individuals or organizations, or establish, exercise or defend legal claims.

Business Transactions

Personal information may be disclosed as part of a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, subject to applicable law.

9. Sale, Sharing and Targeted Advertising

Focus Cloud does not sell personal information for monetary consideration.

Some US state privacy laws define terms such as "sale," "sharing" or "targeted advertising" more broadly than an ordinary commercial sale.

Certain website advertising and analytics technologies, including the LinkedIn Insight Tag and other third-party technologies, may involve disclosures or processing that could fall within those broader definitions under applicable state law.

Where required, eligible residents may opt out of such processing through our Cookie Settings or by contacting us using the details below.

Where legally required, we will also recognize applicable browser-based opt-out preference signals, such as Global Privacy Control.

We do not sell or share SMS opt-in information with third parties for their own marketing purposes. We may provide information necessary to vendors and telecommunications providers that help us deliver requested messaging services.

10. Sensitive Personal Information

In connection with recruitment, contracting or employment-related activities, we may occasionally need to process information treated as sensitive under applicable law, including certain:

• Government identification information
• Financial or payroll information
• Work-authorization information
• Health or accommodation information
• Demographic information where legally required or voluntarily provided

We use sensitive personal information only for purposes reasonably necessary to provide our services, administer employment or contracting relationships, comply with law, provide requested accommodations, maintain security, or for other purposes permitted by applicable law.

We do not use sensitive personal information to infer characteristics about individuals except where permitted by applicable law.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate business, legal, contractual and compliance purposes.

When determining retention periods, we consider:

• The nature and sensitivity of the information
• Our relationship with the individual
• Recruitment and placement requirements
• Contractual obligations
• Payroll, tax and accounting requirements
• Applicable statutes of limitation
• Legal and regulatory obligations
• Potential or actual disputes
• Security and fraud-prevention requirements
• Whether an individual has requested deletion

When information is no longer reasonably required, we take appropriate steps to delete, anonymize or securely dispose of it, subject to applicable law and technical limitations.

12. Security

We maintain administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration and disclosure.

These safeguards include controls appropriate to the nature of the information and the systems through which it is processed

No electronic transmission or storage system can be guaranteed to be completely secure, and we cannot guarantee absolute security.

13. International and Group Access

Focus Cloud Group operates internationally and uses shared technology systems.

As a result, personal information collected in the United States may be stored, processed or accessed from other countries, including the United Kingdom and countries in which our service providers operate.

Those countries may have privacy laws that differ from those in your US state.

Where required by applicable law, Focus Cloud uses appropriate contractual, organizational or other safeguards relating to international processing and access.

14. US State Privacy Rights

Depending on where you reside and whether an applicable state privacy law applies to Focus Cloud or the particular processing activity, you may have rights concerning your personal information.

These may include the right to:

• Confirm whether we process your personal information
• Request access to personal information
• Request correction of inaccurate information
• Request deletion of personal information
• Obtain a portable copy of certain information
• Opt out of certain sales or sharing of personal information
• Opt out of targeted advertising
• Limit certain uses or disclosures of sensitive personal information
• Appeal certain decisions concerning a privacy request
• Not be discriminated against for exercising applicable privacy rights

These rights are subject to applicable legal requirements, exemptions and exceptions and therefore may not apply in every circumstance.

California Residents

Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), applies, California residents may have rights to request information concerning the categories and specific pieces of personal information we collect, the sources of that information, our purposes for using it and categories of third parties to whom it is disclosed.

Eligible California residents may also have rights to request correction or deletion and to opt out of the sale or sharing of personal information, as those terms are defined by the CCPA, and to limit certain uses of sensitive personal information.

California residents also have the right not to receive discriminatory treatment for exercising applicable CCPA rights.

These rights may apply to personal information collected in employment and recruitment contexts where the CCPA applies.

15. Exercising Your Privacy Rights

To submit a privacy request, contact:

• Email: info@focuscloud.org
• Subject: US Privacy Request

You may also use any privacy-request mechanism made available on our US website.

Please tell us:

• Your name
• Your state of residence
• Your relationship with Focus Cloud
• The right you wish to exercise
• Sufficient information for us to locate the relevant records

We may need to verify your identity before completing a request. We will use information provided for verification only as permitted by applicable law.

Where applicable law permits an authorized agent to submit a request on your behalf, we may require evidence of that authority and may also verify your identity directly.

We will respond within the timeframe required by the law applicable to your request.

Where an applicable state law provides a right to appeal our decision, instructions for doing so will be included in our response.

16. Marketing Communications

You may opt out of marketing communications at any time by using the unsubscribe mechanism contained in the communication or by contacting us.

Candidates may also tell their Focus Cloud consultant that they no longer wish to receive communications about opportunities.

Opting out of marketing does not prevent us from sending communications that are necessary for an existing recruitment process, assignment, contract or other business relationship.

17. Cookies and Online Tracking

Our website uses cookies and similar technologies for website functionality, analytics, performance, business intelligence and marketing.

For details about the technologies used and your choices, please review our separate US Cookie Policy.

You can also manage non-essential cookie technologies through the Cookie Settings control on our website.

18. Children's Privacy

Focus Cloud's services are intended for businesses and working-age professionals and are not directed toward children.

We do not knowingly use our website to collect personal information from children under 13 for purposes covered by the Children's Online Privacy Protection Act.

If you believe a child has provided personal information to us inappropriately, please contact us.

19. Third-Party Websites

Our website may contain links to third-party websites and services.

Focus Cloud is not responsible for the privacy practices of websites or services we do not control. We encourage you to review the privacy information provided by those organizations.

20. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our business, technology, privacy practices or legal requirements.

When we update it, we will revise the "Last updated" date at the top of this page.

Where appropriate or required by law, we may provide additional notice of material changes.

21. Contact Us

Questions, concerns and privacy requests concerning Focus Cloud's US operations can be directed to:

Focus Cloud Americas LLC
2700 Post Oak Blvd., FL 21
Houston, TX 77056

Privacy enquiries: info@focuscloud.org
Please include "US Privacy" in the subject line where possible.