Privacy Policy

Last updated: May 14, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to FocusCFO LLC, 1010 Jackson Hole Dr, Blacklick, OH.
• Consent Management Platform or CMP refers to the HubSpot consent banner used by the Company to obtain, record, and manage Your consent to non-essential Cookies and other Tracking Technologies before they are loaded on Your Device.
• Cookies are small files that are placed on Your computer, mobile device or any other Device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Ohio, United States.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Tag Manager refers to Google Tag Manager, the container We use to deploy and conditionally fire third-party tags, pixels, and scripts based on Your consent choices.
• Tracking Technologies means Cookies, web beacons, pixels, tags, scripts, software development kits, session replay tools, and similar technologies used to collect information about Your interactions with the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to FocusCFO, accessible from www.focuscfo.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

Usage Data

Usage Data is collected automatically when You use the Service. Where the collection of Usage Data depends on non-essential Tracking Technologies, that data is only collected after You have provided affirmative opt-in consent through Our CMP.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

If You consent to functionality, analytics, and/or advertisement Cookies as described below, We (and Our Service Providers) may also collect data about how You navigate and interact with the Service, including mouse movements, clicks, scroll behavior, page sequence, and similar interaction signals. This is described in more detail in the Tracking Technologies and Cookies section.

Tracking Technologies and Cookies

Our Consent-First Approach

We use Cookies and similar Tracking Technologies on the Service. By default, all non-essential Tracking Technologies are disabled when You first visit the Website. No analytics, functionality, or advertisement Cookies, pixels, beacons, tags, scripts, session replay tools, heatmapping tools, or similar technologies are loaded, fired, or used to collect information about You unless and until You provide affirmative, opt-in consent through Our consent banner.

This consent-first approach applies to all visitors, including (but not limited to) residents of California for purposes of the California Invasion of Privacy Act ("CIPA"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), and any visitor protected by similar state or federal law.

The only Cookies that may be set before You interact with the consent banner are strictly necessary Cookies required to operate the Website, deliver the consent banner itself, and record Your consent choice.

When You first arrive on the Website, We display a consent notice that reads substantially as follows:

This website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. To find out more about the cookies we use, see our Privacy Policy.

If you decline, your information won't be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.

You may then click Accept, click Decline, or click Cookie Settings to make granular choices among four categories: Necessary, Functionality, Analytics, and Advertisement.

If You decline, You may still use the Service. Non-essential Tracking Technologies will not be loaded. You can change Your choice at any time by clicking the Cookie Settings link on the Website.

Cookie Categories

The Website organizes Cookies and other Tracking Technologies into four categories. Only the Necessary category is active by default. The other three categories load only after You opt in for that specific category through Our consent banner.

Necessary Cookies are required for the Website to function and to record Your consent choices. These cannot be switched off.

Functionality Cookies allow the Website to remember choices You make (such as language preference or login state) and provide enhanced, more personal features.

Analytics Cookies allow Us and Our Service Providers to count visits and traffic sources, understand how visitors move through the Website, measure performance, and identify usability issues. This category includes session replay and heatmapping technologies (described below) which record Your interactions with pages — including mouse movements, clicks, scrolls, and the sequence of pages You view — to help Us identify and fix usability problems. These technologies do not record what You type into password fields, and We have configured them to mask sensitive form inputs. They do not capture the content of communications with other parties.

Advertisement Cookies are used to build a profile of Your interests, measure the effectiveness of advertising campaigns, and show You relevant advertisements on other websites. These Cookies may share data with Our advertising partners.

Specific Cookies and Tracking Technologies in Use

The table below lists the Tracking Technologies deployed on the Service. We use Google Tag Manager to deploy these tags conditionally — meaning each tag is configured to fire only when You have granted consent for the corresponding category through Our consent banner. We also implement Google Consent Mode v2 and Microsoft Clarity Consent V2 so that consent signals are passed through to Google and Microsoft properties in a privacy-safe manner.

Necessary (Always Active — No Consent Required)

Analytics (Loaded Only After Opt-In Consent to the Analytics Category)

About Microsoft Clarity (session replay and heatmaps): With Your consent, Microsoft Clarity records video-like replays of Your interactions with the Website (mouse movements, clicks, scrolls, and page navigation) and aggregates that data into heatmaps to help Us understand how visitors use the Service. We have configured Clarity to mask form field inputs by default so that information You type into fields (other than what You deliberately submit) is not recorded. Clarity is operated by Microsoft as Our Service Provider; recordings are stored on Microsoft's infrastructure and used only to provide analytics to Us.

Advertisement (Loaded Only After Opt-In Consent to the Advertisement Category)

These advertising technologies may share information with the respective providers, including a hashed identifier, Your IP address, and Your interactions with the Website. The providers may use this information to build profiles of Your interests and to deliver targeted advertising to You on other websites and apps.

Functionality (Loaded Only After Opt-In Consent to the Functionality Category)

We do not use HubSpot chat widgets, keystroke-logging tools, or other technologies that record the content of what You type, beyond the form information You intentionally submit to Us.

How to Manage or Withdraw Your Consent

You can review, change, or withdraw Your consent at any time by:

1. Clicking the Cookie Settings link available on the Website to reopen the consent banner and adjust Your category-by-category choices.
2. Adjusting Your browser settings to refuse or delete Cookies. Instructions for the major browsers are available in their respective help menus.
3. Submitting a request through www.focusCFO.com/ask-us-anything.

Global Privacy Control (GPC). We honor the Global Privacy Control browser signal. If Your browser transmits a GPC signal, We will treat that signal as an opt-out of (a) the sale or sharing of Personal Data, (b) advertisement Cookies, and (c) any non-essential Tracking Technologies that fall within the scope of the signal under applicable law.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and to evaluate and improve Our Service, products, services, marketing, and Your experience.

We may share Your personal information in the following situations:

• With Service Providers: We share Your personal information with Service Providers — including Google (Google Analytics, Google Ads, Google Tag Manager), HubSpot, Microsoft (Clarity), Meta Platforms, LinkedIn, and Simpli.fi — to monitor and analyze the use of our Service, deliver advertising, and contact You. These Service Providers receive information only after You have consented to the corresponding Cookie category.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy.
• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Notice to California Residents (CIPA, CCPA/CPRA)

If You are a California resident, the following additional disclosures apply to You.

California Invasion of Privacy Act (CIPA)

We use an opt-in Consent Management Platform that prevents non-essential Tracking Technologies from loading or transmitting any information until You have affirmatively consented through Our consent banner. This includes analytics Cookies, session replay and heatmapping tools (Microsoft Clarity), advertising pixels (Google Ads, Meta, LinkedIn Insight Tag, Simpli.fi), and any similar technologies described above.

By accepting Analytics Cookies through Our consent banner, You expressly consent to the recording of Your interactions with the Service through Microsoft Clarity session replay and heatmapping, including the recording of mouse movements, clicks, scrolls, page navigation, and similar interaction data, for the purpose of improving the Service. By accepting Advertisement Cookies, You expressly consent to the deployment of advertising pixels that share data about Your interactions with the Service with third-party advertising partners for measurement, attribution, and remarketing purposes.

We do not deploy any Tracking Technology on the Service that functions as a "pen register" or "trap and trace device" within the meaning of California Penal Code sections 638.50–638.51 without Your consent. We do not intercept, eavesdrop on, or record the content of confidential communications between You and any third party, and We do not record what You type into form fields beyond information You deliberately submit to Us.

Your California Privacy Rights (CCPA/CPRA)

Subject to certain exceptions, California residents have the right to:

• Know what categories and specific pieces of Personal Data We have collected about You, the sources of that data, the purposes for collecting it, and the third parties with whom We share it.
• Delete Personal Data We have collected from You.
• Correct inaccurate Personal Data We maintain about You.
• Opt out of the sale or sharing of Your Personal Data, including for cross-context behavioral advertising.
• Limit the use of Your sensitive Personal Data.
• Non-discrimination for exercising any of these rights.

To exercise any of these rights, You (or Your authorized agent) may contact Us using the contact information at the end of this Policy. We will verify Your request before responding.

Global Privacy Control

We recognize and honor the Global Privacy Control (GPC) browser signal as a valid opt-out of sale and sharing of Personal Data for California residents.

"Sale" and "Sharing" Under California Law

Some of the Tracking Technologies described in this Policy — particularly advertisement Cookies provided by Google Ads, Meta, LinkedIn, and Simpli.fi — may constitute a "sale" or "sharing" of Personal Data under the CCPA/CPRA, because data about Your interactions with the Service is transmitted to those advertising partners for advertising purposes. We only enable these technologies when You have consented to the Advertisement category in Our consent banner, and We will not enable them if You have transmitted a Global Privacy Control signal or otherwise opted out.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact Us:

• By visiting this page on our website: www.focusCFO.com/ask-us-anything
• By mail: FocusCFO LLC, 1010 Jackson Hole Dr, Blacklick, OH