PRIVACY POLICY

Your privacy means a lot to us and so we want to be transparent about how FocalPoint ("FocalPoint", "We", "Our" or "Us") collects and uses your date on our websites, including https://www.focalpointadvisory.com/ (the "Site"), and all the services related to those sites (collectively, the "Service") by providing you with this privacy policy ("Privacy Policy").

If you have any questions or concerns about this Privacy Policy or how We use it, please contact FocalPoint at info@FocalPoint.online.

• WHAT THIS PRIVACY POLICY COVERS AND UNDER WHAT CIRCUMSTANCES

This Privacy Policy applies to the website at http://FocalPoint.online and any websites using any FocalPoint Services regardless of the device or browser used and regardless of whether you are a registered user or not. This Privacy Policy will remain in full force and effect, even if your use of or participation in the Site or Service ends for any reason. PLEASE NOTE: BY VISITING OR USING THIS SITE AND/OR FocalPoint SERVICES YOU ARE AGREEING TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE DO NOT USE THIS SITE OR SERVICES AND LEAVE NOW.

• INFORMATION COLLECTED AND HOW WE USE IT

When We use the term "Personal Information" we mean information that would allow someone to identify you or contact you, such as your full name, postal address, e-mail address or telephone number. When we use the term "Other Information", we mean any information other than Personal Information that may be collected about you (collectively, Personal Information and Other Information are the "Information").

Information We Collect that You Provide Us. To the extent we offer user registration on the Site certain Personal Information is required to become a registered user ("Member"). Additional optional Information may be requested from time to time. When you provide an email address as a Member you automatically opt-in to receive emails from FocalPoint. If you would like to opt-out of marketing emails you may do so in the Member Account Settings page.

Information We Collect Automatically. We collect Other Information including your IP address, browser type and operating system. We use this information in a variety of ways including, but not limited to, monitoring service, improving service levels, administrative purposes, usage trends, research, contact and anonymous reporting. Information Collected Through Cookies. "Cookies" (which may be html files, Flash files or other technology) are text files that help store user preferences and activity. "Web beacons" (also known as image tags, gif or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. The Site and/or third parties may use "cookies", "web beacons" and other similar tracking technologies (collectively, "Tracking Technologies") to collect Other Information automatically as you browse the Site and the web. We use Tracking Technologies to help tailor our content, allow users to move between associated sites without logging into each site, understand Site and internet usage, improve or customize the content and offerings on this Site, personalize your experience on this Site (for example, to recognize you by name when you return to the Site), save your password in password-protected areas, maintain and administer the Site and for other purposes. These Tracking Technologies collect "click stream" data and additional Other Information regarding your visits to the Site, such as your visits to the Site's webpages, use of our features, and purchasing history or preferences and may also collect your IP address or some other identifier unique to the Device you use to access the Site ("Identifier"). Your Identifier is automatically assigned to the Device you use to access the Site. Your Personal Information is not collected as part of this process. By visiting the Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your activities and your use of the Site through these Tracking Technologies. From time to time We will use Display Advertising from Google and other third-party vendors and may implement Remarketing in conjunction with it. Remarketing refers to the collection of Cookies by first and third party vendors for the purpose of displaying specific ads to you after you leave the Site. If We use Google Display Advertising visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.

• INFORMATION SHARING

We will not share, sell or lease your Personal Information with any third parties except under these circumstances: If you provide Personal Information with us we may share it with employees, contractors, agents or third parties doing work for FocalPoint in order to enhance the Services, perform maintenance our our systems, make you aware of our Services or personalize the Services for you.

We may aggregate users' Personal Information into groupings such as demographics, regions, interests for the purposes of enhancing and developing our Services and/or demonstrating to third parties certain kinds of information about the Service.

We may share your Information with third parties when doing so is reasonably required to perform a request you have made of FocalPoint.

Other Information Collected by Third Party Advertising Service Providers and Advertisers. The use of Tracking Technologies by Third Party Advertising Service Providers and Advertisers is within their control and not ours. Even if we have a relationship with the Third Party Advertising Service Provider or Advertiser, we do not control their websites or their policies and practices regarding your Information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Privacy Policy does not cover any use of Information that a Third Party Advertising Service Provider or Advertiser may directly collect from you. Use of Third Party Advertising Service Providers' and Advertisers' Tracking Technologies is governed by the Third Party Advertising Service Providers' or Advertisers', as applicable, own specific privacy policies and not this Privacy Policy.

When a User or Member publicly shares any Information on the Site (for example in forums or message boards).

If compelled to do so by a Governmental or Judicial body.

If, in our sole discretion, we believe such disclosure to be necessary or appropriate: to investigate or resolve possible problems or inquiries; to protect our business and assets or the rights, property or safety of the Site, the Affiliates, or any of its or their operational service providers, licensors, suppliers, Advertisers, customers, users, or any other party; to limit our legal liability; to defend our interests; to enforce this Privacy Policy or the Terms of Use Agreement and/or to comply with our legal and regulatory obligations and/or in the event of a bankruptcy, merger, acquisition, sale, transfer of control, joint venture or other business combination involving us or our Affiliates.

• YOUR PRIVACY OPTIONS

We will not use share your Personal Information in ways not covered in this Privacy Policy without first obtaining your approval. You may opt out of certain marketing emails by using the "opt out" option contained within any email sent to you. To opt out of any third party emails please visit network advertising for your options and for further information on renewing your opt-outs or opting-out again if you subsequently delete the Tracking Technologies. To stop the use of many Tracking Technologies you may use the options for this purpose built into your browser. For more information visit your grower's Help menu. Terminating certain Tracking Technologies may prevent us from providing you with the best experience on our Site.

• LINKS TO THIRD PARTY WEBSITES

We may, from time to time, provide links to third party websites on our websites. Please be aware that we are NOT responsible for the privacy policies of ANY third party website you choose to visit. If you have questions about the privacy practices of another site, please read their privacy policies.

• USER ACCESS/DISCLOSURE

Any Personal Information you submit in order to become a Member will be accessible to and editable by you through a Account Administration panel. Members may delete their accounts at any time. We do not provide access to non-Members to their Information. If you voluntarily disclose your Personal Information online either through our website (i.e. on message boards, forums, etc) or elsewhere we can take no responsibility for how that Personal Information is accessed, used, stored or disseminated. Please be careful with your Personal Information.

• SECURITY

FocalPoint has security measures in place to protect user information from loss, misuse and alteration. We use industry-standard practices such as encrypted storage, firewalls and password protection systems to safeguard the confidentiality of your personal information. Each of our employees is aware of our security policies, and your Personal Information is only available to those employees as needed and as described elsewhere in this Privacy Policy.

• CHILDREN

FocalPoint is in compliance with the Children's Online Privacy Protection Act (COPPA) and does not knowingly collect or maintain personally identifiable information from persons under 13 years of age. If we learn that such information has been collected on our Site or that any User is under the age of 13, we will take the appropriate steps to remove this information from our databases and prevent that individual from gaining access to our Services in the future.

• U.S. LAW & SAFE HARBOR

If you are using this Service from a European Union member country or other regions, the laws governing data collection and usage may differ from this in U.S. law. All user information is transferred to and processed in Our facilities in the U.S. and is collected and used in compliance with all U.S. laws. By using Our Services you consent to the use of your personal data in accordance with this Privacy Policy

• NOTICE OF CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy in a way that treats our use of your Personal Information in a materially less restrictive manner, we will attempt to notify you and obtain your consent before implementing the change. If we change this Privacy Policy in ways that do not materially affect the privacy of your Personal Information we will seek to post notification of the change on this Site. Remember your continued use of this Site and our Services means you are agreeing to this Privacy Policy and the Terms of Use.

If you have questions or comments regarding this Privacy Policy please contact us as follows:

Focal Point Advisory
Beirut
Lebanon