This privacy policy informs you about how Focus UP uses your personal data. Personal data will not be collected by Focus UP except in terms of information expressly provided by you. For example any information provided in an email, or other form of communication (i.e., verbally, website contact us form, via any social media, etc.) will be considered to be personal data.

1. Focus UP may use the personal data we collect to:

• a) improve our services, and provide you content that may be relevant to you;


• b) provide you with information, products or services that you have requested or agreed to receive including sending to you electronic newsletters, or providing you with marketing materials;


• c) conduct internal market research;


• d) contact you by electronic means with information about products, events and services which may be of interest to you; or


• e) contact you by phone, fax or standard mail for marketing, administrative or other purposes, depending upon your preferences.

With regard to 1 d) and e) above, we will provide you with an opportunity to opt-out from receiving such information, should you not wish to receive these sorts of communications in the future.

2. Focus UP will never disclose your personal data to any third parties. Except in the following cases:

• a) where you have explicitly agreed to the disclosure (for example if we are employing a subcontractor to assist with delivering our services); or


• b) to the fullest extent permitted by applicable law to satisfy any applicable law, regulation, subpoenas, governmental requests or other legal process if in our good faith opinion such is required or permitted by law. Such disclosures may be carried out without notice to you, to the fullest extent permitted by applicable law.

3. Focus UP incorporates commercially-reasonable safeguards to help protect and secure your personal data. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be safe. Please note that we cannot ensure the security of any information you transmit to us; therefore, you provide us with your information at your own risk.

4. Focus UP reserves the right to modify or add to this Privacy Policy at any time without prior notice. You agree that we may notify you of the Updated Privacy Policy by posting it on the website so that it is accessible via a link on the homepage of the website and that your submission of personal data after we have posted the Updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement to the Updated Privacy Policy. Therefore, you should review this Privacy Policy before sending us any personal data.

5. If you would like to contact us for any further information or to make a complaint, please contact us.