SITE / SOFTWARE LIABILITY STATEMENT

LAST UPDATE: February, 19th 2026 It is important to us that you have a safe and secure experience while visiting our web site or use of our many different Solutions (“Site”). This page contains our Privacy Policy. This Privacy Policy explains the privacy practices for this Site. We recognize that we must maintain and use your information responsibly, and this privacy policy explains our practices. This privacy policy may be updated or modified at any time or from time to time without advance notice. Privacy policy updates will be reflected with a revision date which is displayed near the top of the policy. Therefore, we encourage you to check the date of our privacy statement whenever you visit the Site to see if it has been updated since your last visit. By accessing the Site, you consent to the collection and use of information as described herein.

INFORMATION COLLECTED

Personal Information You can travel through most all of our website without giving us registration information about yourself. But sometimes we do ask for information to provide content or services that you request. When you register for certain content and/or services on the Site, we may ask you to provide personal information. For some content and/or services we collect personal information, such as your first name, last name, e-mail address, title, address or telephone number. We may also collect related or demographic information, such as your postal code, interest in certain products or services, and/or preferences. Information we collect may be combined with information we obtained through other services we offer.

Feedback and Responses
Any comments or materials sent to our Site including feedback data, such as questions, comments, suggestions and any other response shall be deemed to be non-confidential. Focus CSS shall have no obligation of any kind with respect to such response, and shall be free to use reproduce, distribute and publicly display such response without limitation. Focus CSS shall also be free to use any ideas, concepts, know-how or techniques contained in such response for any purpose whatsoever.

Third Party We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties.

Aggregated Information Aggregate information is data we collect about a group or category of products, services or visitors, from which individual user identities have been removed. We collect aggregate information about you and your use of our services and combine it with information about how others use the same service. Such aggregate information includes, without limitation, site traffic, page views, and impressions. This information may be correlated to you for our internal use. We may collect, compile, store, publish, promote, sell, or otherwise disclose or use any and all aggregate information (i.e., information that does not personally identify you).

Mobile No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

OUR USE OF PERSONAL INFORMATION

We use personal information to serve our visitors, enhance our services and/or extend our relationship with visitors. We use personal information for the purposes for which it was collected, such as to provide you with the content or services, to anticipate and resolve problems with our Site, to respond to support inquiries, to send periodic e-mail or newsletters, to send you relevant survey invitations, to contact contest winners, and/or for sales and marketing purposes. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. You may unsubscribe or opt-out at any time. We also maintain an opt-in phone list for the purposes cited prior. By agreeing to the terms and conditions of this privacy policy, and providing us with a phone number, Site users are adding themselves to our opt-in phone list and authorizing us to contact them for any of the prior listed purposes, regardless of their phone number’s status on the National Do-Not-Call List, or any do-not-call-list or registry maintained by any of the States or local governments within the United States. Visitors who do not wish to be contacted by phone may opt-out by writing “do not share” in an email sent to Info[at]focuscss.com, along with their phone and contact information. If you no longer wish to receive Newsletter or other mailings, you can also unsubscribe by sending an email to info[at]focuscss.com with “unsubscribe” in the subject line. In the event that our company is merged with or acquired by a third party, we retain the right to transfer all personal (consumer) information databases to successors or purchasers of the site and its assets.

DISCLOSURE OF PERSONAL INFORMATION

We will disclose personal information in the following circumstances: Internal Analysis and Operations: We will use and disclose information about you for our own internal statistical, design or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic, user interest, purchasing and other trends among our users. We may outsource these tasks and disclose personal information about you to third parties, provided the use and disclosure of your personal information by these third parties is restricted to performance of such tasks. We may also share personal information with third-party vendors who assist us in performing internal functions necessary to operate our business. We require our third party vendors to only use the information for the purpose it was provided.

Transaction Processing: We will disclose personal information to one or more third parties, as necessary, to provide you with content or services.

Lawful Compliance: We disclose personal information when we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this privacy statement or our other policies or agreements; to initiate, render, bill, and collect for amounts owed to us; to protect our or our users’ rights, property or safety; or to protect our users from fraudulent, abusive, or unlawful use of, our Site; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

Business Transfers: In addition, information about users of our Site, including personally identifiable information provided to us by our users, may be disclosed as part of any merger, acquisition or sale of company assets.

Co-Branded Services: Some services may be co-branded and offered in conjunction with another company. If you register for or use such services, both our company and the other company may receive information collected in conjunction with the co-branded services.

LINKS

Please be aware that we may provide links to third party Web sites from our Sites as a service to our users and we are not responsible for the content or information collection practices of those sites. We do not control the privacy and data collection practices of external sites and the privacy policies of such sites will differ from that of this Site. Therefore, we encourage you to review and understand the privacy policies of all such sites before providing them any information.

COOKIES

We may use cookies to identify users and customize their online experience on our Site based on information they give us. Cookies are small pieces of information or files that are stored on a user’s computer by the Web server through a user’s browser for record keeping purposes. A cookie itself is not designed or intended to read any information from your computer (other than the contents of the cookie); rather, it is an identifier used by the Web site that originally placed it on your hard drive. The actual contents of the cookie information can be retrieved by the same site’s Web server in order to personalize, monitor, or regulate the use of the site.

SECURITY

We use reasonable security measures to store and maintain personally identifying information to protect it from loss, misuse, alternation or destruction by any unauthorized party while it is under our control.

PRIVACY OF CHILDREN

We understand that young people need special safeguards and privacy protection. We realize they may not understand all the provisions of our policy or be able to make thoughtful decisions about the choices that are made available to adult users. We urge all parents to participate in their children’s exploration of the Internet and any online services, and to teach their children about protecting their personal information while online. This Site will not knowingly collect personally identifiable information from children under 13. If you are under 13 years old, you should not register for our services or otherwise provide information on our Site.

Web Site Terms, Conditions, Notices and Disclaimers
YOUR USE OF THIS WEB SITE WILL INDICATE YOUR AGREEMENT TO BE BOUND BY THE TERMS AND CONDITIONS SET FORTH BELOW. IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS, CONDITIONS, NOTICES AND DISCLAIMERS HEREIN, PROMPTLY EXIT THIS SITE.

This Agreement is VERY IMPORTANT so please read it carefully and in its entirety. PLEASE READ THESE TERMS CAREFULLY AS THEY CONTAIN IMPORTANT INFORMATION REGARDING YOUR LEGAL RIGHTS, REMEDIES AND OBLIGATIONS. THESE INCLUDE VARIOUS LIMITATIONS AND EXCLUSIONS, AND A DISPUTE RESOLUTION CLAUSE THAT GOVERNS HOW DISPUTES WILL BE RESOLVED.

THE TERMS, CONDITIONS, NOTICES AND DISCLAIMERS SET FORTH HEREIN (THE “TERMS”) GOVERN YOUR USE OF THIS INTERNET WEBSITE (“SITE” or “Site”), OR ANY OF THE PRODUCTS OR SERVICES AVAILABLE ON THE SITE. THESE TERMS ARE LEGALLY BINDING ON YOU. IF YOU DO NOT AGREE WITH ANY OF THESE TERMS, DO NOT ACCESS OR USE THIS SITE OR ANY CONTENT CONTAINED ON THE SITE. YOUR USE OF THE SITE SHALL BE DEEMED TO BE YOUR AGREEMENT TO ABIDE BY EACH OF THE TERMS SET FORTH BELOW, INCLUDING ANY MODIFICATIONS THAT WE MAY MAKE AT ANY TIME AND FROM TIME TO TIME WITHOUT ADVANCE NOTICE TO YOU BY POSTING REVISED TERMS HEREIN.

DISCLAIMERS; Please read this carefully.

SITE content is provided with RESTRICTED RIGHTS. This Site does not represent a substitute for professional advice. Content throughout this SITE may include the opinion of the authors. SITE content is not intended to replace or substitute for, the information or advice to be provided by experienced, certified or licensed professionals. SITE visitors or readers assume all responsibilities and obligations with respect to any decisions made or opinions given as a result of the use or reference of any content from this SITE. No legal representation or advice is provided in any way whatsoever. This SITE disclaims any responsibility for any harm resulting from reading, referencing, downloading or accessing any information or material on this Internet SITE.

SITE DOES NOT MAKE ANY WARRANTY AS TO THE CONTENT ON THE SITE. THE SITE AND ITS CONTENT ARE DISTRIBUTED ON AN “AS IS, AS AVAILABLE” BASIS. ANY MATERIAL THAT YOU VIEW, REFERENCE, DOWNLOAD OR OTHERWISE OBTAIN THROUGH THE SITE IS DONE AT YOUR OWN DISCRETION AND RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY POTENTIAL DAMAGES TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM YOUR DOWNLOAD OF ANY SUCH MATERIAL. NEITHER WE NOR ANY OF OUR PARTNERS MAKE ANY WARRANTY THAT (i) THE SITE WILL MEET YOUR REQUIREMENTS, (ii) THE SITE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR FREE, (iii) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE WILL BE ACCURATE OR RELIABLE, (iv) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL THAT YOU OBTAIN THROUGH THE SITE WILL MEET YOUR EXPECTATIONS, AND (v) ANY ERRORS WILL BE CORRECTED. NEITHER WE NOR ANY OF OUR PARTNERS MAKES ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, WARRANTIES OF TITLE OR IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, WITH RESPECT TO THE SITE, ANY CONTENT, OR ANY OF OUR SERVICES, TOOLS, PRODUCTS, OR PROPERTIES. YOU EXPRESSLY AGREE THAT YOU WILL ASSUME THE ENTIRE RISK AS TO THE QUALITY AND THE PERFORMANCE OF THE SITE AND THE ACCURACY OR COMPLETENESS OF ITS CONTENT. NEITHER SITE NOR OUR PARTNERS SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES ARISING OUT OF THE USE OF OR INABILITY TO USE THE SITE, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME STATES DO NOT ALLOW EXCLUSION OF IMPLIED WARRANTIES OR LIMITATION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU. IN SUCH STATES, OUR LIABILITY AND THAT OF OUR THIRD-PARTY CONTENT PROVIDERS AND/OR THEIR RESPECTIVE AGENTS SHALL BE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW.

GOVERNING LAW AND VENUE

Any and all challenges and/or legal claims shall be governed solely in the county of Essex, state of Massachusetts, country of the United States of America (USA).

SITE may be required by state or federal law to notify you of certain events. You hereby acknowledge and consent that such notices will be effective upon our posting them on the SITE or delivering them to you through e-mail. You may update your e-mail address by visiting the Services where you have provided contact information. If you do not provide us with accurate information, SITE cannot be held liable if we fail to personally notify you.

Our failure to exercise or enforce any right or provision of these TERMS shall not constitute a waiver of such right or provision.

You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Site or these TERMS must be filed within ninety (90) days after such claim or cause of action arose or be forever barred.

These TERMS, including all terms, conditions, and policies that are incorporated into these TERMS by reference, constitute the entire agreement between you and the SITE and govern your use of the SITE, superseding any prior agreements that you may have with the SITE owner and/or authors.

If any part of these TERMS is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the TERMS shall continue in effect.

Section titles in this Web Site TERMS are for convenience only and have no legal or contractual effect.

Notice to California Residents (CPRA Privacy Notice)

Effective Date: January 2026

This section applies solely to all visitors, users, and others who reside in the State of California (“Consumers”). We are providing this notice to comply with the California Privacy Rights Act (CPRA) and other California privacy laws.

1. No Sale of California Personal Information

Focus Custom Sourcing Solutions provides healthcare talent sourcing and data lists to our clients. However, we do not sell the Personal Information of California residents. We actively exclude the records of California residents from the data lists and appending services we provide to our clients.

2. Scope and Purpose

These Service Provider Terms (“Terms”) govern the processing of personal information by Focus Custom Sourcing Solutions (“FocusCSS,” “we,” “us,” or “our”) when acting as a Service Provider or Contractor for our clients (“Customer,” “you,” or “your”) regarding California residents. These Terms are designed to ensure compliance with the California Consumer Privacy Act (CCPA), as amended, and the California Delete Act (SB 362). FocusCSS acts as a Service Provider or Contractor as defined under California law. We process personal information (the “Mailing List” or “Data”) provided to us by the Customer solely for the purpose of performing specific marketing, printing, and deployment services.

3. Restrictions on Data Use

In accordance with California law, FocusCSS certifies and agrees to the following restrictions:

• No Sale or Sharing: We will not sell or share any personal information provided by the Customer.
• Purpose Limitation: We will not retain, use, or disclose the personal information for any purpose other than the specific business purposes specified in our service agreement or invoice.
• No Out-of-Relationship Use: We will not retain, use, or disclose the personal information outside of the direct business relationship between FocusCSS and the Customer.
• No Data Augmentation: We will not combine or “append” the personal information provided by the Customer with personal information we receive from other sources or collect from our own separate interactions with consumers.

4. Customer Responsibility and Data Warranty

The Customer is the “Business” and retains primary responsibility for the data provided.

• DROP Compliance: Customer warrants that any list provided to FocusCSS has been cross-referenced and scrubbed against the California Delete Request and Opt-Out Platform (DROP) within 45 days of the campaign deployment.
• Legal Basis: Customer warrants they have the legal right to provide the personal information to FocusCSS for the intended marketing purpose.
• Indemnification: Customer agrees to indemnify and hold FocusCSS harmless from any fines, penalties, or claims resulting from the Customer providing non-compliant data or failing to honor a state-mandated deletion request.

5. Data Deletion and Audits

• Retention: FocusCSS will retain Customer-provided data only for the duration necessary to fulfill the requested services. Data will be purged within thirty (30) days of campaign completion unless otherwise required by law.
• Compliance: We will notify the Customer if we determine we can no longer meet our obligations under the CCPA or the California Delete Act.

6. “Sharing” of Personal Information (Website Analytics)

While we do not sell California data lists, our website uses third-party marketing and analytics tools, including Google Analytics and LinkedIn Insight. Under the CPRA, allowing these third-party tools to collect cookie identifiers and IP addresses for cross-context behavioral advertising may be considered “Sharing” your personal information.

• Categories Shared: Internet or other similar network activity (e.g., browsing history, IP address).
• Purpose: To analyze website traffic and deliver relevant marketing.
• Opting Out: You have the right to opt out of this sharing. You can do so by clicking the “Your Privacy Choices” link in our website footer or by adjusting your browser’s cookie settings.

7. Your California Privacy Rights

Under the CPRA, California residents have the following rights regarding their personal information collected directly by us (such as when you fill out a “Contact Us” form on our website):

• Right to Know: You have the right to request the specific pieces and categories of personal information we have collected about you, the sources of that information, and our business purpose for collecting it.
• Right to Delete: You have the right to request that we delete any personal information we collected directly from you, subject to certain legal exceptions.
• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CPRA rights.

8. How to Exercise Your Rights

To submit a verifiable consumer request to Know, Delete, or Correct, or to Opt-Out of the sharing of your data via cookies, please contact us using one of the following methods:

• Email: privacy[at]focuscss.com
• Phone: 888.851.0940
• Mailing Address: Focus Custom Sourcing Solutions, 110 Haverhill Rd, Suite 298, Amesbury, MA 01913

We will verify your request by matching the identifying information you provide (such as your name and email address) to the personal information we already maintain on file.

QUESTIONS AND CONCERNS

If you have any questions about this privacy statement, the practices of our Site, or your dealings with our Site, or to submit a request to Know, Delete, or Opt-Out, please contact us at email address of privacy[at]focuscss.com or by mail at:
Focus CSS
110 Haverhill Rd.
Amesbury, MA 01913