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Privacy Policy

1. Overview and Scope

This Privacy Policy describes how FOCUS Learning Corporation (“FOCUS Learning,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information across all of our products, services, and digital properties, including:

  • The focuslearning.com marketing website
  • FOCUS Learning Products
  • The FOCUS Learning Support Portal at support.focuslearning.com (knowledge base, help desk, and customer ticketing)
  • Any other FOCUS Learning hosted services or portals

This policy supersedes any prior website-only privacy notice for focuslearning.com and applies to all individuals whose personal information we collect or process, including website visitors, prospective customers, customers, and end users of our products.

Important — FOCUS Learning Product end users

If you are a user of FOCUS Learning products as an employee of one of our customers (for example, as a plant employee completing training), your employer — not FOCUS Learning — is the data controller for your training records and qualification data. FOCUS Learning processes that data on your employer’s behalf. For questions about how your employer handles your personal information, or to exercise your privacy rights with respect to your training records, please contact your employer’s privacy or HR team directly.

2. Who We Are and Our Role

FOCUS Learning Corporation is a workforce performance software company with a remote employee base across the US. We produce and operate training management systems used primarily by organizations in high-consequence industries, including nuclear power, bulk electric utilities, Department of Energy sites, and commercial aviation.

Data Controller

FOCUS Learning is the data controller for personal information we collect about:

  • Visitors to focuslearning.com
  • Prospective customers and contacts in our marketing and sales systems (HubSpot)
  • Users of the FOCUS Learning Support Portal (support.focuslearning.com)
  • FOCUS Learning employees and contractors

As the data controller, we determine the purposes and means for which this data is processed, and we are directly responsible for your privacy rights.

Data Processor

FOCUS Learning acts as a data processor when we host and process training records, qualification data, and related content that our customers upload into FOCUS Learning products. In this role, we process data on our customers’ behalf, under their instructions, and under the terms of our Data Processing Agreement (DPA) with each customer.

If you are an end user of FOCUS Learning products and have questions about how your personal training data is handled, how to access or delete your records, or how to exercise any other privacy right, please contact your employer. We will cooperate with and support our customers in responding to such requests.

3. What Data We Collect

Website Visitors (focuslearning.com)

When you visit our marketing website, we may collect:

  • Contact form data — name, email address, phone number, company, and any message you submit through a contact or demo request form
  • Usage and analytics data — pages visited, time on site, referral source, browser type, device type, and approximate location (country/region), collected through cookies and analytics tools
  • Marketing engagement data — email open rates, link clicks, and form interactions, when you engage with our marketing communications

Support Portal Users (support.focuslearning.com)

When you use the FOCUS Learning Support Portal, we may collect:

  • Account information — name, email address, company name, and your role or title
  • Support ticket content — descriptions of issues, attachments, screenshots, and any other information you include in a support request
  • Knowledge base usage — articles viewed and search terms used, collected through HubSpot portal analytics
  • Communication records — emails and messages exchanged with our support team

FOCUS Learning Product Users

For end users of FOCUS Learning products, the data is processed on behalf of your employer (our customer). Categories of data that may be present in the system include:

  • Name and job title (for user account creation by your employer’s administrator)
  • Training completion records, assessment scores, and qualification status
  • Job task analysis (JTA) data and qualification card information
  • System access logs and activity records

This data is provided to us by your employer and is controlled by your employer. FOCUS Learning does not independently collect this data or use it for our own purposes beyond providing the contracted service.

Data We Do Not Collect

FOCUS Learning does not knowingly collect sensitive personal information such as Social Security numbers, financial account details, health or medical information, or biometric data through our products or website. Our products are not directed at children under 18.

4. How We Use Data

Purpose What we do Legal basis
Responding to inquiries Using contact form submissions to respond to demo requests, questions, and information requests Legitimate interest / consent
Marketing communications Sending product updates, event invitations, and educational content to contacts who have opted in Consent
Providing support services Using support portal data to resolve technical issues, answer questions, and improve documentation Contract performance
Product delivery Processing customer training data within FOCUS Learning products to deliver the contracted service Contract performance (on behalf of customer)
Analytics and improvement Using aggregated, anonymized usage data to improve website performance and product features Legitimate interest
Security and compliance Maintaining access logs, audit trails, and security monitoring to protect systems and meet SOC 2 obligations Legitimate interest / legal obligation

We do not sell personal information. We do not use personal information collected through FOCUS Learning Products for advertising, profiling, or marketing purposes.

5. Who We Share Data With

FOCUS Learning does not sell, rent, or share personal information with third parties for their own marketing purposes. We share data only in the following limited circumstances:

  • Service providers and subprocessors — We share data with companies that help us deliver our products and services.
  • Customers (in the processor context) — For data we process on behalf of a customer, we may share access with that customer’s authorized administrators as directed by the customer.
  • Legal compliance — We may disclose personal information when required by law, court order, or regulatory obligation, or to protect the rights, property, or safety of FOCUS Learning, our customers, or others.
  • Business transfers — In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction. We will notify affected individuals and honor existing privacy commitments.

6. Subprocessors

FOCUS Learning uses third-party service providers to deliver some aspects of our products and services. Each is engaged under data processing terms consistent with applicable privacy law and our security obligations.

Customers who require a complete, contractually binding subprocessor list as part of a Data Processing Agreement (DPA) should contact us at compliance@focuslearning.com.

7. Data Retention

We retain personal information only for as long as necessary for the purposes described in this policy, or as required by applicable law or contract.

When personal information is no longer required, we delete or anonymize it in a secure manner that prevents recovery or unauthorized access.

For more information about our data retention policies, please send a request to compliance@focuslearning.com.

8. Security

FOCUS Learning takes the security of personal information seriously, particularly given the safety-critical nature of the industries we serve. Our security program includes:

  • Encryption — All data is encrypted in transit (TLS) and at rest.
  • Access control — Role-based access controls and multi-factor authentication are required for all production system access. Access is granted on a least-privilege basis and reviewed annually.
  • Vulnerability management — Annual penetration testing is conducted by independent third parties. Continuous automated scanning is performed through GitHub Advanced Security.
  • Incident response — We maintain documented incident response procedures including data breach notification procedures, and test them regularly.
  • Employee training — All employees receive annual security and privacy training.

Security & Compliance documentation

FOCUS Learning products are hosted on secure third-party infrastructure providers that maintain independent security and compliance attestations. Customers and prospective customers conducting a security or vendor assessment may contact compliance@focuslearning.com for additional information regarding our security, privacy, and data handling practices. Information is provided through our standard review process and may be subject to confidentiality requirements.

9. Your Rights

Depending on your location and the nature of your relationship with FOCUS Learning, you may have certain rights regarding your personal information:

  • Right to access — Request a copy of the personal information we hold about you
  • Right to correction — Request that inaccurate or incomplete information be corrected
  • Right to deletion — Request that your personal information be deleted, subject to our legal and contractual retention obligations
  • Right to opt out of marketing — Unsubscribe from marketing communications at any time using the link in any email, or by contacting us directly
  • Right to data portability — Request your personal information in a portable format where technically feasible
  • Right to restrict or object to processing — Request that we limit how we use your data, or object to processing based on legitimate interest

If you are a FOCUS Learning product end user

Rights requests related to training records, qualification data, or other data in FOCUS Learning products must be directed to your employer, who controls that data. FOCUS Learning will cooperate with our customers in fulfilling verified requests. Contact your HR or privacy team at your organization.

For rights requests related to data FOCUS Learning controls directly (website contact data, support portal data, marketing communications), submit your request to compliance@focuslearning.com. We will acknowledge receipt within 5 business days and respond within 30 days. California residents, Virginia residents, and residents of other U.S. states with applicable privacy laws may exercise rights consistent with those laws.

We will not discriminate against you for exercising any privacy rights.

10. Cookies and Tracking

We use cookies and similar tracking technologies on our marketing website (focuslearning.com) and support portal (support.focuslearning.com). Cookies are small text files stored on your device that help us understand how our sites are used and support marketing functions.

You can manage or disable cookies through your browser settings. Disabling analytics and marketing cookies will not affect your ability to use our website or products.

SMS Messaging

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent will not be shared with any third parties.

Do Not Track

Our website does not currently respond to Do Not Track (DNT) signals from browsers, as there is no uniform industry standard for how to interpret these signals.

11. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your personal information, please contact our privacy team:

Nate Jones — Chief Technology Officer

Privacy Contact & Data Protection Lead

FOCUS Learning Corporation

Email: compliance@focuslearning.com

Web: focuslearning.com

For requests related to customer data deletion, please use our Customer Data Deletion Request Form (FLC-OPS-DEL-001), available from your account manager or by emailing compliance@focuslearning.com.

We will acknowledge all privacy inquiries within 5 business days.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, products, or applicable law. When we make material changes, we will:

  • Update the effective date at the top of this document
  • Notify active customers of material changes via email or through the product, where applicable
  • Post the revised policy at focuslearning.com/privacy-policy

We encourage you to review this policy periodically. Continued use of our products and services after any update constitutes acceptance of the revised policy.

Version history: Version 1.0 — Effective January 1, 2026. Initial consolidated product and services privacy policy covering focuslearning.com, FOCUS Learning Products, and the FOCUS Learning Support Portal.