Last updated: October 7, 2025

This Privacy Policy explains how FOCUS FOODSERVICE LLC ("Focus Foodservice," "we," "us," or "our") collects, uses, shares, and safeguards personal information when you visit focusfoodsserves.com, use our client portal, register for or attend our webinars (online or in‑person), purchase memberships or session packages, or otherwise interact with us (collectively, the “Services”). We operate our site on the Wix® platform and process payments through Wix Payments. Some Services are delivered through third‑party tools (e.g., Zoom®, Google Meet™, email and calendar providers).

By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Services.

1. Who We Are & How To Contact Us

FOCUS FOODSERVICE LLC 261 Germantown Bend Cove #101 Cordova, TN 38018, USA Email: privacy@focusfoodsserves.com (or as listed on the Site)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you may also contact us using the above details to exercise rights described in Section 11.

2. Scope

This Policy applies to personal information we collect directly from you or automatically via the Services, as well as information we obtain from service providers and partners in connection with your use of the Services. This Policy does not cover third‑party websites or services that we do not control; their privacy practices are governed by their own policies.

3. Information We Collect

We collect the following categories of information:

1. Identifiers & Contact Information. Name, email address, phone number, postal address, account username/ID, and device identifiers.

2. Account & Profile Data. Passwords, role or plan tier, organization/employer details, time zone and language preferences.

3. Transaction & Billing Data. Membership or session purchases, plan changes, invoices, payment method tokens, billing address, last‑4 of card (where available), and payment confirmations (processed by Wix Payments; we do not store full card numbers).

4. Service Use & Access Logs. Login timestamps, IP address, device and browser metadata, pages viewed, portal access activity, token activity, file downloads, attendance at webinars/events, and check‑in records for in‑person events.

5. Communications. Emails, chat messages, support tickets, feedback, survey responses, and related metadata (e.g., delivery/read confirmations).

6. Content You Provide. Submissions, uploads, assignments, brand assets, questions during webinars, and Q&A/chat messages.

7. Audio/Visual. Webinar recordings, event photography/video (where applicable and disclosed), and your voice or likeness if you speak or appear in a session.

8. Cookies & Similar Technologies. Cookies, pixels, local storage, and analytics identifiers. See Section 9.

9. Inferences. Inferences we derive from the above (e.g., preferences, interests) to tailor Services.

We may also collect limited business contact information about your team (names, work emails) when corporate plans are used. We do not knowingly collect sensitive personal information unless necessary for specific purposes you request (e.g., accessibility accommodations) and with your consent where required.

4. Sources of Information

• Direct from you (forms, checkout, registrations, emails, calls, webinars).

• Automatically (cookies, logs, analytics, session recordings where enabled).

• Service Providers/Partners (Wix, Wix Payments, email, calendar, video platforms, analytics tools).

• Publicly available sources (professional profiles, business websites) for B2B outreach consistent with applicable law.

5. How We Use Information (Purposes)

We use personal information to:

1. Provide and operate the Services, including account creation, plan management, portal access, event registrations, webinars, and Deliverables.

2. Process transactions and prevent fraud (via Wix Payments and our risk controls, e.g., AVS/CVV, 3DS where supported, velocity limits, device/IP checks).

3. Communicate with you, including confirmations, reminders, service updates, and support responses.

4. Record and deliver webinar content and replays where available; manage attendance and follow‑ups.

5. Customize and improve the Services, including analytics, troubleshooting, and feature development.

6. Enforce terms and protect the Services, our users, and our rights (security, abuse/anti‑fraud, chargeback evidence, access revocation when required).

7. Comply with legal obligations, tax and accounting requirements, and respond to lawful requests from authorities.

8. Marketing (with your consent where required): send newsletters, event invitations, and promotions; you can opt out anytime (see Section 10).

6. Legal Bases (EEA/UK/Switzerland)

Where applicable, we process personal data under: (a) contract (to deliver Services you request), (b) legitimate interests (e.g., security, fraud prevention, service improvement, B2B communications), (c) consent (e.g., marketing emails, certain cookies/recordings), and (d) legal obligations (e.g., tax, accounting, regulatory requests). You may withdraw consent at any time without affecting prior processing.

7. Sharing & Disclosures

We share personal information with:

• Service Providers/Processors. Wix (hosting, website builder), Wix Payments (payment processing), email and calendar providers, webinar/video providers (e.g., Zoom/Google Meet), analytics and anti‑fraud vendors, and cloud storage providers. These parties process data on our behalf under contracts.

• Event Partners/Venues. For in‑person events, limited attendee data may be shared to manage check‑ins and safety requirements.

• Professional Advisors. Lawyers, accountants, and auditors under confidentiality.

• Business Transfers. In connection with a merger, acquisition, financing, or sale of assets.

• Legal & Safety. To comply with law or protect rights, safety, and security, or to detect, prevent, or address fraud, abuse, or technical issues.

We do not sell personal information or share it for cross‑context behavioral advertising in the sense of the California Consumer Privacy Act (CCPA/CPRA). We may use cookies/analytics to measure and improve our Services; see Section 9 for your choices.

8. Retention

We retain personal information for as long as needed to provide the Services, comply with legal obligations (e.g., tax and accounting records), resolve disputes, and enforce agreements. Criteria include: the type of data, the length of your relationship with us, legal requirements, and our operational needs. We aim to minimize retention where feasible.

9. Cookies, Analytics & Tracking Technologies

We and our providers use cookies and similar technologies to enable core functionality (e.g., login, security), remember preferences, perform analytics, and measure campaign effectiveness.

• Types of Cookies: strictly necessary, functional, performance/analytics, and (where used) advertising/retargeting.

• Your Choices: You can manage cookies via your browser settings and any Wix cookie banner or preferences tool available on the Site. Disabling cookies may impact certain features (e.g., login persistence).

• Analytics: We may use analytics tools to understand how users engage with the Services (e.g., page views, session duration, device/browser types). These providers may set their own cookies or receive limited de‑identified data.

• Do Not Track: Our Services do not respond to “Do Not Track” signals. You can limit certain tracking via your browser or device settings and preferences tools described above.

10. Marketing Communications

We may send you newsletters, product updates, and event invitations. You can opt out by clicking “unsubscribe” in our emails or contacting us. We may still send transactional or service messages (e.g., confirmations, critical notices) even if you opt out of marketing.

11. Your Rights

Your rights depend on your location and applicable law.

11.1 EEA/UK/Switzerland (GDPR‑Style Rights)

Subject to exceptions and verification, you may have the right to:

• Access your personal data and obtain a copy;

• Rectify inaccurate or incomplete data;

• Erase data (right to be forgotten) in certain circumstances;

• Restrict processing in certain circumstances;

• Portability of data you provided to us, in a structured, commonly used, machine‑readable format, where technically feasible;

• Object to processing based on legitimate interests, including profiling; and

• Withdraw consent at any time where processing is based on consent.

To exercise rights, contact us at privacy@focusfoodsserves.com. We may request additional verification. You also have the right to lodge a complaint with your local supervisory authority.

11.2 United States – State Privacy Rights (e.g., CA, CO, CT, UT, VA)

Residents of certain U.S. states may have rights to access, correct, delete, or obtain a portable copy of personal information, and to opt out of certain targeted advertising or sales (we do not sell personal information). To exercise rights, contact privacy@focusfoodsserves.com and include your state of residence. We will verify your request consistent with applicable law. Authorized agents may submit requests with proof of authorization.

12. Children’s Privacy

Our Services are intended for individuals 13 years of age or older. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, please contact us and we will take appropriate steps to delete such information.

13. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information, including account authentication, access controls, encryption in transit, and logical separation of systems managed by our providers (e.g., Wix, Wix Payments). However, no method of transmission or storage is 100% secure. You are responsible for safeguarding your login credentials and for notifying us promptly of any unauthorized access.

14. International Data Transfers

We are based in the United States and your information may be processed in the U.S. and other countries that may have different data protection laws than your country. Where required, we rely on appropriate safeguards for cross‑border transfers (e.g., Standard Contractual Clauses) with our processors. By using the Services, you understand and consent to these transfers, subject to applicable law.

15. Webinars, Recordings & Community Areas

• Recordings. We may record webinars for quality, delivery of replays, and training. Notices will be provided where legally required. By attending, you consent to being recorded; if you do not wish to be recorded, avoid speaking on mic/camera or use text Q&A where available.

• Participation Data. Chat logs, Q&A, poll responses, and attendance may be captured and used to provide follow‑ups and improve content.

• Sharing Restrictions. You may not upload unlawful content or share confidential or third‑party information without rights to do so. We may moderate community areas consistent with our Terms.

16. Third‑Party Links & Social Media

The Services may include links to third‑party sites or features (e.g., social media). We are not responsible for third‑party privacy practices. Please review their policies before providing personal information.

17. Automated Decision‑Making & Profiling

We do not engage in fully automated decision‑making that has legal or similarly significant effects on individuals. We may use limited profiling (e.g., segmentation for email relevance) consistent with this Policy and applicable law, and you can object where your local law provides that right.

18. Your Choices & Controls

• Account Settings. You can update certain account details in your profile.

• Email Preferences. Unsubscribe links are provided in marketing emails.

• Cookies. Use browser settings and the Site’s cookie banner/preferences where available.

• Recordings. You can attend with camera/mic off or request not to be named in publicly available materials.

19. California Disclosures (CPRA)

Under the California Privacy Rights Act (CPRA), we disclose the following:

Categories collected in the last 12 months: identifiers; customer records information (billing details); commercial information (transactions); internet or network activity (logs); audio/visual (webinar recordings); inferences (preferences). We do not collect precise geolocation, biometric, or sensitive categories except as you may voluntarily provide for specific accommodations.

Sources: you, your devices, service providers, and public sources.

Business or commercial purposes: as described in Section 5.

Disclosures for business purposes: to service providers/processors for hosting, payments, communications, analytics, and security; to advisors; to authorities as required by law; and in business transfers.

Sale/Sharing: we do not sell personal information and do not share it for cross‑context behavioral advertising.

Retention: see Section 8.

Rights: access, correction, deletion, portability, and limits on use/disclosure of sensitive personal information (not routinely collected). Submit requests to privacy@focusfoodsserves.com. We will not discriminate against you for exercising your rights.

20. Changes to This Policy

We may update this Policy from time to time. The “Last updated” date at the top indicates when changes were made. Material changes will be communicated via the Site or email where appropriate. Your continued use of the Services after changes means you accept the updated Policy.

21. How To Exercise Your Rights or Ask Questions

To submit a privacy request or ask questions about this Policy or our practices, contact: privacy@focusfoodsserves.com Or write to: FOCUS FOODSERVICE LLC, 261 Germantown Bend Cove #101, Cordova, TN 38018, USA.

When making a request, please specify your location (e.g., state/country) and the right you wish to exercise. We will respond consistent with applicable law and may request additional information to verify your identity.

Using our Services means you acknowledge this Privacy Policy and consent to the collection and use of your information as described herein, subject to your rights and choices.