Privacy Policy

Effective: 2026-04-23 Last updated: 2026-04-23

Focus Global Talent Solutions, LLC (d/b/a "Focus GTS", operating the Navigator product; "we", "us", "our") respects your privacy. This Privacy Policy explains what information Navigator collects, how we use it, how long we retain it, and the rights you have over it.

This policy covers the Navigator Portal, Navigator Slack bot, and related services (collectively, the "Service").

1. Who we are

Navigator is operated by Focus Global Talent Solutions, LLC, a Delaware limited liability company. You can reach us at:

• Email: privacy@focusgts.com
• Mailing: Focus Global Talent Solutions, LLC — Privacy Office, Delaware, USA

2. Information we collect

We collect only what we need to run the Service.

Account data. Name, work email, employer (organization), role, and authentication identifiers from your SSO provider (Google or Microsoft).

Ticket and conversation content. The questions you ask Navigator, the replies our agents produce, attachments you upload, and the full transcript of support threads. This is the operating data of the Service.

Time-tracking data. When a Navigator delivers work on your behalf, we record the hours worked, the ticket it applies to, and the approver.

Derived AI data. We generate vector embeddings and short summaries of your ticket content so Navigator can retrieve relevant context (RAG). These are derived artifacts that live alongside your content.

Knowledge content. Publicly available documentation we crawl (for example, Adobe and Salesforce product docs) and public company data (SEC EDGAR filings, Wikidata, company websites). This is not your personal data — it is used to enrich answers.

Operational telemetry. Log lines, error reports, request IDs, IP address at time of login, and browser/device fingerprints necessary for security and debugging.

We do not collect health information (PHI), payment card data (PCI), or government identifiers. Navigator is not designed for these categories of data and you should not upload them.

3. How we use your information

• To provide and operate the Service (answer tickets, route referrals, generate reports).
• To improve your experience within your own organization's workspace (for example, surface similar past tickets).
• To secure the Service, detect abuse, and debug failures.
• To send transactional email (ticket notifications, account activity, security alerts).
• To meet legal obligations.

We do not sell your personal information. We do not use your content or any derived embeddings to train foundation models or any model that serves any other customer.

4. AI and machine learning

Navigator uses large language models to answer questions and synthesize knowledge. Specifically:

• Anthropic Claude — used for synthesis, summarization, and conversational responses.
• OpenAI embedding models — used to convert text into vector embeddings for retrieval.

Both providers are contractually prohibited from training their foundation models on your data. Navigator transmits only the text needed to serve the immediate request, and we apply content-minimization where practical.

Your content, your embeddings, and our internal models are never used to train any model that serves another customer or any public-facing model. Retrieval is scoped to your organization's tenant — one customer's content is not used to answer another customer's question.

5. Retention

On termination, we delete or return your data as described in your DPA.

6. Sharing and processors

We share data only with the subprocessors listed in our Subprocessor List. These include Google Cloud (infrastructure), Anthropic (LLM), OpenAI (embeddings), Resend (email, pending), Sentry (error monitoring, pending), and Stripe (billing, future). We require each subprocessor to meet our security and confidentiality standards.

We may disclose information to comply with law, respond to lawful requests, or protect the rights, property, or safety of Focus GTS, our users, or the public. Where we are legally able, we will notify the affected customer before disclosure.

7. International transfers

Navigator is hosted in the United States (Google Cloud us-central1). If you access the Service from outside the United States, your information will be transferred to and processed in the United States. Where required, we rely on Standard Contractual Clauses (SCCs) as the lawful basis for transfer.

8. Your rights

Depending on where you live (GDPR, UK GDPR, CCPA / CPRA, and similar laws), you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete your personal information (subject to legal retention obligations).
• Port your information in a structured, machine-readable format.
• Object to or restrict certain processing.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with your supervisory authority.

To exercise any of these rights, email privacy@focusgts.com. We respond within 30 days.

9. Cookies and local storage

Navigator uses session-only authentication cookies and browser localStorage to remember UI state (navigation drawer position, dismissed banners, PWA install prompt history). We do not use tracking cookies, advertising cookies, or third-party analytics cookies. See our Cookie Policy for the full list.

10. Security

We protect your data using TLS in transit, AES-256 at rest (Google Cloud default), SSO-enforced access for Navigator staff, least-privilege IAM, audit logging, and continuous monitoring. Our full technical and organizational measures are documented in the DPA.

11. Children

Navigator is a business-to-business product. It is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact privacy@focusgts.com and we will delete it.

12. Changes to this policy

We will post updates on this page and revise the "Last updated" date above. Material changes will be communicated by email to the primary account contact at least 14 days before taking effect.

13. Contact

Questions, requests, or concerns:

• Email: privacy@focusgts.com
• Subject line: "Privacy request"

We acknowledge every request within 5 business days.