BY CONTINUING TO USE THIS WEBSITE, YOU AGREE TO THESE TERMS AND OUR POLICY. FOR THAT REASON, YOU SHOULD CAREFULLY REVIEW THIS POLICY BEFORE PROCEEDING. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS TO IMMEDIATE CEASE USING OUR WEBSITE. IN ADDITION, BECAUSE OUR POLICY MAY CHANGE FROM TIME TO TIME, YOUR CONTINUED USE OF THIS WEBSITE AFTER THOSE CHANGES WILL BE DEEMED ACCEPTANCE OF THOSE CHANGES, SO CHECK BACK PERIODICALLY FOR UPDATES.
All of our content, products and services are intended for adult audiences and are NOT directed to children. We do not knowingly permit children under age 18 to register for any content, product or Service, and we do not offer any services or products to person under the age of 18. We do not knowingly collect, use or disclose personal information about users under age 18, except as permitted by law. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT USE OUR WEBSITES, OR PROVIDE ANY INFORMATION TO OUR WEBSITE. If you believe your child has impermissibly provided us with his or her personal information, please contact us, so that we can identify and delete that information.
COLLECTION OF INFORMATION
Information you provide directly
If you are interested in obtaining information, products or services from Compass, participating in certain activities through the Services, or communicating with us electronically, you may need to provide us or our service providers with information about yourself. For example:
- If you register or log-in our website to obtain information, or request further information about any of our products or services, you may be asked to provide your name, email address, telephone number and other personal information.
- If you register to receive a newsletter, or access us through social media, you may be asked for your name, email address, mailing address, phone number and other information.
- If you order a product from us or one of our business partners, you may be asked for your name, postal address, email address, telephone number and your credit card number.
- If you are ordering a product for another, you may be asked for that person’s name, postal address and phone number in order to enable us to deliver the product to the recipient.
- If you send us an email, text message, or otherwise communicate with us electronically, you will have provided us personal information, including but not limited to your name, email address, and other identifying information.
- If you apply for or seek information about an employment position, you may provide and we may collect certain personal data.
- If you contact us by telephone, we may record certain information, including personal data such as telephone number, name, geographic location, call length, and any follow-up information. Such calls may be recorded, so that any personal data you provide during the call may also be collected.
In addition, we may collect information based on any search queries you may perform on our website, survey responses, and copies of correspondence if you contact us.
Information we may collect automatically
In addition to information you choose to provide to us, Compass and our service providers also use standard technologies to automatically collect certain additional information. For example:
- IP Address and Other Identifiers. When you access and interact with our website and our Services, we and our service providers may collect information about your visits in order to permit you to connect to and obtain the Services and so that we can better understand the frequency with which specific visitors visit various parts of our Services. For example, we may collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access the Services, or information about your browser type, authentication identifiers, and other software and hardware information. If you access our website or use our the Services through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. We may combine this information with other information that we have collected to make our Services and our communications to you more targeted to your interests.
- Details of Your Visits. As you navigate through and interact with our Website, we may use automatic collection technologies, that can provide us information about the details of your visits, the resources you access, searches that you perform, and information about the computer and internet connection (including IP address) that were used.
- Web beacons and other tracking technologies. The Services may use other tracking tools, including so-called “pixel tags,” “web beacons,” “web bugs,” “clear GIFs,” etc. (collectively “Web Beacons”) to collect user activity information about your activities on the Services. These are small electronic images embedded in web content (including online ads) and email messages and are ordinarily not visible to users. Like cookies, Web Beacons enable us to track pages and content accessed and viewed by users. Also, when we send HTML-formatted (as opposed to plain text) emails to you, Web Beacons may be embedded in such emails to allow us to monitor readership levels so that we can identify aggregate trends and individual usage to provide our audiences with more relevant content or offers. Web Beacons in emails may recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web Beacons cannot be declined when delivered via a regular web page. Web Beacons can be refused when delivered via email, but if you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
USE AND DISCLOSURE
Compass and our service providers may use information that we collect from and about you or a variety of business purposes, including to operate, maintain, modify and enhance the features of our website, to provide services and fulfill business obligations, and to further the evaluation and development of our products and services. These uses may include, but not be limited to:
- Maintaining and managing your account, delivering content and services that you request, and enhancing your experience on our website;
- Keeping track of your access, and of the services or products of interest to you and to others;
- Processing and tracking your product or service orders and provide the Services and content you request;
- Communicating with you about products, content or services in which you may be interested, and responding to your inquiries or comments;
- Offering you branded or co-branded services, products, or features;
- Furthering any existing or potential business relationship, whether with you or, as applicable, your employer;
- Performing business analyses and other purposes intended to improve the quality of our business, the Services, and the products and services we offer, and to enhance the quality and contents of our website based upon usage trends and visitor preferences;
- Pursuing our legitimate business and other interests, including for our own internal administrative purposes, to investigate or report actual or potential crimes, to prevent or investigate fraud, to represent our interests in any proceedings, and to maintain records of contacts and sales;
- If applicable, evaluating your candidacy for employment; or in accordance with your consent.
- with entities that help us to manage and provide products and the Services, including development of our websites and applications, marketing, product development, research, maintenance and support, personalization, email distribution, measurement and improvement, and fulfillment, to the extent that these entities need the information to perform their services or as required by law;
- with our corporate affiliates and subsidiaries;
- with identified entities whose products or services you specifically use or request to receive while you use the Services;
- with our business partners, such as contractors, sales representatives, service providers and other third parties who support our business and are bound by contractual obligations to keep your information confidential; their use of your personal information will be governed by their own privacy policies;
- with other third parties (for example, freight companies who need your contact details to delivery products; or billing or collection services) in the ordinary course of business in order to process your requests, inquiries, to assist with your orders offered through the Services, or to enforce our agreements or to comply with contractual obligations;
- in accordance with your consent.
When information we collect is aggregated, anonymized or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
INFORMATION AND DATA SECURITY
Safety and security also depend on you. Where we have given you or you have chosen a password and username to access certain parts of our website or to provide us information or communicate with us, you are responsible to keep this password confidential. You should not share your password with anyone.
Personal information and data collected by us or provided to us may be stored and processed in any country where Compass or our affiliates, subsidiaries or service providers maintain facilities or servers. We also utilize Cloud-based storage and processing, and do not have control over where any data or information may be physically stored in the Cloud. Compass is headquartered in the United States, and as a result, it is expected that data, including personal information, is likely to be maintained in or transferred to the United States. Where information is transferred between countries, such transfer will be subject to a contract which ensures the production of information.
Insofar as you have given your consent for us to collect your personal information and process your data, the respective consent forms the legal basis for the processing covered by the consent. This applies to all data and personal information you provide to us, including but not limited to any consent to telephone or e-mail marketing you may have granted. You may withdraw your consent at any time with effect for the future. It is possible to unsubscribe from any email or other newsletters at any time, by sending a message to email@example.com.
If you have given your consent, you may withdraw this at any time with effect for the future. Insofar as we process your data, you can object to such processing. If you lodge a protest, your data will no longer be processed, unless the company responsible can furnish proof of compelling legitimate grounds for processing that outweigh your interests, rights and liberties, or insofar as processing serves the purpose of asserting, exercising or defending legal claims.
USER ACCESS AND CONTROL
You may opt out of having your personal information used or disclosed for certain purposes.
You can opt out of receiving promotional communications from us by contacting us at: firstname.lastname@example.org.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these emails be clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive.
Other than the information outlined above under Collection of Information and Use and Disclosure, we do not share your information with any third-parties. As noted in those sections, you may opt-out of this collection by disabling Cookies, and by changing the privacy settings within your browser.
While you cannot establish an account through our website, you should remember that some information may remain viewable in some circumstances where, for example, you have shared information with social media or other services, or where caching technology preserves information for a period of time. We may also retain backup information related to your use of our website or information you have provided on our servers for some time for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial or legal requirements.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act (“CCPA”):
- If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.
You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
- You can ask us to delete your personal information.
- You can ask that we stop selling your personal information.
More information on each of these requests is below.
- What personal information do you collect about me? If you make this request, we will return to you (to the extent required by law):
- The categories of personal information we have collected about you.
- The categories of sources from which we collect your personal information.
- The business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we have collected about you.
- A list of categories of personal information that we have sold, along with the category of any other company we sold it to. Any of the categories of personal information that we collect could be included in a sale to other companies, including those within our corporate family. If we have not sold your personal information, we will inform you of that fact.
- A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
- You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to personal information we collected about you in the previous 12 months.
- Delete My Personal Information: You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of functions that require your personal information.
- Stop Selling My Personal Information: While we do not sell any personal information we collected, if you are a California resident, you still have a right to “opt-out” of the “sale” of your “personal information.” To do so, please email: email@example.com.
Below is a chart showing the types of personal identifiers that we may have sold in the previous 12 months.
|Categories of Third Parties to whom the Personal Information may be Sold
|Categories of Personal Information Sold
|Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, and others)
We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please know, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require usage of your personal information to function.
To exercise the California privacy rights for requesting or deleting your personal information, please click “Request for Personal Information” at the bottom of this page.
Verifying Your Identity for Requests to Access or Delete Personal Information
We take the privacy of your personal information seriously and want to ensure that we provide only you or your authorized agent with your personal information. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you.
What personal information do I provide to verify my identity?
To verify your identity, we ask you to provide your:
How do you verify my identity?
We may verify your identity in a few different ways. We may work with a third party identification service to help us verify your identity and prevent fraudulent requests. When you make your request, you will be asked to answer a few questions about yourself to help us validate your identity. If you have an online account, we may ask you to log into your account and complete a one-time passcode validation.
In some instances, we may ask you to provide other documentation to verify your identity. If this happens, we will reach out to you directly with this request.
What if you can’t verify my identity?
If we can’t verify your identity, we will not be able to process your request to know what personal information we have about you or to delete the personal information we have about you. If we are unable to verify your identity with a high degree of certainty, we will only be able to provide a report with category-level information and we may not be able to delete some of your information.
How to Submit a Request Using an Authorized Agent
An authorized agent is a person or business who has authorization to request to know what personal information we have about you, to delete the personal information we have about you, or to opt out of the sale of personal information on behalf of a California resident. Authorized agents use the same links described above to submit requests.
If you are submitting a request on behalf of another person, we require a valid power of attorney and a signed attestation form. If you do not have a valid power of attorney, we require an authorization document and a copy of the consumer’s government-issued photo identification in addition to our attestation form. Our attestation form can be downloaded from the request form.
How do I send you my documentation?
If you submit a request on our website, you will be asked to upload this documentation when you submit your request. If you submit your request over the phone, you will be asked to email your forms to firstname.lastname@example.org. Please note, you will have 10 business days to provide all required documentation.
Your California Privacy Rights – Shine the Light
If you are a California resident, California law permits you to request information regarding the disclosure of your personal information by Compass to third parties for the third parties’ direct marketing purposes within the immediately preceding calendar year. Compass will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. To make such a request, please write us at: email@example.com.
GENERAL DATA PROTECTION REGULATION (“GDPR”) OF THE EUROPEAN UNION
This section applies only to EU citizens accessing our websites from within the EU.
Who is Responsible for Data Processing Operations? As defined by basic EU data protection regulations, CompassMSP, LLC is responsible for the processing of your personal data. Our headquarters are 67 Prospect Ave, West Hartford, CT 06106 USA. The contact information for all questions or comments regarding data protection and the use of your data is our Webmaster, who can be reached at firstname.lastname@example.org.
When Do We Acquire and Process Personal Data? As discussed more fully above, we collect information both automatically and by the user’s conduct. Please review our disclosure above for full details. We use the information in the manner disclosed above, and you can learn details by reviewing that section of this policy.
Which Data About You Can Be Collected? As disclosed in more detail above, the data to be collected can include contact data, other personal data (such as IP addresses, browser information, usage information, and others), and how you have used our website. This can include data gathered by means of cookies and other tracking technologies. For more details, please click here.
What Is The Purpose Of Processing Your Data? As disclosed in more detail above, the use of the data depends in part on what data we receive or obtain, and for what purposes. For instance, it may include providing you services, answering questions, providing customer service and care, quoting on products, sales, complying with our legal obligations, fulfilling our contractual obligations, and pursuing our legitimate interests. We also may use the data for marketing purposes, for market and product development and research, and to enhance our website and the user experience. It may also include use for employment purposes, and if you provide your data as part of a job application, your personal information will be used for the purpose of your application. We may also provide your data to third parties, in accordance with our policies described above.
How Do We Protect Your Personal Data? As disclosed above, we use commercially reasonable steps to protect data and information, including administrative, technical and physical safeguards. We again advise that there is no completely secure method of transmitting information, especially over the Internet, but we, and third parties to whom we transfer data, do our best to protect your personal data using current state of the art practices.
How Long Do We Keep Your Data? In accordance with Article 17 of the basic EU data protection regulations, we will keep your data only so long as necessary for the purposes for which we have collected and processed it, and so long as required by applicable laws and regulations. If there are multiple purposes, your data will be deleted (or stored in a manner that does not allow any use directly relating to a particular person) once the last relevant task is completed.
To Whom Do We Grant International Access To Your Data and How Do We Ensure Protection? Compass is a United States- based company, with headquarters in West Hartford, Connecticut, USA. We do not, at present, have any facilities in the EU. To the extent that you are a citizen of the EU and we receive your data, our processing and use of the data occurs in the United States, unless a third-party service provider with whom we have a contractual relationship does so within the EU at its own discretion. As noted above, we cannot ensure that when you transmit your data to us by means of the Internet, it will be secure, but we use suitable technical and organizational measures, along with contractual arrangements, for the purpose of protecting your data once it is in our possession or when it is transmitted to third-party service providers. If you would like further information about our specific security precautions taken for the transfer of data, please contact us here.
Rights to Information, Correction, Deletion and Objection; Rights of Revocation and to Complain
We reiterate that if you are a citizen of the European Union, you have certain rights under the GDPR, including a right, upon request, to a copy of your personal data, and rights provided under the GDPR, which can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rules-business-and-organisations_en. Further, in accordance with the requirements of the GDPR, we hereby advise you of the following Subject to the applicable legal prerequisites, you have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR) with respect to Compass. You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). These rights include a right to a copy of the data (right to access personal data), the right to lodge a complaint with a Data Protection Authority (DPA); the right to withdraw consent (to the extent given) at any time; the right to have corrections made, deletion of, or restrictions on the processing of your data; the right to object to the processing, and to the transfer of data.
OTHER IMPORTANT INFORMATION
Third Party Sites
In addition, we use third-party CRM software and services, some of which may be cloud-based. While our CRM is only used internally for the purposes of lead tracking, customer service, and marketing, to the extent that any of your information may be used by such software or services it may be passed on to the website or cloud-based systems of the third-party, over which Compass has no control, and thus we cannot ensure the security of any information which is passed on to such third parties.
Visiting Our Services from Outside the United States
Webmaster, CompassMSP, LLC
Last revised: 1/3/2022