Introduction
Compass Experience Labs LLC (“Compass”, “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes:
This Privacy Policy applies only to information we collect in the Website, in email, text, and other electronic communications sent through or in connection with the Website.
This Privacy Policy DOES NOT apply to information that:
Our other websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access, register with or use the Website. By accessing, registering with or otherwise using the Website, you acknowledge this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Website after we revise this Privacy Policy means you acknowledge those changes, so please check the Privacy Policy periodically for updates.
Children Under the Age of 16
The Website is not intended for anyone under the age of 18. Accordingly, the Website is therefore not intended for children under 16 years of age, and we do not knowingly collect personal information from any children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at contact@compassexperiencelabs.com.
Residents of certain states that are under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights section below, for more information.
Information We Collect and How We Collect It
We collect information from and about users of the Website:
Information You Provide to Us
When you register with or use the Website, we may ask you to provide information:
This information includes:
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on or made available through the Website is governed by the Terms of Use
Automatic Information Collection and Tracking
When you access and use the Website, we may use technology to automatically collect:
If you do not want us to collect this information do not access or use the Website. Note, however, that opting out of the Website’s collection of certain information will disable certain features related to such information (for example, opting out of the Website’s collection of location information will disable location-based features).
We may also use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
Third-Party Information Collection
When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
These third parties may use tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
The Website uses Google Analytics, a web analytics service provided by Google LLC. (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer or smartphone to help the Website analyze how visitors use the Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google. Google may use this information for the purpose of evaluating your use of the Website, compiling reports on activity and providing other services relating to activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Additional information on how Google Analytics collects and processes data may be made available by Google at the following website: www.google.com/policies/privacy/partners/.
By using the Website, you acknowledge the processing of data about you by Google in the manner and for the purposes set out above. If you do not want your data being used by Google Analytics, please note that you may opt-out of having or making your Website activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on provided by Google. Additional information may be made available by Google at the following website: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose personal information that we collect or you provide:
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You may be able to opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights section below, for more information.
Contests, Sweepstakes, and Other Promotions
We may, at various times, use the Website to collect information for contests, sweepstakes, or other promotions. The information you enter for contests, sweepstakes, or other promotions is voluntarily submitted by you. You may also receive informative email messages as a result of your entrance unless you have chosen to opt out of receiving such messages, either at the time of sign up or in accordance with the opt-out instructions included with the informative message(s) delivered to your email inbox.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at contact@compassexperiencelabs.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Proper access to and use of information provided on the Website is governed by our Terms of Use.
Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights section below, for more information.
Transfer of Information
The Website and information provided on or through the Website may be stored and processed in the United States, and is intended only for users located in the United States. If you are located in the European Union or elsewhere outside of the United States, please do not use the Website or provide any information to us or otherwise through the Website. Please be aware that information we collect will be transferred to and processed in the United States. By using the Website or providing us with any information, you acknowledge any related transfer and the processing of information in the United States.
Data Security
The security of your personal information is important to us. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like forums. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure, and we cannot guarantee the security of personal or other information transmitted through the Website.
Changes to Our Privacy Policy
We may update our Privacy Policy from time to time but reserve the right to change the Privacy Policy at any time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page, update the Effective Date of this Privacy Policy.
The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for visiting this Privacy Policy whenever you access the Website to check for any changes.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: contact@compassexperiencelabs.com.
Your State Privacy Rights
(Privacy Rights and Additional Disclosures for California, Colorado, and Other State Residents)
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (California Civil Code § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@compassexperiencelabs.com. or write us at: 638 E Fifth Avenue Columbus, OH 43201
If you need to access this Policy in an alternative format due to having a disability, please send an email to contact@compassexperiencelabs.com or write us at 638 E Fifth Avenue Columbus, OH 43201
The information contained in this “Your State Privacy Rights” section of the policy applies solely to Website users who meet the definition of the term “consumer” as defined under the California Consumer Privacy Act, as amended, and the regulations adopted by the California Attorney General and California Privacy Protection Agency, as applicable, pursuant thereto (collectively, the “CCPA”) and to other individuals entitled to analogous rights and disclosures under Colorado, Virginia, Nevada, Utah, Connecticut, or other applicable state law, in each case if applicable. Terms and correlative terms defined in the CCPA contained in this section are intended to have the same meaning and effect as set forth in the CCPA or other applicable state law, as applicable.
We collect personal information on and through the Website and process that personal information as set forth in this privacy policy. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a device or consumer's interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations. Possible job opportunity submissions.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Possible job opportunity submissions.
YES
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
Use of Personal Information
We may use, share, sell, or disclose the personal information we collect for purposes that are not materially different from those disclosed in this privacy policy and for one or more of the purposes set forth below, which may include:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales, if applicable. Our personal information sales do not include information about individuals we know are under age 16, unless we have first obtained affirmative authorization to the extent required under the CCPA or other state law, if applicable. In the preceding twelve (12) months, Compass has sold the following categories of personal information to the categories of third parties indicated in the chart below.
Category of Third-Party Recipients
Personal Information Category
Business Purpose Disclosures
Sales
A: Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Vendors
B: California Customer Records personal information categories.
A name, signature, address, telephone number, credit card number, debit card number, or any other financial information.Some personal information included in this category may overlap with other categories.
Vendors
C: Protected classification characteristics under California or federal law.
Age
None
D: Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Vendors
E: Biometric information.
None
None
F: Internet or other similar network activity.
Browsing history, search history, information on a device or device or consumer's interaction with a website, application, or advertisement.
Vendors
G: Geolocation data.
Physical location or movements.
Vendors
H: Sensory data.
None
None
I: Professional or employment-related information.
Current or past job history or performance evaluations. Possible job opportunity submissions
Vendors
J: Non-public education information.
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Possible job opportunity submissions.
Vendors
K: Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Vendors
Your Rights and Choices
The CCPA or other state law, if applicable, provides consumers with specific rights regarding their personal information. This section describes consumer CCPA or other state law, if applicable, rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will verify the request, and review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if permitted by applicable law, including without limitation if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by emailing us at contact@compassexperiencelabs.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, submit a request by emailing us at contact@compassexperiencelabs.com.
You may also make a request to know or delete on behalf of your child by emailing us at contact@compassexperiencelabs.com.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at contact@compassexperiencelabs.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out Right
To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting the following Internet Web page link, "Do Not Sell or Share My Personal Information".
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at contact@compassexperiencelabs.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
For the avoidance of doubt, Nevada consumers who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A, as amended, may submit a request by emailing us at contact@compassexperiencelabs.com
Right to Non-Discrimination
The CCPA prohibits discrimination against you because of your exercise of any of the foregoing privacy rights, or any other rights under the CCPA, including by:
We may, however, charge different rates or prices, or provide a different levels or quality of services or goods, if that difference is reasonably related to the value provided to Compass by your personal information. We may offer loyalty, rewards, premium features, discounts, or club card programs.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: contact@compassexperiencelabs.com.
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