California Privacy Notice
Effective: June 23, 2022
“Affiliates” are our affiliates that retain separate branding, such as Chartwell Escrow, Inc. (“Chartwell”), Glide Labs, Inc. (“Glide”), Modus Technologies, Inc. (“Modus”), and OriginPoint LLC (“OriginPoint”).
“Agents” are people and other entities we contract with, including our independent contractor licensed real estate salespersons and brokers, that may offer or provide services to you. Please note that although Agents may elect to use Compass designated email addresses or marketing materials, Agents are independent contractors who are not employed or controlled by Compass. This CA Privacy Notice does not govern your interaction with Agents outside of the Site, and you will be governed by other privacy terms, if any, of the websites or services through which you are interacting with those Agents.
- California Privacy Rights: Shine the Light Law
California’s Shine the Light law (Cal. Civ. Code § 1798.83) permits users of the Services 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 or opt-out, please send an e-mail to email@example.com or write to us at: Compass, 90 5th Avenue, 3rd Floor, New York, New York 10011, Attention: Legal Department.
- California Privacy Rights: Online Privacy Protection Act (“CalOPPA”)
- California Privacy Rights: Consumer Privacy Act of 2018 (“CCPA”)
As defined under the California Consumer Privacy Act of 2018, if you are a California “Consumer,” you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information.”. We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us directly through the methods specified below. Only you or your Authorized Agent (as defined herein), may make a verifiable consumer request related to your Personal Information.
- Collection of Personal Information
When California Consumers access the Site, use the Services, contact Compass, or visit one of our physical locations, we may collect the following Personal Information: Customer Records Information, such as one’s name, address, email address, social security number, driver’s license, telephone number, or financial information, taken to assist you in the purchase or sale of property and process your transaction; Characteristics of a Protected Class, such as your age or race, in order to process your transaction; Professional or employment information, such as your current occupation, in order to process your transaction; and Inferences, such as what type of property you may be most interested in, thus enabling us to market to you more effectively. These data points are information that you share with us directly when visiting our Site or working with our Agents, and it is shared with our Affiliates, Analytics Providers, Service Providers, Transaction Processors, IT Vendors, and law enforcement (if necessary). Additional information that we collect is provided in the chart below:
In the preceding 12 months, we have not sold Personal Information about consumers.
In the preceding 12 months, we have not sold Personal Information about minors.
- Individual Rights
Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Compass disclose the Personal Information it collects, uses, and discloses about you to third parties.
There are two types of Right to Know requests you can make:
- Request to Know Categories of Information. Upon our receipt of a verifiable request, you will receive the following information about you:
- Categories of Personal Information Compass has collected;
- Categories of sources from which that Personal Information was collected;
- The business or commercial purpose for which the Personal Information was collected;
- The categories of third parties with whom Compass disclosed the Personal Information for a business purpose; and
- The categories of Personal Information that Compass disclosed to third parties.
- Request to Know Specific Pieces of Information Request. If you make a request to know Specific Pieces of Information, you will receive the following information:
- Specific pieces of Personal Information Compass has collected about you.
This information will be provided to you free of charge, unless Compass determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
Compass does not sell any Personal Information of California consumers.
Right to Deletion
You have the right to request that Compass and our service providers delete certain Personal Information about you that Compass has collected from you. Compass shall delete your Personal Information upon receipt of a verifiable request.
Your deletion rights are subject to several legal exceptions, and we are not required to comply with a request to delete your Personal Information if it is necessary for Compass or our service providers to maintain the Personal Information and applicable law permits our retention of your Personal Information.
Compass provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address firstname.lastname@example.org. Compass must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Compass reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Compass requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Compass. Failure to do so may result in Compass denying your request.
Right to Equal Service
Compass will not discriminate against you because you exercised any of your rights, including, but not limited to, by:
- Denying goods or services to you;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing a different level or quality of goods or services to you; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We comply with all applicable California law when providing the Services and honoring your right to equal service. Please note that any differential in Services offered may be related to the amount or quality of data or information we have compiled about you as that data or information is required for the Services, and not on your right to equal service under the CCPA.
- What About Tracking Technologies and Do Not Track Signals?
Tracking Disclosures: We may use tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We will comply with web browser “do not track” signals that you may set in your web browser regarding the collection of Personal Information about your online activities over time and across third-party websites or online services.
- What Terms Apply to California Employees and Job Applicants?
If you are a California employee or job applicant, supplemental terms in the Your California Privacy Rights notice will also apply to the collection of your Personal Information.
- What Happens When There Are Changes To This CA Privacy Notice?
- What If I Have Questions Or Concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to email@example.com.