Terms of Service and Privacy Policy

Last Updated: October 2026

This Privacy Policy explains how we collect, use, disclose, process, and retain personal information through your use of Compass International Holdings (“Company”)-owned and/or operated websites, or mobile applications, that link to this policy (collectively, the “Site”).

Collectively, the websites, mobile applications, and services, products, platforms, features, or content offered by the Company (collectively, “we”, “us”, or “our”) are referred to as the "Services".

Our brand portfolio operates under different business structures, thus our ownership and data collection practices vary across the services we offer. Please note the following distinctions:

• Owned Brands: We own and operate the brokerages, insurance, title and escrow companies, websites, and data platforms for Ansley Real Estate, Anywhere Advisors, LLC., Anywhere Leads Inc., At World Properties, LLC. d/b/a @properties, and Compass, Inc., Compass Integrated Services LLC formerly known as Anywhere Integrated Services, LLC., and Homepoint Insurance Agency Inc., formerly known as Anywhere Insurance Agency Inc.

• Franchisee-Only Brands: We design, host, and maintain the primary home pages for Better Homes & Gardens Real Estate, LLC., Century 21 Real Estate, LLC., Christie’s International Real Estate Sereno, and ERA Real Estate, LLC. However, we do not own, operate, or control the independent franchisee offices or local franchisee-operated digital sites under these brands.

• Mixed-Model Brands: Christie’s International Real Estate, Coldwell Banker Real Estate, LLC., Corcoran Group, LLC., and Sotheby’s International Realty Affiliates, LLC. consist of a mix of both Company-owned brokerages and independently owned and operated franchisees. This Privacy Policy only governs the Company-owned brokerages and corporate-hosted home pages for these brands.

This Policy applies only to brokerage, insurance, or title and escrow offices and websites owned and operated directly by the Company, including through affiliated entities or subsidiaries. It does not cover the privacy practices of franchisee-owned offices or franchisee-operated sites, even if they operate under our brand names. For example, if you submit your information to an independent franchisee agent or on an independently operated franchisee office webpage, that information is not "owned" or governed by us, and our Privacy Policy does not apply. Please visit the privacy policies incorporated on their respective sites to learn more about how they process and protect your personal information.

Our Company is committed to being transparent about our data practices. By continuing to use our Services, you agree to the terms of this Privacy Policy, which detail how we collect, process, and use your personal information to enable the delivery of our Services and to make the experience of using our websites more customary and efficient. We want you to feel confident about your privacy choices and the collection and use of your personal information, but please note that if you do not agree with this Privacy Policy, you may not be able to use some of our Services.

This policy does not apply to our “Affiliates”, which include, but are not limited to: Cartus Corporation, Compass Integrated Services Management (“CISM”), DPP Real Estate, Glide Labs, Guaranteed Rate Affinity, H.D. Randall Realtors, Kinlin Grover Realty, Latter & Blum, Launch Real Estate, Lila Delman Real Estate, OriginPoint, Pacific Union, Parks Village, Randall Realtors, Realty Austin, Stribling & Associates, Suburban Jungle Group, and Washington Fine Properties, and as well as various title and escrow companies. These companies follow their own data collection, sharing, processing, or retention practices that are reflected within their respective privacy policies. Please visit their individual websites to learn more.

“Agents” are people and other entities we contract with, including our independent contractor licensed real estate professionals, salespersons, and brokers, that may offer or provide services to you. Please note that although Agents may elect to use brokerage-designated email addresses (e.g., @compass.com) or marketing materials, Agents are independent contractors who are not employed or controlled by the Company. This Privacy Policy 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, including their own respective non-brokerage owned websites. We are not responsible for personal information Agents collect about you from outside of the Site. Please consult their respective privacy policies if you wish to learn more about an individual Agent’s data collection, usage, retention, or sharing practices.

California residents - please also refer to Section 16. What If I am a California resident? for additional information pertaining to your rights under California privacy laws.

1. What Does This Privacy Policy Cover?

This Privacy Policy covers how the Company collects, uses, discloses, processes, and retains personal information through our websites and other Services. It covers the collection of personal information related to your use of or access to our Services. Please note, Agents may collect information at an open house, an individual website, or via other direct means, that occurs outside of our Site or Services, and such interactions will be governed by their respective privacy practices.

This Privacy Policy does not apply to the data practices of the following:

• our Affiliates - to learn more about their respective practices, please visit their individual, respective website(s);
• third parties that we do not own or control, including but not limited to any landlords, renters, owners, or buyers, or Agents for interactions held outside of our Platform;
• third-party websites, services and applications (“Third-Party Services”) that you elect to access through the Services; or
• employees, and non-employee workers (“contractors”), or individuals that we do not manage or employ.

While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy or that you request through your use of the Services, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access, including without limitation those of our Agents.

Where applicable, different or supplementary notices detailing our data practices may be provided for certain personal information. Such additional notices will control in the event of any conflict with this Privacy Policy.

2. What Information Do We Collect?

In connection with certain aspects of the Services, we may request and collect personal information as well as other information, as outlined below, in connection with your use of, and access to, the Services. We collect the following types of information from our users:

• Information You May Provide Directly to Compass: When you visit our site, submit a web form, or create a user profile you may voluntarily provide us with certain information that could include, without limitation:

  Contact Information:

  • Name
  • Email address
  • Mailing address
  • Phone number

  Search Criteria & Preferences:

  • Intent to buy/sell/lease
  • Basic Geolocation (city)
  • Interested region

  Household Information:

  • Optimal Price Range
  • Number of occupants
  • Occupation
  • Age group of household members (note: we do not collect personal information for minors - but rather may ask for a range of household habitants in case age-related features are important in your search such as school districts, parks, etc.)
  • Occupant relationships
  • Income
  • Past and/or present property purchase information

• Information You May Provide To Our Affiliates: In fulfilling a requested Service, you may choose to voluntarily provide our Affiliates with certain information that could include, without limitation, personal information, such as your:

  Contact and Profile Information:

  • Name
  • Email address
  • Mailing address
  • Phone number

  Identification Information (collected or processed, as needed, in connection with a real estate transaction):

  • Date of birth
  • Photo identification
  • Social security number
  • Background check information

  Professional/Employment Information (collected or processed, as needed, in connection with a real estate transaction):

  • Employment information
  • Reference letters

  Financial Information (collected or processed, as needed, in connection with a real estate transaction):

  • Financial information
  • Financing details
  • Lease or purchase agreement information
  • Rental application information

  Real Estate Preferences & Criteria (collected or processed, as needed, in connection with a real estate transaction):

  • Information provided to help you in your real estate journey
  • Home search criteria and preferences
  • Whether you plan to buy, sell, or lease
  • Information about co-owners

  Real Estate Transaction History:

  • Information about your real estate transactions (including past/current property purchases, sales, and listings, property addresses, prices, photos, and descriptions)

  Other Information:

  • Demographic information
  • Electronic network activity information (if they use pixels, cookies, or other tracking software)
  • Any other information needed to fulfill the requested service

• Information Collected Automatically: We also receive and store certain types of information whenever you interact with the Services. We automatically receive and record information in our server logs from your browser, including:

  • IP address
  • Domain Name
  • Search queries
  • Cookie or pixel information, including basic geolocation (refer to Section 6 for additional information)
  • Mobile device identification
  • Listings, page views, and pages you request or visit
  • Details of your activity on the Services
  • Please note, if you use our Calling and Texting platform, we will collect the text message chat, text history, call time stamps (including a missed call log), email content, and voicemail messages. We keep this information to both assist the Agent with outreach and to provide an audit log for TCPA purposes. Again this only applies to users who communicate with their agent using the Company’s Calling and Texting platform - and it is solely used so that your communications with the agent are saved in one easy to use repository for the agent’s team to assist with your real estate transaction. The agent can also choose to record the call which would result in the issuance of a call transcript, however, you would be notified and have an opportunity to accept or reject this request, at that time.

  This information may be used by us to develop new services or improve the Services and may be shared with third parties, who perform analytics for us, in order to do so. Please note, we do not sell nor share your data for monetary consideration. However, if our use of third-party analytics or ad cookies is considered a "sale" or "share" under applicable state law, you have the right to opt-out, as further described in Section 6.

• Information Collected from Third Parties: We may collect or receive personal information about you and your property from a variety of third-party sources. These include, but are not limited to, public databases, joint marketing partners, social media platforms, independent brokers, affiliated real estate agents, other real estate professionals, and unaffiliated third parties (such as real estate portals data brokers, or client-developers) from whom you have consented to share your contact information.

  Social Media and Account Linking: If you choose to register on our Site, link, or log in to your Services account using a third-party service (such as Facebook, Instagram, X/Twitter, or other third-party websites), or if you engage with a separate app or website that communicates with our Services, we may receive personal information about you or your connections from that service. This may include the same categories of personal information we collect directly from you. Please note that you can typically control what information you share with us by managing the privacy settings within those third-party services.

  Specifically, we may receive the following information about you from these data sources, such as your:

  • Name
  • Email Address
  • Phone Number
  • Home search criteria and preferences
  • Household members/co-owners
  • Property Records
  • Demographic data
  • Employment information
  • Social media networking and imprints
  • Fraud detection information

  We may take this data and combine it with other information that we have about you to customize your Compass experience or enhance your customer experience.

• Information Collected from Agents: If you choose to use our Site or Services, we may receive certain information about you through our Agents. Such information may include, without limitation, personal information, such as your:

  Identification Information:

  • Background check information
  • Date of birth
  • Photo identification
  • Social security number

  Professional/Employment Information:

  • Employment information
  • Reference letters

  Financial Information:

  • Financial information
  • Financing details
  • Lease or purchase agreement information
  • Rental application information

  Real Estate & Household Information:

  • Information about your real estate transactions, including details on past or current property purchases, sales, and listings (like property addresses, prices, photos, and descriptions)
  • Information provided to help you in your real estate journey, such as your home search criteria, preferences, and whether you plan to buy or sell
  • Information about your household
  • Information about any co-owners

  Other Information:

  • Demographic information
  • Registration information (ie: if you attended an open house, or engaged the Agent directly)
  • Any other information needed to fulfill the requested service; or
  • Other information an Agent may request from you that is required by law or is otherwise required to facilitate a real estate transaction.

  By providing this information to our Agents, you understand that we may process, use, or store such information and contact you to send you information about a real estate transaction, provide the Services, or for any other reason set forth in this Privacy Policy.

Certain information we collect (including Social Security Numbers, financial account details, precise geolocation, and background check information) is considered 'Sensitive Personal Information' under applicable state laws. We collect and use this information solely to provide the requested services, process transactions, or comply with legal obligations (e.g., real estate licensee and background checks), and we do not use it to infer characteristics about you.

3. How Do We Use Your Information?

In addition to the uses set forth above, we may use information that we collect about you or that you provide to us, including any personal information for the following reasons:

Requested Services:

• to present the Services and its contents to you;
• to present brokerage services from our Affiliates to you;
• to present other adjacent services from our Affiliates to you;
• to develop Services that help Agents provide real estate transaction services to you;
• to provide you with information or services that you request from us;
• to fulfill any other purpose for which you provide your information;
• to contact you regarding the Services or your account;
• to provide you with promotional information regarding the Services;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to the Services;
• to allow you to participate in interactive features of the Services;

Email Communications, Phone Calls, SMS Communications:

As part of the Services, you may occasionally receive email, phone calls or SMS (text), and other communications from us or Company Agents, such as communications relating to a transaction, promotion, marketing, or recruiting. By creating an account on our Site, you acknowledge and agree that by providing us with your contact information and/or posting information on or through the Services, or requesting that we do so on your behalf, we and our Agents, the landlords, tenants, buyers or sellers relevant to your request for Services, and others may send you e-mail, call you or text you or otherwise contact you or engage in other communications pursuant to your request. You may also receive phone calls or SMS (text) from Agents who utilize the calling & texting capabilities of the Services.

Research and Development:

We may use your information to conduct research and development for the improvement of the Services, the development of new services and offerings and in connection with our business.

Personalized Content and Experiences:

We use your information to make our Services feel more personal to you. This includes recommending content and features we think you'll like, showing you information based on your general location, and customizing your overall experience.

Advertising and Marketing:

We use your information for marketing and to promote our services. This allows us to improve our ads, send you special offers and newsletters, and inform you about our latest promotions and contests.

We may also share information about new home sales and other products, like home warranties, so that businesses can contact you with offers; however, this will only occur after you have expressed interest in receiving the offer or promotion.

New Product Features:

We also use your data for any other purpose that we describe to you at the time we collect the information, or for any other purpose with your consent.

Legal:

To comply with our audit, legal, vendor, and regulatory obligations, attempt to prevent fraudulent claims (including wire fraud), attempt to protect against threats related to cybersecurity and financial crimes, and to defend the company against legal claims.

4. Do We Use Artificial Intelligence?

We are committed to using advanced technologies to improve your experience and to help you achieve your real estate goals. We leverage artificial intelligence (AI) and machine learning to make our platform more efficient, personalized, and effective for our consumers.

We use AI in a few key ways:

• To Improve Our Services: We use our own AI and machine learning tools, along with trusted third-party services, to analyze data on our platform. This helps us to improve the accuracy of our property recommendations, streamline searches, and make our overall services more responsive to your needs. For example, AI helps us to better understand market trends and suggest relevant properties.
• To Develop and Innovate: We use AI to build new features and tools that can offer you a more intelligent and useful experience. This may involve using de-identified or aggregated data to train and refine our AI models.
• To Ensure Data Integrity: We use AI-powered tools to help us identify and prevent fraud, protect against spam, and ensure the security of our platform and your data.

Our Commitment to Your Privacy

Your privacy is paramount. We take the following steps to ensure that our use of AI aligns with our privacy principles and legal obligations:

• No Data Training by Third Parties: When we share information with third-party service providers for AI-driven services, we enter into strict agreements that prohibit them from using your personal information to train their own AI models. We also require these providers to commit to not selling your personal data.
• De-identification: Whenever feasible, we use de-identified or aggregated data to train our internal AI models. This process removes information that could be used to personally identify you.
• Vendor Vetting: We conduct a rigorous review of each third-party AI tool and service to ensure they meet our high standards for data security and privacy before we integrate them into our platform.
• Automated Decision-Making or Profiling: While we use AI to help tailor listings and property recommendations, we do not utilize automated decision-making or profiling that produces legal or similarly significant effects on a consumer. All final real estate transactions and decisions are guided directly by human agents.

5. How, And With Whom, Is My Information Shared?

• Affiliates: We may receive and share your Personal Information or other information about you with our Affiliates to develop, support, or provide our Services. Information shared with or received from Affiliates is typically limited to your name, email address, physical address, phone number, basic geolocation data (city), demographic information (if provided), and electronic network activity information

• Transaction-Specific Information: If you pursue a real estate transaction, we, our Agents, and our Affiliates may receive, collect, or share the following additional transaction-related information as necessary to facilitate and complete your transaction:

  • Rental and sales listing information
  • Financial, credit card, or other payment information
  • Background check and rental application information
  • Information contained in any lease or purchase agreement you are negotiating or entering into, and related transaction information
  • Photo identification and reference letters
  • Bank statements and income tax returns
  • Address of a listing you intend to rent
  • Other information required by law, or any other information you provide to us, our Agents, or our Affiliates

• Agents: We may receive or share your name, email address, phone number, current address, basic geolocation (city), and search criteria, including region of interest from Agents. The sharing of this Personal Information would be in connection with their provision of services to you related to the sale, purchase, lease or financing of properties and the advertising and marketing of such properties and related services.

  • Information you provide to a Company agent may (or may not) be directly inputted into our platform by the Agent. We do not access or review this information for any business purpose, nor do we sell or share this information, for any purpose. Our Engineering team may only access this information in the event of an adverse data or IT event.
  • Agents may upload your contact information within our Platform to use our Services. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Any sharing would be solely to enable opt outs or obtain consent.

• Service Providers: We may share information about you, such as analytical data, demographic data, financial information, or fraud detection information, with service providers. Also, we work with service providers (such as AI LLM tools, auditors, advertising networks, advisors, cloud storage providers, consultants, cybersecurity consultants, e-mail distribution services, financial and accounting service providers, internet service providers, mobile network carriers, payment processors, web hosting services, customer relationship management tool providers, law firms, etc.) to perform services on our behalf, and we only (may) disclose your Personal Information with such service providers to help us provide the Services.

• Third-Party Partners:

  • Business Partners: We share information with a wide range of partners who help us run our business and provide services to you. Aside from Agents (noted above) these include: real estate aggregators, brokerage companies, concierge services, etc. We also share your information to fulfill requests you make, such as connecting you with a specific service.
  • Government Entities/Law Firms: As required by law, or pursuant to a Court order or legal action.
  • Publicly Available Information: We may share details about property transactions, most of which are already publicly available through official records.
  • With Your Consent: We will share your information with third parties when you specifically choose, and consent for us to do so. This includes other apps or websites you connect to our services.
  • Marketing and Analytics: We may work with third parties, such as social media networks, or consultants, to provide you with more relevant content, measure the effectiveness of our advertising, and better understand how our services are used.
  • Public Posts: If you submit information to public areas of our services, such as comments or social media posts, that information will be visible to others.

• Artificial Intelligence (“AI”): We use AI in order to expedite processing within our Platform, and sometimes your basic Personal Information, such as your email address, may be included when necessary to provide the requested service; however, we use techniques such as data minimization and masking, whenever appropriate. We do not engage in machine learning or use AI to create profiles, for automated decision making or for substantial decision making. To learn more about our practices concerning AI, please refer to Section 4.

• Information Disclosed Pursuant to Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

• Information Disclosed for Our Protection and the Protection of Others: We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms of Service, the California Notice at Collection, or this Privacy Policy, including investigation of potential violations thereof or hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

MLS and Real Estate Aggregator Disclosure:

Please note, when you list a property with a Company agent, and you want to publicly market it, the Agent is often required to disclose that listing with the Multiple Listing Service (MLS), enabling it to be visible to other real estate agents. The MLS, in turn, typically shares those listings with real estate portals or companies such as Zillow or Redfin, or other independent brokerages, who may also display that listing on their respective websites. Our agents must adhere to MLS listing requirements, therefore, We can not opt out of this type of information sharing practice, and do not have any control over that information once it is on the MLS.

6. What About Online Tracking and Advertising?

We use cookies and other tracking technologies (such as pixel tags and web beacons) to support our Service, analyze usage, and deliver more relevant experiences and advertising.

What Are Cookies and Tracking Technologies?

• Cookies are small text files placed on your device (e.g., computer, smartphone) when you visit a website or application. Your browser stores cookies and manages these files, allowing websites to remember your preferences, assist with site navigation, enable log-in persistence, measure site performance, and assist with advertising.
• Other Tracking Technologies, e.g., pixel tags (also known as web beacons or clear GIFs) are small blocks of code placed on websites or in emails, loaded when you access a webpage. The collected information includes data such as your IP address, web browser type, operating system, pages you view from within our Site, and links you click on. This collection helps us analyze how our website is used and allows us to enhance the functionality and performance of our services, by compiling statistics about usage, and understanding the response rates to our emails (e.g., whether an email was opened or forwarded).

Third-Party and Behavioral Advertising: Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers.

• Third-Party Tracking: These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect personal information about your online activities over time and across different websites and other online services. They use this information to provide you with Interest-Based (Behavioral) Advertising or other targeted content.
• Conversion Tracking: We use conversion tracking from third-party advertising platforms, including Google and Facebook. These programs may use cookies or pixels to help us determine aggregate, anonymous actions people took on our website after clicking an ad. Additional information related to these advertising platforms are provided below.

How Can You Opt Out From Non-required Cookies or Tracking Technologies?

Sharing and Targeted Advertising: We use tracking technologies to collect information about your online activities over time and across different social media websites like Facebook and Instagram, to better understand your interests and improve our marketing. This activity constitutes "Sharing" (Cross-Context Behavioral Advertising) under certain state laws, though we do not sell your personal information for monetary consideration.

We are committed to providing you with control over these technologies:

• Your Opt-Out Right: We respect legally recognized browser privacy signals (e.g., Global Privacy Control, or GPC). You can also opt out of the sharing of your personal information for targeted advertising at any time by clicking the “Do Not Sell/Share My Personal Information” link on our websites.
  • What is GPC? GPC is a browser setting or extension that acts as a universal "Do Not Sell or Share" signal. When enabled, it automatically tells every website you visit to stop selling or sharing your personal data and to limit targeted advertising—without you having to opt out of each site individually. Note that it is per browser - so if you set it on Mozilla Firefox and switch to Google Chrome (for example), you would have to set it again under Google Chrome.
• Analytical Use Only: Please note that if you opt out, we will continue to use certain tracking technology for essential functional, performance, and analytical purposes to enhance the website.
• Browser Settings: Most web browsers are set to accept cookies by default. You can usually adjust your browser settings to refuse or remove non-essential cookies. If you choose to disable non-essential cookies, please be aware that this may negatively impact the functionality and features of our Service.
• Opt-In/Out Mechanisms: You can adjust your preferences regarding the collection of data via pixel technology at any time by visiting the Cookie Preferences link on our site.
• Pre-existing Data: If you disable a tracking technology, we will cease using that specific technology to collect new information. However, we may still use information collected prior to your preference being set or disabled, in accordance with our Privacy Policy.

Aggregate Information: We may use and share data that has been made anonymous or de-identified (data that cannot be reasonably linked to you, your household, or your device, and that is maintained with technical and legal safeguards to prevent re-identification). This information helps us with quality control, analytics, and product development.

We are committed to keeping this data in its de-identified state and will not attempt to re-identify it, except as required or permitted by law.

7. What About Email Opt-outs?

You may opt-out of receiving marketing-related email communications from us by following the instructions included with such emails, or emailing us at opt-out@compass.com. This opt-out only applies to email messages from our Company and not third parties, Agents or Affiliates. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you want to opt-out of communications from third parties (including, without limitation Agents or Affiliates), please follow their opt-out instructions as prescribed in their respective privacy notices or email communications.

Important note regarding agent advertisement mailers: As an organization, we will not send you advertisements via mail. However, affiliated real estate agents may do so in their capacity as an independent Company real estate agent.

If we receive an opt-out request pertaining to a mailer, we forward that request to the specific agent referenced in the opt-out. However, usually the mailer is sent out using a postal service known as Every Door Direct Mail (“EDDM”). When agents use this service, provided by USPS, the agent sends mailers to every address within a given zip code, rather than to named individuals. Since these mailers are not sent to specific residents, they are not subject to opt out requests.

8. How We Limit and Protect Your Connected Email and Account Data (Google, Microsoft, Nylas, and Facebook)

Google API Disclosure:

Additional Limits on Use of Your Google User Data: If you provide certain information to us, that information may be subject to Google’s Privacy Policy and/or Terms of Service. Notwithstanding anything else in this Privacy Policy, if you provide us access to your Google account data, including Gmail, calendar, and contacts (generically referred to herein as “Google Data”), our use of that Google Data will be subject to these additional restrictions:

• We will use access to read, write, modify, or control your Gmail messages (including attachments), metadata, headers, calendar events, and contacts to provide a web client that allows users to compose, send, read, and process communications and will not transfer this Google Data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• We will not use this Google Data for serving advertisements.
• We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

Your Google Data is subject to the terms in the Google Privacy Policy.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Microsoft API Disclosure

Additional Limits on Use of Your Microsoft User Data: If you provide certain information to us, that information may be subject to Microsoft’s Privacy Statement and/or Terms of Use. Notwithstanding anything else in this Privacy Policy, if you provide us access to your Microsoft account data, including Outlook email, calendar, and contacts (generically referred to herein as “Microsoft Data”), our use of that Microsoft Data will be subject to these additional restrictions:

• We will use access to read, write, modify, or control your Outlook email messages (including attachments), metadata, calendar events, and contacts to provide a web client that allows users to compose, send, read, and process communications and will not transfer this Microsoft Data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• We will not use this Microsoft Data for serving advertisements.
• We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

Your Microsoft Data is subject to the terms in the Microsoft Privacy Statement.

Company’s use of information received from Microsoft APIs will adhere to the applicable Microsoft APIs Terms of Use, including requirements regarding the secure processing and limited use of user data.

Nylas API Disclosure

Use of Nylas for Communication Integration: To facilitate the seamless synchronization of your email, calendar, and contact services (including the Google and Microsoft integrations described above) with our Platform, we utilize the API services of a third-party infrastructure provider, Nylas.

Notwithstanding anything else in this Privacy Policy, our use of Nylas to process your connected account data is subject to the following restrictions:

• Nylas acts as a service provider (or "sub-processor") on our behalf. When you authorize a connection, Nylas will access, process, and transmit your data strictly for the purpose of enabling the communication and synchronization features within the Services.
• Nylas is contractually prohibited from using your connected account data for serving advertisements or for their own independent marketing purposes.
• Nylas's processing of your data is governed by strict confidentiality and security obligations designed to protect your information in transit and at rest.

For additional information on how Nylas safeguards data as an infrastructure provider, your data is subject to the terms in the Nylas Privacy Policy.

How about Facebook?

If you wish to delete your linked account with a platform such as Facebook, you can make a request by emailing us at compass-facebook-integration@compass.com, and request that your account be deleted.

9. How Is My Personal Information Secured?

We use industry-standard security controls across our systems, including technical (e.g., encryption), administrative (e.g., access controls), and physical measures, to safeguard your personal information. However, due to the inherent nature of the internet and the risk of sophisticated attacks, no transmission or storage system can be guaranteed to be 100% secure. Should you become aware of any security compromise related to your account, please contact us immediately at security@compass.com.

Please do what you can to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account, particularly on public computers. We endeavor to protect account information to ensure that it is kept private; however, we cannot guarantee the security of any account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Also, please be mindful of scams that target the real estate industry. We have created some guidance on these issues that can be found here. We are not responsible for any security incidents that result from your use of third party services including those offered by Agents associated with us. In no event shall We incur any legal, financial, or other liability for security incidents caused by your use of third party services or otherwise attributable to Company-affiliated Agents, Affiliates, or third party service providers.

10. Do We Process Data Internationally?

We are headquartered in the United States. Because our international-focused real estate and brokerage activities are operated exclusively by independent franchisees, those franchisees process your personal data in accordance with their own privacy policies. Our processing of international data is strictly limited to supporting our franchise network operations and facilitating requested relocation services (such as data transfers between your departure and destination locations). For such transfers, we rely on legally approved transfer mechanisms, such as Standard Contractual Clauses (SCCs), as provided by Article 46 (specifically Article 46(2)(c)) of the EU General Data Protection Regulation (GDPR), when applicable.

11. How Can I Manage My Information, and How Long Is It Retained?

When you update personal information from our system, we often maintain a copy of the unrevised information in our records for identification and logging purposes. You may request deletion of your account by submitting your request through our webform located in our Privacy Center. Please note, we may retain some information in our records after deletion of your account in order to identify and track the request.

Data Retention:

We will retain your user information and documentation for the retention period required by law, and may occasionally retain it beyond the required period, if deemed to be reasonably necessary to fulfill an ongoing business need (for example, account recovery), or to comply with applicable tax, legal or accounting requirements.

When we have no ongoing legitimate business need to use your user information, we will either delete, anonymize, aggregate, or de-identify it, or if this is not possible (for example, because your personal information has been stored in back-up archives), then we will securely store your personal information and prevent any further processing of it, until deletion is possible. When we dispose of personal information, we use reasonable procedures designed to erase or render it unreadable (for example, shredding documents and wiping electronic media).

The following principles help guide the length of our retention of records involving personal information:

• Minimize retention periods to protect the privacy of our users, while adhering to governing regulations.
• Maintain appropriate retention periods for the business purpose in which the records were collected.
• Maintain appropriate retention periods to ensure the support, operations, and security of our tech environment.
• Leverage Legal Counsel to determine when it is appropriate to share data beyond us or the third party vendors we contract with, or concerning the preservation of data in response to litigation or law enforcement requests.

12. What if I am a minor (under the age of 18)?

We do not knowingly collect, share, or sell personal information of anyone under the age of 18 years old.

13. What if I am a non-California resident?

If you are a non-California resident, and residing in a state that has a comprehensive privacy law, you may have certain legal rights related to the handling of your Personal Information, as described in greater detail below:

• The right to request information about personal information collected about you
• The right to access personal information in a portable format
• The right to opt out of the processing of your personal information for targeted advertising, the sale of your personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects (please note, we do not profile in this manner)
• The right to request deletion of personal information, aside from information necessary to use the Service
• The right to correct your inaccurate personal information
• The right to not face discriminatory or retaliatory action for exercising any of these rights

You can submit your verified consumer request for any of the above-referenced rights by submitting your request through our webform located in our Privacy Center. To verify residency, we may request up to three pieces of Personal Information for comparison against our records.

We may deny or fulfill certain requests, either in part, or in full, based on our legal rights and obligations. You have the right to submit an appeal if you are not satisfied with the outcome of your request, by emailing us at mydata@compass.com.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies.

Authorized Agents:

You may choose a person 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.

Our webform located in our Privacy Center includes an affidavit to submit if an Authorized Agent is submitting a consumer request on behalf of a consumer. Alternatively, an Authorized Agent may e-mail proof of signed permission along with a copy of their identification and have the consumer directly confirm with us that they provided permission to submit the request on their behalf, by sending an e-mail to mydata@compass.com.

14. What About Privacy Policy Updates?

We review our Privacy Policy, at least annually, to account for updated state law requirements. We also periodically update our Privacy Policy if there are changes in how we collect, use, or share your personal information. If we make a material update to our Privacy Policy we will determine the best way to notify consumers, commensurate with the nature of the change.

15. What If I Have Questions Or Concerns?

If you have any questions or concerns regarding our privacy practices using the Services, please send us a detailed message to mydata@compass.com.

16. What If I am a California resident?

If you are a California resident the foregoing privacy policy applies to your data, including the consumer rights and protections afforded above in Section 13. Yet, if you reside in California, please refer to the California Privacy Notice for additional information concerning the processing of your personal information. Notably, in addition to the webform located in our Privacy Center to exercise your rights, you may also call us toll free at: (833) 206-7824 for any consumer access requests.