Terms of Service and Privacy Policy
California Privacy Notice
Effective: July 1, 2024
Notice at Collection and California Privacy Policy
Compass, Inc. (“Compass”) respects your privacy, and we are committed to providing you with transparency as to our collection, use, disclosure, sale, sharing, and retention of personal information (“Information Practices”), and how you can manage your privacy preferences. This California Notice at Collection and Privacy Policy (“CA Privacy Notice”) applies solely to California residents. The CA Privacy Notice does not apply to information we collect in the context of an individual’s interaction with us as a job applicant, employee, contractor, or other role within Compass - for that information please refer to our “CCPA Workforce Disclosure”.
Notice at Collection
The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared.
General Personal Information
| Do We collect? | Categories of Personal Information | Purposes for Collection | Sold to Third Parties or Shared with Third Parties for Cross-Context Behavioral Advertising |
|---|---|---|---|
| Yes | A. Identifiers: For example, a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, agent license number and licensing state; date of birth; debit card information; credit card information; IP address; Cookie Session Identifier; or other similar identifiers |
|
No |
| Yes | B. Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, 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 history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
|
No |
| Yes | C. Characteristics of CA or Federal Protected Classifications: For example, race, religion, national origin), age (40 and over), gender, sexual orientation, medical condition, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), familial status, disability, veteran status, or genetic information |
|
No |
| Yes | D. Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
|
No |
| Yes | E. Biometric Information: For example, photos indicating a physical likeness, and keystroke patterns |
|
No |
| Yes | F. Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, or Zoom data for employees |
|
No |
| Yes | G. Geolocation Data: For example, information that can be used to determine a device’s physical location |
|
No |
| Yes | H. Sensory or Surveillance Data: For example, audio, electronic, visual, thermal, olfactory, or similar information that can be linked or associated with a particular consumer or household |
|
No |
| Yes | I. Professional or Employment-Related Information: For example, compensation, evaluations, performance reviews, personnel files and current and past job history. |
|
No |
| Yes | J. Education Information (defined as information that is not publicly available personally identifiable information as defined in 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 education institution or party acting on its behalf, for example, non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information |
|
No |
Sensitive Personal Information
| Do We collect? | Categories of Sensitive Personal Information | Purposes for Collection | Sold to or Shared with Third Parties for Cross-Context Behavioral Advertising |
|---|---|---|---|
| Yes | Social Security Number, Driver’s License, State Identification Card, or Passport Number |
|
No |
| Yes | Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account |
|
No |
| Yes | Precise geolocation |
|
No |
| Yes | Racial or ethnic origin, religious or philosophical beliefs, or union membership |
|
No |
| Yes | Contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication) |
|
No |
| No | Genetic data | N/A | N/A |
| Yes | Biometric information for the purpose of unique identification |
|
No |
| Yes | Health information* |
|
No |
| No | Information concerning sex life or sexual orientation | N/A | N/A |
Please note that Compass does not collect any sensitive personal information for the purpose of inferring characteristics about any consumer. Therefore, we are not required to include a “Limit My Sensitive Personal Information” link on our website.
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 the Compass environment.
- Leverage Legal Counsel to determine when it is appropriate to share data beyond Compass or third party vendors we contract with, or concerning the preservation of data in response to litigation or law enforcement requests.
Please note that Personal Information does not include publicly available information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; or de-identified or aggregated consumer information.
We will not collect additional categories of personal information without providing you with a new Notice at Collection disclosing those categories.
We share your personal information with third parties for the purpose of providing contracted or requested services, or to carry out a business purpose such as information security support, or employment/HR services.
Do Not Sell/Share My Personal Information
You have the right to request that Compass and our service providers not sell or share certain Personal information that Compass has collected from you to a third party, outside of information necessary to conduct certain business purposes (ie: payroll/HR functions). You can exercise that right at any time, by clicking the “Do Not Sell/Share My Personal Information” link available on our website in our dedicated Privacy Center. The link is also available on the homepage of our website and mobile apps.
You can also request an opt out by emailing us at: opt-out@compass.com, or submitting your request through an opt-out preference signal (described further in the Privacy Policy section entitled “Opt-out Preference Signals”.
California Privacy Policy
This CA Privacy Notice specifically addresses applicable California laws and the privacy practices of Compass, Inc. d/b/a Compass and its affiliates (collectively, “Compass,” “we,” “us,” or “our”) in providing Services (as defined in the Privacy Policy) to California residents. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, retention, disclosure and other uses of your information by Compass and its Affiliates as described in this CA Privacy Notice and the Privacy Policy.
“Affiliates” include entities such as Glide Labs, Inc. (“Glide”), OriginPoint LLC (“OriginPoint”), Compass Integrated Systems Management (“CISM”), and various title and escrow companies. For more information on the terms and conditions of some of our Affiliates, please review the Glide Privacy Policy, OriginPoint Privacy Policy, and OriginPoint California Consumer Privacy Notice.
“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 only governs the handling of personal information Compass collects directly, or for which agents input into the Compass platform. This policy does not govern personal information or sensitive personal information obtained by an Agent and retained or stored 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. If an agent collects your personal information and it is not stored or retained on our platform we will be unable to process your opt-out request, and you would need to contact the agent directly to change your privacy preferences.
All other defined terms used in this CA Privacy Notice shall have the same meanings included in the Privacy Policy.
- 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 opt-out@compass.com or send us a request via our webform located in our dedicated Privacy Center.
- California Privacy Rights: Online Privacy Protection Act (“CalOPPA”)
California’s Online Privacy Protection Act (Bus. & Prof. Code § 22575) requires operators of a commercial website or online service that collect personally identifiable information as defined under CalOPPA (“PII”) about California consumers through the Internet to satisfy certain requirements. For more information about our tracking practices, please review Section 9. If you want to review and request changes to the handling of your PII, collected through the Site (as defined in the Privacy Policy) or our Services, please send an email to opt-out@compass.com or send us a request via our dedicated Privacy Center.
- California Privacy Rights: California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”)
As defined under the CCPA and further revised by the CPRA, if you are a California “Consumer,” you have certain rights with respect to the collection, use, transfer, retention, selling, sharing, 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, the retention of your information is necessary to fulfill a service or business objective, 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 in section 6: Individual Rights, Control, and Choices. 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, Compass, or a Compass agent 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, or employment with Compass (if applicable); and Inferences derived from public record information (not personal characteristics), such as what type of property you may be most interested in, thus enabling us to market to you more effectively.
The chart below, contains the categories of Personal Information that we may collect or have collected over the past twelve (12) months, the business purpose for the collection/disclosure, and the category of third party the information was disclosed to. Please note that we may not collect these categories of Personal Information for every California consumer, as Personal Information collection depends on the user’s activity or use in connection with the Services. We will not collect additional categories of personal information without providing you a new Notice at Collection disclosing those categories.
Please note that Compass does not collect any sensitive personal information for purposes other than those business purposes specifically enumerated under CCPA. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.
General Personal Information
| Category | In the preceding 12 months this category was: Collected / Disclosed |
Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed |
|---|---|---|---|
| A. Identifiers | Yes / Yes |
|
|
| B. Personal Information Categories from Cal. Civ. Code § 1798.80(e) | Yes / Yes |
|
|
| C. Characteristics of CA or Federal Protected Classifications | Yes / Yes |
|
|
| D. Commercial Information | Yes / Yes |
|
|
| E. Biometric Information | Yes / Yes |
|
|
| F. Internet or Other Similar Network Activity | Yes / Yes |
|
|
| G. Geolocation Data | Yes / Yes |
|
|
| H. Sensory or Surveillance Data | Yes / Yes |
|
|
| I. Professional or Employment-Related Information | Yes / Yes |
|
|
| J. Education Information | Yes / Yes |
|
|
| K. Profile Data | No / No | N/A | N/A |
Sensitive Personal Information
We do not use or disclose the below sensitive personal information other than those business purposes specifically enumerated under CCPA. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.
| Category | In the preceding 12 months this category was: Collected / Disclosed |
Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed |
|---|---|---|---|
| Social Security Number, Driver’s License, State Identification Card, or Passport Number | Yes / Yes |
|
|
| Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account | No / No | N/A | N/A |
| Precise geolocation | Yes / Yes |
|
|
| Racial or ethnic origin, religious or philosophical beliefs, or union membership | Yes / Yes |
|
|
| Contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication) | Yes / Yes |
|
|
| Genetic data | No / No | N/A | N/A |
| Biometric information for the purpose of unique identification | Yes / Yes |
|
|
| Health information * Please consult Employee Disclosure for more information |
No / No | N/A | N/A |
| Information concerning sex life or sexual orientation | No / No | N/A | N/A |
The categories identified as collected in the tables above were collected from the following categories of sources:
- You directly
- Our real estate agents
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Selling and Sharing of Personal Information of Minors
In the preceding twelve (12) months, we have not knowingly sold Personal Information about consumers under the age of 16.
- Individual Rights, Controls, and Choices
Summary of Your Rights
California consumers have certain legal rights related to their Personal Information, as described in greater detail below:
- The right to request information about personal information collected about you;
- The right to request disclosure of categories of personal information a business shares or discloses;
- The right to access personal information in a portable format;
- The right to opt out of the sharing of personal information to a third party;
- The right to correct your inaccurate personal information;
- The right to request deletion of personal information; and
- The right to equal service and price, regardless of whether they exercise their privacy 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.
Upon our receipt of a verifiable request, you will receive the following information about you:
a. Categories of Personal Information Compass has collected;
b. Categories of sources from which that Personal Information was collected;
c. The business or commercial purpose for which the Personal Information was collected;
d. The categories of third parties with whom Compass disclosed the Personal Information for a business purpose; and
e. The categories of Personal Information that Compass disclosed to third parties.
f. 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.
Right to Opt-Out of Third-Party Sharing (Do Not Sell/Share My Personal Information)
You have the right to request that Compass and our service providers not sell or share certain Personal information that Compass has collected from you to a third party, outside of information necessary to conduct certain business purposes (ie: payroll/HR functions). You can exercise that right at any time, by clicking the “Do Not Sell/Share My Personal Information” link available on our website in our dedicated Privacy Center.
You can also request an opt out by emailing us at: opt-out@compass.com, or submitting your request through an opt-out preference signal (described further in the section entitled “Opt-out Preference Signals”.
Right to Correct
You have the right to request that Compass correct inaccurate Personal information about you that Compass maintains. We may request documentation from you to determine the accuracy of the information we have maintained. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used or maintained by us for the purpose of correcting your personal information and complying with our recordkeeping requirements under the CCPA and/or CPRA. We may deny your request if we have previously denied your same request to correct an alleged inaccuracy in the past six (6) months, unless you provide new or additional documentation that the information at issue is inaccurate.
As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
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, or shared with service providers. 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 applicable law permits our retention of your Personal Information and it is necessary for Compass or our service providers to maintain the Personal Information for the following reasons:
- To complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
- To help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
- To debug to identify and repair errors that impair existing intended functionality;
- To exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
- To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the California Penal Code;
- To engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent;
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information; and
- To comply with a legal obligation.
Submitting A Verified Consumer Request
You can submit your verified consumer request by emailing us at opt-out@compass.com. You may also submit these requests online here through a webform located online within our dedicated Privacy Center, or call us at 888-599-8869.
The response to a request to know will provide all personal information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve disproportionate effort. Please note that we are not required to provide personal information to you more than twice in a twelve (12) month period. 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.
Once we receive your verifiable consumer request, we will confirm receipt of the request within ten (10) business days. We will respond to your request within forty-five (45) calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted. We will request an additional 45 days to respond substantively, if needed to fulfill your request.
If requests from you are unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee or refuse to act on the request, notifying you of our reason for refusing to act. If we determine that the request warrants a fee, we will notify you of the reason for that determination and provide you with a cost estimate before completing your request.
Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data.
Requests to Know or Delete for Child Under the Age of 16: We do not knowingly collect information of minors under the age of 16.
Verifying Consumer Requests
Compass provides California Consumers with the ability to submit requests through a webform located on our website, toll-free number at 855-551-8930, and our email address opt-out@compass.com. 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.
Authorized Agents
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.
Our webform includes an affidavit to submit if an Authorized Agent is submitting a consumer request on behalf of a California 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 opt-out@compass.com.
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;
- Retaliating against you, as an employee, applicant for employment, or independent contractor; 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 laws 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 and/or CPRA.
- Opt-Out Preference Signals
Compass.com employs technology that is compatible with certain opt out preference signals such as global privacy controls (on the browser or browser extensions that support such a signal). Please adjust the preferences within your personal browser, or browser extension if you wish to utilize this function.
- 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 to ensure the support, operations, and security of the Compass environment.
- Maintain appropriate retention periods for the business purpose in which the records were collected.
- Leverage Legal Counsel to determine when it is appropriate to share data beyond Compass or third party vendors we contract with, or concerning the preservation of data in response to litigation or law enforcement requests.
Please note that Personal Information does not include publicly available information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; or de-identified or aggregated consumer information.
- 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 collect this information for both IT debugging purposes, and to provide us with valuable information used when considering possible web and mobile enhancements.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, as recognized by many state Attorney General offices. You may also opt out of these practices at any time by clicking the “Do Not Sell/Share My Personal Information” link available on our website or within our dedicated Privacy Center.
- What Terms Apply to California Employees and Job Applicants?
If you are a California job applicant, specific terms in the Your California Privacy Rights notice will apply to the collection of your Personal Information.
If you are a California employee, specific terms in the Your California Privacy Rights notice will apply to the collection of your personal information.
- What Happens When There Are Changes To This CA Privacy Notice?
We may amend this CA Privacy Notice from time to time. Use of information we collect now is subject to the Privacy Policy as supplemented by this CA Privacy Notice in effect at the time such information is collected unless we obtain your consent for another purpose. If we make material changes to this CA Privacy Notice, we will publicly post an updated version of this CA Privacy Notice for your review.
- 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 opt-out@compass.com.