At Compass, our core mission is to help teams protect data on the internet. As a result, our goal is to set a high standard for protecting the privacy of your information. We want to be clear about how we collect, use, protect, and share your information, including your personal information, and the rights and choices you have about the ways in which you can help us protect your privacy.
This Privacy Statement explains:
Scope: This Privacy Statement applies to the information that we obtain through your use of Compass products and services, including our website (https://compasshp.org).
This Privacy Statement does not apply to personal information arising from Compass employment-related activities. Except to the extent that a third party provides services on our behalf (such as a SaaS vendor), this Privacy Statement also does not apply to the practices of third parties to which we may link or otherwise refer you, such as consultants, pen testing firms, audit firms, and other vendors.
Geography: Compass is a U.S.-based company that offers our Services to domestic and international business customers. As a result, information that we collect, including personal information, may be transferred to our U.S. offices to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may provide information to third-party service providers in the U.S. and in other countries to the extent necessary to support Compass’s business activities, and we may access personal information collected by our customers to support the Services that we provide to our customers. Thus, personal information may be transferred to and stored on servers located in the United States and in countries different from the country in which that information was initially collected. Similarly, information we collect may be accessed by Compass and our third-party service providers and business partners from countries other than the ones in which the information is stored.
If you have any questions or concerns about this Privacy Statement or about our privacy or data security practices, please contact us at firstname.lastname@example.org.
For purposes of this Privacy Statement, "Personal Information" means information from or about you that identifies you directly and information that is associated with you and thus could potentially identify you, including when combined with other information from or about you.
"Sensitive Personal Information" includes data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union memberships, genetic and biometric data when used for identification purposes, and data about health, sex life, and sexual orientation.
Other submissions: We collect other data that you may submit to our Services or to us directly, such as when you request customer support or communicate with us via email.
Web Logs and Analytics Information: We record certain information and store it in log files when you interact with our Services. This information may include Internet protocol (IP) or other device addresses or ID numbers as well as browser type, Internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information that you search for, your locale and language preferences, your mobile carrier, and system configuration information. We and our analytics providers, also collect and store analytics information when you use our Services to help us improve our Services.
Information from third parties: We may obtain information, including personal information, from our business partners and service providers. This information includes, but is not limited to, information that we receive from our direct marketing providers, product referrals, and other interactions. We also may combine information we receive from third parties with other information we collect from you through our Services as described in this Privacy Statement. If we use this information to provide you with opportunities that we think may be of interest to you, you will have the ability to inform us that you do not wish to receive such offers, and you may unsubscribe from our marketing and other email communications by clicking on the link in the email, sending an e-mail to email@example.com, or accessing your user account and changing your distribution preferences.
Information provided by other individuals: While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of personal information as described in this Privacy Statement. Please contact us immediately at firstname.lastname@example.org if you become aware of an individual providing us with personal information about another individual without being authorized to do so, and we will act consistently with this Privacy Statement.
Our customers and their designated users use our Services, in particular the Compass Web Application, to create, manage, and maintain their health-related activities, which may include sensitive data, personal information and sensitive personal information. While using our Services, our customers may create, input, submit, post, upload, transmit, or store personal information that they have collected from individuals. During the course of our business relationship, we may need to access a customer’s account and the information it contains to provide support for our Services.
Our users and prospective users are responsible for complying with all applicable federal, state, local, and international laws and regulations regarding notice, disclosure, consent, and transfer of personal information, prior to providing that personal information to Compass.
In addition, our customers and prospective customers are also responsible for identifying, in a Services agreement or in a related document (such as a HIPAA business associate agreement), any additional requirements for protecting, accessing, and handling personal information in a particular matter that exceeds the reasonable, risk-based administrative, technical, and physical safeguards that Compass would otherwise routinely implement, or that are inconsistent with the collection and use practices identified in this Privacy Statement.
Unlike the other collections of information described in this section, our agreements with customers include specific protections and limitations regarding our access to and use of personal information collected by customers, and we do not access, use, copy, retain, or aggregate that customer data except as stated in those agreements.
We will not use your personal information for anything other than the following lawful purposes:
When possible, we will use anonymized data for these purposes, but if we do not, or if we combine it with Personal Information we will treat it in accordance with this Privacy Statement.
Except to the extent necessary to fulfill our business obligations, to accomplish one of the lawful purposes described in this Privacy Statement, or pursuant to your express instructions, we do not sell, transfer, or otherwise disclose personal information that we collect from or about you.
We may share your information in the following ways:
With your express consent: We will share your personal information with companies, organizations, or individuals outside of Compass when we have your consent to do so.
When you choose to directly share your information while using our Services: When you use our Services, certain features allow you to make some of your content accessible to the public or other users of the Services. We urge you to consider the sensitivity of any information prior to sharing it publicly or with other users.
When your account is accessed by your organization’s designated Compass administrator: Your Compass account owners and administrators may be able to:
With our vendors and business partners, to accomplish our business purposes: We may share your information with our service providers and other third parties who perform services on our behalf. We also work with third-party service providers to provide the cloud-based tools that our customers use to create their secure storage containers and securely store their sensitive information, including personal information.[PM14]
When necessary to comply with laws and law enforcement requests, or otherwise to protect our rights or those of individuals, we may disclose your information (including your personal information) to a third party if:
As the result of a business transition: We may share or transfer your information (including your personal information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will take reasonable steps to assure that any other entity involved continues to comply with the terms of this Privacy Statement. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
Sharing aggregate, anonymized, deidentified, or otherwise non-personal data: We may share aggregate, anonymized deidentified, or otherwise non-personal information that does not directly or indirectly identify you and that cannot, with reasonable effort, be used to reidentify you in order to improve the overall experience of our Services. Such aggregated, anonymized, deidentified, or otherwise not re-identifiable information is not personal information within the scope of this Privacy Statement.
To exercise any of these options, or for additional information about our privacy and data security practices, contact us at email@example.com.
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. That said, we certainly try very hard, employing a variety of organizational, technical and administrative measures to provide a level of security appropriate to the risk associated with the personal information you trust us with.
To that end, we manage our data protection program consistent with HITRUST, and applicable legal and regulatory requirements such as HIPAA.
Compass protects personal information under its control, and requires its service providers to also protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, personal data transmitted, stored, or otherwise processed.
If you have concerns about the security of your information with Compass, please contact us immediately at firstname.lastname@example.org to report an issue.
We retain your personal information only as long as necessary to accomplish the business purpose for which it was collected or to comply with our legal and contractual obligations, plus 1 year, and then securely dispose of that information.
Our Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at email@example.com.
California Civil Code Section 1798.83 permits Compass customers who 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 contact us at firstname.lastname@example.org.
We may change this Privacy Statement from time to time. If we make any changes, we will notify you by revising the version and date at the top of this Privacy Statement and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to the log-in screen or sending you an email notification).
Your continued use of our Services after the revised Statement has become effective indicates that you have read, understood, and agreed to the current version of this Statement.
Please contact us with any questions or comments about this Statement, your personal information, our use and disclosure practices, or your consent choices by email at email@example.com.