This Privacy Policy is effective as of February 1, 2019.

 

At Compass Components, Inc. (“us,” “we,” “our,” or “Compass”), we recognize that your privacy is very important, and we take it seriously. Please read this privacy policy (“Privacy Policy” the “Policy”) carefully to get a clear understanding of how we collect, use, protect, and otherwise handle your personal information or data. Please check back regularly to keep track of any updates.

 

We care about your privacy and want to be transparent about our privacy practices. We only collect personal information necessary to deliver our services and handle it carefully and sensibly.

 

This Privacy Policy explains our privacy practices for madecompass.com (the “Website” or “Site”). This Policy describes what personal information we collect of our customers and website visitors. The Policy also defines why and how we collect, use, and store such personal information or whether any information is shared with the third-party sources. The Policy also explains the choices you can make about the way that we use your information and how to contact us with any concerns or requests in relation to that.

 

Compass Components, Inc. is a corporation registered and existing under the laws of California, USA, with registered address: 48133 Warm Springs Boulevard, Fremont, CA USA 94539-7498, and is the data controller of the personal information we collect from you. If you have any questions, comments or concerns about any aspect of our Privacy Policy, please contact us using the details set out in the “How to Contact Us” section at the end of this Privacy Policy.

 

Below you will find information about the following:

 

1. Information We Collect and Its Use
2. Cookies, Beacons, IP Addresses
3. Purpose of Data Processing

 

4. Security Measures
5. Retention Periods and Unsubscribe or Opt-Out
6. California Residents Privacy Rights
7. Children’s Online Privacy Act and Age Restrictions
8. Do Not Track Signals
9. Fair Information Practices
10. CAN-SPAM Act
11. Transferring Your Data
12. International Transfers
13. EU General Data Protection Regulation (“GDPR”)
14. Changes to the Privacy Policy
15. Acceptance of Terms
16. How to Contact Us

 

1. INFORMATION WE COLLECT AN ITS USE:

 

In the course of engaging with our Site, you may provide personal information about you and your contacts. Personal information is often, but not exclusively, provided to us when you fill out a form on our website, register with us, make a purchase from us, sign up for our newsletter, respond to a survey or marketing communication. You may be asked to provide personal contact information such as your name, company name, address, email address, phone number, or any other information necessary for us to help enhance your experience on our website or the use of our products or services.

 

The information you provide may be used to answer your questions, improve our website, customize the content and communications about our products and services, including special offers, announcements, and new features. By giving us this information, you agree to this information being collected, used, and disclosed as described in this Privacy Policy.

 

When you access and browse the Site (including when you submit personal information to us through data entry fields on the website) we will collect the following from you:

 

Information you provide us directly:

 

Contact Information – We receive and store any information you enter on our Site. Our Site uses forms to collect your personal information including your name, address, telephone number, email address so you can place orders, request information, get support and use our services.

 

Payments and Billing Information – When signing up for any of our Services, products, or programs, we request additional personal and payment information such as your name, credit card information, PayPal or relevant service, billing address, personal, government or TAX identification number or other information including but not limited to certificates, tax declarations, forms, payment documents and other relevant documents.

 

Surveys and Contests – We may, from time to time, offer surveys and opinion polls and ask you to provide information about your experience and feedback for our services. Occasionally we may organize you to contests, sweepstakes, competitions, prize draws, or other promotions (collectively “Contests”) on our Site or through our Social Media channels and may offer a prize as a sign of appreciation to the people who have participated, qualified and/or completed our Contest. Information requested for entry may include personal contact information such as your name, email, address, phone number, etc. Participation is entirely voluntary and it’s up to you whether you choose to disclose any information or not.

 

Other Information – We also receive and store any information that you provide on our Site, our Chat service, any complaint forms on our site, email, telephone, or any other type of communication with our team or related to the provisioning of our services. Whenever you contact us, we will record the ticket, chat or call to ensure we have an accurate record of all communication, which is needed to provide our services and to support any action taken by our team as a result in the event of a dispute over our response.

 

Information we receive automatically and why we use it:

 

Automated Information – When you visit our website we receive and collect information, which may – in certain circumstances constitute personal information – and which includes your IP address, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.  We may use such information to diagnose problems with our servers, to administer our Site and services. This is not linked to any personally identifiable information, except if necessary, to prevent fraud or abuse on our Site and systems.

 

Information Logs – When you visit the Site, view content provided by us, use our services, use our Chat service, ask us a question, request technical assistance in regards to our services, send us an email or participate in a contest or survey on our website, we automatically collect and store certain information in log files. This includes your IP address, URL, referral URL, exit URL, browser software, operating system, date/time, requests type to our Site and error responses returned by our Site or Services. We may use such information for diagnosing problems, administering our Site and resolving issues.

 

Cookies/Beacons/IP Addresses Information – Please see our Cookies, Beacons, IP Addresses section below.

 

Information we may receive from third parties and why we use it:

 

Website Analytics Tools – We use analytics services by third parties to collect information about the use of this Site, such as number of visits, pages visited, popularity of certain content. Analytics tools use tracking technologies (like cookies) to recognize your device and compile information about you. They collect information such as what pages you visit and how much time you spend on these pages, the IP address assigned to you, what operating system and web browser you use, and what site you visited prior to visiting our website.

 

Third-Party Behavioral Tracking – Our site allows third-party behavioral tracking. Some third parties issue cookies through our Website to serve ads that are relevant to your interests based on your browsing activities. These third parties may also collect your browser history or other information to determine how you reached our Website and the Website you visit when you leave our Website. Information gathered through these automated means may be associated with the personal information you previously submitted to our Website.

 

Surveys – Any answers to surveys and opinion polls are stored separately from your details and we either anonymize or pseudonymize the data collected, which can be used for ascertaining the usage of certain aspects of our Site and services and market research. We may share the anonymized or pseudonymized data with third parties when they need the information to fulfill their obligations to process it on our behalf. However, neither the anonymized data nor the pseudonymized data allows to identify you personally without the use of additional information which is kept separately, and is subject to technical and organizational measures to ensure that none of the data is attributed directly to you.

 

Contests – If you enter a Contest, we use the data you provide for the successful administration of the Contest, to contact you or work with third parties to contact you in case you’ve won anything and fulfill prizes in accordance to the announcement and terms of the participation for the respective Contest. We may also, where you have opted in to receive such communication, and unless prohibited by law, use your information provided via our surveys and Contests to send you details about our services or offers.

 

We may use such information as follows:

 

• To tailor the content and information that we may send to you.
• For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about our products or information we may think interest
• To gather metrics to better understand how users access and use our website.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• To prevent misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, inappropriate or offensive activities or violations of this Privacy Policy.

 

Third-party sources and why we may share your information with them:

 

Ensuring your privacy is important to us. All personal information collected by Compass Components, Inc. is treated as confidential. We only disclose entire or part of your data in the limited circumstances described below and with appropriate safeguards on your privacy as follows:

 

By Law or to Protect Rights and Property – We will disclose information about you in response to a subpoena, court order, or other legitimate governmental request. We may share account and personal information with companies, organizations or individuals when we believe in good-faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our Terms of Service and other agreements; to investigate potential violations; to protect against harm to the rights, property or safety of Compass Components, Inc., our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

 

Compass Components, Inc. Group Companies, Subsidiaries, Employees, and Independent Contractors –  We may disclose information about you to our Compass Components, Inc. group companies, subsidiaries, business partners, external consultants, auditors, collaborators or other third parties, some of our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf and also for administrative purposes, billing and tax and all other purposes related to the management of your account. We require all of them to comply strictly with this Privacy Policy.

 

Third Party Vendors – We will share information with third party vendors based within the United States, Canada and European Union, Data Center services providers based within the United States, European Union and Singapore, external advisors/consultants, business partners, tax, accounting and legal companies, collaborators based within United States and the European Union, who need to know information about you in order to provide various services on our behalf. This group includes vendors that help us provide our services such as payment providers that process your credit card information or information about alternative payment methods and invoicing, and accounting companies as well as vendors that help us prevent fraud. This group also includes trusted vendors we partner with that perform analysis of our products or customer demographics and do market research that help us understand and enhance our services and help us serve better advertisements. This group also includes third party providers that perform analytic services and analyze the data of our surveys and/or contests. We will only share information about you that is necessary for the third-party vendor to provide the requested service. These companies will process the provided data under instructions of Compass Components, Inc. and in compliance with this Privacy Policy. We do not authorize vendors to retain, share, store or use your personally identifiable information for any secondary purposes. The third-party vendors include companies that operate in different industries such as Fraud Detection, Technology Service, Internet Information Providers, Payments and Data Processors, Specialty Finance, Media, Internet Content & Information Industries, Advertising & Marketing and Technologies that are located in the territory of the European Union and United States.

 

To Serve Ads that are Relevant to Your Interests – Our Site includes marketing cookies and remarketing pixel provided by third parties. That These cookies allow third these parties to collect the information that you have visited our Site and were interested in certain offers in order to serve ads that are relevant to your interests based on your browsing activities. These third parties may also collect your browser history or other information to determine how you reached our Website and the website you visit when you leave our Website. Information gathered through these automated means may be associated with the personal information you previously submitted on our website.

 

Domain Registrars – The domain’s owner information (WHOIS Data) for any domain name is required and controlled by the Registry for the top-level domain which you wish or have registered a domain name in. We share your information to the extent necessary to comply with ICANN’s rules, regulations and policies and with rules and policies by the ICANN-accredited registrar providers we represent. The use and disclosure of the personal information as part of the domain registration process is governed by the Domain Name Agreement in our Terms of Service.

 

Business Transfers – In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Compass Components, Inc. goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events happens, we will take any reasonable steps to notify you and this Privacy Policy would continue to apply to your information and the party receiving your information shall continue to use your information, but only consistent with this Privacy Policy.

 

With Your Consent – With your explicit consent or at your direction we may share and disclose information you have authorized us to with third parties. We will not, however, sell, rent, share or otherwise disclose personally identifiable information for commercial purposes in any way that is contrary to the commitments made in this Privacy Policy. We will take all reasonable steps to notify you when and what information might go to third parties and you will be able to choose whether to share it or not.

 

Third-Party Disclosure and Links – Except in the case of a sale of our company, in which we would transfer your personal information and personal data to the buyer in order for to continue to provide services to you, we do not sell your personal information or personal data to third parties to use for their own marketing purposes. We do not otherwise transfer to outside parties your personal information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

 

We do not include or offer third-party products or services on our website.

 

 

2. COOKIES, BEACONS, TAGS, AND PIXELS:

 

As you interact with our website, we may automatically collect information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, web beacons, Internet Protocol (IP) addresses, and other similar technologies.

 

Cookies – We use Cookies to collect some of the information set out in this Privacy Policy. A cookie is a small piece of data sent from a website and stored in your web browser on your computer, mobile or other handheld device, while you are browsing a website and is used to store or track information about your use of the site.

 

• Our site uses cookies for several reasons. Some cookies are strictly

necessary to enable core site functionality. We refer to these as “required” cookies. For example, we may use required cookies to authenticate your access to various areas of our Website. Other cookies allow us to identify you to enhance your browsing experience, tailor content to your preferences, and make your interactions with our Website more meaningful. We refer to these as “functional” cookies. For example, we may use functional cookies to determine whether you have visited our Website before and inform us about site features in which you have interest, thereby permitting us to better tailor our Website content. Functional cookies also allow us to analyze Website traffic, so we can measure and improve performance and speed up your searches. Cookies can also be used for technical purposes such as keeping track of your current shopping session and enabling you to proceed to checkout and pay for your according order or to save information which has already been entered (languages choices, and your region), so that we can offer improved and more personalized services, products and other relevant communication tailored to you. Cookies also allow us to fulfill our contractual obligations to third parties and partners if you have made a purchase on our website by following a link from theirs.

 

• You can control or reset your cookies through your web browser, which

will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site may not function properly if the ability to accept cookies is disabled.

 

Beacons – We also use web beacons (also known as internet tags, pixel tags, and clear GIFs). Web beacons are clear electronic images that can recognize certain types of information on your computer, such as the type of browser used to view a website page, when you viewed a particular site linked to the web beacon, and a description of a site tied to the web beacon. Certain pages on our Website may contain such Web beacons, which the we use to, gather information about user base as a whole and how we can improve our service and Site, provide advertising based upon activities and interests, and measure advertising effectiveness. As a result, we may display targeted, or interest-based, offers to you based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Site, on other websites part of the third party’s network.

 

IP Addresses – An IP address is a unique identifier that certain electronic devices used to identify and communicate with each other on the Internet. When you visit our Website, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and the geographic regions of our visitors.

 

3. PURPOSES OF DATA PROCESSING:

 

When you access or use our Services, we need to collect, use, and otherwise process your information, as set out in this Privacy Policy. We are committed to your privacy and follow a few fundamental principles when we process your personal data:

 

• We strive to collect only the minimum personal data that we need to deliver any Services to you.
• We aim for full transparency on how we use your information to comply with legal or other lawful purposes and respect your privacy.
• We make sure we only use your information for the purposes you have given us permission for.

 

We rely on a number of legal bases to use your information, as set out in this Privacy Policy:

 

Contract – The use of your information is necessary to perform any contractual obligations in order to provide any Services to you or to administer any Contests you enter into.

 

Legal Obligations – Our use of your personal information is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. For example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or to use your personal information for tax calculations.

 

Our Legitimate Interests – Our use of your personal information is necessary for our legitimate interests, such as to:

 

• Run, grow, develop and deliver our services;
• Detect and prevent fraudulent activities;
• Enhance the security of our network and information systems;
• Better understand how people interact with our website;
• Determine the effectiveness of our promotional campaigns and advertising; And enhance, modify, personalize or otherwise improve our services and communications for the benefit of our customers.

 

Consent – We rely on your consent for us to use your personal information to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may withdraw your consent at any time by updating your personal Info/Settings in your user profile in our User Area, using our Unsubscribe option in relation to email subscriptions, or contacting us using the details set out in the “How to Contact Us” section of this Policy.

 

4. SECURITY MEASURES:

 

We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our Site in order to protect its security during transmission to and from our Site. When storing information, we protect its security by encryption and pseudonymization of critical data. When we process credit card information and payments, the credit card is subject to tokenization and strong security measures.

 

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures require us in some cases to request proof of identity before disclosing personal information to you.

 

To protect against unauthorized access to your account and information, we implement session management, login expiration mechanisms and the option of using 2-factor authentication for User Area access. As an additional safety measure, be sure to sign off when you finish using your account and your computer.

 

Although we take all these measures to maintain the safety and security of your personal information, please note that no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.

 

 

 

5. RETENTION PERIODS AND UNSUBSCRIBE OR OPT-OUT:

 

Retention Periods:

 

Information collected on our website will only be retained for as long as necessary to fulfill the purpose for which it was collected. In general, we will automatically delete your User Area account information 2 years after you no longer have any active services with us. Since we offer a service for customers worldwide and we need to comply with regulations across the globe in regard to retention of personal information related to contractual agreements, provision of services, financial, billing, invoicing operations and tax calculations, a versioned copy of your contact, payment and billing personal data associated with your past invoices is stored for a period of 7 years and 10 years for payroll records after deactivating an account. Your personal data is deleted automatically by our systems in accordance with these retention periods.

 

Unsubscribe or Opt-Out:

 

All users and/or visitors to this Website have the option to discontinue receiving communications from us and/or reserve the right to discontinue receiving such communications by way of email or newsletters. To discontinue or unsubscribe to this Website, please send an email that you wish to unsubscribe to teresamartinez@madecompass.com. If you wish to unsubscribe or opt-out from any third party website, you must go to that specific website to unsubscribe and/or opt-out.

 

6. CALIFORNIA RESIDENTS PRIVACY RIGHTS:

 

Under California law (California Online Privacy Protection Act (CalOPPA)), you have the right to review and change, edit or update your personal information. Contact us at teresamartinez@madecompass.com to find out what information we have collected about you and to request any changes.

 

7. CHILDREN’S ONLINE PRIVACY ACT AND AGE RESTRICTIONS (COPA):

 

Our communications, business process, products, and services are not directed to and we do not specifically market to individuals under the age of eighteen (18). Compass Components, Inc. does not knowingly collect personal identifiable information from children under the age of thirteen (13) without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission before using this Website.

 

8. DO NOT TRACK SIGNALS:

 

While we attempt to honor do not track (“DNT”) instructions we receive from your browser, we cannot guarantee that we will respond to such signals, in part because of the lack of common industry standard for DNT technology. We continue to monitor developments in DNT technology and stay apprised of DNT industry standards as they evolve.

 

9. FAIR INFORMATION PRACTICES:

 

We take reasonable measure to prevent personal data breaches. Should a data breach occur we will notify users via email within 7 business days or sooner when practical or as required by law.  In all cases, we will work together with affected parties to minimize effects, to make all notifications and disclosures that are warranted or otherwise required by applicable law, and to take action to prevent future breaches. We strive to systematically outline responsibilities in cases of Personal Data breaches in our contracts, both with customers as well as with our vendors.

10. CAN-SPAM ACT:

If at any time you would like to unsubscribe from receiving future emails you can do so by using the “unsubscribe” link at the bottom of each email or by emailing us with your opt-out/unsubscribe request. Once we receive your request, we will promptly remove you from ALL correspondence.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

11. TRANSFERRING YOUR DATA:

We are headquarted in the United States. As such, we transfer, process and store your personal information in the United States but our service providers may process and store it elsewhere where the data protection levels may not be equivalent to the levels of data protection as in your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

 

 

12. INTERNATIONAL TRANSFERS:

 

We host, store or otherwise handle your personal information within the borders of the USA and European Economic Area (EEA).

 

We will make sure that any transfers of your personal information from one country to another comply with the data protection and privacy laws that apply. (For example, see EU General Data Protection Regulation (“GDPR”) section below.)

 

European data protection laws, in particular, include specific rules on transferring personal information outside the EEA.

 

In any event, your information will be processed in accordance with this Privacy Policy.  If you would like further information about the global handling of your personal information, please contact us using the details set out in the “How to Contact Us” section below.

 

13. EU GENERAL DATA PROTECTION REGULATION (“GDPR”):

 

Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). If you are a user in the EU you have the right to:

 

• Request access to information that we have about you;
• Receive information related to our use and processing of your information;
• Correct or delete any information that we have about you;
• Withdraw your consent to our use of your information at any time;
• Request that we restrict our use and processing of your information;
• Object to our processing of your personal data including for marketing purposes based on profiling and/or automated decision making;
• File a complaint related to our handling of your personal information with a supervisory authority.

 

14. CHANGES TO THE PRIVACY POLICY:

 

Compass Components, Inc. reserves the right to update and/or change the terms of this Privacy Policy Agreement, and as such, we will post those changes to this Website’s homepage at madecompass.com, so that our users and/or visitors are always aware of the type of information we collect, how it will be used, and under what circumstances, if any, we may disclose such information. If, at any point in time, Compass Components, Inc. decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be provided reasonable notice  to their email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.

 

15. ACCEPTANCE OF TERMS:

 

Through the use of this Website or any portion thereof, you hereby accept the terms and conditions set forth in this Privacy Policy Agreement. If you are not in agreement with any such terms and conditions, then you should immediately refrain from further use of this Website. In addition, your continued use of this Website following the posting of any updates or changes to our terms and conditions shall mean that you are in full agreement and acceptance of any such changes.

 

16. HOW TO CONTACT US:

 

Please feel free to contact us at the following email, telephone number or mailing address should you have any questions or concerns regarding this Privacy Policy Agreement.

 

Email: teresamartinez@madecompass.com

 

Telephone Number: (800) 622-2261

 

Mailing Address:

Compass Components, Inc.

48133 Warm Springs Boulevard

Fremont, CA 94539-7498 USA