Privacy Policy

Effective Date: January 1, 2020

Last Updated: January 1, 2020 This Privacy Policy describes the policies and procedures of Urban Compass, Inc. d/b/a Compass and its affiliates (“Compass” “we”, “our” or “us”) on the collection, use and disclosure of your information on www.compass.com (the “Site”) and the services, features, content or Applications (as defined in Section 14 of the Terms of Service) we offer (collectively with the Site, the “Services”). When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) and other information collected in connection with your use of, or access to, the Services. This Privacy Policy also covers our treatment of any Personal Information that we collect outside the Services and are combined with such Personal Information collected in connection with your use of, or access to, the Services. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any landlords, renters, owners, buyers, and third party websites, services and applications (“Third Party Services”) that you elect to access through the Services or to 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.

What About International Users?

YOUR INFORMATION MAY BE MAINTAINED ON AND TRANSFERRED TO COMPUTERS LOCATED OUTSIDE OF YOUR STATE, PROVINCE, COUNTRY OR OTHER GOVERNMENTAL JURISDICTION WHERE THE PRIVACY LAWS MAY NOT BE AS PROTECTIVE AS THOSE IN YOUR JURISDICTION. IF YOU ARE LOCATED OUTSIDE THE UNITED STATES AND CHOOSE TO PROVIDE INFORMATION TO US, WE TRANSFER PERSONAL INFORMATION TO THE UNITED STATES AND PROCESSES IT THERE. YOUR USE OF THE SERVICES AND YOUR SUBMISSION OF SUCH INFORMATION EACH REPRESENTS YOUR CONSENT TO THAT TRANSFER

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 in connection with your use of, and access to, the Services. We collect the following types of information from our users.

Information You Provide Us: You may choose to provide us with certain information that could include, without limitation, Personal Information, such as your name, email address, geolocation data, employment information, social security number, demographic information, rental listing information, credit card or other payment information, background check information, rental application information, information contained in any lease you are negotiating or entering into, photo identification, reference letters, bank statements, income tax returns, or address of a listing you intend to rent, or other information we request from you that is required by law. You acknowledge that this information may be personal to you, and by providing this information to us, we may store such information and contact you to send you information about the Services or for any other reason set forth in this Privacy Policy.

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 your IP address, search queries, cookie information, mobile device identification and the listings and pages you request. We also record the details of your activity on the Services. This information may be used by us to develop new services or improve the Services.

Information Collected Using Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet. Our cookies do not, by themselves, contain Personal Information. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties, including our third party partners and service providers.

We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer. Ads appearing on the Services may be delivered to users by our advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Compass and does not cover the use of cookies by any third parties, including advertisers or partners.

Information Collected from Third Parties: If you choose to register on our Site or otherwise link your Compass account with a third party’s service (such as Facebook), we may receive the same type of information we collect from you (described above) directly from those services. We may receive additional information about you, such as demographic data, employment information, social media networking and imprints or fraud detection information, from third party partners and service providers and combine it with other information that we have about you.

Aggregate Information: We collect statistical information about how both users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you. This type of aggregate data enables us to figure out how often users use parts of the Services so that we can make the Services appealing to as many users as possible, and improve the Services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use our site. We share this type of statistical data so that our partners also understand how often people use their services and the Services, so that they, too, may provide you with an optimal online experience.

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:

• to present the Services and its contents to you;
• to provide you with information or services that you request from us;
• to fulfill any other purpose for which you provide it;
• to contact you regarding the Services or your account;
• 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 or any services we offer or provide though the Services;
• to allow you to participate in interactive features of the Services;
• to conduct research and development for the improvement of the Services, the development of new services and offerings and in connection with our business;
• in any other way we may describe when you provide the information; or
• for any other purpose with your consent.

How, And With Whom, Is My Information Shared?

Third Party Partners and Service Providers. We may receive additional information about you, such as demographic data, employment information, or fraud detection information, from third party partners and service provides and combine it with other information that we have about you. We work with third party partners and service providers to perform Services on our behalf, and we may share your Personal Information, such as your email address, with such partners and service providers to help us provide the Services.

Email Communications with Us and Other Users: As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to promotions we are offering through the Services. You acknowledge and agree that by 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, contact you or engage in other communications that they determine in their sole discretion relate to your profile or use of the Services. You may opt-out of receiving communications from us by following the instructions included with such emails, or emailing us at opt-out@compass.com, but then you may not have access to certain features of the Services.. Note that this opt-out only applies to messages from Compass and not third parties. In addition, we and others you interact with through the Services may wish to send you a house-warming gift or other expression of appreciation, and you acknowledge and agree that we may share your Personal Information with such persons, or use your Personal Information for such purposes.

Information Shared with Our Agents:  We contract with people and other entities, including our independent contractor licensed real estate salespersons and brokers, that may offer or provide services to you (“Agents”). We may share Personal Information with our Agents 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. You hereby consent to our sharing of Personal Information with our Agents.

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 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.

Information We Share in Connection with the Services Performed for You: The information you provide, including, without limitation, your profile information, search criteria, user name, email, address, and co-habitant information, may be used to facilitate and provide the services for you and transactions within the Services. This may include, without limitation, sharing your Personal Information with potential landlords, owners, co-brokers, our Agents and our third party partners and service providers, as applicable, to your request for Services; and if you are landlord or owner, we may also share your Personal Information (such as name, listing address, etc.) to potential tenants, buyers, co-brokers, our Agents and our third party partners and service providers, as applicable, in connection with the Services.

Information We Share with Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Tracking Disclosures: We may use tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We will comply with web browser “do not track” signals that you may set in your web browser regarding the collection of personal information about your online activities over time and across third-party web-sites or online services.

Additional Limits on Use of Your Google User Data: Notwithstanding anything else in this Privacy Policy, if you provide us access to the following types of your Google data, our use of that data will be subject to these additional restrictions:

• We will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail 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 Gmail 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.

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. These third parties may use cookies alone or in conjunction with 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 information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We use conversion tracking from third-party advertising platforms, including Google and Facebook. These advertising programs use cookies to help determine aggregate, anonymous actions people took on our website after clicking an ad. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Is Personal Information About Me Secure?

You need 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. 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. We otherwise store all of our information, including your IP address information, using industry-standard security techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you we store, Personal Information or otherwise.

What Information Can I Access?

We may allow you to access certain information about you for the purpose of viewing, and in certain situations, updating that information. This list will change as the Services change. When you update information, however, we often maintain a copy of the unrevised information in our records. You may request deletion of your account by sending an e-mail to our webmaster at opt-out@compass.com. Please note that some information may remain in our records after deletion of your account. California Privacy Rights

California Civil Code Section § 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, please send an e-mail to mydata@compass.com or write us at: Compass, 90 5th Avenue, 3rd Floor, New York, New York 10011, Attention: My Data Department.

California Privacy Rights

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California Consumers access the Compass websites, use Compass services, contact Compass, or visit one of our physical locations, we collect the following Personal Information.

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that Compass disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

1. Right to Know (Categories of Information): Upon verifiable request, you will receive the following information about you:a. Category of personal information collected,b. Categories of sources from which that information was collected,c. The business or commercial purpose(s) for which the information was collected,d. The categories of third parties to whom Compass sold or disclosed the category of personal information for a business purpose, ande. The business or commercial purpose for which Compass sold or disclosed the category of personal information.
2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:a. Specific pieces of Personal Information collected about you.

Compass does not sell any Personal Information of California consumers. 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 of Deletion

You have the right to request that Compass and our service providers delete any Personal Information about yourself that Compass has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests

You can submit your request by calling us at 1-888-622-2942. You may also submit your request online here through a webform.

Verifying Requests

Compass provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. 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 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 Agent

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Compass requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Compass. Failure to do so may result in Compass denying your request.

Right to Equal Service

Compass will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

• Denying goods or services to you.
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to you.
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

What Happens When There Are Changes To This Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected unless we obtain your consent. If we make material changes to this Privacy Policy, we will notify you by posting an announcement on the Services for a period of time. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.