Compass Interactive, LLC.

Email: dataprotectionofficer@compassbrowser.com

Updated: December 30, 2019

This Privacy Policy applies to the websites located at https://www.compassbrowser.com/, http://browserfacts.com, and http://browserfacts.org (“Compass Interactive Sites”), and the Compass browser application (“Compass Browser Application”), each of which are owned and operated by Compass Interactive, LLC (“Compass Interactive”, “we”, “us”, or “our”). This Privacy Policy describes what information is collected by us from any end user (collectively or individually "user(s),” “yourself,” or “you”) of the Compass Interactive Sites  and Compass Browser Application, as well as our use and disclosure of that information. We treat your privacy seriously.

Please read this Privacy Policy carefully, as it governs your use of the Compass Interactive Sites and Compass Browser Application. Your use of our Compass Interactive Sites and/or download of the Compass Browser Application indicates to us that you have read and accepted our privacy practices, as outlined in this Privacy Policy. 

We use your data, as described throughout this Privacy Policy, to provide and improve the Compass Interactive Sites and Compass Browser Application. By using the Compass Interactive Sites and/or Compass Browser Application, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from the Compass Interactive Sites.

 

MINORS UNDER THE AGE OF 18 MUST NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING, BUT NOT LIMITED TO, THEIR EMAIL ADDRESS, TO COMPASS INTERACTIVE. IF COMPASS INTERACTIVE IS NOTIFIED IT HAS PERSONAL INFORMATION REGARDING A MINOR UNDER THE AGE OF 18, THAT INFORMATION WILL BE PROMPTLY DELETED FROM OUR DATABASE. 

Definitions

Extensions
Extensions means any third-party, add-on software application, that provides additional services other than the services offered by the Compass Browser Application, which can be uninstalled by you at any time in your Compass Browser Application settings. The Compass Browser Application has the following Extensions pre-installed in the Compass Browser Application:

• AdZero AdBlocker – Helps block pop-ups, banners, and video ads, that are otherwise displayed on the webpage of the websites you visit. AdZero’s privacy policy can be found here: https://www.adzero.org/privacy.

  • Smarty –Extension that helps you find coupon codes and offers cash back offers, while you shop online. Smarty’s privacy policy can be found here: https://www.joinsmarty.com/privacy-policy.
  • TouchVPN – The TouchVPN Extension is pre-installed in the Compass Browser Application, but to receive the TouchVPN services you must complete an extra step and connect to the VPN server. To receive the TouchVPN service, you can click the TouchVPN browser extension, and then select the country you would like to connect to, or just click “connect” and a VPN server will automatically be selected for you. TouchVPN provides an additional layer of privacy by directing all of your website traffic through an IP address provided by the Touch VPN service. The Touch VPN privacy policy can be found here: https://touchvpn.net/privacy.
  • Windows Defender Browser Protection – Helps protect against online threats, like phishing and malicious websites, with real-time protection from Microsoft. Microsoft’s privacy policy can be found here: https://privacy.microsoft.com/en-US/privacystatement.

 

Personal Information

Personal Information means data about a living individual who can be identified from the data (or from information either in our possession or likely to come into our possession).

Usage Data

Usage Data may include information such as, how often the Compass Browser Application was installed, the time period between when it was installed and uninstalled, the type of operating system the Compass Browser Application was installed on, and other similar types of information related to installation metrics and providing the of the Compass Browser Application itself.

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Information.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. The Service Providers we use are listed in the “Service Providers” section of this Privacy Policy.

Data Subject (or User)

Data Subject is any living individual who is using our Compass Browser Application and is the subject of Personal Information.

Information Collection and Use

You do not need to provide Compass with any Personal Information in order to download the Compass Browser Application. The Compass Browser Application does not collect any Personal Information, except as expressly stated in this Privacy Policy, which is necessary to provide the services. For example, the Compass Browser Application may share your IP Address with our server logs, which we store on our servers.

The Extensions that are pre-loaded on the Compass Browser Application may collect Personal Information, and Compass Interactive recommends that you review the links provided above for each Extension regarding the data practices of those companies, as well as any privacy policy of any Extensions you install. Compass Interactive is not responsible for the data practices of any Extension, whether the Extension was pre-loaded when you installed the Compass Browser Extension, or installed by you after you installed the Compass Browser Application.

Types of Data Collected

Personal Information

While using our Compass Browser Application, we may collect certain information, which is collected automatically by our server logs and is necessary to provide you with the services provided by the Compass Browser Application. Information we may collect includes:

  • IP Address

* and other similar information necessary for the Compass Browser Application to operate.

Browser, Network, and Device Information

The Compass Browser Application stores some information locally on your system, such as standard information from websites you last visited, such as the URL’s of websites you visited, an index of websites you previously visited, and cookies deposited by those websites. The foregoing activity will not apply if you are browsing in Incognito Mode. In that case, any cookies stored on your system that are dropped while in Incognito Mode will be deleted at the end of your Incognito Mode session. While in Incognito Mode, the websites you visit are not stored in the Compass Browser Application.

We may also collect information when you use our Compass Browser Application relating to your type of operating system, network, device, and other similar information. This information is collected to ensure you have a consistent experience when using our Compass Browser Application, to ensure our content is displayed properly, and to improve the overall quality of our Compass Browser Application.  Information collected related to your browser, network, and device information, includes:

  • • Device ID
    • Operating System
    • Browser Type
    • Network Type
    • Cookies
    • Usage Data
    * and other similar information

Usage Data

Third party websites and third-party Extensions may collect Personal Information, such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Compass Browser Application that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

Compass Interactive does not use any cookies to track your website behavior. Compass Interactive only uses Cookies that are necessary to operate the Compass Browser Application, such as Preference Cookies (see below). On the other hand, third party Extensions may use cookies and similar tracking technologies to serve tailored advertisements based upon your interests, which is based upon your browser history and the types of websites you have visited.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

You can instruct your browser to refuse all cookies. However, if you do not accept cookies, you may not be able to use some portions of our Compass Browser Application.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Compass Browser Application.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

Use of Data

Compass Interactive may use the collected data for various purposes:

  • To provide and maintain our Compass Browser Application
  • To notify you about changes to our Compass Browser Application
  • To allow you to participate in interactive features of our Compass Browser Application when you choose to do so
  • To gather analysis or valuable information so that we can improve our Compass Browser Application
  • To monitor the usage of our Compass Browser Application
  • To detect and prevent fraud
  • To detect, prevent and address technical issues

Third Party Websites and Extensions

Websites you visit with the Compass Browser Application will receive certain public facing information containing personally identifiable information, which includes the type of device you are using to browse the website, operating system type, IP address, referring website, language preferences, and any information you voluntarily provide to the third-party website, such as when you submit a form on the third-party website with any of your information.

Third-party Extensions may receive Personal Information if the Extension is installed in the Compass Browser Application while you use the Compass Browser Application. Compass Interactive has no control over third party websites or third-party Extensions, and each website you visit is governed by its own privacy policy and data practices. The third-party websites and Extensions may set their own cookies or othwerwise implement their own data collection practices. Please read and review each third-party website’s privacy policy to understand how those third-party websites use your data.

Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Compass Interactive’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

Compass Interactive may process your Personal Information because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it's not overridden by your rights
  • To comply with the law

Retention of Data

Compass Interactive will retain your data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Compass Interactive will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Compass Browser Application, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Compass Interactive will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

Disclosure of Data

Generally

We do not share your Personal Information when we provide our Compass Browser Application. Third-party websites and Extensions may collect Personal Information as disclosed in their privacy policies located on their websites, and you may uninstall Extensions at any time in the Compass Browser Settings.  The Extensions may collect information, such as websites you have previous visited to serve tailored advertisements based on your interests, and other related information with third party advertisers to allow third party advertisers to deliver advertising, marketing, or other content through Extensions within the Compass Browser Application for commercial purposes.

Business Transaction

If Compass Interactive is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Compass Interactive may be required to disclose your Personal Information if required to do so by law, or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Compass Interactive may disclose your Personal Information in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Compass Interactive
  • To prevent or investigate possible wrongdoing in connection with the Compass Browser Application (e.g. to prevent or investigate fraud)
  • To protect the personal safety of users of the Compass Browser Application or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Compass Interactive aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us at dataprotectionofficer@compassbrowser.com.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at dataprotectionofficer@compassbrowser.com.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Information.

The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Compass Interactive relied on your consent to process your Personal Information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

California Residents – California Consumer Privacy Act (“CCPA”)

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to request certain information regarding our collection of personal information from California consumers. If you are a California consumer, you have a right to request the following:

(1) The categories of personal information we may have collected about you;

(2) The categories of sources from which the personal information may have been collected;

(3) The business or commercial purpose for collecting or selling personal information;

(4) The categories of third parties with whom we share personal information; and/or

(5) The specific pieces of personal information we may have collected about you.

The categories of information you may provide us are listed in the “Types of Data Collected” section of this Privacy Policy.

We may share Personal Information with service providers solely for a business purpose pursuant to a written contract between Compass Interactive and the service provider. Compass Interactive service providers use the Personal Information as necessary to perform the business purpose stated in a written contract with the service provider. 

Compass Interactive does not “sell” your Personal Information as that term is defined under CCPA, however if you would like to receive further confirmation that any Personal Information we may have about you is not “sold” to third parties, you may contact our Data Protection Officer with your “do not sell my Personal Information” request as follows:

Email: dataprotectionofficer@compassbrowser.com

You may also request that Compass Interactive delete your Personal Information by contacting us at the email or phone number provided above. Please understand that Compass Interactive is required by CCPA to first verify any request received prior to complying with any CCPA request. 

In some instances, Compass Interactive is not required by CCPA to delete Personal Information. In such instance, Compass Interactive will notify you if your Personal Information was unable to be deleted for one of the permitted exceptions under CCPA.

Service Providers

We may employ third party companies and individuals who are compliant with CCPA and GDPR to facilitate our Compass Browser Application ("Service Providers"), to provide the Compass Browser Application on our behalf, to perform Compass Browser Application-related services or to assist us in analyzing how our Compass Browser Application is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We use the following data center to store information on our server logs disclosed in this Privacy Policy:

Servers

The below third-party Service Provider is used to store data necessary to provide the services provided by the Compass Browser Application.

CoreSite

CoreSite’s privacy policy can be found here: https://www.coresite.com/privacy.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Compass Browser Application.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Compass Browser Application. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Compass Browser Application available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Links to Other Sites

Our Compass Browser Application may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Compass Browser Application does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Compass Browser Application, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us


Compass Interactive, LLC.
15445 Ventura Blvd., #318
Sherman Oaks, CA 91403
USA

If you have any questions about this Privacy Policy or have any requests regarding Personal Information we may have collected about you, please contact us at the following email address:

Email: dataprotectionofficer@compassbrowser.com

We will respond to reasonable requests for access, revision, or deletion requests to the extent required or permitted by law. Please note, if your request for access or revisions is too burdensome, creates an excessive expense upon Compass Interactive, or violates the rights of other individuals, Compass Interactive will weigh the risks to your individual privacy and act accordingly.