1. Introduction and Scope

This Privacy Policy explains how Compass International Holdings (“Company”, “we”, “us”, or “our”) collects, uses, discloses, processes, and retains personal information. This Policy applies to the compassinternationalholdings.com corporate website and any associated digital corporate communications (collectively, the “Site”).

As the strategic parent organization overseeing a global portfolio of real estate brands, this Site is designed for an institutional audience, including investors, analysts, business media, and corporate talent. Note: This Policy does not cover the consumer-facing real estate services or agent productivity platforms (such as the Home Platform) operated by our affiliated brokerage brands, which are governed by their own respective privacy policies.

2. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or device (“Personal Information”).

1. Information You Provide Directly to Us

• Contact and Inquiry Information: If you contact our Corporate Headquarters or Press/Media teams, we may collect your name, email address, phone number, professional affiliation (e.g., media outlet or firm), and the contents of your message.
• Career and Application Information: If you interact with the corporate career link on this site, we may collect personal and professional data, employment history, resumes, and other application materials. (Note: If you click on our career links, you will be redirected to our affiliate or partner portals, which will process your data in accordance with their respective policies. We do not collect this information directly on this Site).
• Investor Relations Data: Personal information, such as your name and email address, provided when subscribing to investor alerts, financial reports, or corporate governance updates.

1. Information Collected Automatically

• Device and Usage Data: We do not use pixels or tracking technologies on this Site.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar enterprise-grade tracking technologies to optimize Site performance, remember user preferences, and compile aggregated corporate site analytics.

1. Information from Third Parties

• We may receive information from third-party service providers, such as investor relations platforms and public relations databases.

3. How We Use Your Information

We will only process your personal information when we have a valid legal basis to do so under applicable data protection laws, including the California Consumer Protections Act (CCPA), General Data Protection Regulation (GDPR). Depending on the specific purpose for which we use your data, we rely on the following legal bases:

4. Automated Processing and Analytics

While this Site does not utilize consumer-facing AI assistants or communications monitoring like our brokerage platforms, we do utilize automated systems for backend corporate operations:

• Security Monitoring: Automated systems monitor Site traffic to detect and mitigate cybersecurity threats.
• Recruitment Automation: If applying for a corporate role, your application may, where applicable, be processed using automated applicant tracking systems to align qualifications with open roles.

5. Disclosure and Sharing of Information

As a global holding company, we may disclose Personal Information to the following categories of third parties:

• Affiliated Brands and Subsidiaries: We may share inquiries with the appropriate operating brand (e.g., Compass, Coldwell Banker, Sotheby’s International Realty) if your request pertains specifically to their operations.
• Service Providers: We share information with trusted enterprise vendors who perform services on our behalf, such as investor relations hosting, corporate communications delivery, recruitment platforms, and cybersecurity firms. These providers are bound by strict Data Processing Addendums (DPAs) and Standard Contractual Clauses (SCCs), where applicable.
• Legal and Regulatory Authorities: When required by law, subpoena, or to protect the rights, property, or safety of CIH, our shareholders, or the public.

6. International Data Transfers (GDPR and Global Compliance)

Compass International Holdings supports a network spanning over 100 countries and territories. Personal Information collected through this Site may be transferred to, processed, and stored in the United States or other jurisdictions where our affiliates or service providers operate.

For users located in the European Economic Area (EEA), the United Kingdom, or other regions with comprehensive data protection laws, we ensure that international data transfers are safeguarded by recognized legal mechanisms, including Standard Contractual Clauses (SCCs) and adherence to applicable Data Processing Addendums.

7. Additional Disclosures for California and Other State Residents

The following details the categories of personal information we currently collect, and expect to collect, disclose for a business purpose, or share moving forward:

Categories of Information – 

We do not collect the following personal information on this Site:

• Protected classification characteristics under California or federal law
• Biometric information
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information
• Professional or employment-related information (we may have a link to apply to a corporate position, but this information would be collected on a different Site)
• Non-public education information (we may have a link to apply to a corporate position, but this information would be collected on a different Site)
• Inferences drawn from other personal information
• Sensitive personal information

Also, please note we do not sell or share any of your personal information for cross-contextual behavioral advertising. We also do not collect sensitive personal information on this Site, therefore we do not have a link entitled “Limit the Use or Disclosure of My Sensitive Personal Information.

Consumer Rights Concerning Their Personal Information

Depending on your state of residence, you may have specific rights regarding your Personal Information:

• Right to Know/Access: The right to request the specific pieces and categories of Personal Information we have collected about you.
• Right to Delete/Erasure: The right to request the deletion of your Personal Information, subject to certain legal exceptions (e.g., retaining data for financial compliance, business reason, or security purposes).
• Right to Correct/Rectify: The right to request the correction of inaccurate Personal Information.
• Right to Opt-Out: The right to opt-out of the “sale” or “sharing” of your Personal Information. (Note: Compass International Holdings does not sell nor share visitor data from this corporate Site to third parties for targeted consumer advertising).
• Right to Non-Discrimination: The right to not receive discriminatory treatment for exercising your privacy rights.
  
  

Exercising Your Rights (Data Subject Rights – DSR):
To submit a DSR request, please click here and click on ‘Submit Privacy Request’, or call us toll free at 833-206-7824. Authorized agents may also submit requests on your behalf, subject to standard verification procedures.  Please note that for your protection, prior to fulfilling your DSR request, we may need to verify your identity before fulfilling your request, such as by asking you to confirm information we have on file for you.

We may deny or fulfill certain requests, either in part, or in full, based on our legal rights and obligations. You have the right to submit an appeal if you are not satisfied with the outcome of your request, by emailing us at mydata@compass.com.

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 mydata@compass.com or send us a request via our webform located in our dedicated Privacy Center.

8. Data Security and Retention

We implement commercially reasonable technical, administrative, and physical safeguards designed to protect Personal Information. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements. We retain Personal Information only for as long as necessary to fulfill the corporate purposes outlined in this Policy, comply with our financial and legal obligations, and resolve disputes.

9. Minor Data

This Site is not directed to or intended for use by children under the age of 16. We do not knowingly collect Personal Information from children under 16. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it.

10. Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this Policy.

11. Contact Us

If you have any questions or about this Privacy Policy, our corporate data practices, or if you wish to exercise your privacy rights, please contact us at:
Email: Mydata@compass.com 

Address: Compass International Holdings, Corporate Headquarters, 110 Fifth Avenue, New York, NY 10011

If you want to make a complaint, you can also contact the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose. We ask that you please attempt to resolve any issue with us first, but here is the contact information for those regulating bodies: