June 2023

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia (collectively the “Applicable Residents”) respectively, the California Consumer Privacy Act (“CCPA”), Colorado Privacy Act (“CPA”), Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), or Virginia Consumer Data Privacy Act (“VCDPA”) (collectively the “US Privacy Laws”), provide you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to opt-out of the sale of your personal information; and the right not to be discriminated against. All these rights are subject to certain exceptions.

To review our privacy practices in general, please review our privacy policy.

Collection of Personal Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may keep your personal information for as long as necessary to carry out the purposes identified below; in most cases this is 24 months. We may have collected the following categories of personal information over the past 12 months:

· Identifiers, such as your name, email address, or IP address.

· Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and telephone number.

· Commercial information, such as records or products or services purchases, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Protected classification characteristics under California or federal law, such as gender.

· Internet or other electronic network activity information, such as cookies, web logs, IP addresses, and mobile device IDs. professional or employment-related information, such as your company name and address or any information that you share with us on your job application.

· Inferences drawn from any of the information identified above.

We collect the personal information listed above from the following sources:

· From you directly, when you visit our website or provide us with your personal information as part of interacting with our services or as a survey participant.

From your operating system and platforms, as well as your internet service provider.

· From other third parties, including advertising networks, data analytics providers, government entities, industry trade groups, and data brokers.

Disclosure or Sale/Share of Personal Information

In the last 12 months, we may have disclosed the following categories of personal information for our business or commercial purposes:

· Identifiers, such as your name, email address, or IP address.

· Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and telephone number.

· Protected classification characteristics under California or federal law, such as gender.

· Commercial information, such as records or products or services purchases, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Internet or other electronic network activity information, such as cookies, web logs, IP addresses, and mobile device IDs.

· Professional or employment-related information, such as your company name and address.

· Inferences drawn from any of the information identified above.

Of the above categories, we may “sell” or “share”, as those terms are defined in the US Privacy Laws, the following categories of information:

· Identifiers, such as your name, email address, or IP address.

· Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and telephone number.

We may have disclosed any of the information listed above with:

· Our affiliates.

· Our business partners, clients, and service providers.

· Data analytics providers.

· Social networks.

· Advertising companies.

· Government entities (to the extent required by law).

· Other third parties, if our assets are the subject of a sale or a similar corporate transaction.

We use or disclose your information for the following purposes:

· To provide marketing, advertising, and analytics services.

· To provide you with materials and information you requested.

· To send you information that may be of interest to you, such as newsletters, whitepapers, news bulletins, and other business information.

· To respond to specific queries, you may raise regarding Compas.

· To process your queries and requests, such as those submitted via or pursuant to the “Contact Us” and “Careers” sections on our website.

· To allow you to submit information to our new business team.

Please note that you may find additional information about any of the topics above in our privacy policy.

Your Rights

Right to Know

Applicable Residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you the following information (unless an exemption applies):

· The categories of personal information we collected about you.

· The categories of sources for the personal information we collected about you.

· The categories of personal information that we have disclosed for a business or commercial purpose.

· Our business or commercial purposes for collecting or selling personal information.

· The categories of third parties with whom we share that personal information.

· The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Delete

Applicable Residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Opt-Out of Sale or Share

The US Privacy Laws provides Applicable Residents with the right to opt-out of the “sale” of your personal information and depending on the state in which you reside, the right to opt-out of “sharing” of your personal information for the purpose of cross-context behavioral advertising or targeted advertising.

We do not knowingly collect or sell personal information about Applicable Residents under the age of 16.

Right to Nondiscrimination

The US Privacy Laws provides Applicable Residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights

If you are a California, Colorado, Connecticut, Utah, or Virginia resident and wish to exercise any of the above rights, you may submit a request to us through the following ways: · By email at privacysupport@compas-inc.com.

· By phone at our toll-free number +1 888 822 1828.

Upon receiving a request from you, we will first verify your identity by comparing the information you provide (your name, email address, or phone number) with the information we have on file. We may ask you for additional information to verify your identity or to comply with your request. We will also inform you if we are unable to complete your request due to an exemption.

Authorized Agent

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by you that authorizes the agent to act on your behalf. You may submit this document at the email address below. We may still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Contact for More Information

If you wish to contact us regarding this Notice, you may do so through the following methods:

· By email at by email at privacysupport@compas-inc.com.

· By phone at our toll-free number +1 888 822 182.