PRIVACY POLICY

Effective Date: April 01, 2022

Compass Government Solutions, LLC and affiliated entities (“CGS,” “us,” or “we”) adopted this privacy policy (the “Privacy Policy”) to reflect our commitment to protecting your privacy and to inform you of our policies and practices regarding the collection, retention, use, and disclosure of any Personal Information that we may collect. We take the collection of Personal Information seriously and are committed to protecting your Personal Information in accordance with this Privacy Policy. Please read below to learn how we collect, use, and disclose Personal Information.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable U.S. privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice. We have also included specific information for other applicable privacy laws so the users of our Sites who may be subject to those laws can be informed of their rights and the options CGS provides to enable the exercise of those rights.

For information about specific rights under applicable privacy laws that may be different from the general information applicable to all users of our Sites, please see the sections labelled “Rights and Choices for California Consumers,” and/or “Rights and Choices for Nevada Consumers.”

If you would like to download or print a copy of this Privacy Policy, you may do so by clicking here.

Where This Privacy Policy Applies

This Privacy Policy applies to our websites, including the websites available at http://www.compassgovernmentsolutions.com (each, a “Site” and collectively the “Sites”). If a particular service provided by or on behalf of CGS refers or links to a different privacy policy, then that privacy policy – not this Privacy Policy – applies. We encourage you to review the privacy policies and terms and conditions of use for all third-party services or links provided by or on behalf of CGS.

By submitting any information through a Site, you acknowledge and agree that CGS may process (i.e., collect, use, etc.) your Personal Information as described in this Privacy Policy.

The Types of Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). We limit the collection of personal information to the information that we need to administer and improve the Site, to provide our services to our customers, and to fulfill any legal and regulatory requirements. The categories of personal information that we collect may include, but are not limited to: contact information to allow us to communicate with you regarding services or employment opportunities, and: personal information for applications that will be collected, with your knowledge/release and cooperation, through the credentialing process for employment.

Personal information primarily collected:

Applications, forms, and other information you provide us on the website and through the credentialing process; including resumes directly sent to us or submitted through the site.
Ongoing credential documents.
If you provide us with comments or suggestions, request information about our services, or contact us via phone, email or other forms of communication.
From third parties who may be used to verify information given to us.

‌We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, when you create an account, from forms you complete, or from products or services you request.
Indirectly from you. For example, from observing your actions on our Sites including by technological means. For more information about how we may collect your Personal Information by technological means, please see the section labelled “Personal Information Collected Via Technology.”
From Service Providers. For example, from vendors that provide services to us, which enable us to provide services to you. This may include demographic and site usage information from analytics firms.
From third parties. We collect contact and employment information from third parties, including clients and from technology, staffing, and social media partners.
From publicly available sources, such as social media sites, when permitted by the terms of service for those sources. For example, if you communicate with us over Twitter or Instagram, we may receive additional information about you from your profile.

We do not require you to provide any personal information in order to have general access to the company website. However, in order to access or use certain information, features or Services at the Site, you may be required to provide personal information. Personal information will be collected, with your knowledge/release and cooperation through the credentialing process for employment.

Personal Information Collected via Technology

We may use Cookies to enhance user experience with us. Cookies are small files that your web browser places on your computer’s hard drive to ensure everyone who uses our website a more personalized site experience. A cookie is used to help us measure the number of visits, average time spent, page views, and other statistics relating to the site. You have the option of setting your browser to notify you when you receive a cookie or to prevent cookies from being sent. Please note that by not accepting cookies, you may limit the functionality of the site. We do not use “cookies” to collect information for third parties for marketing purposes.

How We Use Your Personal Information

We use the information provided on the website, through the credentialing process and through the ongoing business relationship with the company to perform the process/maintain employment.

We limit the collection of personal customer information that we need to:

Facilitate customer requested services and transactions
Provide service to our customers
Comply with legal, reporting and regulatory requirements
Administer and improve our websites
Detect fraud or theft to protect our business and client information

We limit the collection of personal applicant/candidate/employee information that we need to:

To fulfill or meet the reason you provided the information. For example, we may use the Personal Information you provide to send you job listings or to contact you about a placement opportunity, or to identify new candidates or clients.
For employment-related purposes. We may also use your Personal Information for applicant tracking, recruitment and hiring, to staff open positions at CGS or with clients, and to provide payroll and administer benefits, for travel arrangements and performance management, for record-keeping, for safety purposes, to meet legal and compliance obligations, or for other permissible internal purposes.
Process credentialing required by the company, customer or regulations for employment at government or commercial sites
Maintain required credentials throughout tenure
To provide, support, personalize, and develop our Site, products, and services.
To process your requests, transactions, and payments and to prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses, communicate with you about this Privacy Policy or any other legal notice related to our Sites, and any other purpose described in this Privacy Policy.
To personalize your experience on the Site and to deliver content and product and service offerings relevant to your interests and CGS and its affiliates and subsidiaries, including targeted offers through our Site, third-party sites, and via email or text message (with your consent, where required by law).
To help identify fraud and maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
To prosecute or defend legal claims and to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in applicable privacy laws, including the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

You may not opt out of non-promotional communications from CGS, including messages relating to your candidacy for a job or your employment with CGS. Please note, regardless of your communication settings, we may continue to communicate with you regarding changes to terms and conditions, Privacy Policy updates, data breaches, or other significant information related to your Personal Information for as long as it is retained by CGS.

If you provide feedback on any of our products or services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Information. We will collect any information contained in your feedback and will treat the Personal Information in such communication in accordance with this Privacy Policy.

We may create Deidentified Information records from Personal Information by excluding information (such as your name and/or IP address) that would allow someone to identify a specific individual. “Deidentified Information” means information that is not associated with or linked to your Personal Information, including any feedback you may provide, which cannot be reidentified with your Personal Information. Deidentified Information does not permit the identification of individual persons. We may use this Deidentified Information to analyze request patterns and usage patterns so that we may enhance our products and services. CGS reserves the right to use and disclose Deidentified Information to third parties in its discretion.

CGS retains your Personal Information for as long as needed to carry out the purposes described above or for as long as we are required to retain it for records management, legal, and compliance purposes, whichever is longer. We may be required to retain your Personal Information as necessary to comply with certain legal obligations we might have, such as in connection with threatened or on-going litigation, which might exceed normal retention periods. We take commercially reasonable efforts to delete any Personal Information that we no longer need or are required to retain as described in this Privacy Policy.

How We Share Your Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

Internal corporate employees with a need to know to provide services, facilitate assignment, or maintain ongoing credentialing
Benefit companies to provide requested benefits
Government or commercial customers to complete placement
Government agencies to fulfill legal, reporting and regulatory requirements
Clients and business partners;
Government entities, including judicial and law enforcement authorities pursuant to lawful requests.
Service providers;
Affiliates of CGS;
Partners;
Internet cookie data recipients, such as Google Analytics; and,
Successors (or potential successors) to all or part of our business.

While we may request your consent to use or share your Personal Information to fulfill or perform services regarding your requests through the Sites, including in connection with any applications you submit, we may also use or share your Personal Information without your consent for any legitimate purpose as allowed under the applicable laws and regulations (see the section labelled Notice Regarding Requested Consents, below), including fulfilling our contractual obligations to you. CGS has taken certain organizational and technological security measures to protect your Personal Information, described in the How We Protect Your Information section, and requires at least the same degree of organizational and technological security measures to be used by all third parties with whom we may share your Personal Information.

Additionally, we may share some or all of your Personal Information with “Affiliates” (parent company, subsidiaries, joint ventures, or other companies under common ownership and/or control), in which case we will require our Affiliates to provide at least the same degree of protection for your Personal Information as we do under this Privacy Policy. If our company or our assets are acquired by another company, that company will possess the Personal Information collected by us and it will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

In certain circumstances, we may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Disclosures of Your Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other Personal Information.

We may disclose your Personal Information for a business purpose to the following categories of third parties:

Clients and business partners;
Government entities;
Service providers;
Affiliates of CGS;
Internet cookie data recipients, such as Google Analytics; and,
Successors (or potential successors) to all or part of our business.

We do not collect Personal Information related to Categories D (“Commercial information”) or COMPASS (“Sensory information”), so have not disclosed such information to third parties.

Sales of Your Personal Information

It is our policy not to sell Personal Information. As such, in the preceding twelve (12) months, we have not sold Personal Information.

How We Protect Your Personal Information

To protect your Personal Information, we have put in place reasonable technical and organizational precautions, in addition to following industry best practices, to help prevent your Personal Information from being accidentally lost, misused, altered, accessed, or disclosed in an unauthorized way. Except as provided elsewhere in this Privacy Policy, CGS limits access to Personal Information, regardless of if it is stored electronically or in physical form, to those persons (including employees and contractors) in our organization who have a business need for such access.

We have also put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The safety and security of your information also depends on you. If you choose, or are provided with, a user name, password, or any other piece of information when you create an account as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any other person or entity. You also acknowledge that your account is personal to you and agree not to provide any other person with access to that account, or any portion thereof, using your user name, password, or other security information. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer or device so that others are not able to view or record your password or other personal information. You are entirely responsible for maintaining the confidentiality of the information you hold for your user name, password, or other information related to your account. You may be held liable for losses incurred by us as a result of your failing to keep your login information secure and confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information when it is received by us, we cannot guarantee the security of your Personal Information transmitted to our Sites and cannot completely eliminate security risks associated with Personal Information. Any transmission of Personal Information is at your own risk. We are not responsible for any circumvention of any privacy settings or security measured related to the Sites.

Notice Regarding Requested Consents

If you use the Site, you may be asked to consent to the collection and use of your Personal Information for particular purposes. While you will not be penalized or prejudiced for refusing to consent to the collection, retention, and use of your information as described in this Privacy Policy, failure to provide consent may interfere with or disrupt certain features of the Sites or prevent us from fulfilling requests you make.

When we are using your Personal Information on the basis of your consent, you are entitled to withdraw that consent at any time. If you revoke your consent, you will not be penalized or prejudiced for revoking your consent.

Even if you refuse or revoke your consent, CGS may continue to collect, retain, and use your Personal Information or sensitive Personal Information so long as such retention and use is consistent with the purposes described in this Privacy Policy and that collection, retention, and use is lawful and allowed without obtaining your consent under the applicable laws and regulations.

These uses, among others, may include:

Complying with legal obligations, for example, tax, employment, and other laws or regulations;
Fulfilling our contractual obligations to you;
Fulfilling our legitimate business interests and purposes, whether performed by ourselves or a third party, so long as that purpose does not override your fundamental rights and freedoms;
Preventing fraud;
For internal administrative purposes, whether your information is maintained internally or shared with our subsidiaries and affiliates, franchisees, or third-party contractors for this purpose;
Ensuring network and information security;
Establishing, exercising, or defending against any legal claims; or,
Using your Personal Information in accordance with any valid consents you have given.

Information that contains PII or PHI will be released to third parties with a need to know only upon written approval. Aside from the purposes described above, we will never share your personal information with any other third party without express permission or under special circumstances, including instances where the disclosure is required by law.

Compass Government Solutions is responsible under the Health Insurance Portability and Accountability Act (HIPAA) regulations to ensure the strict confidentiality of all protected health information and we will protect your information from public or unauthorized view or access.

When we collect, retain, or use your Personal Information based on a legitimate interest or the public interest, as described above, you may have the right to object at any time to that use of your Personal Information if your local law gives you that right.

Notice Regarding Children

We do not target our Site or Services toward or intentionally gather Personal Information about visitors who are under the age of 13. If a child under 13 submits Personal Information to us and we learn that the Personal Information is the information of a child under 13, we will attempt to delete that Personal Information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us using the information in the below “Contact Us” section.

By using this Site, you represent that you are at least the age of majority in your state, province, or country of residence, or that you are the age of majority in your state, province, or country of residence and you have given us your consent to allow any of your minor dependents to use this Site.

Links to Other Sites

If we have provided a link to any other website or location, it is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites. We encourage you to review the privacy policies and any other terms and conditions of use for any linked website or location before using and accessing those websites or locations so that you are informed about the respective owner’s privacy practices and any legal terms to which you might be agreeing.

Updates to this Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. If we change the way we collect, use, or disclosure your Personal Information that require us to make changes to this Privacy Policy, we will post a notice on this page and update the Privacy Policy’s effective date. Your continued use of our Sites following any posted updates to the Privacy Policy constitutes your acceptance of such changes. If you object to any of the changes to our Privacy Policy, you must stop using the Sites.

How to Contact Us

If you have any questions on our Privacy Policy or would like to remove your information with us please contact us at privacy@compassgovernmentsolutions.com or at any time, you may use the unsubscribe link at the bottom of from any email you receive.

Phone: (877) 795-0834
Website: https://www.compassgovernmentsolutions.com/contact-us
Email: privacy@compassgovernmentsolutions.com
Mailing Address:
Compass Government Solutions, LLC
1910 Towne Centre Blvd, Ste 250

Annapolis, MD 21401

Rights and Choices for California Consumers

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Your Personal Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the section labelled “Exercising Your Access, Data Portability, and Deletion Rights”), we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and,
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see the section labelled “Exercising Your Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies that allows or requires us to retain your Personal Information.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or,
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). It is our policy not to sell Personal Information. We also do not sell the Personal Information of consumers we actually know are less than 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing privacy@compassgovernmentsolutions.com, "DO NOT SELL MY PERSONAL INFORMATION."

You may also choose to submit a request to opt-out of the sale of your Personal Information by using the general CCPA Rights Request process as described in the section labelled “Exercising Your Access, Data Portability, and Deletion Rights.”

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by using the general CCPA Rights Request process as described in the section labelled “Exercising Your Access, Data Portability, and Deletion Rights.”

As with the other rights made available to you under the CCPA, you do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and respond to the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or,
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites 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 email privacy@compassgovernmentsolutions.com.

Rights and Choices for Nevada Residents

If you are a resident of the State of Nevada, you have the right to request that CGS not sell the Personal Information we currently have about you or that we might collect about you in the future. Although it is currently our policy not to sell Personal Information, if you would like to register an email address with CGS to request that we not sell your Personal Information now or in the future, please email privacy@compassgovernmentsolutions.com.

Following our receipt of your request, we will make reasonable efforts to verify your identity and that the request is authentic. When we have verified your request, we will confirm that your Personal Information will not be sold by CGS. If you change your email address in the future, please note that you will need to re-register the new email address with us so we can continue to ensure that we do not sell your Personal Information.

CGS will only use the information you provide in connection with your request to process that request. Because of the on-going nature of your right not to have your Personal Information sold under Nevada law, we will retain the information provided in this request until you withdraw the request.

SMS Messaging Privacy Policy

At Compass Government Solutions, we are committed to protecting the privacy and personal information of our candidates and employees. This Privacy Policy outlines how we collect, use, and safeguard the information provided through SMS (Short Message Service) communications.

1. Collection of Personal Information

When you provide us with your phone number, either through job applications, employment forms, or other company processes, you will receive a single text message from us to confirm your enrollment in SMS/text messaging. Reply YES to consent to the messages, or NO to not enroll.

By consenting, you certify, warrant and represent that the telephone number you provided to us is your contact number and understand that consent is not a condition to apply for a job.

These messages may include, but are not limited to:

Job application updates
Interview scheduling and reminders
Employment offers and onboarding information
Work-related updates, notifications, and reminders

2. Use of SMS Communications

The phone numbers collected will be used solely for the purpose of communicating relevant information regarding employment, recruitment, and work-related activities. SMS communications will be limited to necessary updates, including but not limited to:

Interview confirmations and follow-ups
Employment status updates
Time-sensitive work-related instructions or alerts
Notifications about benefits, payroll, and other important employment information

3. Opt-Out Policy

You have the right to opt out of SMS communications at any time. To stop receiving SMS messages, you may reply "STOP" to any message received.

4. Data Security

We take the security of your personal information seriously. All phone numbers and SMS communications are stored in a secure environment and accessed only by authorized personnel. We implement industry-standard security measures to protect your data from unauthorized access, misuse, or disclosure.

5. Data Sharing

We do not sell, rent, or share your phone number or any personal information with third-party companies for marketing purposes. Your information will only be shared with third parties when necessary to comply with legal obligations, respond to court orders, or protect the rights, property, or safety of Compass Government Solutions, its employees, or others.

6. Message Frequency and Costs

The frequency of SMS messages will vary depending on your role, application status, and the need for communication. Compass Government Solutions does not charge for these SMS services, but message and data rates may apply depending on your mobile carrier and service plan. Please check with your carrier for details on rates.

7. Changes to this Privacy Policy

Compass Government Solutions reserves the right to modify this Privacy Policy at any time. Any changes will be posted on our website, and continued use of our SMS service will constitute your acknowledgment of the updated policy.

8. Contact Information

If you have any questions or concerns about this Privacy Policy or your rights regarding SMS communications, please contact us at: privacy@compassgovernmentsolutions.com.

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