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Compass Marketing Solutions LLC Online and Offline Privacy Policy Compass Marketing Solutions LLC helps companies increase sales and customer loyalty through our high-value data, market intelligence and innovative digital solutions. We uncover and unlock revenue growth by enabling our clients – from local businesses to Fortune 100 companies – to connect and engage with their most valuable audience millions of times each day. Compass data powers the top 5 internet search engines and provides point-of-interest data for the leading in-car navigation systems. Compass recognizes the privacy interests of the businesses and consumers on which it collects information and has implemented comprehensive and formal data protection policies which balance privacy expectations with the legitimate business need of our customers. Data Compilation The information compiled by Compass incorporates several data elements for businesses and consumers. The information is acquired from reliable sources, and Compass takes great care through specific quality-control procedures to verify and maintain the accuracy of the information. Compass requires our data providers, partners, and customers to comply with all applicable federal, state, and local laws, statues, rules, regulations and ordinance (“Laws”), including but not limited to, privacy, data protection and direct marketing laws and laws concerning facsimile and email transmissions. Furthermore, we require all partners/providers to represent and warrant that (a) it has legally sufficient rights to the data and the right to enter into and perform its obligations under a License Agreement with Compass free and clear of any claims of any third parties; (b)partner/provider has not converted, misappropriated or otherwise wrongfully secured the data in whole or in part from third parties that the data and use thereof does not infringe upon the intellectual property rights of any third party; (c) there are not liens or encumbrances affecting the data; and (d) entering into a licensing agreement with Compass will not in any way constitute a breach or violation of any agreement to which the partner/provide is a party or applicable laws. Security Compass uses several security systems and procedures to safeguard the information, ensuring the data is accessed only by authorized individuals for legitimate business purposes. Compass will not transmit or sell the compiled information to third parties without obtaining a written or electronic agreement that defines the rights and responsibilities with respect to the data. Furthermore, Compass will review our customers’ use of the data to ensure sensitive data is being handled in accordance with required protections, and that this information is not used for deceptive, misleading, distasteful, or suspicious purposes. Compliance, Data Use, Access, Correction, Communication and Opt-Out Compass complies with all applicable laws, rules, regulations and self-regulatory guidelines pertaining to the collection, use and/or disclosure of information from or about a unique user of its website including but not limited to the following: FTC Mobile Privacy Report dated February 2013 (currently available at http://www.ftc.gov/opa/2013/02/mobileprivacy.shtm; The Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”), currently available at http://www.aboutads.info/principles; The code of Conduct of the Network Advertising Initiative (“NAI”), currently available at http://www.networkadvertising.org/code-enforcement/code, and the NAI Mobile Application Code currently available at http://www.networkadvertising.org/mobile/NAI_Mobile_Application_Code.pdf); The Principles of the European Interactive Digital Alliance (“EDAA”) currently available at http://www.edaa.eu/european-principles/. The use of data compiled by Compass will be used for both offline and online marketing to both businesses and consumers. In accordance with the DAA guidelines, we will not knowingly use or disclose data for online advertising purposes on anyone under the age of thirteen (13). Compass offers multiple ways for you to opt-out of third-party collection and use of your information for internet –based marketing/advertising. Opting-out does not mean you will stop seeing advertisements; however, it will allow you to directly opt-out from specific entities using your information for online and/or offline third party marketing and advertising. Please visit the following to learn more about your rights to opt-out. Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/ Network Advertising Institute (NAI): http://www.networkadvertising.org/choices/ European Interactive Digital Adverting Alliance (EDAA): http://www.youronlinechoices.eu/ and http://www.edaa.eu/ BlueKai/Oracle: If your browser accepts cookies, you can opt out directly from third-party interest based advertising by downloading Oracle’s BlueKai opt-out cookie. This cookie, when deposited on your browser, will prevent Oracle's BlueKai technology from creating Interest Data based on information collected from that browser. You can access and learn more about the BlueKai opt-out cookie here. o “Note: The opt-out tools described above are currently cookie-based, and prevent [companies] from using Marketing Information for interest-based advertising on the browser on which they are installed. As a result, the opt-out will only function if your browser is set to accept third-party cookies, and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again.” Upon a reasonable request, Compass will explain to businesses and consumers the nature and types of sources used to compile the data. Compass maintains procedures by which businesses and consumers can request corrections for any incorrect data, as well as request any business or consumer information be suppressed from compiled lists which are marketed to Compass customers. Requests for information can be made in writing to [email protected] or Compass LLC; Attn: Content Feedback; 808 P Street, Suite 300; Lincoln, NE 68508. Right to Change/Amend Privacy Statement Compass has created this privacy statement in order to demonstrate our firm commitment to privacy. Compass believes that concern for everyone’s privacy is a basis for sound business practices within direct marketing and other arenas. This statement is intended to apply to all visitors of websites owned and operated by Compass. If you have any questions after reading this privacy statement, you may contact us at 888-692-3744 or email us at [email protected]. Compass reserves the right to amend and/or modify this Privacy Statement at its sole discretion. In the event Compass changes this Privacy Statement in a material way, Compass will post an updated Privacy Statement to the website reflecting these changes so users can become aware of such changes. Do you wish to opt-out of a Compass product or database? Please call 888 692 3744 or email us at [email protected] and a customer service representative will be happy to assist. Effective Date: September 9, 2015