Protecting your personal information is our priority.

This Privacy Policy describes how Compass Innovations LLC (“Compass Innovations,” “we,” “us,” or “our”) collects, uses, or discloses personal information we receive through the Compass Innovations’ website, https://compass-innovations.com/, and any related mobile applications and other services we provide (collectively, the “Services”). It sets out how we collect and use information about our website visitors, patients, and any other entity (“you”), why we use it, when we share it, the rights to which you may be entitled, your choices about our use of your information, and what we do to protect it.

Please read the Privacy Policy carefully before you start to use our Services. By using the Services, you agree to be bound and abide by our posted Terms of Service (“Terms”) and Privacy Policy. If you do not agree to both the Terms and our Privacy Policy, or if you violate them in any way, your right to access or use the Services is terminated.

If you are using our Services in a manner covered by the Health Insurance Portability and Accountability Act (“HIPAA”), please refer to our HIPAA Notice of Privacy Practices, which describes how we use and disclose your protected health information (“PHI”), our legal duties with respect to your PHI, your rights with respect to your PHI and how you may exercise them. In the event of any conflict between this Privacy Policy and our HIPAA Notice of Privacy Practices in connection with HIPAA-covered services, our HIPAA Notice of Privacy Practices will prevail. Consistent with HIPAA, we may at times request your consent to use your PHI for certain purposes.

1. How We Collect Information

We may collect information about you by various means, including:

• Directly from you;
• Through our websites, mobile apps, and other connected devices and services;
• From our partners when you use drug coupons and discount cards provided by our Services;
• By combining information from different sources, including online and offline data; and
• From other sources and social media platforms that you may use to engage with us

2. Types of Information We Collect

In order to better provide you with our Services, Compass Innovations may collect the following categories of information:

• Profile and contact information, such as your name, phone number, mailing address, e-mail address, and usage and subscription preferences (which may include signing up to some of our Services or other communications from us or selected third parties);
• Demographic Information, including age, gender, race, ethnicity,
• Medical Information, including allergies, medications, vital signs (height, weight, blood pressure), conditions, family and social history.
• Survey information in response to questions we may send you through the Services, including for research purposes;
• Communications between you and us, such as via e-mail or other electronic channels; and
• Online User Activity described in the next section.

If you provide us with contact information regarding another individual, such as for your referrals, you represent that you have that person’s consent to give us that information and to permit us to use the information in accordance with this Privacy Policy, such as to contact that individual.

3. Cookies and Information Collected by Other Automated Means

Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We, our service providers, and our business partners may collect information about your use of our websites and mobile apps by such automated means, including but not limited to cookies, pixels, SDKs and other similar technologies.

Cookies and similar technologies can help us automatically identify you when you return to our website or app. Cookies help us review website traffic patterns and improve the website, determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the website or app, the information we may collect by automated means includes, for example:

• Usage Details Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses, and referral contact information and demographics);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and
• Location information where you choose to provide the website or app with access to information about your device’s location.

We may also ask advertisers or other partners to serve ads or services to your device (e.g., retail coupons for other items available in your area), which may use cookies or similar technologies placed by us or the third party.

We may share non-personal information obtained via cookies with our advertisers and partners. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Note that we and our service providers and advertising partners may collect information about users’ online activities over time and across third-party websites.

We may use the following cookies:

Cookie Provider	Purpose and Type of Cookie	Privacy Notice of Provider
LinkedIn (AnalyticsSyncHistory, bcookie, li_sugr, lidc, UserMatchHistory)	Analytics and Advertising	https://www.linkedin.com/legal/privacy-policy
Google Analytics (_ga, _ga***, gcl_au, AEC)	Analytics	https://policies.google.com/privacy
GoDaddy (_tccl_visit, _tccl_visitor)	Analytics	https://www.godaddy.com/legal/agreements/privacy-policy

To opt-out of certain cookies, please see the Cookie Settings link on the website homepage. Also, certain cookies are set by browsers and your browser may allow you to disable cookies, or the third party listed above may provide an opt-out tool. For example, to learn more about Google Analytics and how to opt-out, please visit https://tools.google.com/dlpage/gaoptout. Note that disabling cookies may in some instances impact the functionality of our Websites.

You may also be able to utilize a global privacy control or universal opt-out mechanism in connection with your browser, however, please note that if you do this, you may not be able to use the website’s full functionality.

Also, you may learn more about advertising networks and opt-out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to their opt-out sites are set forth below.

Network Advertising Initiative:

• Browser Opt-Out: http://www.networkadvertising.org/choices

Digital Advertising Alliance:

• Browser Opt-Out: http://www.aboutads.info/choices

Please note, these websites are managed by unrelated third parties and Compass Innovations therefore accepts no liability in relation to the respective contents.

Note that, when you opt-out of personalized advertising, you may continue to see online advertising on the websites and/or our ads on other websites and online services. Also, your choice to opt-out is specific to the device, website, and browser you are using, and is deleted when you clear your browser’s cookies.

4. How We Use Information We Collect

We may use the information we obtain about you for purposes allowed by applicable laws, including:

• Provide our Services to you, establish and maintain your account, and respond to your requests, questions and comments and provide customer support;
• Tailor the content we display to you in our communications, including advertising, and offering promotions, products or services that we believe may be of interest to you;
• Operate, evaluate and improve our programs, our websites and other products and services we offer (including to develop new programs and services), as well as diagnose or fix technology problems;
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Inform you about changes to our Services, this Privacy Policy, our Terms and other policies;
• Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights; and
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns.

Any uses described here will be restricted where required by HIPAA or other applicable laws, and where appropriate, we will limit these uses in accordance with any choices you have exercised under such laws.

Please note, we may share aggregated, de-identified personal information with our partners and service providers. Any PHI will deidentified in accordance with HIPAA requirements. We will maintain and use such information in deidentified form and not to attempt to reidentify the information.

5. Online Advertising

You may see us advertising on various websites, web pages, social media and other platforms. Please note that online advertising service do not always provide us with complete information about the platforms or website on which our advertising may appear. These outlets may in some cases not be aligned with our values as a company. If you believe that our advertising is displayed on platforms that promote inappropriate or offensive content, please contact us.

We may serve advertisements, and allow third parties to serve advertisements, through our Services. These advertisements are sometimes targeted and served to particular users and may come from third party organizations called “ad networks. ” Ad networks can include a number of third party ad servers, ad agencies, ad technology vendors and research firms. Advertisements served through our Services may be targeted to users who fit a certain general profile category, which may be inferred from information you provide to us or, based on your website or mobile app usage patterns, or based on your activity on other website or online services as may be available to the ad networks.

6. How We Share Your Information

We may share your personal information, including contact demographic, medical and survey information with our service providers that perform services on our behalf, or partners with whom we may collaborate. We collaborate with services providers and business partners on: development and support of our Services and associated operations, surveys and market research; clinical or market research with reputable healthcare organizations; and advertising and promotional campaigns. Our service providers are prohibited from using your personal information except to provide such services to us, and they are required to maintain the confidentiality of your information.

We will share your name, address and amount donated to each charity you donate to, in order for the charity to provide you with a donation receipt.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.

We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your information (e.g., e-mail, name, address, telephone number) is not transferred to the third party. Instead, we may share anonymous data with trusted partners to help perform statistical analysis, and then we would send you an email or postal mail, on their behalf.

Any sharing described here will be restricted where required by HIPAA or other applicable laws, and where appropriate, we will limit such sharing in accordance with any choices you have exercised under such laws.

7. Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

Please see our HIPAA Notice of Privacy Practices regarding your choices in connection with your PHI for our HIPAA-covered Services.

Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communications. In order to improve our Services, we may be notified when you open an email from Compass Innovations or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such marketing communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.

Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites and mobile apps may not function correctly.

Targeted Advertising: Some of our business partners that collect information about your activities on our websites and in our mobile apps may be members of organizations or programs that provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. For example, you may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative or the Digital Advertising Alliance Mobile app users may opt out of receiving targeted advertising in mobile apps through members of the Digital Advertising Alliance by installing the App Choices mobile app, available here, and selecting the desired choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

User Account: You may terminate your account by contacting us as provided below. We may retain account information for internal purposes, as required by applicable laws, or as otherwise provided in this Privacy Policy and our Terms.

8. Links to Other Websites and Third-Party Content

Our Services may contain links to other websites or apps. This can include social media integrations. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information. With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automated data collection practices.

9. How We Protect Information

We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information.

10. Children

We do not knowingly collect personal data from children under the age of 13 on our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us, and we will endeavor to delete that information from our systems. If we learn that we collected personal information from a child under age 13 without parental consent, we will endeavor to promptly delete that information.

11. International Data Transfers and Use

Our Services are controlled by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. Any information you provide through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside, such as to our support staff outside of the United States. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed, and will seek assurances for any support staff or service providers do to the same.

12. Jurisdiction Specific Notice – Texas Residents

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. If you are a Texas resident, see the information below for additional information as to your rights and to how to exercise those rights.

Texas residents have certain rights around Compass Innovations’ collection, use, and sharing of their personal information. Compass Innovations does: (i) sell your personal information; (ii) engage in profiling in furtherance of decisions that produce legal or similarly significant effects; or (iii) engage in “targeted advertising” as the term is defined in the Texas Data Privacy and Security Act (“TDPSA”).

Compass Innovations collects various categories of personal information when you use our website or services. A more detailed description of the information Compass Innovations collects and how we use it is provided above in the sections titled “Types of Information We Collect” and “How We Use Information We Collect.” The section titled “How We Share Your Information” describes categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Texas, you have the right to: (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a portable copy of your personal information; and (5) opt out of selling, profiling, and targeted advertising.

You may submit a request to:

• Access or delete your data: Access your data online through Compass Innovations Patient Navigator portal, and select “My Profile” to view the information stored. You can request that a portion or all of your data be deleted by emailing us at getresults@compass-innovations.com.
• Opt-out of sale/sharing: You may opt out of the sale or sharing of personal information, which is limited to use through online tracking technologies (i.e., cookies) by following the instructions in the link in the footer of the website.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. When you make a request, we may require that you provide information and follow procedures so that we can verify your identity. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.
We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

Please note that the right to appeal a decision to deny processing of a request can be made by sending an email to getresults@compass-innovations.com, using the subject line: “Texas DSR Appeal.”

• Data Retention: We retain personal information for as long as needed to fulfill the purposes for which it was collected and to comply with legal obligations.

13. Updates to Our Privacy Policy

We may revise or update this Privacy Policy at any time. We will post the updated version on our Services and may electronically notify you of any significant changes to our Privacy Policy. We will indicate on our Privacy Policy when it was most recently updated. Your continued use of our Services after such updates will constitute acknowledgment of the change and agreement to abide and be bound by the updated Privacy Policy.

14. Contacting Us

If you have any questions, concerns, or comments about this Privacy Policy, our privacy practices, or if you would like us to update your information or preferences you provided to us, please contact us at: getresults@compass-innovations.com or via mail at:

Compass Innovations LLP
1701 Pennsylvania Avenue NW, Suite 200,
Washington, DC 20006

This Privacy Policy was last updated June 25, 2025.