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Compose, Inc. Privacy Policy

Last Revised: 8/28/2014

Compose, Inc. (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.compose.io (the “Site”), related mobile applications, interfaces and other related services (collectively, the “Services”).

1. Questions; Contacting Company; Reporting Violations.

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at support@compose.io.

2. User Consent.

By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

3. A Note About Children.

We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at support@compose.io.

4. A Note to Users Outside of the United States.

We adhere to the United States/European Union Data Protection Safe Harbor Arrangement. For additional information, please see the Compose EU Safe Harbor Policy located at https://docs.compose.io/policies/eu-safe-harbor.html.

5. Types of Data We Collect.

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

5.1. Information You Provide to Us.

(a). We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, company name, database name and password when you create an account to log in to our network (“Account”).

(b). If you use our Services on your mobile device, we may collect your phone number and the unique device id number.

(c). When you order Services on our Site, you will be directed to our credit card processor, which will collect all information necessary to complete the transaction, including your name, credit card information and billing information. This information will be shared with third parties who help process your purchases. When you submit credit card numbers, the information is encrypted using industry standard technology.

(d). If you insert or modify information in a database, we will collect such information as part of the Services; however, we will not control or direct the use of such information and will not directly access it except as authorized by you or as necessary to provide the Services.

(e). If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

(f). When you post comments on the Compose Blog on our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.

(g). When you participate in one of our surveys, we may collect additional profile information.

(h). We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.

(i). We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected.

5.2. Information Collected via Technology.

(a). Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, a date/time stamp for your visit and/or logs of various levels that your database processes or server and server processes generate.

(b). Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

(c). Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

6. Use of Your Personal Data.

6.1. General Use.

(a). In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

• facilitate the creation of and secure your Account on our network;
• identify you as a user in our system;
• provide improved administration of our Site and Services;
• provide the Services you request;
• improve the quality of experience when you interact with our Site and Services;
• send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
• send you administrative e-mail notifications, such as security, or support and maintenance advisories;
• respond to your inquiries related to employment opportunities or other requests;
• send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.

6.2. Creation of Anonymous Data.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

7. Use of Your Personal Data.

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

7.1. Third Party Service Providers.

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.

7.2. Affiliates.

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

7.3. Corporate Restructuring.

We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

7.4. **Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

8. Third Party Websites.

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. 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 this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

9. Your Choices Regarding Your Information.

9.1. Email Communications.

We will periodically send you e-mails that directly promote the use of our Site or Services. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.

9.2. Cookies.

If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above.

9.3. Changing or Deleting Your Personal Data.

You may review, update, correct or delete the Personal Information in your Account by contacting us or by editing your profile via the Service. If you completely delete all of your Personal Data, then your Account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

10. Security of Your Personal Data.

Company is committed to protecting the security of your Personal Data. We use and offer a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. We cannot be responsible for any harm that occurs if you disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Company cannot guarantee the absolute security of your data.

11. Changes to This Privacy Policy.

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on https://docs.compose.io/policies/privacy.html. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

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