Privacy Policy
Copyright © 2020 - 2023 CompoSecure, L.L.C. – All Rights Reserved.
Last updated in April 2023 (“UpdateDate”)
This website is hosted by CompoSecure, L.L.C., a Delaware limited liability company (“Company”). This Privacy Policy describes the types of information we collect on the Sites, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy applies only to this website (www.composecure.com), our mobile sites, and our use of social media sites (collectively, the “Sites”), and any other personal information obtained when you call, email, or otherwise communicate with Company. By accessing the Sites on any computer, mobile phone, tablet, or other device (collectively, “Device”) or otherwise interacting with Company, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Sites.
We may modify this Privacy Policy at any time, and will post the current version on the Sites. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.
Information That You Give Us
For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of personal information we have collected, where we got it from, and with whom we have shared it:
Category of Personal Information Collected
- Contact information: such as name, email address, business or personal address, and phone number.
- From visitors to the Sites who call us, sign-up for emails or another service, or otherwise interact with us.
- To communicate with and respond to visitors and our customers about the products we sell or the work we do for them, including verification of identity or to meet legal obligations.
- We may share this information with select marketing, information technology, or other service providers and partners.
- Browsing information: such as your IP address, MAC address or other device identifier, HTTP Referrer information, the kind of browser or computer you use, pages and content that you visit on the Sites, what you click on, the state and country from which you access the Sites, date and time of your visit, and web pages you linked to our Sites from.
- Our Sites and your interactions with the Sites, including through the use of cookies and other tracking technologies explained further below.
- To evaluate usage of the Sites and improve performance and our services; to protect the security and integrity of the Sites and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations.
- Our service providers who help us with fraud protection and website analytics.
In some jurisdictions, such as the European Union and United Kingdom, individuals may have the right to opt-in or withdraw consent for certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in “Access, Correction, & Deletion."
Information We Collect Automatically
When you visit the Sites, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, device-identifying information, the specific web pages visited immediately preceding your connection, and the domain name from which you accessed the Sites. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing the Sites, the number of times you return to the Sites and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.
Like many commercial websites, we analyze how visitors use our Sites through what is known as “cookie” technology or similar tracking tools. A cookie is a small text file that is placed on your computer when you access the Sites and allows us to recognize you each time you visit the Sites. We may use cookies to: (1) allow you to use the Sites without having to re-enter your user name and password (if applicable); (2) enhance or personalize your Sites usage and shopping experience; (3) monitor Sites usage; (4) manage the Sites; and (5) improve the Sites and our products and services, including providing you with interest-based ads. For more information on our advertising, see below: “Interest-Based Advertising.” If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Sites, or that we may put on our Sites in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.
We may combine the information we collect through cookies, web beacons, or other technology tools with other information we have collected from you or information from other sources.
Your Choices
If you sign up for our mailing list, we will send you informational emails about offers of services. At any time, you can ‘unsubscribe’ yourself from our email list simply by clicking the ‘unsubscribe’ button. If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications. For more information about interest-based advertising, including how you can manage advertising, please see below “Interest-Based Advertising.”
Disclosure of Information
We may disclose information collected from and about you as follows: (1) to our related companies and service providers, to perform a business, professional or technical support function for us; (2) to our business, sales and marketing partners and affiliates, advertisers or other third parties, who may contact you with their own offers; (3) as necessary if we believe that there has been a violation of the Site Terms of Use or of our rights or the rights of any third party; (4) to respond to legal process (such as a search warrant, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (5) in the event that our company or substantially all of its assets are acquired, or there is a re-structuring, your personal information may be one of the transferred assets. We may also disclose your personal information with your express consent. We may share aggregate, non-personally identifiable information about Sites users with third parties.
Please note that if you voluntarily submit any personal information for posting on the Sites, such as a review or a blog post, the information becomes publicly available and can be collected and used by others, so you should use care before posting information about yourself online.
Interest-Based Advertising
We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Sites and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Sites and elsewhere over time. Other companies may also use such technology to advertise on our Sites. You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:
https://www.networkadvertising.org/choices
https://www.aboutads.info/choices
In the EU, please visit: https://www.youronlinechoices.eu
Retention of Personal Information
We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
Security
We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from visitors to the Sites. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
Children
The Sites are not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly using the contact information detailed in the “Contact Us” section below, and we will promptly investigate and then delete such information from our systems if warranted.
Third Party Websites
The Sites may contain links to third party websites, such as social media sites like Facebook and Twitter, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the Privacy Policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.
Changes to This Privacy Policy
We may change this Privacy Policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Sites. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.
We may process personal data under the following conditions:
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and whether the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The information below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for:
Our reasons
- Statistical analysis to help us manage our business.
- For our legitimate interests or those of a third party, i.e., to be as efficient as we can.
- Updating and enhancing customer records.
- For the performance of our contract(s) with you or to take steps at your request before entering into a contract.
- To comply with our legal and regulatory obligations.
- For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products.
- Marketing our existing and new products and services and those of selected third parties to:
- existing and former customers;
- third parties who have previously expressed an interest in our products or services;
- third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers.
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “Basis for Processing Personal Data”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside of the Company for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
• Contacting us by using the contact information detailed in “Contact Us” below.
Where Your Personal Information is Held
Information may be held at our offices and those of our third party service providers, representatives and agents as described above (see “Disclosure of Information”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see “Transferring Your Personal Information Out of the EEA”.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
Your information, including personal data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
If you would like further information, please contact us or our Data Protection Officer (see “Contact Us” below).
Access, Correction, & Deletion
We respect your right to access and correct your personal information. You may exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.
If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “Contact Us” section below.
California Privacy Rights Disclosure
California law permits our customers who are California residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. To make such a request, please write to us at the following address:
CompoSecure, L.L.C.
ATTN: General Counsel
309 Pierce Street
Somerset, NJ 08873 (USA)
(908) 518-0500, Extension 2540
If you are a California resident, California law provides you with the following additional rights with respect to your personal information:
When you exercise these rights and submit a request to us, we may verify your identity. We also may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of our goods or services. For the 12-month period prior to the date of this Privacy Policy, we have not sold personal information about our users; nor do we have any plans to do so in the future.
Your Rights
We want you to be in control of how your personal data is used by us. Please note that our ability to access or control your personal data will be limited, as required or permitted by applicable law. Depending on your jurisdiction, you may have the right to be informed of, and request access to, the personal data we process about you; update and correct inaccuracies in that information; have the information restricted or deleted; object or withdraw your consent to certain uses of data; and lodge a complaint with your local data protection authority. You may also have the right not to be subject to automated decision-making, including profiling, where it would have a legal or similarly significant effect on you; and the right to data portability with regard to the data you provided to us. We will not discriminate against you for the exercise of these rights.
If you would like to exercise any of the rights described above, please send us a request by using the contact information in “Contact Us” below. In your message, please indicate the right you would like to exercise and your jurisdiction. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, please contact us using the contact information detailed in the “Contact Us” section below.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by phone, email, or in writing, you will need to provide us with:
· Enough information to identify you (e.g., your full name, address and customer or matter reference number);
· Proof of your identity and address (e.g., a copy of your driving license or passport); and
· A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. We hope that we or our Data Protection Officer can resolve any query or concern you raise about our use of your information.
If you have any concern or complaint about the way we handle your personal information, please contact us using the contact information detailed in the “Contact Us” section below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside.
If you are a United States resident, you may contact the US FederalTrade Commission regarding your concerns. For more information, please see: https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Visitors from Outside the United States — Cross-Border Transfer
The Sites are hosted in the United States. If you are visiting the Sites from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Sites and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.
If you have questions or concerns about this Privacy Policy or how we collect and use the information of our customers, you can contact us by sending a letter to us at the appropriate address below:
If you live in the United States or any other country outside of the European Union, EFTA States, or the United Kingdom, the data controller responsible for your personal data is CompoSecure, L.L.C., with an address of:
CompoSecure, L.L.C.
ATTN: General Counsel
309 Pierce Street
Somerset, NJ 08873, USA
If you live in the European Union, EFTA States, or the United Kingdom, the data controller is CompoSecure, L.L.C., with an address of
Our Data Protection Officer’s contact details:
Steven J. Feder, General Counsel
CompoSecure, L.L.C.
ATTN: Data Protection Officer
309 Pierce Street
Somerset, NJ 08873, USA
(908)518-0500, Extension 2540
If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.
We may modify this Privacy Policy at any time, and will post the current version on the Sites. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.
