PRIVACY POLICY

Effective Date: September 15, 2024
Last Updated: June 8, 2026

Composite Digital LLC (“Composite,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information through our website located at www.composite.global (the “Site”).

This Privacy Policy applies solely to information collected through the Site for marketing and business development purposes. It does not apply to personal information processed by Composite on behalf of clients under separate contractual agreements.

1. Categories of Personal Information We Collect

We collect the following categories of personal information:

CategoryExamplesCollectedIdentifiersName, business email address, phone number, IP addressYesProfessional InformationCompany name, job title, business contact detailsYesCommercial InformationRecords of inquiries, services requestedYesInternet or Network ActivityBrowser type, device type, pages visited, session duration, referring URLsYesApproximate GeolocationCity/state derived from IP addressYesSensitive Personal InformationWe do not intentionally collect sensitive personal informationNo

We do not knowingly collect Social Security numbers, financial account information, biometric identifiers, or precise geolocation data through the Site.

2. Sources of Information

We collect personal information from:

  • You directly (e.g., contact forms, email communications)
  • Automated technologies (cookies, analytics tools)
  • Service providers supporting website functionality and analytics
  • Third-party data partners and visitor identification services

3. How We Use Personal Information

We use personal information for legitimate business purposes, including:

  • Responding to inquiries and requests
  • Providing marketing communications (where permitted)
  • Improving website functionality and performance
  • Analyzing site usage
  • Maintaining security and preventing fraud
  • Complying with legal obligations

We do not sell personal information. We may use third-party visitor identification services that associate website activity with email addresses to send marketing communications, as described in Section 7.

4. Disclosure of Personal Information

We may disclose personal information to:

Service Providers

Vendors that provide:

  • Website hosting and infrastructure
  • Analytics services
  • CRM or marketing tools
  • Security and monitoring tools
  • Visitor identification and intent data services

Service providers are contractually obligated to safeguard personal information and may not use it for unrelated purposes.

Legal Compliance

Where required by law, regulation, subpoena, or to protect legal rights.

Business Transfers

In connection with mergers, acquisitions, financing, or asset transfers.

5. Data Retention

We retain personal information only as long as reasonably necessary to:

  • Fulfill the purposes described in this Policy
  • Maintain business records
  • Comply with legal obligations
  • Resolve disputes

Retention periods vary based on business and legal requirements.

6. Security Safeguards

Composite implements reasonable administrative, technical, and organizational safeguards designed to protect personal information, including:

  • Encryption in transit (HTTPS/TLS)
  • Role-based access controls
  • Multi-factor authentication (MFA) for employees
  • Vendor due diligence
  • Limited internal access to personal information

No system can guarantee absolute security.

7. Cookies and Analytics

We use cookies and similar technologies to:

  • Enable essential website functionality
  • Analyze traffic and usage patterns
  • Improve user experience

We may use third-party analytics providers, such as Google Analytics. Users may manage cookie settings through their browser.

The Site does not currently respond to “Do Not Track” signals.

Third-Party Visitor Identification and Marketing

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting: https://app.retention.com/optout.

If you are located in a jurisdiction covered by the GDPR or similar privacy regulations, you may also opt out of the collection of your personal data at: https://www.rb2b.com/rb2b-gdpr-opt-out.

8. Your U.S. Privacy Rights

Depending on your state of residence, you may have rights to:

  • Request access to personal information
  • Request correction of inaccurate information
  • Request deletion of personal information
  • Opt out of certain data uses
  • Appeal denial of a privacy request (where applicable)

To exercise your rights, contact:

privacy@composite.global

We may verify your identity before responding.

9. California Privacy Rights (CPRA)

For California residents:

  • We do not sell personal information.
  • We use visitor identification services to associate web activity with email addresses for marketing purposes, as described in Section 7. You may opt out at https://app.retention.com/optout.
  • We do not use sensitive personal information beyond permitted purposes.

Authorized agents may submit requests on your behalf.

10. Children’s Privacy

The Site is not directed to children under 13. We do not knowingly collect personal information from children.

11. Client Data Processing

Composite may process personal information on behalf of clients under separate agreements. In such cases, Composite acts as a service provider and processes data only as directed by the client.

12. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted with a revised “Last Updated” date.

13. Contact

Composite Digital LLC
33 Nassau Ave
Brooklyn, NY
privacy@composite.global