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Privacy Policy


Privacy is an essential right that Comintech Corp strives to ensure for all of its customers and users. Comintech maintains its systems and procedures to be able to deliver its Clients the highest possible levels of protection for their information. Comintech is constantly working to implement new and improved quality standards that guarantee online privacy.
Comintech takes the confidentiality clause worked into every Client contract very seriously. Our privacy policy reflects that commitment and outlines the ways we handle, use and gather information with special attention paid to safeguarding the trust placed in Comintech by each individual Client.

  • Comintech does not and will not offer for sale, share, or lease any information given to us, except as disclosed in this privacy policy (“Privacy Policy”).
  • Our Privacy Policy applies to prospective, current, and former Clients and users, representing multiple stakeholders within Comintech’ user community.

Datacenter Services and Corporate E-mail Services

As a cloud , hosting and eMail service provider, Comintech provides access to physical and virtual servers and resources such as cloud services and eMail systems for customers around the globe to store and manage their data and applications. Comintech does not own this specific data and is not a “controller” as outlined in the EU Directive.


How we gather and use information:

Comintech gathers information from our customers and third parties when they access any one of the company’s solutions or services, specifically Comintech corporate eMail service corpmail; eMail marketing— hosting control panels; other managed services.
The source of the information collected from and/or about its users are three: (i) from Comintech web server logs, (ii) with cookies and (iii) directly from the user.
Comintech shall not use the information collected for any purpose related to sales, use or renting to third parties without due authorization. The information is used solely to contact prospect Clients in the event they have expressed an interest in regard to the purchase of one of our services.
Any eMail addresses solicited in order to interact with one of our control panels or another online service (and/or any other information in Comintech possession) are sent only if exclusively requested. Comintech eMail and eMail marketing services are built on the premise of Permission-based Marketing and the company’s communications are aimed at customers who have granted Comintech permission to contact them. All sent eMails include opt-out options to cancel subscription at any given moment, providing customers with the tools and guarantee against unwanted communications.
The information we gather from our Clients when they visit and interact with our service and control panel is limited to that information that helps Comintech to better customize the sites for Clients. Information collected includes: records of actions and movements made on one of the sites, visited pages, clicks, available information obtained from the webpages, IP direction and type of browser.


Use of our Clients’ information:

All of our Clients’ information regarding their lists of customers is handled with the utmost privacy and is guaranteed in a confidentiality clause of the services contract.


Cookies:

A cookie is a small text file transferred to a user’s computer from a web server. Its function generally involves authentication, monitoring of navigation, and gathering of specific information on users. Our cookies are only used to monitor time and forms of navigation through Comintech sites in order to improve the company’s sites, the value of information, and the user experience overall. These cookies are not linked to any address aside from Comintech and users can choose to accept or decline their use in their Internet browser. For further information on how to manage cookies within Internet browsers, visit the site www.aboutcookies.org
Web Server Logs:
Comintech may collect “Non-Personally Identifiable” information to administer the site and analyze its usage, such as:

  • Internet protocol address (explained below);
  • The type of browser or computer in use;
  • The number of links clicked within our website;
  • The state or country from which the website was accesses;
  • The date and time of the user’s visit;
  • The name of the user’s Internet service provider;
  • The webpage from which the user linked to Comintech’ website; and
  • The pages viewed.

Internet Protocol (“IP”) Address: An IP Address is a number assigned to a user’s computer while using the Internet from which Web servers can automatically identify the user’s computer. Comintech servers collect the IP address and the webpage from where the user linked to our website. The user’s IP address assists Comintech in administering and optimizing the website for individual users, analyzing website usage, and diagnosing problems with the website.
Personal Information:
When registering with or contacting the company for technical support assistance or for commercial or administrative reasons, among others, Comintech may ask users to provide “Personal Information” which may include, but may not be limited to, the user’s full name, postal address, phone number and email address. Comintech may then contact the user with information about Comintech products and services.
When purchasing products or services, Comintech will request financial information, specifically a tax ID number, only used to create the invoice for the products and services purchased.
Additional Information:
As a security measure and to ensure that Comintech websites and computer network remain available to all its Clients, Comintech may use software programs to monitor network traffic or to identify unauthorized attempts to upload or change information, or otherwise cause damage. These software programs may also collect information regarding use of Comintech websites and computer network.


Information used by third parties:

Because Comintech is a company that offers online, on-demand solutions often sold through Resellers, the company’s privacy policy applies to resellers as well as customers and users to create a full chain of trust between Comintech and all the stakeholders within its user community based on respect for the individual identification and individuals’ information. Each Reseller must comply with the Privacy Policy as stated in the confidentiality clause of their contract with Comintech.
Safe harbor privacy principles:
To the extent that Comintech is exposed to customer or user data, Comintech adheres to the Safe Harbor Privacy Principles.

  • Notice - Individuals must be informed that their data is being collected and about how it will be used.
  • Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties.
  • Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles.
  • Security - Reasonable efforts must be made to prevent loss of collected information.
  • Data Integrity - Data must be relevant and reliable for the purpose it was collected for.
  • Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate.
  • Enforcement - There must be effective means of enforcing these rules.

All of the terms and conditions herein apply to the users of all Comintech Services


How information may be used:

Comintech uses collected information in order to inform its Clients regarding their accounts, notify them regarding changes to the terms and conditions governing their use of our websites, products and services. Comintech may also use the information collected to inform Clients about other products and services deemed of interest or about special offers. All communications will be provided with an “opt-out” option (also see the Comintech Acceptable Use Policy).
Comintech employees, contractors, Resellers or Agents will at times require access to a Client’s Personal Information. Comintech permits access to such information only for business purposes, such as administration and developing our products or services.
In no instance will Comintech use your Personal Information in a manner inconsistent with the purposes described herein without your prior consent.


Released information:

Comintech may release some client Non-Personally Identifiable information, as well as traffic patterns, and related website usage information to company affiliates and reputable third parties on an aggregated basis.
Comintech may share or disclose Personal Information with Resellers or Agents (“Agents” are persons or companies who act on behalf of or under the instructions of Comintech) in connection with administering or delivering Comintech products and services. Prior to disclosing Personal Information to its Agents, Comintech will either: (a) ensure that the Agent subscribes to the Safe Harbor Privacy Principles, (b) assess whether the Agent is subject to the EU Directive, (c) determine that the Agent complies with another “adequacy” finding or (d) execute a written agreement with the Agent requiring the Agent to provide at least the same level of privacy protection as the Safe Harbor Privacy Principles. Comintech will not otherwise disclose your Personal Information to third parties without first obtaining your consent pursuant to the Opt-In and Opt-Out Provisions below.
SPECIAL CASES OF RELEASE:
Both Personal Information and Non-Personally Identifiable information may be transferred to a third party:

  1. As required by law, in a matter of public safety or policy, or as compelled by a court of law
  2. In the event of a change of ownership or assets; and
  3. To affiliated entities of common control, such as subsidiaries and parent companies. The use of your information by these affiliates of common control will comply with this Privacy Policy.

Direct contact:

Comintech may contact you directly through the email address or other information you provide to confirm information regarding Comintech services. Comintech may also contact you to respond to your questions, to provide the services you request, to manage your account, to inform you of service announcements, and/or to notify you of special offers or other information, products or services we think you will find valuable.


Opt-out provision:

All promotional email from Comintech or our marketing partners shall include an ‘Unsubscribe’ link so that the recipient may remove his/her eMail from future mailings. Recipients may also “opt out” of promotional emails by contacting Comintech at info (at) comintechcorp.com. To delete their Personal Information, recipients may contact Comintech at info (at) comintechcorp.com and Comintech will take reasonable efforts to delete a user’s Personal Information from its database and/or third-party sites. However, please note that it may be impossible to entirely delete a user’s Personal Information because some residual information may reside on backups or records of deletions. We may require the retention of a minimal amount of contact information from active or former clients in order to maintain service-related communications and/or billing history.
Comintech will always offer recipients the opportunity to opt out before their Personal Information is:

  • disclosed to a third party that is not an Agent of Comintech; or
  • used for a purpose that is inconsistent with the purpose(s) for which it was originally collected (as we have explicitly described in this Privacy Policy or at the time the recipient provided such information) or as the recipient subsequently authorized.


Additionally, if a user’s Personal Information to be disclosed or used in the above situations is “Sensitive Information” (i.e. Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), Comintech will first obtain the user’s explicit consent by requiring that the recipient “opt in” prior to such uses or disclosures of Sensitive Information.


Third-party sites:

Comintech’ websites may include links, ad banners, etc. to other websites which may or may not be affiliated with Comintech. Notwithstanding any affiliation, Comintech does NOT control and is NOT responsible for the information and/or content any user may provide to and/or any transactions users may engage in with such third party sites. Users should be aware that the operators of these other websites may collect and use different information about the user that is not consistent with this Privacy Policy. For any concerns as to the privacy of a user’s information on these third-party websites, the user should refer to the respective privacy policies of each site.


Children:

In accordance with the Children’s Online Privacy Protection Act (COPPA), Comintech does not knowingly collect or solicit any Personal Information from children under the age of thirteen (13).


Security:

Like privacy, Comintech understands that another key issue of concern for all of the company’s Clients and user community is security. Acting in a proactive and responsible manner always to ensure effective and efficient protection of data, Comintech takes every security measure available to the company aimed at protecting the data in the company’s possession against loss, malicious use or alteration.
Comintech employs the use of electronic security measures to protect against the loss, theft, misuse, alteration, or unauthorized disclosure of Client information submitted to Comintech websites. These measures include firewalls, use of passwords, anti-virus and detection software.
When we ask Clients or users to provide personal financial information, data is protected using Secure Sockets Layer (“SSL”) technology. However, please note that electronic communication (e.g. email, online chat or instant messaging) that may be sent to Comintech may not be secure unless security measures are put into place prior to the transmission of the information. For that reason, Comintech asks that its Clients do not send confidential information such as financial information, social security numbers/tax ID numbers or passwords via unsecured electronic communication.


Content made available publicly:

Some pages of Comintech Clients’ websites may make chat rooms, forums, message boards, news groups or instant messaging available to their users/customers. Any information disclosed in these areas is public. Users of one of these services should exercise caution when disclosing Personal Information in these areas. Information that might be considered confidential—such as financial information, social security numbers, passwords or email addresses—should not be disclosed in these areas. Users should be aware that when they voluntarily disclose Personal Information on the bulletin boards or in the chat areas, that information and any substantive information disclosed in the communication can be collected and used by third parties. This could result in unsolicited messages from others who post on such sites and are beyond the control of Comintech.
Users represent and warrant that posting content to any public area of Comintech’ websites will not infringe or violate the rights, including but not limited to intellectual property rights, such as copyrights, patents, trademarks and trade secrets and rights of privacy and publicity of any third party.


Transfer of data abroad:

When visiting Comintech’ websites from a country other than the countries in which the company’s servers are located, the various communications will necessarily result in the transfer of information across international boundaries. When visiting our websites and communicating electronically with us, users are implicitly consenting to the processing and transfer of their data as set out in this Privacy Policy.


Access to personal information and/or corrections of inaccuracies:

If a user wishes to access and/or update the Personal Information Comintech may have collected from the user, the user may either a) as a registered user, log into the associated account and view and change his/her information online; or b) contact us at info (at) comintechcorp.com.


Modifications to the Privacy Policy:

Comintech reserves the right to amend, alter, modify, replace or suspend this Privacy Policy, from time to time, at its sole discretion. All such changes to this Privacy Policy will be posted on Comintech’s primary website: www.comintechcorp.com and effective immediately.


Ensuring Compliance with the Privacy Policy:

Comintech uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Safe Harbor Privacy Principles.


Questions or concerns:

Any comments, questions or disputes regarding this Privacy Policy or the use and disclosure of Personal Information, should be sent via email to info (at) comintechcorp.com and we will attempt to resolve any concerns brought to the company’s attention.
Please, also review our Terms, Conditions & Acceptable Use Policy

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