Privacy Policy
Updated February 2024

This privacy policy for Cominsi Limited (trading as Cominsi) ("Cominsi," "we," "us," or "our") outlines the methods and reasons behind our collection, storage, utilization, and sharing ("processing") of your personal data during your interaction with our Services. This includes instances when you:

  • Access our main site at http://www.cominsi.com, or any other portal we operate that references this privacy policy
  • Interact with us through various channels, including sales, marketing, or any events

Have any questions or concerns? Reviewing this privacy policy will help you comprehend your privacy rights and options. If our approach does not align with your expectations, kindly refrain from utilizing our Services. For further inquiries or concerns, reach out to us at data-privacy@cominsi.com.

EXECUTIVE SUMMARY

This section highlights critical aspects of our privacy policy. For comprehensive details on any topic, follow the accompanying link or consult the table of contents below to navigate to the desired section.

  • What types of information do we gather?
  • What methods do we employ to handle your data?
  • On what legal grounds do we process your data?
  • Under what circumstances and with whom is your personal data shared?
  • For how long is your data retained by us?
  • What measures do we take to protect your information?
  • Is data collected from individuals under the age of consent?
  • What rights do you have regarding your privacy?
  • What are your options regarding do-not-track settings?
  • What specific rights do California residents have regarding their privacy?
  • What specific rights do Virginia residents have regarding their privacy?
  • Are there any updates to this policy?
  • What are the ways to contact us about this policy?
  • How can you inspect, modify, or remove the data we have collected from you?

    • WHAT TYPES OF INFORMATION DO WE GATHER?

    Personal Information You Provide to Us
    Summary: Your voluntary submission of personal information is the primary source of the data we collect.
    We gather personal data directly from you when you show interest in our products, services, or when you engage with our activities or reach out to us. This includes any information you provide when you register for our services, participate in community discussions, or communicate with our customer support.

    Sensitive Personal Information:
    We only handle sensitive information, such as financial details, creditworthiness, or government identifiers, when absolutely necessary and with your explicit consent or under lawful circumstances.

    • Financial details
    • Credit assessments
    • Social security numbers or similar identifiers

    Please ensure that all personal data you provide is complete, accurate, and kept up-to-date.

    Information Collected from Other Sources
    Overview: We might receive additional information about you from external sources.

    To improve the relevance of our marketing efforts and service offerings, we occasionally collect data from external sources, including public databases, marketing partners, and third-party data aggregators. Such information may encompass mailing lists, professional titles, email addresses, phone numbers, behavioral insights, IP addresses, social media profiles, and URLs, facilitating tailored advertising and more personalized event recommendations.

    Return to Table of Contents

    WHAT METHODS DO WE EMPLOY TO HANDLE YOUR DATA?

    In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

    We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

    • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.



    Back to Table of Contents

    In Essence: Our processing of your personal data is performed only when deemed necessary and based on legitimate legal grounds as per relevant legislation. This includes obtaining your consent, complying with legal obligations, providing services under contractual agreements, protecting individual rights, or pursuing legitimate business interests.

    For EU and UK Residents:
    Under the General Data Protection Regulation (GDPR) and the UK GDPR, we are required to disclose the legal grounds for processing your personal information. We may process your data based on the following justifications:

    • Consent: Your personal data may be processed upon your explicit consent for specific purposes. You retain the right to withdraw this consent at any time.

    • Legal Obligations: We may process your data as necessary to fulfill legal requirements, such as cooperating with law enforcement, defending legal claims, or as mandated by court proceedings.

    • Vital Interests: We may use your information to protect the crucial interests of you or another person, particularly in emergency situations that pose a threat to health or safety.


    If you are located in Canada, this section applies to you.
    We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

    In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

    • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
    • For investigations and fraud detection and prevention
    • For business transactions provided certain conditions are met
    • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
    • For identifying injured, ill, or deceased persons and communicating with next of kin
    • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
    • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
    • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
    • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
    • If the collection is solely for journalistic, artistic, or literary purposes
    • If the information is publicly available and is specified by the regulations



    Back to Table of Contents

    UNDER WHAT CIRCUMSTANCES AND WITH WHOM IS YOUR PERSONAL DATA SHARED?

    We may share information in specific situations described in this section and/or with the following third parties.

    We may need to share your personal information in the following situations:

    • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company
    • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions



    Back to Table of Contents

    FOR HOW LONG IS YOUR DATA RETAINED BY US?

    Briefly: We retain your personal data only as long as necessary for the objectives described in this privacy policy, or as required by applicable law.

    Your personal information will be maintained for the duration necessary to fulfill the purposes outlined in this privacy notice, adhering to our internal policies and legal obligations. This includes considerations for tax, accounting, or other statutory requirements that might dictate a longer retention period.

    Upon concluding the need for your personal data in connection with the purposes set forth in this notice, we will proceed to either delete or anonymize your information. In cases where deletion or anonymization is currently unfeasible (such as information stored in backup systems), we will securely warehouse your personal data and exclude it from further processing until deletion can be achieved.

    Return to Table of Contents

    WHAT MEASURES DO WE TAKE TO PROTECT YOUR INFORMATION?

    Summary: Our priority is the protection of your personal data through comprehensive security protocols.

    We employ a range of technical and organizational measures tailored to ensure the safety of your personal information. These are designed to secure your data against unauthorized access, theft, and misuse. However, it is important to acknowledge that no method of transmission over the Internet or method of electronic storage is entirely infallible. While we strive to use commercially acceptable means to protect your personal data, absolute security cannot be guaranteed. We urge you to transmit personal information using only secure networks and to engage with our Services within a protected environment. Please be aware that the safety and security of your data also depend on you.

    Return to Table of Contents

    IS DATA COLLECTED FROM INDIVIDUALS UNDER THE AGE OF CONSENT?

    Briefly: We strictly avoid collecting information from individuals under the age of 18.

    Our Services are not designed for, nor do we knowingly acquire or engage in marketing towards, children under the age of 18. If you use our Services, you affirm that you are at least 18 years old, or that you are the parent or legal guardian consenting on behalf of a minor under your care. Upon discovering that we have inadvertently gathered personal data from individuals under the age of 18, we will promptly deactivate any such accounts and undertake appropriate steps to swiftly remove the information from our systems. Should you have knowledge of any such data in our possession, please immediately inform us at data-privacy@cominsi.com.

    Return to Table of Contents

    WHAT RIGHTS DO YOU HAVE REGARDING YOUR PRIVACY?

    You may have various rights regarding your data depending on where you are located, especially if you are in regions such as the European Economic Area (EEA), United Kingdom (UK), and Canada. These rights allow you to access, modify, or delete your personal information and, in some cases, control the use of your data.

    Specifically, if you are from the EEA, UK, Canada, or similar jurisdictions, you are entitled to certain rights under data protection laws. These rights include the ability to (i) access and receive a copy of your personal data, (ii) correct or delete your data, (iii) limit the processing of your data, and (iv) obtain and reuse your data for your own purposes across different services (data portability). Additionally, under certain conditions, you have the right to object to the processing of your personal data. To exercise any of these rights, please reach out to us as detailed in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

    We will process all requests in line with local laws and our policies. If you believe that we are processing your personal data unlawfully, you have the right to complain to your local data protection authority in the EEA, UK, or Switzerland.

    Withdrawing Consent: If you have given consent for the processing of your data, you have the right to withdraw that consent at any time, though this will not affect any processing already performed. Withdrawal can be done using the contact details listed in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section.

    For any questions or concerns regarding your privacy rights, please contact us at data-privacy@cominsi.com.

    Back to Table of Contents

    WHAT ARE YOUR OPTIONS REGARDING DO-NOT-TRACK SETTINGS?

    Many web browsers, as well as certain mobile operating systems and applications, offer a Do-Not-Track ("DNT") option, which allows you to express a preference against having your online browsing activities observed and collected. However, currently, there is no consistent industry standard for recognizing and implementing DNT signals. Consequently, our systems do not recognize DNT browser signals or any similar mechanisms that automatically indicate your decision against online tracking. Should a universally accepted standard for online tracking emerge that requires our compliance, we will update our practices accordingly and provide you with details in an updated version of this privacy notice.

    Back to Table of Contents

    WHAT SPECIFIC RIGHTS DO CALIFORNIA RESIDENTS HAVE REGARDING THEIR PRIVACY?

    Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

    California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

    If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

    CCPA Privacy Notice

    The California Code of Regulations defines a "resident" as:

    (1) every individual who is in the State of California for other than a temporary or transitory purpose and
    (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

    All other individuals are defined as "non-residents."

    If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

    What categories of personal information do we collect?

    We have collected the following categories of personal information in the past twelve (12) months:

    A. Identifiers
    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

    B. Personal information categories listed in the California Customer Records statute
    Name, contact information, education, employment, employment history, and financial information

    C. Protected classification characteristics under California or federal law
    Gender and date of birth

    D. Commercial information
    Transaction information, purchase history, financial details, and payment information

    E. Biometric information
    Fingerprints and voiceprints

    F. Internet or other similar network activity
    Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

    G. Geolocation data
    Device location

    H. Audio, electronic, visual, thermal, olfactory, or similar information
    Images and audio, video or call recordings created in connection with our business activities

    I. Professional or employment-related information
    Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

    J. Education Information
    Student records and directory information

    K. Inferences drawn from other personal information
    Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

    L. Sensitive Personal Information
    Drivers' licenses, passport numbers, social security numbers and state id card numbers

    We will use and retain the collected personal information as needed to provide the Services or for:

    • Category A - we dont keep any information
    • Category B - we dont keep any personal information
    • Category C - we dont keep personal information
    • Category E - we dont keep personal information
    • Category G - we dont keep personal information
    • Category L - we dont keep personal information

    Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests; and
    • Facilitation in the delivery of our Services and to respond to your inquiries

    How do we use and share your personal information?
    More information about our data collection and sharing practices can be found in this privacy notice.

    You may contact us by email at data-privacy@cominsi.com, or by referring to the contact details at the bottom of this document.

    If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

    Will your information be shared with anyone else?
    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

    We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

    Cominsi Limited has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Cominsi Limited will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

    Your rights with respect to your personal data

    Right to request deletion of the data — Request to delete

    You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

    Right to be informed — Request to know

    Depending on the circumstances, you have a right to know:

    • Whether we collect and use your personal information;
    • The categories of personal information that we collect;
    • The purposes for which the collected personal information is used;
    • Whether we sell or share personal information to third parties;
    • The categories of personal information that we sold, shared, or disclosed for a business purpose;
    • The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
    • The business or commercial purpose for collecting, selling, or sharing personal information; and
    • The specific pieces of personal information we collected about you

    In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

    Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
    We will not discriminate against you if you exercise your privacy rights.

    Right to Limit Use and Disclosure of Sensitive Personal Information
    If the business collects any of the following:

    • Social security information, drivers' licenses, state ID cards, passport numbers
    • Account login information
    • Credit card numbers, financial account information, or credentials allowing access to such accounts
    • Precise geolocation
    • Racial or ethnic origin, religious or philosophical beliefs, union membership
    • The contents of email and text, unless the business is the intended recipient of the communication
    • Genetic data, biometric data, and health data
    • Data concerning sexual orientation and sex life

    you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.

    Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

    Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

    To exercise your right to limit use and disclosure of sensitive personal information, please email data-privacy@cominsi.com or submit a data subject access request.

    Verification process
    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

    We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

    Other privacy rights

    • You may object to the processing of your personal information
    • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information
    • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA
    • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission

    To exercise these rights, you can contact us by email at data-privacy@cominsi.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

    Back to Table of Contents

    WHAT SPECIFIC RIGHTS DO VIRGINIA RESIDENTS HAVE REGARDING THEIR PRIVACY?

    Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

    Virginia CDPA Privacy Notice
    Under the Virginia Consumer Data Protection Act (CDPA):

    "Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

    "Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

    "Sale of personal data" means the exchange of personal data for monetary consideration.

    If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

    The information we collect, use, and disclose about you will vary depending on how you interact with Cominsi Limited and our Services. To find out more, please visit the following links:

    • Personal data we collect
    • How we use your personal data
    • When and with whom we share your personal data

    Your rights with respect to your personal data

    • Right to be informed whether or not we are processing your personal data
    • Right to access your personal data
    • Right to correct inaccuracies in your personal data
    • Right to request deletion of your personal data
    • Right to obtain a copy of the personal data you previously shared with us
    • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

    Cominsi Limited has not sold any personal data to third parties for business or commercial purposes. Cominsi Limited will not sell personal data in the future belonging to website visitors, users, and other consumers.

    Exercise your rights provided under the Virginia CDPA
    More information about our data collection and sharing practices can be found in this privacy notice.

    You may contact us by email at data-privacy@cominsi.com, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.

    If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

    Verification process
    We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

    Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

    Right to appeal
    If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at data-privacy@cominsi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.

    Back to Table of Contents

    ARE THERE ANY UPDATES TO THIS POLICY?

    Summary: We commit to maintaining compliance with relevant laws by updating this notice as needed.

    We periodically revise this privacy notice to reflect changes and updates. Any new versions will be denoted by an amended "Revised" date, becoming effective immediately upon being made available. In the event of significant modifications to our privacy practices, we will inform you by either prominently displaying a notification of these changes or sending you a direct alert. We recommend regularly reviewing this privacy notice to stay informed about how we safeguard your personal data.

    Return to Table of Contents

    WHAT ARE THE WAY TO CONTACT US ABOUT THIS POLICY?

    If you have questions or comments about this notice, you may email us at data-privacy@cominsi.com or by post to:

    Cominsi Limited
    333, 1333 - 8th Street SW
    Calgary, Alberta, T2R 1M6, Canada

    Back to Table of Contents

    HOW CAN YOU INSPECT, MODIFY, OR REMOVE THE DATA WE HAVE COLLECTED FROM YOU?

    Depending on the laws in your jurisdiction, you may possess certain rights regarding the personal information we hold about you. These rights typically include accessing, modifying, or removing your data. If you wish to exercise these rights and review, amend, or delete your personal information, please reach out to us via email at data-privacy@cominsi.com

    Back to Table of Contents