EFFECTIVE DATE: May 24, 2018
INFORMATION YOU PROVIDE TO COMMA
COMMA collects information that you voluntarily submit to COMMA through the Service. For example, we collect information when you contact us to inquire about our products and services. The information we collect may include information that identifies or could identify you (whether alone or in combination), such as your name, email address, or physical address. Do not submit any information to us that we have not requested.
INFORMATION COLLECTED AUTOMATICALLY
COMMA also automatically collects certain information about your device and how your device interacts with our Service. Examples of this type of information include your device’s IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Service, and your browsing habits on and usage of the Service through your device.
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.
Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Third Party Services, Features, and Devices” and “Your Rights and Choices” below.
INFORMATION FROM OTHER SOURCES
- Data brokers from which we purchase demographic data to supplement the data we collect;
- Social networks when you reference our Service or grant permission to us to access your data on one or more of these services;
- Partners with which we offer co-branded services or engage in joint marketing activities; and
- Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Party Services, Features, and Devices” below.
USE OF INFORMATION
COMMA uses information we collect through the Service for our legitimate interests, including the following purposes:
- To manage our Service;
- To perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service;
- To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- To prevent and address fraud, breach of policies or terms, and threats or harm;
- To monitor and analyse trends, usage, and activities; and
- To improve the Service or other COMMA websites, applications, marketing efforts, products and services.
We also use information about you with your consent, including:
- To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
- To provide you with advertisements tailored to your interests; and
- To fulfill any other purpose disclosed to you and with your consent.
We may use information that does not identify you (including personally identifiable information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
SHARING OF INFORMATION
COMMA shares information we collect through the Service as follows:
Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may process your information in connection with their work on our behalf. These Service Providers are contractually prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
We may share your information with our affiliates for internal business purposes. For example, we may share your information with our affiliates for customer support, marketing, or technical operations.
We may share your information with third parties for purposes of providing you with advertisements tailored to your interests.
SWEEPSTAKES, CONTESTS, PROMOTIONS
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties. If you voluntarily choose to enter a Promotion, your information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
MERGER or ACQUISITION
We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
SECURITY AND COMPELLED DISCLOSURE
We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Service rules or policies, or the rights of third parties or to investigate any suspected conduct which COMMA deems improper. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with third parties or affiliates except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
THIRD PARTY SERVICES, FEATURES AND DEVICES
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated, owned, and maintained by third parties. (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you “like” or “share” content over social media through our Service. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with COMMA in a tweet or post), we may use your reference on or in connection with our Service.
Our Service also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
YOUR RIGHTS AND CHOICES
Tracking Technologies Choices
Most browsers are initially set up to accept cookies; however, you generally can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilize all features of the Service.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Analytics and Interest-Based Advertising
Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit http://www.aboutads.info/choices. In addition, some of these third parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You have the option to opt-out of receiving promotional emails from COMMA by clicking on the unsubscribe link that appears at the bottom of every promotional email that is sent out to you by COMMA in relation to this Service, or contacting us at firstname.lastname@example.org with the word UNSUBSCRIBE in the subject field of the email. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions.
YOUR EUROPEAN PRIVACY RIGHTS
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service.
To exercise any of these rights, please e-mail us at email@example.com or send us a letter to the mailing address in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. For information on how to exercise your rights for information collected and processed at the direction of our customers, see the section entitled “Customer Data” below.
EEA WITHDRAWAL OF CONSENT
If you are a data subject in the EEA, you have the right to opt out or withdraw your consent for us processing your personal data collected through the Service (or providing it to third parties to process) for direct marketing purposes (including promotional emails) or purposes materially different than for which it was originally collected or subsequently authorized by you. You may also withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please note that withdrawal of your consent does not impact any data that was processed on the basis of that consent before it was withdrawn.
To exercise this right, please e-mail us at firstname.lastname@example.org or send us a letter to the mailing address in the section entitled “Contact Us” below and specify your withdrawal of consent. We will try to make the requested changes in our active databases as soon as reasonably practical.
COMMA acknowledges that you may have rights in connection with Customer Data. If your information has been processed by COMMA on behalf of a customer and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to COMMA, please provide the name of the COMMA customer on whose behalf COMMA processed your information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
We take reasonable steps to help protect the security of your information. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put into place physical, electronic, and managerial procedures. However, due to the inherent open nature of the Internet, we cannot guarantee the security of your information collected through the Service.
In addition, our mailing address is:
Kifisias Avenue. 308, Halandri
FAO: Privacy Compliance Officer