PRIVACY POLICY

INTRODUCTION

The following Privacy Policy summarizes the various ways we treat personally identifiable and other information about you and any device from which you visit the Website. This Privacy Policy does not cover information collected through sites, applications, destinations, or services linked to from the Website.

Your privacy is important to Comserve Online.

We have created this Privacy Policy to make you feel comfortable to use our website by informing you what information would be collected from you on our website and how we intend to use the information that we have collected. As per the Privacy Policy, we may collect several types of information and utilize them in various ways depending on how you use our website.

It also explains your choices regarding use, access and correction of your personal information. By using the website, you agree to accept the terms of this Privacy Policy. Kindly spare a moment to review the terms of this Privacy Policy. Please do not use our website if you do not agree to the terms laid down under this Privacy Policy.

PERSONAL INFORMATION

1. Active Collection and Usage:

In order to be able to access our website, services and the information available on our website, you may be required to register with the website and share some of your personal information, such as your name, telephone number, email address and certain financial information, including but not limited to credit card information. If you provide us with personal information, we will retain such information and may use that information to contact or respond to you.

We also may retain or use your information for the period of time that may be required to pursue our legitimate business interests. This time period would not exceed 10 years, unless otherwise agreed by you in writing. Our legitimate business interests may include customizing the services that we provide to you and also to ensure compliance with Comserve Online policies and applicable laws, ensuring you are satisfied with Comserve Online's support and services, authentication confirmation for secure handling of Comserve Online’s clients' accounts, etc. We will retain such information even if you choose to delete your account with us but will only use it as described above.

We may share your personal information with our partners. The Website generally collects personally identifiable information with your specific knowledge and consent. For instance, when you fill out a form, make a purchase, subscribe to any of our publications, register for certain services, or register and/or set up an account to access certain portions of the Website, or the Website as a whole, you may provide a credit, debit, or charge card number, or other payment information such as your name, telephone number, email, street address, age, gender, mobile phone number, and other personally identifiable information. You may also provide information about your company such as your position/title, customer demographics, budget preferences, size of company, and other information regarding your job and company, so that we can better cater to your needs. All such information shall be referred to in this Privacy Policy as your “Registration Information”. It also describes your choices regarding use, access and correction of your personal information. Please take a moment to review the terms of this Privacy Policy. By using the Sites, you agree to accept the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the website. This Privacy Policy applies only to information collected on the website. It does not apply to information that we may collect by means other than on the website.

Our services collect, store and process this personal information on servers in the United States of America.

We collect your personal information to:

•   Provide you with a tailored experience to our Platforms.
•   Notify you about your account activity.
•   Process transactions and collect requests as directed by you.
•   Provide customer support and resolve disputes.
•   Verify your identity and account information.
•   Identify, prevent, and report potentially prohibited, fraudulent or illegal activities.
•   Provide transaction, risk mitigation and “KYC - Know Your Customer” reports to our Financial Institution Partner(s) and/or merchants.
•   Contact you at your telephone number by voice or SMS to validate the telephone number or your account.
•   Notify you about important changes to Comserve Online’s Platform and/or Comserve Online’s terms and conditions.
•   Provide you with news, offers and information about Comserve Online’s offerings based on your communications preferences.
•   Any other purpose that we disclose to you in the course of providing Comserve Online’s Services to you.
•   Compare and create audiences based on interest of your personal data and or requests.

2. Aggregate Information and Collection of Passive Information:

We may collect general, non-personal, statistical information about the use of website from time to time such as how many visitors visit a specific page on the website, the time period they remain on that page, and the hyperlinks, if any, that they “click” on.

We collect this information through the use of technologies such as “cookies” and “IP addresses,” which are discussed in detail below. Our system may also automatically collect operational information about the technology you use, such as your browser, type of computer, operating systems, internet service providers and the domain name of the websites from which you were directed to our website.

We collect this information in order to determine which areas of the website is most popular and to enhance the website for our visitors. We may use this information for security purposes in order to detect and block security breaches and to provide you with a safe online environment. We may also share this information with our partners.

3. IP Addresses:

IP address is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. Comserve Online collects IP addresses for the purposes of system administration, in order to report aggregate information to third parties and for tracking the use of the website. When visitors request pages from the website, our servers log the visitors' IP addresses. It is not our practice to link IP addresses to anything personally identifiable, which means that a visitor's session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with the website’s policies or to protect Comserve Online, its website, its visitors or others.

4. Cookies, Beacons and Successor Technologies:

We partner with a third party to display advertising on our website. Our third-party partner may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, you may choose to do so on your account page. Please note you will continue to receive generic ads.

In addition to these, Comserve Online and our partners use cookies and similar technologies to analyze trends, administer the website, track users’ movements around the website in order to gather demographic information about our user base as a whole.

Cookies are pieces of information transferred by a website onto an individual's hard drive for record-keeping purposes. Cookies make web-surfing easier by saving your preferences while you are on the website. The use of cookies is an industry standard – you will find them in almost all websites.

By showing how and when visitors use the website, cookies help us see which areas are popular and which are not. Information such as the total number of visitors and pages viewed is most easily tracked with cookies. We may use the information from cookies to make improvements and updates to the website and to tailor our services according to the needs of our visitors

You are provided with the option to disable cookies using your browser preferences. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, please be aware that some features of the website may not function properly or may be slower if you refuse cookies.

Pages of our website may contain electronic images known as web beacons that are also referred to as single-pixel gifs that permit Comserve Online to count the number of users who have visited those pages and for other related website statistics (e.g., recording the popularity of a particular website content and verifying system and server integrity). Web beacons are not used to access your personal information on the website; they are being solely used in order to compile aggregated statistics concerning the use of the website. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.

In addition to the foregoing, we use certain analytics platforms, which will track certain personal information of yours. Information collected about you is limited to age, gender and affinity categories. If you would like to opt out of the collection of such information you may do so on your account page. Further, most Web browsers provide technology plugins that prevent your data from being collected and used by analytics platforms.

5. User Data Supplementation

We may receive information about you from other sources, including publicly available databases or social media sites and we may combine this data with the information we already have about you. This helps us to update, expand and analyze our records, identify new customers and provide products and services that may be of interest to you.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you (for the purpose of creating more tailored advertising and products), may include:

•   Purchased marketing data about our customers from third parties
•   Data and other information available publicly on social media sites.

6. Do Not Track Signals

At this point of time, we do not have the ability to comply with any setting within your web browser that would send “do not track” signals or other similar technology that would provide consumers the ability to exercise choice regarding the collection of personally identifiable information.

II. Disclosure of Personal Information

A. Personally Identifiable Information:

We may use information collected via this website to improve the content of our website, to customize the website according to your preferences, to communicate information to you (if you have requested for it) for our marketing and research purposes, to ensure you are no longer contacted in the event you unsubscribe from marketing campaigns, to market future available services and software of relevant interest to you and for any other purpose specified.

Except for the limited situations that have been discussed in this Privacy Policy, we will not share your personally identifiable information with any third parties. We may sometimes use third parties to perform certain services for us, such as hosting of websites, sending postal mail and providing data analysis. We may provide personally identifiable information to those businesses when that information is necessary for them to respond to your requests or otherwise perform their duties. These companies are authorized to use your personal information only as necessary to provide these services to us.

B. Legal Notice:

In certain situations, Comserve Online may be required to disclose personal data in response to lawful requests made by public authorities, that includes necessity to comply with national security or law enforcement requirements.

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request or subpoena.

If Comserve Online is involved in any merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, use of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

We may purchase other businesses or their assets or sell our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that Comserve Online or all of its assets are acquired, or in cases of liquidation, dissolution, reorganization or other transfer of the business, the customer information, including any visitor information collected through the website may be one of the transferred assets.

Finally, Comserve Online reserves the right to disclose visitor information in special cases, when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who maybe causing injury to or interference with (either intentionally or unintentionally) the rights or property of Comserve Online, or any other visitors or anyone else that could be harmed by such activities. Comserve Online also reserves the right to disclose visitor information when we believe in good faith that the law requires it. However, we will have no liability for disclosure of information obtained due to errors in transmission or the unauthorized intervention of third parties.

C. Aggregate Information:

We may group information into aggregate visitor data in order to describe the use of our website to our existing or potential business partners or other third parties, or in response to a government request. However, please be assured that this aggregate data will in no way personally identify you or any other visitors to the website.

III. Links to Other Sites:

Please be aware that when you are on our website, you could be directed to other websites that may be beyond our control. There may be links to other sites from the website’s pages that take you outside our website. These other sites may send their own cookies or other tracking technologies to visitors to collect data or solicit personal information. The privacy policies of all these other sites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any of your personal information collected there.

IV. Security:

Protecting the security of your personal information is very important to us.

When you transmit personal information from your computer to our servers, your information is protected by both a “firewall” (a combination of computer hardware and software that helps in keeping unauthorized visitors from accessing information within our computer network) and industry standard SSL (secure socket layer) encryption. Once we receive your transmission, we will take reasonable precautions to ensure its security on our systems. While we utilize all of our security and data protection preventative measures, the internet is inherently insecure. As a result, while Comserve Online strives to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Users are required to sign-in to specific secured areas of the website and services using a user ID and password. These authenticate the user and are designed to safeguard against unauthorized access and use of a user's account. The user ID and password are used on a secure web page and encrypted when transmitted over the internet.

The safety and security of your information also depends on you.

If you have access to password-protected features, never share your password with anyone else, notify us promptly if you believe your password security has been breached, and remember to log off of this site before you leave your computer. Similarly, any personally identifiable information or personally sensitive data that you disclose through online forums and blogs hosted on the website may be collected and used by others. We recommend caution when giving out personal information to others in these public online forums.

If at any point you suspect or become aware of a security incident (i.e. your password is stolen or you receive suspicious communication from someone holding themselves out to be a Comserve Online employee or from a fake website claiming to be affiliated with Comserve Online), please forward the communication to us or report the incident by email to info@comserveonline.com at the earliest possible time.

V. Privacy Policy for Children:

We do not knowingly collect information from children under the age of 13 on our website. If you are under the age of 13, please do not provide any personal information to us. If we become aware that we have collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

VI. Changes to These Terms:

The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of our website for a reasonable period of time, prior to the changes becoming effective, that this Privacy Policy has been updated, and by changing the “Updated and Effective” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of our website following the posting of changes to these terms will mean you accept those changes.

VII. Access and Review of Your Personal Information:

Our services collect, store, and process personal information on servers in the United States of America.

When using our website and services, we make commercially reasonable efforts to provide you with access to your personal information and either correct this data if it is inaccurate or delete inaccurate data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

Comserve Online provides you with information about whether we hold, or process on behalf of a third party, any of your personal information on your account page.

You may access, correct, or request deletion of your personal information by accessing your account page. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

We will respond to these requests within a reasonable timeframe.

Users must identify themselves and the information requested to be accessed, corrected or removed prior to processing such requests, and we may decline to process such requests that are deemed unreasonable or inappropriate. In any case, the information access and data corrections are performed free of charge, except if doing so would require a disproportionate effort. Due to the methods that we maintain certain services, once your information is corrected or deleted; residual copies may take a period of time before they are deleted from our active systems and may remain in our backup systems.

VIII. International Privacy Principles

A. EU-US and Swiss-U.S. Privacy Shield Principles for EU & Swiss Data Transferred to the United States:

Comserve Online complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Comserve Online has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ Comserve Online is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Comserve Online remains liable for all data transferred under the Privacy Shield Framework(s)unless we can prove we were not a party giving rise to the damages.

Pursuant to the Privacy Shield Frameworks, we acknowledge the right of EU and Swiss individuals to access their data. Such individuals may also correct, amend, or delete the personal information we hold about you if it is inaccurate or has been processed in violation of the Privacy Shield Principles. Individuals wishing to exercise this right should refer to Section VII (Access and Review of your Personal Information) for more details regarding how they can gain such access.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@comserveonline.com.

In compliance with the Privacy Shield Principles, Comserve Online commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Comserve Online at: info@comserveonline.com.

Comserve Online has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.bbb.org/EU-privacy-shield/file-a-complaint/ for more information or to file a complaint. The services BBB EU Privacy Shield are provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Comserve Online is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, Comserve Online may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Comserve Online is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Comserve Online remains liable for all data transferred under the Privacy Shield Framework(s), unless we can prove we were not a party giving rise to the damages.

Pursuant to the Privacy Shield Frameworks, we acknowledge the right of EU and Swiss individuals to access their data. Such individuals may also correct, amend, or delete the personal information we hold about you if it is inaccurate or has been processed in violation of the Privacy Shield Principles. Individuals wishing to exercise this right should refer to Section VII - Access and Review of Your Personal Information for more details regarding how they can gain such access.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than for which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@comserveonline.com.

In compliance with the Privacy Shield Principles, Comserve Online commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Comserve Online at: info@comserveonline.com.

Comserve Online has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.bbb.org/EU-privacy-shield/file-a-complaint/ for more information or to file a complaint. The services BBB EU Privacy Shield are provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction . With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Comserve Online is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, Comserve Online may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

B. GDPR for EU Individuals

As of May 25th, 2018, Comserve Online has been in compliance with Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and Comserve Online’s processing and control of personal information, if you are located within the European Union that will be in accordance with the standard set forth in the GDPR.

EU individuals with GDPR complaints are encouraged to contact us directly at info@comserveonline.com. You also have the right to bring any grievance directly to the Data Protection Authorities (DPA’s) in your area. Please refer to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your specific DPA.

C. Email or Newsletter Preferences

You may also be provided an option to choose to subscribe to an email list. If you subscribe to our electronic mailing list and later decide to opt-out, simply follow the instructions that are included in each email.

IX. Consent

By using our platform, visiting our website, you are consenting to the terms of this Privacy Policy, except as otherwise required by law or the Privacy Shield Frameworks. As you become a registered user on our website from time to time, you will be asked to consent again to the use of your information based on your request. It should be noted for purposes of GDPR regulations, we will be required to have you consent to this use each and every time a request is made in a manner consistent with the GDPR standard. In order to learn more about GDPR, please visit https://en.wikipedia.org/wiki/General_Data_Protection_Regulation . Such action could be email double opt in verification, SMS verification for two-factor authentication, and or a clickwrap or checkboxes to consent to the use.

X. Questions

At any time, if you believe that Comserve Online has willingly violated the above Privacy Policy, please let us know by sending an email to info@comserveonline.com. Comserve Online values your trust and will take appropriate measures to ensure that the website and services we provide to you are secure.

Any questions that you may have regarding this Privacy Policy should be directed to info@comserveonline.com.