Privacy Policy

Comin

Effective date: March 9, 2018

Privacy and online safety are important to Comin. We value Your private information, therefore we try our best to ensure that Your personal information is protected and well secured. For purposes of protecting Your personal information please read and accept the Privacy Policy.

This Privacy Policy together with the Terms of Service form the entire legal Agreement (“Agreement”) between Comin Systems (“Comin”, “Company”, “we”, or “us”) You as a User (“You”, “Your”, “Customer”, or “User”). This Agreement regulates relationships arising from the use of the Comin Website https://comin.co (the “Website”) and/or Comin Services (“Service”, “Services”).

This Privacy Policy applies to the Website and the Service owned and operated by Comin and/or Comin affiliates (collectively, “Comin”). By using the Website and/or our Services User fully accepts this Privacy Policy and allows the Company to collect, use and/or disclose information in accordance with this Agreement and confirms the fact that we have an authority to perform such actions.

We inform You that Your personal information is being collected for a lawful purpose. Without having provided us with Your personal information, We won’t be able to provide You with a Service. Therefore, a collection of data is necessary and directly related to the purpose of our Service.

By using the Website and the Services You confirm that You have sufficient legal capacity and ability to act in accordance with laws of Your country to consent to this Agreement and consent to the processing of Your personal information under the terms and conditions set forth herein. In case You do not possess sufficient legal capacity, You hereby confirm that the consent to this Agreement was provided by Your parents or fiduciaries who have the full civilian capacity and are authorized by the laws of Your jurisdiction to give such consent.

The supply of Your personal data has voluntary nature. It is Your sole decision whether or not You want to provide us with Your personal information. However, if You are willing to use our Service You will have to disclose personal information as stated in this Agreement. Your personal information will be used for the purpose of us delivering our Services to You.

Comin proclaims and accepts its responsibility to protect the User’s private information. This document contains the rules upon which such information is gathered and/or used, and also reasons for disclosure of such information. These rules apply to any personal information gathered by Comin.

We reserve a right to revise and to introduce changes to the Agreement from time to time. In case of adopting any changes to this Privacy Policy We shall inform You by updating the date at the top of this Policy, therefore we suggest visiting this Policy from time to time. We strongly encourage You to familiarize Yourself with the Policy when You access the Website in order to stay informed about our information methods and ways in which You can help protect Your confidentiality.

In case You do not agree with the Agreement as a whole or with a part of it, please immediately stop using the Website and/or Services presented on it.

OVERVIEW

The information that we collect depends on how You use the Website and/or the Service. We may receive information directly including, but not limited to: when You create an account, contact us via the Website etc. Also, we may gather information automatically by, for example, using technologies like cookies and/or web beacons. We may also get information from third parties including, but not limited to, financial partners and/or identity verification services.

The collection and usage of the information from different sources are crucial to the ability to provide our Services. Collected information helps us to increase the safety of Your online payments, and minimize the risk of fraud, money laundering, and other harmful actions.

INFORMATION COLLECTION AND USE

Information collected automatically

While using Our Website and/or Our Services, certain information is being collected automatically. By entering and using the Website and the Service You give Us Your consent to process and collect the following information:

  • Browser and device information: we register the information concerning the use of the Website, including IP address, device type including the information about device’s software and hardware etc., operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using, address of another website the User came to the Website from, time of the visit, and browser type and language version;
  • Cookie and tracking technology information: we collect information gathered by cookies and/or other tracking technology information such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data;
  • Usage information: we collect the information relating to the usage of the Website, including Your actions on the Website if such actions are present;
  • Geolocation information: we collect the information about Your geolocation.
  • Transaction data: we collect the information relating to transactions such as purchases, purchase amount, date of purchase, and payment method etc.

We may also get the information from other sources and combine it with the information which we are gathering through the Website.

Information provided by You

In order to use the full functionality of Our Website and Services, You may be required to provide certain personal information, such information may be collected upon the creation of a Personal Account, (for more detailed information related to the operation of Personal Account, please familiarize Yourself with Our Terms of Service).

NOTE: You may register a Personal Account using sing-in services of social media. These services will authenticate Your identity and provide You with the option to share certain personal information with us such as Your name and email address to pre-populate our sign up form.

The personal information we may require from You includes, but is not limited to:

  • Contact details: first name, last name, email, avatar photo;
  • Personal ID.

You may request access to and correction of Your personal information, in case if You consider that information You have provided is inaccurate. For further information related to such request please contact us at info@comin.co.

Our use of personal information

We use personal information to: provide the Services; to detect and prevent fraud; to mitigate loss or other harm to Users, Customers, and Comin; and to promote, analyze and/or to improve the quality of our Services, systems, tools etc. Examples of how we may use personal data include, but are not limited to:

  • Verification and identification for compliance purposes;
  • Conducting of manual and/or automated monitoring for fraud and/or other harmful actions;
  • Payment processing;
  • Auditing purposes;
  • Development of new products;
  • Sending of marketing communications;
  • Improving and/or modifying our Services etc;
  • Providing You with the Services etc.

By accepting this Policy or by providing us with information in any other way, You give Your explicit consent to collect, process and/or transfer the information.

PERSONAL INFORMATION DISCLOSURE

Comin, in the course of its operations, may use third party partners, service providers and affiliates to provide its services, and may share the information provided by the User to such third parties. Comin shall remain responsible for the data collected and shared under the Privacy Policy, except where it can be established that Comin was not responsible for a violation.

Except in situations clearly stated within this Policy, we do not disclose, sell, lease, lend, rent or make available personal information of the User to any third parties. We may share Your personal information with trusted third parties, including, but not limited to:

  • Service providers. We may share certain information with third-party providers who may need access to such information in order to provide services on our behalf;
  • Our Users. We may share certain information with some Users (such as merchants) as it is necessary for processing the payments and/or provision of the Services;
  • Authorized Third Parties. We may share certain information with parties directly authorized by a User to receive information, such as when a User logs in and/or registers via social networks;
  • Third parties. We will share information in the event of any merger, acquisition, reorganization, the sale of assets, venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
  • Safety, Legal purposes, and Law enforcement. We use and/or disclose information as we believe necessary: under applicable law and/or payment method rules; to enforce our terms and conditions; to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and to adequately respond to requests from any authority such as courts, law enforcement agencies, regulatory agencies, and/or other public and government authorities, which may include authorities outside Your country of residence.
User’s control of information

The user may opt out of receiving electronic communications from us. In case You no longer want to receive marketing-related emails from us on a going-forward basis. You have an option to opt-out, by using the unsubscribe link attached to such emails.

User reserves a right to oppose the collection of all information mentioned herein, or otherwise to choose the way it is treated. Also, User may execute a right to be forgotten, which means that User is entitled to be deleted from all of our systems and databases. Comin, upon User’s request, shall delete all information that has been collected from User during the whole use of the Website and/or the Service. In order to execute the right to be forgotten User should contact us via email info@comin.co and indicate the description and reason of such request.

USE OF COOKIES AND OTHER TECHNOLOGIES

Cookies are small text files that are stored in a computer’s web browser memory. They help website providers with things like understanding how people use a website, remembering a User’s login details, and storing website preferences.

Comin uses cookies or similar technologies to analyze trends, administer the Website, track Users’ movements around the Website, and gather demographic information about our User base. You can control the use of cookies in Your browser settings You can allow or forbid the use and acceptance of cookies in the setting of Your browser.

SECURITY

We take reasonable measures to protect Your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

Moreover, we are actively monitoring and enforcing the information protection standards during all of our activities, namely:

  • Limitation of the rendered access to information only to those employees who need it for providing services to the User;
  • Signature of non-disclosure agreements by employees;
  • Signature by partners and external companies invited for the fulfillment of particular functions of non-disclosure agreements and agreements concerning non-usage of such information for any unauthorized purposes;
  • Storing of the personal information obtained from the User in encrypted form, at protected servers secured from unauthorized access.

Since there is no perfect secure method of protecting information during its storage, processing, and transfer into electronic form, we do not give the full warranty of its complete safety, despite all efforts made by the Company.

THIRD-PARTY SERVICES, ADVERTISING, ANALYTICS

We may allow third parties to provide contextual and other advertising and to provide analytical services related to the work of the Website and/or the Service. These individuals may use different identifiers to collect information about the usage of the program, including Your IP address, MAC address, device identifiers, software and hardware, time zone and information about usage, including, but not limited to the Information Collected Automatically. This information may be used by the Company and others, among other things, to determine the popularity of certain content, to provide contextual and other advertising, and for a better understanding of Your activities on the Website.

LINKS TO THIRD PARTY WEBSITES

The Website pages can contain links to websites, services, and functions of third parties, subsidiaries, and affiliates that may use and conform to different rules and procedures of confidentiality provision from those stated here. Comin is not responsible for the policy of confidentiality of such resources.

CONTACT US

If You have any questions, concerns or suggestions regarding Our Privacy Policy, please contact us via email info@comin.co.

Push Notification: with Your consent, we may send a Push Notification when You are on the Website or to Your email or mobile number that You specified upon completion of the request form on the Website to provide information related to the Website, service updates, promotional messages and other relevant messages.

By filling out the request form on the Website, You automatically agree to receive informational or advertising messages from the Company and/or its partners.

NOTE: There is a space designated for You to write the message to us. Please be attentive when writing the message. You bear sole responsibility for the information You disclose in the designated space. Do not write any information that You are not willing to disclose.

STORAGE OF THE INFORMATION

We will store the information for the period necessary to fulfill the purposes outlined in this Policy unless a longer storage period is needed or permitted by law. Please note, that we have variety of obligations to store the information that You provide to us, including, but not limited to, ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers etc. Note, even if You close Your Account, we will store certain information to meet our obligations. There may also be residual information that will remain within our databases and other records, which will not be removed.

Disclaimer: The original, legally binding version of this document is written in English, and it is translated into other languages for the courtesy of Our non-English-speaking Users. If there are any discrepancies between the English version and a translated version, the English version supersedes the translated version.