Last Updated: Dec 5, 2022

This privacy policy (“Privacy Policy”) governs how we, Comeet Technologies Inc (together, “Comeet” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

  1. When you browse or visit our website, https://www.comeet.com/ and its subdomains (“Website”)

  2. When you make use of, or interact with, our Website

    1. When you complete a form in our Website (e.g., request a product demo, request a quote, request to become a partner)

    2. When you contact us (e.g., via chat, website form or email)

    3. When you register to receive product/service updates and/or newsletters

    4. When we process your job application

    5. When you sign up to join one of our events

  3. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data

  4. When we use the Personal Data of our customers and their users

  5. When we use the Personal Data of our service providers, partners and suppliers

  6. When we acquire your Personal Data from third-party sources (such as lead-generation companies, LinkedIn)

  7. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents

  1. What information we collect, why we collect it, and how it is used

  2. Customer Information

  3. How we protect and retain your Personal Data

  4. How we share your Personal Data

  5. Additional information regarding transfers of Personal Data

  6. Your privacy rights

  7. Use by children

  8. Interaction with third party products

  9. Analytic tools

  10. Do not track notice

  11. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

When you browse or visit our Website

  • Personal Data we collect – As mentioned in our cookie policy here.

  • Why is the Personal Data collected and for what purposes? Marketing, analytics, and statistics, to improve our website.

  • Consequences of not providing the Personal Data – Cannot collect and store the information, cannot use or access some parts of the Website. Read more about the purposes of each cookie here.

When you make use of or interact with our Website

1. When you complete a form in our Website (e.g., request a product demo, request a quote, request to become a partner)

  • Personal Data we collect – Full name, company name, company size, company email, phone number, and any other Personal Information you decide to provide/supply us with. We ask the partners additional information (e.g., how many customers do we have in common).

  • Why is the Personal Data collected and for what purposes? – To provide you a demo. To provide you with a quote. To allow you to make use of the tools and features available on our Website. To communicate with you about the form that you submit. To communicate with you as a partner. To answer your request. To customize the services.

  • Consequences of not providing the Personal Data – Cannot provide you a demo. Cannot provide you with a quote. Cannot allow you to make use of the tools and features available on our Website. Cannot communicate with you. Cannot communicate with you as a partner. Cannot answer your request. Cannot customize the services.

  • Marketing communications – We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Data, we cannot send marketing communications.

2. When you contact us (e.g., via chat, website form or email)

  • Personal Data we collect – Full name, email address, phone number and any other Personal Information you decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – To respond to your questions and queries.

  • Consequences of not providing the Personal Data – Cannot respond to your questions and queries.

  • Marketing communications: We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Data, we cannot send marketing communications.

3. When you register to receive product/service updates and/or newsletters and/or marketing communications

  • Personal Data we collect – Full name and email address.

  • Why is the Personal Data collected and for what purposes? – To send you updates, news, promotions, communications, surveys, and marketing emails.

  • Consequences of not providing the Personal Data – Cannot send you updates, news, promotions, communications, surveys, and/or marketing emails.

4. When we process your job application

  • Personal Data we collect - Full name, email address, phone number, your CV, your LinkedIn profile URL, your personal website, your cover letter, your portfolio, answers to the candidates questionnaires (e.g., qualification for the job) and any other Personal Information you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – Process your job application and to assess you as a candidate.

  • Consequences of not providing the Personal Data – Cannot process your job application, cannot assess your suitability as a candidate.

5 When you sign up to join one of our events

  • Personal Data we collect - Full name, company name, company email, company size, phone number and any other Personal Information you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – Process your request join one of our events. To send you communications related the event (e.g., reminder or surveys).

  • Consequences of not providing the Personal Data – Cannot process your request to join one of our events and cannot send you communications related the event.

6. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data

  • Personal Data we collect – Full name, email address, company name, job title and any other Personal Data you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – To establish a business connection and send you marketing communications.

  • Consequences of not providing the Personal Data – Cannot establish a business connection, cannot send you marketing communications.

7. When we use the Personal Data of our customers and their users

  • Personal Data we collect – Full name, email address, company names, log-in details, IP address, usage of our services, payment information and any other Personal Information you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – To provide our services and to send service related communications (including to analyze your requests and questions regarding the services), to perform the agreement, to send surveys and to receive feedback about our services, to analyze the usage of the services, to monitor the functionality of the services, to customize your experience and to improve our services.

  • Consequences of not providing the Personal Data – Cannot provide our services and cannot send service related communications (including to analyze your requests and questions regarding the services), cannot perform the agreement, cannot send surveys and cannot receive feedback about our services, cannot analyze the usage of the services, cannot monitor the functionality of the services, cannot customize your experience and cannot improve our services.

  • Marketing communications: We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Data, we cannot send marketing communications. You have the right to unsubscribe from all marketing communications.

8. When we acquire your Personal Data from third-party sources (such as lead-generation companies, LinkedIn)

  • Personal Data we collect – Contact details.

  • Why is the Personal Data collected and for what purposes? – To establish a business connection. To contact possible candidates.

  • Consequences of not providing the Personal Data – Cannot establish a business connection. Cannot contact possible candidates.

9. When we use the Personal Data of our service providers, partners and suppliers

  • Personal Data we collect – Full name, email address, company name, phone number, payment information and any other Personal Information you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – To contact our service providers/partners, to execute and perform the agreement and to collaborate together on our partnership.

  • Consequences of not providing the Personal Data – Cannot contact our service providers/partners, cannot execute and perform the agreement and cannot collaborate together on our partnership.

10. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter and LinkedIn)

  • Personal Data we collect – Full name, company name, position and title, work history, possible email, other information provided by the social media networks when you interact with an advertisement (e.g., information provided by the social media channel when you click on an Ad) and any other Personal Data you chose to decide to provide/supply us with.

  • Why is the Personal Data collected and for what purposes? – To establish a business connection and to communicate with you and to send you marketing communications.

  • Consequences of not providing the Personal Data – Cannot establish a business connection and cannot communicate with you, cannot send you marketing communications.

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. CUSTOMER INFORMATION

  1. For the avoidance of doubt, Comeet is processing the Customer Information on behalf of the applicable customer. Therefore, the customer is responsible party for the security, integrity and authorized usage of Customer Information in the context of the services and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Information.

  2. Comeet has a contractual relationship with its customers. In the context of Comeet’s services, the customer can upload, add, input and/or receive to the platform (at the customer’s sole discretion) information, including Personal Data (“Customer Information”).

  3. Customer Information is not regulated by this privacy policy, and this paragraph is provided only for transparency purposes, as well as other policies that Comeet makes available, for example the notice for users of the platform, see here. If you have any questions related to the Customer Information, please contact the customer directly.

  4. For the avoidance of doubt, Comeet’s platform has installed cookies, analytic tools and other tracking technologies for the purpose of gathering analytics and statistical information as well as to understand the usage patterns of the platform for Comeet to be able to improve the platform, its services and the users’ experience.

3. HOW WE PROTECT AND RETAIN YOUR INFORMATION

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

  2. Retention of your Personal Data. Your Personal Data will be stored until we proactively delete it or you send a valid deletion request. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy.

4. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

  1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.

  2. We may use third party service providers to process your information for the purposes outlined above, including, without limitation:

    1. With cloud service providers for hosting purposes;

    2. With websites and web content creation platforms in order to help us manage our Website and our services;

    3. With email providers, marketing, CRM, automation tools other similar tool providers and/or sales dialer software;

    4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy (including, survey tools); and/or

    5. With billing companies.

  3. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

  4. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

  5. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@comeet.co.

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

  1. Internal transfers: Transfers within the Comeet group will be covered by an internal processing agreement entered into by members of the Comeet group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

  2. External transfers: Where we transfer your Personal Data, we will generally obtain contractual commitments from them to protect your Personal Data.

6. YOUR PRIVACY RIGHTS

  1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

    1. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

    2. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;

    3. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

    4. You have the right to object, to or to request restriction, of the processing;

    5. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

    6. You have the right to object to profiling;

    7. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal; and/or

    8. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.

  2. You can exercise your rights by contacting us at privacy@comeet.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@comeet.co.

8. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

9. ANALYTIC TOOLS

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

  • Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.

  • YouTube API. Our website and platform uses YouTube API to help visitors who go to YouTube to have an easier search for videos relevant for them. For further details please see the Youtube API terms of service at https://developers.google.com/youtube/terms/api-services-terms-of-service and the Google privacy policy at https://policies.google.com/privacy

  • Heap. The Website may use a tool called “Heap Analytics” which is a user behavioral analytics product and service. Heap collects and analyzes data about how users are interacting with our Website. Heap does this by collecting data on what users are doing, including but not limited to what webpages they visit, what users click on, where those users are located, what browser or platform those users are using. You can read further information on https://www.heap.io/privacy.

  • Advertising Partners. Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, online identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

  • We reserve the right to remove or add new analytic tools.

10. DO NOT TRACK NOTICE

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We may collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We allow third parties (such as such as companies that provide us with analytics tools), to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@comeet.co. Comeet’s address is 244 Fifth Avenue, Suite 2729 New York, NY 10001.

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