Comito Co. Privacy Policy
Effective Date: March 1, 2021

Comito exists to inspire people to have a positive impact on the world. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy.

This Privacy Policy describes how Comito Co. (“we,” “us,” or “Comito”), process personal information that we collect through the Comito Platform. It applies to information that we collect and use about you when you access or use the Comito website, or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

Information We Collect
It is possible that we will collect information about you through any of the means discussed below. In order to provide the Services to you, please note that we need certain types of information. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.

Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. For example, we collect information from you through:

Account registration and administration of your account
The Services you use or processing your orders
Requests or questions you submit to us via online forms, email, or otherwise
Your participation in sweepstakes, contests, or surveys
Any reviews that you submit about the Services
Information about you
While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:

Email address
Name, if you choose to provide it
Log-in credentials, if you create a Comito account
Billing information, such as shipping address, credit or debit card number, verification number, zip code, and expiration date
Information about purchases or other transactions with us
User-generated content you provide to us, such as when you respond to a survey request, or participate in any public forums
Experiences in which you enroll
Any other information you choose to directly provide to us in connection with your use of the Services
Information We Collect Through Automated Means
When you use our Services, we also collect certain information automatically. We, and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.

Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and/or postal code associated with an IP address, city/state) from your computer or mobile device.

Information We Collect From Social Media and Other Content Platforms
If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or Google), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, and your “likes”, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use.

Information We Collect from Others
We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant Experiences for you. We also use it to improve our products, analytics, and advertising.

How We Use Your Information
We, or our service providers, use your information for various purposes depending on the types of information we have collected from and about you, in order to:

Provide our Services–for example, to set up and maintain your account, host your profile, invoicing and accounting;
Communicate with you, for example through an email, about offers and promotions offered by Comito that we think will be of interest to you, solicit your feedback, or keep you up to date on Comito and our products;
Respond to your request for information and provide you with more effective and efficient customer service;
Further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to create and manage their profiles more efficiently;
Monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
Monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Comito and others;
Personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users;
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

Cookies and Similar Technologies
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Cookies are placed in your browser cache.

As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Online Analytics and Advertising
Analytics
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. If you receive email from us, we may use certain analytics tools to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. These third parties may also serve tailored ads to you as you use the Internet and Internet-connected applications, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties (e.g., ad networks and ad servers such as Google Analytics, and others). To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

How We Share and Disclose your Information
Comito will share your information in the following ways:

We may share information we collect to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.

We provide access to or share your information with select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.

By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Comito, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

From time to time, we may share Aggregate/Anonymous Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.

Information Shared Publicly
Information that you choose to make public is disclosed publicly.

That means that information like your public profile, posts, other content that you make public on your profile, are all available to others.

Public information may also be indexed by search engines or used by third parties.

Please keep all of this in mind when deciding what you would like to share.

How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it which are described in the sections above; and when we are not legally required to continue to keep it.

How We Protect Your Information
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Third Party Links and Features
The Services contain links to third-party websites such as social media sites. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We highly recommend that you read the privacy and security policies of these third-parties.

Children's Privacy
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Data Subject Rights and Choices
Depending on your jurisdiction of residence, you may have certain rights with respect to your information as further described in this section.

Your Legal Rights
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

Request access to your personal data;
Request correction or deletion of your personal data;
Object to our use and processing of your personal data;
Request that we limit our use and processing of your personal data; and
Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to Contact Information.

EU individuals also have the right to make a complaint to a government supervisory authority.

Marketing Communications and Sharing
You may instruct us not to use your contact information to contact you by email regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information found in the Contact Information section. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding classes in which you are enrolled.

Legal Bases for Use of Your Information
The legal bases for using your information as set out in this Privacy Policy are as follows:

Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you);
Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services);
Where we are required to process information in accordance with an EU Member State legal obligation; or
Where we have your consent, in accordance with applicable law.
International Transfer and Privacy Shield
The information discussed in this Policy is processed in the United States by Comito, whose principal office in the United States is located at 245 Shrader Street, San Francisco, CA 94117.

Comito complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union and Switzerland to the United States, respectively. Comito has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the policies 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 page, please visit https://www.privacyshield.gov/.

In compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Principles, Comito commits to resolve complaints about your privacy and our collection or use of your personal data. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Comito at admin@comito.co. Comito is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within the Comito group of companies, service providers, and business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services.

By providing us with your information, you acknowledge any such transfer, storage or use. Comito will take reasonable and appropriate steps necessary to ensure that any third party who is acting as a “data processor” under EU and Swiss terminology is processing the personal data we entrust to them in a manner that is consistent with the EU-US and Swiss-US Privacy Shield Principles.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you reside. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

Changes to our Privacy Policy
Although most changes are likely to be minor, Comito may change its Privacy Policy from time to time. Comito encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice, or send you a notification through email. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

This Privacy Policy is effective and was last updated on March 1, 2021.

Comito Co. is a registered company located at 245 Shrader Street, San Francisco, CA 94117.

Contact Information
Please feel free to contact us if you have any questions about Comito’s Privacy Policy or the information practices of the Services.

You may contact us as follows:

245 Shrader Street

San Francisco, CA 94117
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