Privacy Policy
- Contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
- Biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
- Location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
- Communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
- Conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
- Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
- Engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
- ▪Provide customer support;
- Process, evaluate and respond to requests, inquiries and applications;
- Administer and register participants in our courses;
- Provide investor services;
- Conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
- Operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
- Verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
- Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use);
- Maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.
- Your consent;
- Performance of a contract with you or a relevant party;
- Our legitimate business interests; or
- Compliance with our legal obligations.
- We may share your Personal Information with our service providers, in accordance with this Privacy Notice and applicable laws, in order for them to assist us in providing certain services, such as website hosting, information technology and related infrastructure provision, cloud service, order fulfilment, customer service, email delivery, auditing and other services. We will require these service providers to protect your Personal Information that they process on our behalf with contract or other manners.
- We may share your Personal Information with third parties, for them to send you marketing communications, if you agreed to receive marketing communications from them.
- We may also share your Personal Information with our business partners where it is necessary for the purposes listed in this Privacy Notice, for example where we may sell a product or offer certain services to you together with our business partners.
- We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
- In addition, Comen may also share your Personal Information to a third party (including any agent, auditor or other service provider of a third party) in the event of any contemplated or actual reorganization, merger, sale, joint 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).
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.
To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.