This Como Hub privacy policy (“Como Hub Privacy Policy“) describes how Como AI Malta Limited d/b/a. “Como” and/or its Affiliates (“Como”, “we“, “us“, or “our“) treats and uses information that it collects and receives about you via usage of Como Hub, including the personal information we collect in connection with the various, features, services and software that Como provides to the Business or you (collectively, the “Como Hub”).
BY ACCESSING AND USING COMO HUB, YOU INDICATE THAT YOU HAVE READ AND AGREE TO THE TERMS AND CONDITIONS OF THIS COMO HUB PRIVACY POLICY, AS MAY BE UPDATED BY COMO FROM TIME TO TIME.
This Como Hub Privacy Policy is incorporated to Como Hub Terms of Use which is available at: https://privacy.comosense.com/como-hub-terms-of-use.html (“Hub Terms”).
By using Como Hub, including the Business Account or Como Solution (“Our Products”), you agree to accept the terms of this Como Hub Privacy Policy. If you do not agree to the terms of this Como Hub Privacy Policy, please do not use Our Products.
Collection of Personally Identifiable Information
Como does not require Como Hub users to provide Personally Identifiable Information (“PII“) in order to use or view the Content on Como Hub or to browse the different sections of Como Hub. Como may collect PII from Como Hub users or visitors who voluntarily choose to provide PII upon creation of Business Account or choosing username and/or password.
Children’s Privacy
Personal information about children who are under 13 years of age is not knowingly or intentionally collected.
Other Information Collected
We, our service providers and partners may collect various types of non-PII when you visit Como Hub. Examples of non-PII that may be collected from visitors include: Internet protocol address, the type of browser (e.g., Firefox, Internet Explorer), type of operating system, (e.g., Microsoft Windows or Mac OS), domain name of Internet service provider (e.g., Comcast, Verizon or AT&T), type of handheld or mobile device used to view Como Hub (e.g., iPhone, Blackberry) and content accessed. We may use third parties to conduct web analytics and similar services with respect to an individual’s interaction with Como Hub.
Registration
In order to use Como Hub, you must complete a registration process. During this registration, you will be asked to provide a user name, a password, a valid email address and additional information as may be required as part of the specific service or program for which you choose to register. You may also provide us with additional information (such as company name, title etc.).
Choice/Opt–out
When registering for Como Hub, you may receive occasional email updates from Como in your capacity as Business Representative. Such updates can include a newsletter or other notifications in relation to Como Hub and/or Como Solution. If you no longer wish to receive our email updates, you may opt out of receiving them by contacting ComoSupport@comosense.com.
Use of Collected Information
The information collected may be used for the following purposes only:
- To share it with third parties, as detailed in the next section (“Sharing Collected Information“);
- To provide you with Como Hub and Como Solution functionality and services, as available to the Business subject to its Business Agreement and the Terms;
- To improve and customize the users’ experience on Como Hub, including Como Solution and develop new services, capabilities and features;
- To manage the administrative and operational aspects of Como Hub, including Como Solution;
- To enforce Como Hub TOS, this Como Hub Privacy Policy, the Business Agreement and the Terms and to prevent unlawful activities and misuse of Como Hub, including Como Solution.
- To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and,
- To take any action in any case of dispute involving the Business or you with respect to Como Hub and/or Como Solution.
Sharing and Transferring Collected Information
The information that we collect or obtain, as outlined in the preceding sections, may be shared with or transferred to others, as the case may be, in any of the following instances: (a) if you have breached the Terms of Use, abused your rights to use the Como Hub, including the ComoSense and/or Como DIY or violated any applicable law, your information may be shared with competent authorities and with any third party, as may be required; and/or (ii) if we reasonably believe that we are required by law to share or disclose your information; (iii) in any case of dispute or legal proceeding of any kind involving the Business or you with respect to Como Hub, including the Como Solution; and (iv) personally identifiable information may be shared with our corporate group Affiliates, but their use of such information must comply with this Como Hub Privacy Policy.
Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or other reorganization in our ongoing business, the information that we collect or obtain, as outlined in the preceding sections, may be shared with or transferred to that respective entity, provided that it undertakes to be bound by the provisions of this Como Hub Privacy Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, such entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and Como will be released from any liability to you, regarding said entity’s use and processing of the information.
In any case other than the above mentioned in this Como Hub Privacy Policy, your personally identifiable information will be shared with others only if you provide your consent.
Aggregated or Anonymized Information
Como collects within the operation of Como Hub, including Como Solution anonymized as well as aggregated information, which does not identify you personally. Such anonymized or aggregated information may be used in any way, including by posting, disseminating, transmitting or otherwise communicating or making it available to any other third party.
Transfer of Data outside Your Territory
Como Hub, including Como Solution by its nature as an online service, may store and process information in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.
Use of Cookies and Server Logs
Cookies (which may be HTML files, Flash files or other technology) are text files that help store user preferences and activity. “Web beacons” (also known as image tags, gif or web bugs) are small pieces of code used to collect data, such as counting page views or promotion views. Como Hub may use “cookies”, “web beacons” and other similar information-gathering technologies (collectively, “Information Gathering Technologies“) to collect non-PII automatically as you access and browse Como Hub, including Como Solution. This Como Hub Privacy Policy covers the use of cookies by Como only and does not cover the use of cookies by any other third party.
Como uses both session ID cookies and persistent cookies. Como uses session cookies to make it easier for you to navigate Como Hub, including Como Solution. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You may remove persistent cookies by following directions provided in your Internet browser’s “help” file. We set a persistent cookie for such uses as to store your app name and/or user name so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the users’ experience on Como Hub including Como Solution. If you reject cookies, you may still use Como Hub including Como Solution, but your ability to use some areas of Como Hub including Como Solution may be limited.
By visiting Como Hub, including Como Solution, you acknowledge, understand and hereby agree that you are giving us your consent to gather information about your use of Como Hub, including Como Solution, through these Information Gathering Technologies.
Server logs capture certain non–PII, such as the time and date of a web and/or mobile visit, the browser and operating system being used, the IP address or domain name of the user’s ISP, and the web URL a user linked from. This information is generally but not exclusively used to help plan system enhancements when necessary and to provide content that is compatible with our visitors’ web browsing systems.
Access to Your Personally Identifiable Information
You may send us a request to access the Personally Identifiable Information that we may collect through your use of Como Hub, including Como Solution. We may require that you provide us with additional information to verify your identity.
Data Retention
We may delete your Personally Identifiable Information from our systems or anonymize it if we deem it no longer necessary for our reasonable business needs.
Security
The security of your personal information is important to us, and we implement security measures regarding your Personally Identifiable Information, to the extent collected, to reduce the risks of damage, loss of information, and unauthorized access or use of information, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is absolutely secure. Therefore, while we strive to use means to protect and secure your Personally Identifiable Information, we cannot guarantee and you cannot reasonably expect that Como Hub, including Como Solution, and its databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse. If you have any questions about security on Como Hub, including Como Solution, you can contact us at privacy@comosense.com.
Changes to this Como Hub Privacy Policy
This Como Hub Privacy Policy may be changed from time to time. Substantial changes will take effect thirty (30) days after an initial notification is posted on Como Hub or in the following link: https://privacy.comosense.com/como-hub-privacy-policy.html. Other changes will take effect immediately after their initial posting. However, if this Como Hub Privacy Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Como Hub Privacy Policy is accessible on Como Hub and/or in the following link: https://privacy.comosense.com/como-hub-privacy-policy.html.
You agree to be bound by any of the changes made to this Como Hub Privacy Policy. Your continued use of Como Hub, including Como Solution after the changes take effect will indicate your acceptance of the amended Como Hub Privacy Policy. If you do not agree with the amended Como Hub Privacy Policy, you must avoid any further use of Como Hub, including Como Solution.
Governing Law, Jurisdiction
This Como Hub Privacy Policy will be governed by and construed in accordance with the laws of United Kingdom, excluding any otherwise applicable rules of conflict of laws, which would result in the application of the laws of a jurisdiction other than United Kingdom.
The Courts located in London shall have sole and exclusive jurisdiction over you and Como and the subject matter of this Como Hub Privacy Policy. Each party hereby expressly consents to personal jurisdiction in United Kingdom and expressly waives any right to object to such personal jurisdiction or the convenience of such forum.
Please note that no entity worldwide, whether it is a representative, distributor, contractor, reseller or Affiliate of Como AI Malta Limited is authorized to accept service of process on behalf of Como AI Malta Limited.
Miscellaneous
If any provision of this Como Hub Privacy Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Como Hub Privacy Policy, which shall remain in full force and effect. No waiver of any term of this Como Hub Privacy Policy shall be deemed a further or continuing waiver of such term or any other term, and a party’s failure to assert any right or provision under this Como Hub Privacy Policy shall not constitute a waiver of such right or provision. The section headings in this Como Hub Privacy Policy are included for convenience only and shall take no part in the interpretation or construing of this Como Hub Privacy Policy. In this Como Hub Privacy Policy, the word “including” is used illustratively, as if followed by the words “but not limited to”.
Contact Us
If you have any questions or concerns about this Como Hub Privacy Policy, please contact us by email at privacy@comosense.com or write to us (English only) at:
Como AI Malta Limited, d/b/a “Como”
Suite 10, 189 Marina Suites
Marina Street, Pieta PTA 9041, Malta
Attn: Legal Department, Como Hub Privacy Policy Issues
Last update: 05.07.2020