Privacy Policy
A. INTRODUCTION
This Website is operated by Comversum d.o.o., a company organized under the laws of the Bosnia and Herzegovina and laws of European Union, and is committed to keeping your information secure and managing it in accordance with our legal responsibilities under the applicable privacy and data protection laws.
This Privacy Policy provides information about how we process personal information through the websites https://www.comversum.com, https://cloud.comversum.com, (“Website”) and our Products and Services.
Upon reading this Privacy Policy, you will be informed regarding the following:
1. What personally identifiable information of yours or third party personally identifiable information is collected from you through the Website as well as through the Products and Services;
2. The organization collecting the information;
3. How the information is and will be used;
4. With whom the information may be shared;
5. What choices are available to you regarding collection, use, and distribution of the information;
6. The kind of security procedures that are in place to protect the loss, misuse, or alteration of information under Comversum control; and
7. How you can access and correct any inaccuracies in the information collected about you.
COMVERSUM PRIVACY POLICY IS INCORPORATED AND MADE A PART OF COMVERSUM TERMS OF SERVICE (HTTPS://WWW.COMVERSUM.COM/TERMS-AND-CONDITIONS/). PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE CONTINUING TO USE OUR WEBSITE OR SERVICES. BY CONTINUING TO USE COMVERSUM’S WEBSITE AND SERVICES YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.
You do not have to provide your personal information to us, but if you do not provide certain information it may affect the service we are able to provide to you. By continuing to use this Website, you agree to us, as data controllers collecting and using your personal information in accordance with this Privacy Policy and for the purposes of properly running the Site and offering our Products and Services to you.
Changes in the Privacy Policy
We reserve the right to update this Privacy Policy from time to time. Please review this policy periodically for changes. If you do not accept the amended Policy, please stop using this Website.
B. COLLECTED INFORMATION
Personally, identifiable information We Collect
Most of the Products and Services offered to visitors of the Website require you to register for a user account with Comversum (“User Account”). When registering for a User Account, Comversum will ask you to voluntarily supply Comversum with certain information about yourself by filling out and submitting an online form. Such information may include your name, phone number, credit card or other billing information, email address and home and business postal addresses. It is completely optional for you to register for a User Account or engage in activities requiring a User Account.
When ordering Products and Services via the Website, you may be asked to provide a credit card number, account and/or billing and shipping information enabling the consummation of the transaction. The foregoing information is collected and processed by online payment services, including but not limited to merchant accounts services, which we may utilize for payment processing, including automatic subscription renewals. In addition, as noted below, minimum information is requested if you choose to subscribe to product updates.
You never have to answer any questions, and you can decline this exchange of information at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some or all of the Products and Services. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as optional. If you do not provide the mandatory information with respect to a particular activity or purchase, you will not be able to engage in that activity or make such a purchase. Comversum will inform you of the mandatory and/or optional character of the requested and/or required information.
You may be provided an opportunity to subscribe to a periodic newsletter and product updates. This newsletter allows Comversum to inform you of new Products and Services, updates, as well as other news relevant to the company. The subscription service requires you to provide your first and last name, your email address, and other information. Optionally, you are asked to provide the name of the company you represent.
Non-Personally identifiable information we collect
When you use the Website, Comversum or trusted third parties authorized by Comversum may also collect certain technical and routing information about your computer (also known as environmental variables) to facilitate your use of the Website and its services. When you browse the Internet, your Internet browser (such as Mozilla Firefox or Microsoft Internet Explorer) automatically transmits some information to Comversum every time you access content on one of our internet domains. Examples of such information include the URL of the particular Web page you visited, the IP (Internet Protocol) address of the computer you are using, or the browser version that you are using to access the Website. All of this information may be collected by Comversum and used to help improve our offerings to you.
Comversum may collect information about the use of the Website, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually.
We use such data to facilitate and track your use of the Website and its services. Comversum also uses environmental variables to measure traffic patterns on the Website. We do not match such information with any of your personally identifiable information.
Browsing
The Website collects non-personally identifiable information from your computer when you browse the Website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with your personally identifiable information, Comversum will not know your name, your e-mail address, or any other personally identifiable information. When you request a page from our Website, our servers log the information provided in the HTTP request header, JavaScript or similar technical tools, including the IP number, the time of the request, the URL of your request and other information.
We collect this information in order to make the Website function correctly and provide you the functionality that you see on the Website. We also use this information to better understand how visitors use the Website and how we can better adjust the Website, its contents, and functionality to meet the needs of our users. We do not match such information with any of your personally identifiable information.
Files
Comversum collects and stores the files you upload, download, or access via the Products and Services offered through the Website. We understand that these files may be confidential or contain sensitive information. Accordingly, Comversum does not share or permit third parties to access such files. However, no password-protected system of data storage and retrieval can be made entirely impenetrable. Although Comversum uses a number of security technologies and procedures to make sure that the data on the Website is secure, it may be possible for an unauthorized third party to access, view, copy, modify and distribute the data and files you store on the Website or via Products and Services despite Comversum efforts.
Your User Account and Public profile
As described above, you will be given an opportunity to create a User Account containing your personal information. A User Account is required for using most Products and Services offered on the Website.
Your public profile
Once the User Account is created, you may provide additional information to your profile, access, review and update your account information online via the Website.
Providing additional information about yourself beyond what is minimally required for the account creation is entirely up to you. Any information you provide at registration or in your profile section may be used by us as described in our Terms of Use and this Privacy Policy. You can review the personal information you provide to us and make any desired changes to the information you publish at any time by logging in to your account on the Website.
If you wish to deactivate your User Account, you can do so through the User Account interface or by contacting Comversum at privacy@comversum.com. When you deactivate your User Account, all information stored and maintained as part of your account will be deleted from our servers, including the files you stored via the Website or its Products and Services.
Because laws applicable to personal information vary by country, our offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this Privacy Policy is processed and stored in the United States and possibly other jurisdictions and also in other countries where Comversum and its service providers conduct business. All Comversum employees are obligated by our privacy and security policies. Your information is only accessible to those employees who perform technical support of the service.
Information Relating to Children
We do not knowingly collect personal information from children under 16 without the consent of the child’s holder of parental responsibility. You must be 16 years old or the age of majority in your jurisdiction in order to use our Website, Products or Services. If you are under 16 years old, you may only use our website with your parent or legal guardian’s permission. Parents and Legal Guardians may request from us to review, delete or stop the collection of the personally identifiable information of their child by contacting us by letter (using the address information provided at the bottom of this page) or email to privacy@comversum.com.
Securing the Transmission and Storage of Information
Comversum is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information. In particular, we use all reasonable endeavors to ensure that appropriate security measures are in place to protect your Personal Data. We apply the security measures foreseen in the applicable regulations as well as our own technical and organizational security measures including policy, governance, procedures, responsibilities, risk assessment; network and sub-processor security.Comversum operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our users. Comversum takes steps to ensure that your information is treated securely and in accordance with this Privacy Policy.
Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of your Personal Data transmitted through the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We treat the information you provide to us, including the Files, as confidential information; it is, accordingly, subject to our company’s security procedures and corporate policies regarding protection and use of confidential information. After personally identifiable information reaches Comversum, it is stored on a server with physical and electronic security features as customary in the industry, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access from outside of Comversum.
Because laws applicable to personal information vary by country, our offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this Privacy Policy is processed and stored in the United States and possibly other jurisdictions and also in other countries where Comversum and its service providers conduct business. All Comversum employees are obligated by our privacy and security policies. Your information is only accessible to those employees who perform technical support of the service.
If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving any site or service to protect access to your information from subsequent users.
C. USE AND DISCLOSURE OF INFORMATION
How Your Personal Information Is Used
On Contract Lawful basis
If you subscribe to a service or register a product, for example, such information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. We also use your personal information for registering you for an account or for a webinar, sending a confirmation e-mail, responding to your requests and helping to process the purchase or service you have selected, communicating with you when you contact a sales consultant or authorized partner, processing, fulfilling, and following up on transactions for our products and services, support, and training, to process any request by you for information or advice, to manage your account and content that you upload, to deal with enquiries, complaints and feedback from you and our partners;
Based on our Legitimate interests
Comversum may use aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes to help improve our offerings to you, to help diagnose any problems with our server and administer the Website or to improve your browsing experience by personalizing the Website;
We reserve the right to send a one-time registration confirmation email, and infrequent service alert messages to users to inform them of specific changes that may impact their ability to use a service they have previously signed up for, regardless of email contact opt-in status.
Based on our Legitimate interests and Your consent
We use your personal information to develop and conduct our business. Some examples of how we use personal information include: improving our products and services; personalizing communications with you; conducting market research; conducting customer surveys; engaging in more targeted, customer-specific advertising; processing. Comversum collects your information in order to record and support your participation in the activities you select.
Based on your consent, your personal information also may be used to keep you informed about new products, product upgrades, patches, special offers, and other products and services of Comversum and selected third parties if you have consented to receive such communications.
When you create a User Account with Comversum and/or provide your e-mail address and other personal identification information, based on your personal preferences, we may periodically contact you via e-mail and provide information about special offers and promotions that may be of interest to you. These communications will relate to Comversum offers and/or the promotions of select, reputable third parties with whom Comversum has a strategic marketing relationship because they offer products or services that we believe would be of interest to you. We may use a third-party e-mail service provider to send e-mails to you.
This service provider is prohibited from using your e-mail address for any purpose other than to send Comversum related e-mail. If you do not wish to receive e-mails with updates and information, please unsubscribe by sending email to: unsubscribe@comversum.com. In addition, every time you receive an e-mail you will be provided the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out online by updating your User Account as described in the User Account section of this Privacy Policy (above).
Legal obligation
We may hold some of your information for complying with legal requirements and enforcing our website terms of use or otherwise protecting our legal rights. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty and purchase agreements.
Comversum is retaining these rights because in limited cases we feel that we may need to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications is rare.
Disclosure of your personal data to Third Parties
Comversum uses services of third parties, such as e-mail service providers, voice and messaging application (“VMA”), purchase, shipping and order processing merchants and marketing companies that act as independent contractors on behalf of Comversum. These parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose Comversum specifies. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of personal information to entities outside of the Comversum affiliates for their use without your approval. Notwithstanding anything to the contrary herein, you hereby acknowledge and agree that third party services described in this paragraph are subject to such party’s terms of services and privacy policies, links to which can be provided to you upon request as set forth in Section D of this Privacy Policy.
Comversum may disclose your personally identifiable information if we believe in good faith that we are required to do so in order to comply with applicable law, a subpoena, or other legal process.
Comversum may also disclose personally identifiable information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating this Privacy Policy, the terms of your agreements with the Company (such as the Terms of Service) or to protect the safety of our users and the public or under confidentiality and licensing agreements with certain third parties which assist us in developing, operating and maintaining the Website and its content.
Comversum may be required by law enforcement or judicial authorities to provide personally identifiable information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, Comversum will provide this information upon receipt of appropriate documentation. Comversum may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute. In the event that all or substantially all of Comversum stock and/or all or substantially all assets are transferred or sold to another entity, Comversum may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, your personally identifiable information will be used in a materially different manner, you will be given choice consistent with our policy regarding notification of changes.
Where we store your personal data
The Personal Data that we collect from you is transferred to and stored inside European Economic Area. We may also provide information to third party service providers who, as data processors, will only process information on our behalf and under our instructions to help run some of our internal business operations including email distribution, payment services providers or to provide advertising on the Website. These recipients, both service providers and Comversum entities will not be located in countries outside the European Economic Area, or any other country, that do not offer an equivalent level of protection of privacy as in the European Economic Area. Different privacy laws may apply in these countries and you understand and unambiguously consent to the transfer of personal information to these countries, group companies and service providers.
These transfers might be necessary for the performance of the agreement between you and Comversum. We will take all steps reasonably necessary to ensure that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country and in accordance with this Privacy Policy.
D. YOUR CHOICES, RIGHTS AND PRIVACY-RELATED INQUIRIES AND COMPLAINTS
Choices Available to You
You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information and you will be given an opportunity to “opt-in” and make your preference choices for any items that are optional, and which are not prerequisite for our rendering such services.
You can choose at any time to opt out of receiving emails from Comversum or from having your personally identifiable information shared with selected companies. If you wish to opt out, you can do so by editing your User Account preferences with respect to e-mail or the sharing of information. If you elect to “opt out” we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.
Access, rectification, cancellation and objection rights
some jurisdictions you may have the following rights concerning our processing of your personal data:
- Right to access;
- Right to rectification;
- Right to erasure;
- Right to restriction of processing;
- Right to data portability;
- Right to object (on grounds relating your particular situation) in case of processing of your personal data based on our legitimate interest (e.g. direct marketing);
- Right to withdraw your consent at any time in case of any consent-based processing of your personal data without affecting the lawfulness of processing based on consent before your withdrawal; and
- Right to lodge a complaint with a supervisory authority.
You may exercise your legal rights by contacting us via email to privacy@comversum.com. This request must include at least the following information: your complete name, notification address, copy of your ID card or passport and explanation of the right that it is exercised. We will respond to your requests within all applicable timeframes.
Comversum takes and addresses its users’ privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your personal information or you have other related inquiries or concerns, you may write or contact Comversum at email: privacy@comversum.com.
In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly.
Please note that if you provide Comversum with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), Comversum cannot guarantee that your most recent privacy preference will be honored.
You may exercise your legal rights by contacting our representative in European Union Area and Data Protection Officer via email to info@comversum.com.
Cookies and Web Beacons
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us.
In addition, cookies are used to:
- Measure usage of various pages on our Website to help us make our information; more pertinent to your needs and easy for you to access;
- identify and categorized the internet webpages from which the visitor came to the Website and observe the browsing patterns; and
- provide functionality such as online orders, Comversum services and other functionality that we believe would be of interest and value to you.
The types of cookies that we use are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted once you leave the Website. Persistent cookies remain on your computer hard drive until you delete them. We do not use cookies to gather information concerning your visits to other websites, nor ascertain any personally identifiable information about you apart from what you voluntarily provide us in your dealings with Comversum. Cookies do not, under ordinary circumstances, corrupt or damage your computer, programs, or computer files.
In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. There are no cookies in the advertisements or e-mails. A cookie is placed on your computer only if and when you click on an advertisement or open the e-mail. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1-pixel x 1 pixel) that is placed on a site. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of a web beacons allows the site to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited at a website.
Comversum uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website, and to facilitate those visitors’ interactions with the Website. Comversum may make the aggregate data obtained from web analytics (including from our third-party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.
Copyright © 2020 Comversum d.o.o. All rights reserved.
This Website and accompanying products and documentation are the copyrighted property of Comversum d.o.o. and/or its licensors and protected by copyright laws and international intellectual property treaties. Comversum and related logo, and all related product and service names, design marks and slogans are the trademarks and/or registered trademarks of Comversum d.o.o. All other product and service marks contained herein are the trademarks of their respective owners. Any use of the Comversum or third-party trademarks or logos without the prior written consent of Comversum d.o.o. or the applicable trademark owner is strictly prohibited.
