Collection of Personally Identifiable Information
Como does not require its Website users or visitors to provide Personally Identifiable Information (“PII”) to view the Content in the Website or to browse the different sections of the Website. PII is information that identifies an individual including full name, postal or physical address, photograph, e-mail address and/or telephone number. Como may collect PII from Website users or visitors who choose to register as members within the Como online mobile proprietary platform (“Como Platform”) or otherwise subscribe to one of Como’s mobile subscription plans or other programs, features or services offered by Como (“Services”) via the Site.
You may correct or update certain PII by logging in to your account with Como and making the change on your personal information page. If you no longer desire our Services or wish to delete or deactivate your account, you can contact us at firstname.lastname@example.org.
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 the Website. 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), web pages visited, websites visited before and after visiting the Website, type of handheld or mobile device used to view the Website (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 our Website.
In order to create and maintain apps by using the Como Platform or use other services or programs offered by Como, 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 register (such as your PayPal, Amazon or Shopify user information – but not your password), all of which are used to validate your registration, maintain your account as a publisher with Como and provide you with the features and functionalities of the Como Platform and Services. You also may provide us with additional information (such as company name, title etc.) so we can provide you with a more customized experience on the Website and offer you better support.
Additional personal information may be required from you if you choose to add certain functionality, customer membership, “frequent buyer club”, rewards program or other equivalent features to your App. For example, your business’s physical address will be asked in order verify that a gift card provided under “frequent buyer club” loyalty feature is activated while your customer is in your place of business, and your phone number will be asked upon payment for this feature as a mean to get in touch with you regarding your customers use of “frequent buyer club” loyalty feature.
From time to time we may provide you the opportunity to participate in contests, surveys or special promotional or other programs on the Website or the Como Platform, as applicable. If you choose to participate, we may request certain PII from you. Participation in such contests, surveys or programs is voluntary, and you have a choice whether to provide this information. The requested information typically includes contact information (such as name and shipping address), demographic information (such as zip code), and, in the case of a special program involving a form of payment, payment details. We use this information to notify participants, to monitor Website traffic, customize the Website or send participants email updates.
When you send email or other communications to Como, we may retain these communications to process your inquiries, respond to your requests and improve our services.
When registering for our Services, you may receive occasional email updates from Como. Such updates can include a newsletter or other notifications in relation to the Website or the Como Platform. We provide you with the opportunity to ‘opt out’ of having your PII used for such purposes when we ask for this information. For example, if you no longer wish to receive our email updates, you may opt out of receiving them by following the instructions included in each update.
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 the Website’s functionality and Services;
• To improve and customize the users’ experience on the Website and develop new services;
• To manage the administrative and operational aspects of our Platform (such as publisher payments);
• 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 you with respect to the Website.
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:
• Registration and payment information, information on forms you have filled out and requests you have submitted will all be shared with our service providers, for payment collection and processing purposes;
• Contact information you have provided upon registration to the Site may be shared with our service providers for the purpose of distributing emails to our registered users and/or app publishers;
• Photos and other multimedia or content you have uploaded through the Website’s forums, blog or other public areas will be shared with all other users of such public area as well;
• To operate, maintain and enhance the Website and the Como Platform, including by using server maintenance, optimization services, management and operation services of a discussion board or other open forum or blog within the Website, provided by third party service providers;
• If we reasonably believe that we are required by law to share or disclose your information;
• In any case of dispute or legal proceeding of any kind involving you with respect to the Website; and
• Personally identifiable information may be shared with our corporate group Affiliates, but their use of such information must comply with the 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, the entity which succeeds the business, provided that it undertakes to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, the succeeding 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 the succeeding entity’s use and processing of the information.
In any case other than the above, 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 the Website 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.
Third party links
The Website may contain or present third party links to third party sites or services – all of which are not owned or controlled by us. Though we collect certain parameters related to your interactions with these third-party services (as detailed in this Policy), we are not responsible for the privacy practices of such third party sites or services and this Policy does not apply to them. Please refer to the privacy policies of those other sites and services, to determine whether their privacy practices are acceptable to you.
Transfer of Data outside Your Territory
The Website, 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 provide your express and unambiguous consent to such transfer.
Como uses both session ID cookies and persistent cookies. Como uses session cookies to make it easier for you to navigate the Website. 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 the Website. If you reject cookies, you may still use the Website, but your ability to use some areas of the Website may be limited.
By visiting the Website, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to gather information about your use of the Website through these Information Gathering Technologies.
Server logs capture certain non–PII, such as the time and date of a web 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 the Website or the Como Platform. We may require that you provide us with additional information to verify your identity.
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.
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 the Website and the Como Platform 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 the Website, you can contact us at email@example.com.
Changes to this Privacy Statement
This Policy may be changed from time to time. Substantial changes will take effect thirty (30) days after an initial notification is posted on the Website. Other changes will take effect seven (7) days after their initial posting. However, if the 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 Policy is accessible on the Website at: http://www.como.com/privacy-policy/.
You agree to be bound by any of the changes made to this Policy. Your continued use of the Website after the changes take effect will indicate your acceptance of the amended Policy. If you do not agree with the amended Policy, you must avoid any further use of the Website.
Conduit Ltd., d/b/a “Como”
2 Ilan Ramon Street
Ness-Ziona, Israel 7403635