Effective Date: June 1, 2021

Last updated: June 18, 2021


COMSPOC Corp.

Privacy Policy



www.comspoc.com is owned and operated by COMSPOC Corp. (“COMSPOC”). To obtain our most up-to-date privacy policy notice, please visit this page often.

Your privacy is very important to us and we are committed to protecting it. This Privacy Policy describes how the Comspoc website collects, uses, and shares your personal information whether collected through our websites, by using our products or services, by attending or signing up for our events, or by other means.

We reserve the right to update this Privacy Policy at any time and such updates will be posted on this page and be effective immediately. We encourage you to review this Privacy Policy periodically to remain informed.

1. Types of Information we Collect and Why

2. How we use the Information

3. How we Share the Information

4. Security

5. Data Integrity and Access to Your Information

6. Retention Period

7.    Children Under 13

8.    Notice to EU/UK/Swiss Users

9. Other International Users

10. Notice to California Resident Users

11. Data Breaches

12. Contact Information


1.    Types of Information we Collect and Why

o    Directly from you: If you scan your badge at an event (webinar, conference, expo) or provide your business card, we may obtain your name, mailing address, email address, telephone number, job title, the name of your organization, your areas of interest. If you visit our offices, we may require you to register as a visitor and to provide your name, the name of your organization, your address, and proof of citizenship (including passport information); in addition, sometimes we may need to take a photograph of you. Scanning your badge at an event will provide COMSPOC with the same or similar information herein. If you participate in a meeting that is being recorded, your name, your image and voice might be captured. Where applicable law permits, our offices’ cameras capture images for security purposes and for crime prevention.

 

o    Through our website: our website might collect certain information automatically and store it in log files.  The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information of our website, including a history of the pages you view. We use this information to help us design our site to better suit your needs. We may also use your Internet Protocol “IP” address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

o    Analysis: We analyze the traffic on comspoc.com in the aggregate through the use of services, such as Google Analytics and Pardot cookies, which are subject to their own individual Privacy Policies; which we encourage you to review. We use this information to improve your user experience and determine the effectiveness of our website. If you do not want Google to drop a cookie (_ga) in your browser, please get the Google Analytics Opt-out Browser Add-on here: https://tools.google.com/dlpage/gaoptout. We also use a third- party digital assets management tool, Widen, which records metrics of access and downloads from our websites and is also subject to its own Privacy Policy. Local Storage: We use technologies such as local storage and cookies to store an access token on your browser which enables us to recognize you and your preferences the next time that you log in. We do this specifically to enhance your experience and improve our site, products, and services. See our Cookie Policy for additional important information. Note that we do not respond to Do Not Track signals.

Note that in addition to the information that we collect from you directly, we may receive information about you from other sources, including third parties, business partners, affiliates, or publicly available sources.

2.    How we use the Information

In addition to the uses described above, we may use your personal information, sometimes in combination with non- personal information, in the following ways:

o    To operate, maintain, monitor, and protect the security and integrity of our services. The information collected may also be used to comply with U.S. Government requirements, ensure appropriate use of licensed COMSPOC software, provide notification about software updates, and help provide technical   support.

o    When you contact us, we keep a record of your communication to help solve any issues.

o    If you have submitted personal information to us or have opted-in to receiving materials, we may use the email address that you provided to notify you with product information and services that you requested, marketing information, events, newsletters, or product release announcements that may be of interest to you. You can make changes to your subscription preferences at any time by visiting Comspoc.com or by following the steps described in the COMSPOC correspondence that you receive. You can also unsubscribe from all email lists.

o    We use certain personal information for system administration, auditing the use of centerforspace.com, and statistical marketing purposes, as well as providing our product partners with general statistical information about our users.


3.    How we Share the Information

o    Affiliates and Acquisitions: We may share your personal information with corporate affiliates (e.g., sister companies, subsidiaries, joint ventures, or other companies under common control). If COMSPOC becomes or plans to become involved in a merger, acquisition, reorganization, or any form of sale or transfer of some or all of its assets, we may share your personal information with the acquiring party, including at the negotiation stage.

 

o    Suppliers and Service Providers: We share your personal information with suppliers and Service Providers to enable such parties to perform functions on our behalf and, under our instructions, to carry out the purposes identified in this policy and those that are necessary to perform the services. This includes, but is not limited to, our IT service providers, data back-up and disaster recovery providers, our webinar service, our customer relationship management databases; our website host, our auditors, our lawyers and tax advisers, third-party consultants who provide us with support with respect to business analytics and marketing campaigns, and the providers of external venues where we host conferences and events. To the extent that Service Providers have guaranteed to us, they do not further collect, sell, or use your personal information, except as necessary to perform the service for which they were engaged. COMSPOC requires all Service Providers to continue to safeguard your personal information adequately. Service Providers might anonymize the personal information and use it in the aggregate.


o    Business Partners: If you attend an event organized or hosted by us, we may disclose your business contact details to others who attend or participate in the joint organization of that event, per your direction. You have the opportunity to opt out of such sharing at any time by sending an email to privacy@comspoc.com. In the instance that we share your business contact information with our business partners, we will enter into a contract that protects your information from being shared downstream without obtaining your   consent.


o    External websites and Social Media: Please note that centerforspace.com may contain links to independent websites, products, or services, including social media features and widgets, which are hosted by third parties and are governed by their privacy practices. If you visit these sites, it is your responsibility to protect your privacy by reviewing the other parties’ Privacy Policies.

o    Disclosures without your consent: We may share your personal information if we determine that it may be needed or requested to satisfy any applicable governmental law, regulation, investigation by public authorities, or proceeding. We may also share your personal information if we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend centerforspace.com, or protect the rights, property, and safety of COMSPOC, our customers, users, and the public.

o    Disclosures with your consent: We may share your personal information in any other way for which we obtain your consent or as directed by you.

4.    Security

While no methods of transmission over the Internet, or method of electronic storage is fully secure, and we cannot completely ensure, warrant and guarantee the security of your personal information, we take reasonable measures to protect your information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. All personal information is protected using appropriate physical, technical, and organizational measures. We also use reasonable efforts to prevent unauthorized, third-party access to personal information, of the information that you transmit, and you agree that you do so at your own risk. In the event that we are required by law to inform you of any breach of personal information, we will do so according to the laws and regulations that apply.

5.    Data Integrity and Access to Your Information

We rely on you to update and correct your personal information. Some of our websites allow you to modify your account profile. If you want to access the information that is collected about you or believe that any of the information needs updating, correcting, amending, or deleting, please sign in to your profile to edit it at any time or contact us   at privacy@Comspoc.com. You may also contact us at the aforementioned address to access the personal information that may not be accessible from your account. We will correct our records upon verification of the requested change. We may decline to process requests that are frivolous, jeopardize the privacy of others, are extremely impractical, or when allowed by law.

 

6.    Retention Period

Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy unless longer retention is required or permitted by law. We may also decide to delete your data if we believe that it is incomplete, inaccurate, or if we no longer need it. When we delete your personal information, it will be removed from our active database but it may remain in archives where it is not practical or possible to delete it. Furthermore, we may keep your information as needed to comply with our legal obligations, resolve disputes, and/or enforce any agreements.

If you elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable duration from the date that you last expressed interest in our content, products, or services. We retain information derived from cookies and other tracking technologies for a reasonable duration from the date that such information was created.

7.    Children Under 13

COMSPOC does not knowingly or intentionally collect personal information from children under the age of 13. If it comes to our attention that you are under 13, we will terminate your account and take reasonable steps to delete the persona data that you have shared with us. You may also contact us to request deletion if you believe that we have inadvertently collected information about a child under the age of 13.

8.    Notice to EU/UK/Swiss Users

This section applies to you only if you are in the European Economic Area (“EEA”) or the United Kingdom or Switzerland.

Permitted Purposes for Processing Information

We process your personal information for a variety of permitted purposes, including:

o    Contractual Reasons: Where it is necessary to perform our contract with you or to begin contract negotiation; whether for our products or services, for employment engagement or application, to become our customer, or to perform a contract we have with you.

o    Legal Obligation: Where it is necessary for compliance with legal obligations; whether it is to carry out denied party screening, due diligence, to perform a pre-hiring check, to comply with export control laws, anti- bribery laws, or corruption laws.

o    Legitimate Business Interest: Where the processing is in our legitimate interest and not overridden by your data protection interests; whether to ensure compliance with our internal policies, security and business continuity, to improve business processes, training and webinars, advertising, marketing and public relations, to organize corporate events, conferences, or to protect, manage, and improve our websites and other services.

o    Consent: Where you provide us your consent; whether it is to deal with your inquiries or requests to obtain more information about our company, to the extent required by laws consent for advertising, marketing,  and public relations purposes.

International Transfer of Information

Your personal information is processed in the United States and other countries, where we have offices, servers, and resellers, where privacy laws may be less stringent than the laws in your country and where the government courts or law enforcement may be able to access your information. By submitting your personal information to us, you agree to the transfer, storage, and processing of your information. Where possible COMSPOC takes steps to treat personal information using the similar privacy principles that apply pursuant to the law of the country in which we first received your information. With respect to transfers originating from the EEA to the US and other countries, we implemented Standard Contractual Clauses approved by the European Commission and other appropriate solutions as required

 

and permitted by Art. 13(1)(f), 46 and 49 of the GDPR. COMSPOC may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security, law enforcement, or other public interest requirements.

Your Rights

If you are in the EEA, you have the following rights with respect to your personal information, under specific circumstances:

o    Access to your personal information;

o    Rectify inaccurate or incomplete information or request it to be erased;

o    Ask us to move, copy, or transfer your personal information back to you or another;

o    Object to the processing of your personal information for marketing purposes;

o    Withdraw consent if we are processing your personal information solely on the basis of  consent;

o    Ensure that any significant decisions affecting you are not made purely by automated means based on an online profile and you have the opportunity to challenge the decision;

o    Complain to a supervisory authority about our privacy  practices.

If you wish to exercise these rights, please email us at privacy@Comspoc.com. For further details about your privacy rights under GDPR, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/my- rights_en

9.    Other International Users

COMSPOC is headquartered in the United States and Comspoc.com is hosted in the United States. If you are an international visitor, you should be aware that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States, which do not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy.

10.    Notice to California Resident Users

This section applies to you only if you are natural person residing in California, pursuant to the California Consumer Protection Act of 2018. Upon authentication of your identity, under specific circumstances, you may have the right to:

o    Request the categories and specific pieces of personal information being collected, the categories of sources for the personal information we collected about you, how the data is being used, if the information is disclosed or sold, and the categories of third parties with whom we share the personal information;

o    Request that your information not be sold per the definition of the CCPA;

o    Request deletion of personal information, subject to certain exceptions;

o    Not to be discriminated against because you exercised any of your consumer rights. Categories of Personal Information Collected

The table below indicates the categories of personal information we collect and transfer in a variety of contexts. This table includes the personal information of business customers and leads, job applicants, as well as employees. So, all categories of personal information will not directly apply to you.



 

 

Categories of Personal Information

Information collected by COMSPOC?

Audio, electronic, visual, thermal, olfactory, or similar information

 


 

Bank account number

 

Biometric information

 

Characteristics of protected classifications (e.g., age, sex, race, ethnicity, physical or mental handicap, etc.)

 

Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies)

Credit card number / Debit card number

 

Driver’s License Number / State ID

 

Education

 

Electronic network activity (e.g., browsing history)

Email address

Employment

 

Employment history

 

Geolocation data

 

Health insurance information

 

Identifiers (e.g., name or alias)

Insurance Policy Number

 

Medical information

 

Online identifier (e.g. IP address)

Other financial information

 

Passport Number

 

Postal address

 

Signature

 

Social Security Number

 

Telephone Number

Transaction information

 

 


Exercising your Rights

California Residents can submit a verifiable consumer request to us to exercise their rights either by calling our toll- free number or by emailing us at the contact information below. You can only make a request twice within a 12- month period. The verifiable consumer request must provide sufficient information that allows us to reasonably  verify your identity (or that of an authorized representative) and to properly understand, evaluate, and respond to   it. We will not provide you with personal information if you cannot verify your identity in a reasonable time period, and will close the case of your request. You are free to reopen a case if you are ready to verify your identity. Making a verifiable consumer request does not require you to create an account with us.

Response and Timing

We endeavor to respond to your request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opting out

 

You have the right to direct us to not share your personal information at any time. We may disclose your personal information to our business partners as explained above. If you previously opted in to the sharing of your personal information, you can opt-out of future sharing at any time.

To exercise the right to opt-out, submit a request to us by emailing us at info@comspoc.com. Once you make an opt-out request, we will wait at least  twelve

(12) months before asking you to reauthorize the sharing of personal information. However, you can change your mind and opt back in to personal information sharing at any time by sending us an inquiry at the same internet page. You do not need to create an account with us to exercise opt-out  rights.


For further details about your privacy rights under the CCPA, please visit: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1121

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to the contact information provided below.

11.    Data Breach

If a data breach occurs, that is likely to result in a high risk of adversely affecting your rights and freedoms, or where the unauthorized acquisition of computerized data compromises the security, confidentiality, or integrity of your personal information, we will inform you of this, as required by law, without undue delay, or within the period specified under applicable law. Where legally permitted, this notification will be made via email, post, or telephone.

12.    Contact Information

If you have any questions, comments, complaints, or would like to submit a request, please contact us at:

COMSPOC Corp. 

220 Valley Creek Blvd Exton, PA 19341

Email: info@comspoc.com (610) 220-0272


Please note that any requests will require verification of your identity, which may require disclosure of additional personal information. Furthermore, we may not be able to comply with your request in certain circumstances, especially if unfounded or excessive.