Privacy Policy

Last Updated: 09. January 2026

Effective Date: 09. January 2026

This Privacy Policy explains how Comentec LLC (“we,” “us,” or “our”) collects, uses, and protects personal information when you interact with our website at https://www.comentec.com, our products, or any related services (collectively, the “Services”). We are committed to safeguarding your information and handling it responsibly in accordance with applicable data protection laws.

Our business is located at 5815 Windward Pkwy
Alpharetta, GA 30005
USA.

If you have questions about this Privacy Policy or the way we process personal information, you can contact us at privacy@comentec.com or via post to the address indicated below.

Our Role in Data Processing

Depending on the context, we act as both a data controller and a data processor.

As a data controller, we determine how and why personal information is processed when we operate our website, manage user accounts, provide customer support, or carry out other core activities related to offering our Services.

As a data processor, we may process personal information on behalf of other organizations and according to their instructions when our Services are used to store, manage, or handle data that belongs to those organizations.

1. Information We Collect

We collect personal information that you provide directly, information generated automatically when you use our Services, and information obtained from third-party tools that support our operations. The specific personal information we collect depends on how you interact with our Services, the features you use, and the choices you make.

Personal information we receive directly from you or collect automatically includes:

Identifiers

• Name
• Email address

Technical and Device Data

• IP address
• Browser type and operating system

Usage Data

• Pages visited
• Actions taken

Analytics and Tracking Data

• Cookie data

Communication Data

• Messages or information provided through forms or support

Preferences and Localization Data

• City-level location (if available)

Some features of our Services require specific personal information to function.

All personal information you provide must be accurate, complete, and up to date. You are responsible for notifying us if any of your information changes so we can maintain accurate records.

2. How We Collect Information

We collect personal information through a combination of information you provide directly, information gathered automatically when you use our Services, and information supplied by third-party providers that support our operations.

Information You Provide Directly

We collect personal information that you choose to provide when you interact with our Services. This includes information submitted when you:

• create an account or update profile details
• complete forms, make purchases, or engage with customer support
• respond to surveys, request information, or communicate with us

This information typically includes identifiers (such as name, email, phone number), account details, and any other information you voluntarily provide as part of your use of the Services.

Information Collected Automatically

When you visit our website or use the Services, we automatically collect certain technical and usage information. This data does not usually reveal your identity but may include:

• IP address and device identifiers
• browser type, operating system, and device characteristics
• language settings and time zone
• pages viewed, links clicked, and navigation patterns
• error logs, performance data, and diagnostic information
• cookie data, analytics events, and usage logs

This information helps us operate, secure, and optimize the Services, and supports internal analytics, reporting, and service improvement.

Information From Your Interactions With the Services

We collect information related to your actions within the Services, including:

• features you use
• content you view
• settings or preferences you configure
• interactions with user interfaces or in-app tools

This data helps us personalize the experience and understand how users engage with our platform.

Information From Third-Party Service Providers

We may receive information from service providers that support our operations. This can include:

• analytics platforms that provide aggregated usage insights
• email and communication systems that log delivery or engagement details
• hosting and infrastructure providers that supply technical metadata
• customer support tools that record interactions or issue details

3. How We Use Your Information

We only process personal information when we have a valid legal basis under applicable data protection laws. This means we process data when it is necessary to provide our Services, fulfill our contractual obligations, comply with legal requirements, protect important interests, or pursue legitimate business purposes that do not override your rights.

Legal Bases We Rely On

We may rely on the following legal bases to process personal information:

• Contract - when processing is necessary to provide the Services or take steps at your request.
• Consent - when you voluntarily provide information for a specific purpose; you may withdraw consent at any time.
• Legitimate interests - when processing is necessary for our business operations and does not override your rights.
• Legal obligation - when we must process data to comply with applicable laws.
• Vital interests - when necessary to protect the safety or vital interests of an individual.

Purposes for Which We Process Personal Information

• We use personal information to provide customer support, answer inquiries, and resolve issues.
• Legal basis: to perform our contract with you
• We may send newsletters, updates, or promotional content. Users can opt out at any time.
• Legal basis: with your consent
• We analyze usage data to understand how our Services are used and to improve functionality, performance, and user experience.
• Legal basis: with your consent
• We may process personal information to detect, prevent, or investigate fraud, abuse, or security incidents.
• Legal basis: based on our legitimate interests (e.g., We process limited technical data (such as IP addresses) to protect our website from spam, bots, and unauthorized access. This processing is strictly necessary for our legitimate interest in maintaining a secure site and preventing fraudulent form submissions.)
• Our legitimate interests include we process limited technical data (such as ip addresses) to protect our website from spam, bots, and unauthorized access. this processing is strictly necessary for our legitimate interest in maintaining a secure site and preventing fraudulent form submissions..
• We may process personal information as required by applicable laws, regulations, or legal processes.
• Legal basis: to comply with legal obligations

4. How We Process Your Information

We process personal information in ways that are appropriate to the nature of the data and the purposes for which it is collected. This includes storing, organizing, using, transmitting, and deleting information when it is no longer required. We apply principles of data minimization, purpose limitation, and accuracy to ensure that personal information is processed only when necessary and for clearly defined purposes.

Access to personal information is limited to authorized personnel who require it to perform their job duties and who are bound by confidentiality obligations. We implement technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or misuse. These measures may include access controls, authentication procedures, logging, encryption in transit and at rest (where appropriate), monitoring, and routine security assessments.

We may combine information collected from different sources when this is necessary to operate the Services or when required to meet a lawful purpose, such as preventing fraud or maintaining the security of our platform.

We retain personal information only for as long as needed for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. For more details, see the “How Long We Retain Information” section.

Where required by applicable laws, we provide users with the ability to access, update, delete, restrict, or withdraw consent to the processing of their personal information. Additional rights may apply depending on your location; see the “Your Rights” section for more information.

5. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling in a way that produces legal or similarly significant effects. If this changes in the future, we will update this Policy and provide any required notices or options.

6. Cookies & Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons, tags, and pixels) to operate our website, understand how it is used, improve performance, and enhance your experience. These technologies help us maintain platform security, remember your preferences, prevent errors, and support essential site features.

We may use the following categories of cookies:

• Necessary / Essential Cookies: Required for the website to function properly and to provide services explicitly requested by the user.
• Functional / Preference Cookies: Enable a website to remember user preferences or settings.
• Analytics / Performance Cookies: Collect aggregated or behavioral data to help website owners understand usage and improve performance.

Some cookies are set directly by us (“first-party cookies”), while others may be placed by third-party providers that support our operations (“third-party cookies”), such as analytics, advertising, or customer support tools.

Where required by law, we display a cookie banner or notice to obtain consent and to give users control over cookie settings.

Necessary/Essential cookies are always active, while Analytics/Performance, Advertising/Marketing, and Functional/Preference cookies are used only with consent where required by law. You can manage your preferences at any time through the Cookie Banner or settings page.

7. How We Share Your Information

We may share personal information with trusted third-party service providers that help us operate our Services, perform functions on our behalf, or support our business operations. These third parties may access personal information only as necessary to perform their tasks, must protect it through appropriate contractual safeguards, and are not permitted to use it for their own purposes. They must also retain the data only for the period we instruct.

We may share personal information with the following categories of third parties:

• Hosting and infrastructure providers: Support the operation, storage, and hosting of our website or Services.
• Analytics providers: Help us understand how our Services are used and improve performance.
• Email or messaging platforms: Send notifications, updates, and transactional communications.
• Customer support tools: Assist with user inquiries and service requests.
• CRM or sales platforms: Manage customer relationships and communication.
• Security and fraud prevention tools: Detect, prevent, and investigate unauthorized or harmful activities.

We may also share information in the following situations:

• Business transfers: We may disclose or transfer information in connection with (or during negotiations of) any merger, sale of assets, financing, or acquisition of all or part of our business.
• Affiliates: We may share information with our affiliates, in which case they must honor this Privacy Policy. Affiliates include subsidiaries, parent companies, or other entities under common ownership or control.
• Business partners: We may share information with partners to offer joint products, services, or promotions when applicable.

We only share personal information when necessary to provide our Services, comply with legal obligations, or protect our rights and the rights of others.

8. International Transfers

We may transfer personal information to countries outside the European Union (EU), the European Economic Area (EEA), or the United Kingdom. These countries may have different data protection laws than those in your region.

When we transfer personal information internationally, we take appropriate steps to ensure it remains protected. Depending on the circumstances, we may rely on one or more of the following safeguards, and may also perform Transfer Impact Assessments to evaluate the laws of the destination country:

• Standard Contractual Clauses (SCCs): Approved contractual terms designed to ensure your information receives adequate protection.
• Adequacy decisions: When the destination country has been officially recognized as providing an adequate level of data protection.

Personal information may be transferred to: United States.

Our servers and some of our service providers may be located in multiple countries, including the United States, Canada, and Australia. The specific countries where your information may be processed depend on the service providers we use to operate our Services.

If applicable, certain third-party providers may participate in internationally recognized data transfer frameworks designed to ensure adequate protection of personal information. When such frameworks apply, transfers are handled in accordance with those requirements.

You may request additional information about the safeguards we use for international transfers by contacting us using the details provided in the “How To Contact Us” section. We only transfer personal information when permitted by applicable data protection laws and when appropriate safeguards are in place.

9. How Long We Retain Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. We do not keep personal information longer than needed, and retention periods may vary depending on the type of data and the reason it was collected.

When we no longer have a legitimate business need to process personal information, we will delete or anonymize it. If deletion is not immediately possible (for example, due to technical constraints or backup systems), we will securely store the information and isolate it from further processing until deletion is feasible.

We retain personal information for the following periods:

• Usage logs and activity data: 1 year.
• Cookies and tracking data: 1 year.
• Security logs: 1 year.
• Legal and regulatory records: 10 years.
• Customer support records: 3 years after resolution.
• Marketing communications: 1 year after user unsubscribes.

With regard to cookies and tracking data, we retain personal information according to the durations listed in the Cookie Policy. If no specific retention period applies, we delete or anonymize personal information once it is no longer necessary for the purpose collected.

10. How We Keep Your Information Safe

We implement appropriate technical and organizational measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures are designed to provide a level of security appropriate to the risks associated with processing personal information.

Our safeguards may include:

• Encryption of data in transit and at rest
• Access controls to limit who can view or handle information
• Monitoring and logging of system activity to detect potential issues
• Regular security assessments and updates to our systems
• Secure data storage and transmission practices
• Employee training on data protection and security

While we take reasonable steps to safeguard personal information, no system or method of transmission over the internet is completely secure. Because of this, we cannot guarantee absolute security.

If we identify a data breach that affects your personal information, we will notify you and any applicable supervisory authorities when required by law.

11. Your Rights

Individuals have certain rights regarding their personal information. These rights vary depending on where they live, but we aim to provide clear and accessible options for all users.

Rights for Users in the European Union (EU/EEA)

If you are located in the EU/EEA, you have the following rights under the GDPR:

• Right of access: Request a copy of the personal information we hold about you.
• Right to correction: Request that we correct inaccurate or incomplete information.
• Right to deletion: Request deletion of your personal information in certain circumstances.
• Right to restrict processing: Request that we limit how your data is used.
• Right to object: Object to processing based on legitimate interests or direct marketing.
• Right to data portability: Request your information in a structured, commonly used format.
• Right to withdraw consent: Withdraw consent at any time when processing is based on consent.

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with a data protection authority. You can usually contact the authority in your country of residence, place of work, or where you believe a violation has occurred.

Rights for Users in the United Kingdom

If you are located in the United Kingdom, you have the following rights under the UK GDPR:

• Access
• Correction
• Deletion
• Restriction of processing
• Objection
• Data portability
• Withdraw consent

If you believe we are processing your personal information unlawfully, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Rights for Users in Switzerland

If you are located in Switzerland, you have the following rights under the Swiss Federal Act on Data Protection. This section supersedes any other possibly divergent or conflicting information contained in this Privacy Policy. Further details regarding the categories of data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about personal data can be found in the relevant sections within this document.

You may exercise certain rights regarding your personal information within the limits of the Swiss Federal Act on Data Protection, including the following:

• right of access to personal data;
• right to object to the processing of your personal data (which also allows you to demand that processing of personal data be restricted, personal data be deleted or destroyed, specific disclosures of personal data to third parties be prohibited);
• right to receive your personal data and have it transferred to another controller (data portability);
• right to ask for incorrect personal data to be corrected.

How to exercise these rights

Any requests to exercise user rights can be directed to us through the contact details provided in this document. Such requests are free of charge and will be answered by us as early as possible, providing you with the information required by law.

Rights for Users in the United States

Your privacy rights under US state laws

You may exercise certain rights regarding your personal information. In particular, to the extent permitted by applicable law, you have:

• the right to access personal information: the right to know. You have the right to request that we confirm whether or not we are processing your personal information. You also have the right to access such personal information;
• the right to correct inaccurate personal information. You have the right to request that we correct any inaccurate personal information we maintain about you;
• the right to request the deletion of your personal information. You have the right to request that we delete any of your personal information;
• the right to obtain a copy of your personal information. We will provide your personal information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the sale of your personal information;
• the right to non-discrimination; We will not discriminate against you for exercising your privacy rights.

In addition to the rights listed above common to all users in the United States, as a user residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota or Montana, you have

• the right to opt out of the processing of your personal information for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• the right to freely give, deny or withdraw your consent for the processing of your sensitive personal information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of sensitive personal information is necessary for the provision of a product or service specifically requested by you.

In Minnesota, users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer’s personal data.

Note that in some states like Minnesota, in addition to the rights listed above common to all users in the United States, you have the following specific rights connected to profiling:

• the right to question the results of the profiling;
• the right to be informed of the reason that the profiling resulted in the decision; if feasible;
• the right to be informed of what actions you might have taken to secure a different decision and the actions that you might take to secure a different decision in the future;
• the right to review your personal data used in the profiling;
• if inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all users in the United States, as a resident of Utah or Iowa, you have the following additional rights under the Utah Consumer Privacy Act (UCPA) or the Iowa Consumer Privacy Act (ICPA):

• the right to opt out of the processing of your personal information for targeted advertising;
• the right to opt out of the processing of your sensitive personal information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of sensitive personal information is necessary for the provision of a product or service specifically requested by you.

Additional Rights for California Residents

If you are a resident of California, in addition to the rights listed above common to all users in the United States, you have the following rights under the CCPA/CPRA:

• Right to know the categories of personal information we collect and how it is used.
• Right to access specific pieces of information we hold.
• Right to deletion of your personal information, with certain exceptions.
• Right to correct inaccurate information.
• Right to opt out of the sale or sharing of personal information.
• Right to limit the use and disclosure of sensitive personal information.
• Right to non-discrimination for exercising your rights.

We do not use sensitive personal information for inferring characteristics or for purposes other than those that are reasonably necessary to provide the requested services. Sensitive personal information is not sold or shared for cross-context behavioral advertising.

In addition, California residents may exercise their rights through the following clearly-labeled links provided on this website:

• “Do Not Sell or Share My Personal Information”“Limit the Use of My Sensitive Personal Information”

These links allow users to opt out of cross-context behavioral advertising, targeted advertising, or the use of sensitive personal information.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request according to the details in the “How To Contact Us” section of this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any personal information collected from you in connection with the verification of your request solely for verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of sale or sharing and targeted advertising you can also use the cookie banner, consent management options or privacy choices link provided on this website.

If you want to submit requests to opt out of sale or sharing and targeted advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a technically frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial. Afterwards, you may at your option then contact the relevant regulatory authority to submit a complaint.

We will not charge a fee to process or respond to your request unless such request is manifestly unfounded or unduly excessive and in all other cases where it is permitted by the applicable law. In such cases, at our discretion, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices to you and explain the reasons behind them.

Rights for All Users

Regardless of where you live, we provide all users with the ability to:

• Request access to the personal information we hold.
• Request corrections or updates.
• Request deletion where appropriate.
• Withdraw consent where processing is based on consent.

You can submit a request to exercise your rights by contacting us using the details provided in the “How To Contact Us” section. Users in jurisdictions requiring consent for cookies and tracking (e.g., EU/EEA) may withdraw consent at any time via the cookie banner, privacy settings page, or by contacting us. Withdrawal does not affect the lawfulness of processing performed before withdrawal. We may need to verify your identity before processing your request.

12. Children's Privacy

Our Services are not intended for children under 16, and we do not knowingly collect personal information from individuals under this age. If we become aware that we have collected personal information from a child under 16, we will delete it as soon as reasonably possible.

If you believe that a child has provided personal information to us, please contact us using the details in the “How To Contact Us” section.

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, operational needs, or applicable laws. When we make changes, we will update the “Last Updated” date at the top of this Policy.

We use the following method(s) to notify users of significant changes to this Privacy Policy:

• Posting a notice on our website
• Sending an email notification

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information.

14. How to Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or our handling of personal information, you may contact us using the details below:

Comentec LLC
privacy@comentec.com
5815 Windward Pkwy
Alpharetta
GA 30005
USA

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