COM3 Systems Privacy Policy

COM3 Systems Engineering LTDA and its global affiliates (hereinafter collectively referred to as "COM3", "We", "Us" or "Our" as required in context) deeply understand the importance of privacy to you and respect your privacy. Before submitting your personal information to COM3, please read and understand this COM3 Privacy Policy ("Policy"). The Policy applies to COM3's websites, products, and services displaying or linked to this Policy.

The Policy sets forth how COM3 collects, uses, stores, and shares your personal information and how We provide you with the access to, updating, and protection of your personal information. We will, with your written consent, collect your personal information in accordance with the Policy and use your personal information for the purposes permitted by the Policy. The Policy probably cannot cover all possible circumstances of data treatment in your use of COM3 products. If COM3 needs to collect any data uncovered by the Policy when providing you with a specific product or service, COM3 will release supplementary policy from time to time or in the notice of collection of specific data and obtain your written consent.

If you have any questions or doubts about Our privacy policy, please contact Us by sending an email to support@com3telecom.com.br.

1. What Information Do We Collect?

1.1 What does your personal information do we collect?

The information submitted by you on your own initiative. When you make a request for information, subscribe for or order a product or service, register to be a user, complete the online questionnaire, or send data to Us on your own initiative, we generally collect your name, email address, mailing address, company name, telephone number, job title, and specific information and data relating to the business you are engaged in. In each of the abovementioned circumstances, your information is submitted by you on your own initiative, so you will know what data we are collecting.

The information collected by Us automatically. As a part of standard operation of Our website, We may collect information, including but not limited to the type of your browser, your operating system, and the IP address and domain name used by you when visiting Our website, from your computer or mobile terminal. If you visit Our website using a mobile terminal, we may also collect the type of your mobile terminal. In addition, we will probably collect the information about the manner you use Our website, such as the date and time of your visit, the section of Our website and the webpage you visit, the time you spend on visiting Our website, the number of times of your return to Our website, and other clickstream data.

If you refuse to provide relevant information, you probably cannot register as Our user, visit Our website, use some of Our products, enjoy some of Our services, or realize the intended effect of relevant services.

You agree that We may automatically collect your personal information mentioned above for the purposes specified herein within the scope specified herein.

Cookie. We may use cookie, web beacon, or similar technologies to collect the abovementioned information. Cookie is a small text file stored on the hard drive of your computer or terminal when you browse a website. We may use cookies for: (1) providing you with customized contents or services on the website; (2) monitoring the use of the website; (3) identifying you when you return to Our website; and (4) carrying out research so as to improve the contents and services of Our website.

In addition, We may also allow any third party (such as network analysis tool partner, advertising company, or advertising network) to set or visit their cookie or web beacon (also known as 1x1 pixel.gifs or action label) at the website.

You may reject cookies without restriction, but you probably cannot use certain functions of Our website or fully utilize all contents and services provided by Us if you do so. You may check the Help menu on your browser to understand how to change your cookie preference.

For more information, please refer to the COM3 Cookie Policy.

1.2 Sensitive personal information

Some information is considered as sensitive personal information for its particularity, such as your email address, mailing address, telephone number, and bank account number. Sensitive personal information is protected more strictly than other personal information.

It should be noted that the contents and information (such as the photos relating to your social activities) provided, uploaded, or released by you when using Our services may disclose or leak your sensitive personal information. You should prudently consider whether to disclose your relevant sensitive personal information when you use Our services.

You agree to process your sensitive personal information for the purposes specified herein in the manner specified herein.

2. How Do We Use Your Personal Information?

We may use your personal information collected by Us for the following purposes:

Registering services for you or your COM3 equipment;

Providing you with the services or functions requested by you;

Repairing or maintaining your COM3 equipment;

Understanding the manner the users use Our products and services so as to improve Our services and develop new products and services;

Providing customized contents and making recommendations to you according to your prior use of Our services;

Releasing advertisements such as pushing customized advertisements and sponsored contents and sending to you promotion information;

Evaluating and analyzing the market, customers, products, and services (including inquiring your advice on Our products and services and carrying out customer survey);

Holding the activities of free prize draw, contest with prizes or promotions within the scope permitted by law; and

Any other use with your consent.

3. Who Would We Disclose Your Personal Information To?

If certain service will be provided by a cooperative partner authorized by COM3, COM3 will share your personal information with such partner as stated herein. For example, when you purchase a COM3 product online, COM3 must share your personal information with the logistics service provider to deliver the product to you or arrange a cooperative partner to provide service for you.

In addition, We may share your personal information between Our affiliates because We are transnational companies, but We ensure that We will obtain your prior consent before sharing your personal information and sharing of your personal information complies with the personal information protection law governing COM3 or that of the affiliate receiving the information.

COM3 may also disclose your personal information to relevant law-enforcing authority or any other government department as required by applicable laws or according to relevant legal procedures, including but not limited to disclosing your personal information to any competent law-enforcing authority, regulator, government body, court, or any third party when necessary for performing COM3's obligations under applicable laws or observing the provisions or requirements of any judicial decision or judgment or any government or regulatory authority. If COM3 or COM3's affiliate is restructured, merged, bankrupt, or in liquidation proceedings, your personal information may also be disclosed to the counterparty. In addition, COM3 may also disclose your personal data when reasonably necessary and appropriate, for example for the purpose of performing a contract, exercising, establishing, or protecting Our lawful rights, protecting the vital interests of you or others, preventing personal injury or property loss, or investigating threatening or actual illegalities.

4. Your Rights

To refuse to receive information. We may take advantage of your personal information to send marketing information to you by Our services, email, or other means. If you do not want to receive such marketing information, you may refuse to receive such marketing information or unsubscribe for relevant service by clicking relevant option or linkage in Our advertisement or email. We may send to you an announcement on services when necessary (for example, when a specific service needs to be suspended for system maintenance). You probably cannot refuse to receive the announcements that are relating to services and are not promotional information. Please note that Our affiliates and other parties receiving data have their own data privacy policies. So, you need to contact the aforementioned parties with respect to refuse to receive the requests from those parties according to privacy policies.

To have access to, modify, update, and delete information. If you want to know what kind of your personal information has been collected and kept by COM3 or to update or request Us to delete your personal information that has been submitted by you via Our website and is not accurate or complete or is outdated, you may send your request for modification or deletion by email to support@com3telecom.com.br. After receiving your request, We will use your prior personal information to authenticate your identity first and, after you pass the identity authentication, We will provide, update, modify, or delete your personal information at your request. We will take any action We deem appropriate to treat the too frequent or manifestly unreasonable requests.

To make a complaint about personal information. If you think that your personal information has been misused or disclosed without due authorization by COM3 or you make any objection to or complaint about COM3’s collection or treatment of your personal information, you may send an email to support@com3telecom.com.br and We will deal with your compliant and suggestion as early as possible.

5. How Do We Protect Your Information?

COM3 attaches importance to the security of personal information. We adopt appropriate physical measures, management methods, and technologies to protect your personal information from being accessed without due authorization, disclosed, used, modified, damaged, or lost. For example, We will use encryption technology to keep data confidential; We will adopt protection mechanism to protect data from malicious attack; We will deploy access control mechanism to ensure that only the authorized persons may access personal information; and We will hold the training courses of security and privacy protection to enhance the employees’ understanding of the importance of protecting personal information. We will try our best to protect your personal information, but it should be noted that no security measure is invulnerable.

6. Period of Data Preservation

We will preserve your personal information during the period that is necessary to achieve the purposes specified herein, unless the period of data preservation is prolonged with your consent or as required by law. The periods of data preservation for different products and services under different circumstances may be different. The standards taken by Us for determining the period of data preservation: the time needed for preserving personal information for achieving relevant business purpose including provision of products or services, maintenance of corresponding trading and business records, control and improvement of the performance and quality of relevant products or services, safeguarding relevant system, products, or services, handling of possible user inquiries or complaints, or positioning of problems; whether the user accepts longer period of data preservation; and whether there are special requirements on preservation of data specified in a contract or by law. We will preserve your registration information so long as your account is necessary for providing you with services. You may also choose to cancel your account, but We will stop providing you with products and services under such account and, if no laws otherwise require, delete your relevant personal information after such account is canceled by you.

7. International Transfers of Personal Data

COM3 will share your personal information with Our global subsidiaries and authorized partners as stated herein. Your personal information will be transferred to and processed in other countries, which have implemented their own data protection laws and regulations, different from that of Brazil (or your personal data may not be protected under some conditions). COM3 transfers your personal data to other countries complies with the personal information protection law governing COM3 or that of the party receiving the information, and We take reasonable measures to protect your personal information. Where required, COM3 implement Standard Contractual Clauses provided by the EU Commission when personal information transferred by Our affiliates located in EU, which requires Our global offices to protect and process the personal information collected from EU with EU data protection laws.

8. Third-party Social Network

Certain contents, advertisements, and functions at Our website may be provided by third parties that are not affiliated to Us.

You may choose to authorize COM3 to link to your third party social media accounts such as WhatsApp, Instagram, Facebook, Twitter, Google+, and LinkedIn. If you authorize COM3 to link to your certain social network service, We will obtain and store other information you allow Us to obtain and store when you are linked to such social network service. In addition, such social network service will obtain the information generated when you use COM3 products and/or services and you may share the aforementioned information with others by such social network service.

It should be noted that, when you use such third party social network service, you shall be bound by such third party's service terms and conditions and privacy policy (other than the Policy) and you should read those terms and conditions and policy carefully. The Policy only applies to the information collected by Us, not to the services provided by any third party or any third party’s information use rules. We will not assume any liability for use by any third party of the information provided by you.

9. Kids Privacy

The target group of Our website is adults. We will not intentionally collect any personal information about a juvenile who is younger than 14 and the juveniles who are younger than 14 shall not submit any personal information at Our website.

10. Policy Changes

We reserve the right, at Our sole discretion, to modify, revise, supplement, or delete the Policy from time to time and state in the Policy the date of the last update, and such revision is an integral part of the Policy. The updated privacy policy will be published at Our websites. You may understand the updated privacy policy by visiting Our websites. If such revision leads to substantial reduction of your rights under the Policy, We will notify you of such revision before it becomes effective by prompting you at a marked position of Our homepage, sending you an email, or otherwise. We suggest that users read the Policy anew from time to time to know relevant changes.

11. Contact Us
If you have any doubts, advice, or suggestions, please send an email to support@com3telecom.com.br to contact Us.

You have fully read and understood all contents of the Policy and hereby authorize COM3 to collect and process your personal information according to the Policy.