Our Data Privacy Policy

Your privacy is important to us. This Privacy Statement describes the personal data that COMING – Computer Engineering (CCE) collects, how we use it, and when we share it, as we interact with you, deliver our products and services, and conduct our business operations.

Some of the data that we either collect individually, or aggregated, may be considered as personal. We treat this data in a special way, as required by law.

The term ‘personal data’ refers to such information, which, directly or indirectly, may refer to you as an individual. Examples of such data are name, image, personal ID number, contact details or IP address. Personal data processing refers to any action that we or a third party that we have engaged take with the personal data, such as collection, registration and storage.

We will always honour your decisions for how your data is used. We have safeguards in place to protect your data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Please take some time to read this Privacy Policy, and make sure you are happy with our use and disclosure of your information.

Please note that this Privacy Policy only applies to the Website and the Services of CCE. When you are using them, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. CCE is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your CCE account or sharing any personal data.

Personal Data We Collect

CCE collects data to operate effectively and provide you the best experiences with our products and services. You provide some of this personal data directly, such as when you create an account or contact us for support. We get some of it by recording how you interact with our products by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device.

Some personal data we collect only when you provide it to us. This information may include your name, address, E-mail address, telephone number, and if you pay by credit card, your payment information. This may happen when you:

• Create a user account or place an order;
• Request product support or other services;
• Request information about products;

Some personal data we collect automatically when you use our website or products. This information may include some or all of the following types of information:

• Your Internet Protocol (“IP”) address;
• User and account names and related data;
• Phone number; and
• Searched values;

Unless we need the data to retain its personally identifiable characteristics, we anonymize the data we collect and store it in a manner that does not identify you. For instance, when we collect your IP address, we anonymize your IP address by obfuscating the last group of digits (e.g., changing 192.168.1.1 to 192.168.1.XXX).
Any Personal Data that we collect from you will be stored at a secure cloud data centre hosted by Microsoft and located within the European Economic Area.

CCE will only collect your personal information (such as your name and contact details, including a valid email address) if you provide it voluntarily. If you do not want this information to be collected by us, please do not submit it. We will never pass any of these details on to any other party unless legally compelled to do so, and we will not retain your personal information longer than is necessary for the purpose for which it is collected.

You have choices about the data we collect. When we ask you to provide personal data, you may decline. However, if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.

The data we collect depends on the context of your interactions with CCE, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include the following:

• Name and contact data. We collect your first and last name, E-mail address, postal address, phone number and other similar contact data.
• Credentials: We collect passwords used for authentication and account access.

We also collect information you provide to us, and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for technical support.

How We Use Personal data

At CCE, we process personal data that you have given us for the sole purpose of administering inquiries and agreements from/with you, as well as providing information and services in connection with such inquiries and agreements.

If we were to process your personal data for any purpose, which according to applicable legislation requires your consent, we will obtain your consent before commencing with such processing. The data we collect in accordance with the above is deleted when the purposes of the processing have been completed.

CCE uses and stores personal data and information, which are collected, for five basic purposes, described in more detail below:

1. To operate, maintain, enhance and provide all features of the services.
2. To provide technical support to users of the services.
3. For processing your inquiries.
4. For sharing necessary contact details with our partner TecAlliance, subject to your consent, since the most of our services depend on their data.
5. To enhance website effectiveness, marketing activities and offers.

We will, from time to time, send you promotional offers and information regarding our products and services of our carefully selected partners, in order to better provide you with a range of products and services and improved customer service. You have a choice whether you wish to receive information from us. If you want to receive direct marketing communications from us about the

Services and any of our exciting products and services, then you can select your choices by ticking the relevant box situated on the form on which we collect your information. You may opt out of this at any point, because we enable you to “opt out” of certain uses of your information or elect not to receive future communications or services.

We will not contact you for marketing purposes by E-mail or text message unless you have given your prior consent. You can change your decision at any time by sending us an email to info@comingce.com

From time-to-time, we may request information from you via surveys or contests. Participation in these surveys or contests is voluntary, and, therefore, you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code, or age).

We can use collected personal data for other purposes, provided we disclose this to you at the relevant time, and if you agree to the proposed use of your personal data.

Reasons We Share Personal Data

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

We may share some of your personal data, such as your E-mail address, with certain distributors and other partners to enable them to contact you on our behalf about products, services or offers we believe are important to you or your business, to fulfil any terms under your licensing and service relationship with CCE, or to provide you with local technical and customer support.

We may share certain personal and non-personal data:

• When necessary to deliver data to certain third parties, such as TecAlliance GmbH, to provide us with specialized services related to our products and services.
• When authorized by law or necessary to comply with a valid legal process;
• When required to protect and defend the rights or property of CCE, including the security of our products and services;
• When necessary to protect the personal safety, property or other rights of the public, CCE or its customers or employees;
• In connection with a sale of all or part of our business.

We may appoint external partners to perform tasks on our behalf, such as providing IT services. The performance of these services may mean that our partners, within the EU/EEA, are able to gain access to your personal data. These external partners will have access to certain information about you, but only when this is necessary, in order to those third parties provide their services to us.

When we transfer personal data to these third parties, we ask and require from them to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us.

CCE will also disclose your personal data to third parties, for example to the police or other public authorities, if it concerns criminal investigations or if we are otherwise required to disclose such data by law or public authority decision. CCE will not disclose your personal data to any extent other than described in this section.

How to Access & Control Your Personal Data

You have the right to request access to the personal data that we hold about you and you may always direct us not to perform any of the procedures of collecting, storing or sharing the information about you as described in this Privacy Policy. If you request that we no longer process your data, we will no longer be able to provide the services to you.

What are your rights regarding the information collected and processed?

With regard to your information, that are collected and/or processed by CCE, you may exercise the following rights:

Right of access: You may request CCE to confirm if information about you is processed. If such is the case, you will receive access to your information.

Right of rectification: If our information about you is incorrect, you may request CCE to rectify your information. This includes the right to have incomplete information completed, taking into account the purpose of the processing.

Right to erasure: You may request CCE to erase your information, for instance if the information is unlawfully processed, or if you have withdrawn your consent.

Right to restrict processing: You may request CCE to restrict the processing of your information, if (i) the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention period for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending.

Right to data portability: You may request CCE to provide you with an electronic file of your information.

Deleting Your Data – If your data are no longer required for the aforementioned purposes, we will delete them. If you delete your account, we will also delete all data completely from your account. Data you have entered, belonging to third parties will remain in existence, as these are part of third party accounts. If data has to be retained for statutory reasons, these will be blocked and will then no longer be available for any further use.

Data Retention – CCE will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you may delete your account.

We will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up.

If you would like to request a copy of your personal data, or to amend, delete or update certain personal data or withdraw your consent to the processing of data from us, you can contact us at info@comingce.com with your request.

Cookies and similar technologies

Cookies are small data files, which are placed on your computer, mobile device or any other device as you browse our website or use any of our applications or web-based software. They reside in your Internet browser to help remember your preferences and previous activity.

We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

When you visit our website, the following categories of cookies may be set in your browser:

• Technical cookies: These cookies are necessary for proper functionality in certain areas of our site, such as enabling the e – commerce part of our site, offering you product and pricing combinations relevant for your region, allowing us to balance the load on our servers, recording user preference for cookies usage, etc. Cookies in this category comprise both session as well as persistent cookies. Our sites may not work well or at all without these cookies. Therefore, our site, and not third – party domains, always set these cookies. In this category, our site use:
  ASP.NET_SessionId – This cookie is used to identify the users session on the server. It is used when you open the browser and then go to a website that implements ASP.NET session state. This cookie is deleted when you close your browser.
  ARRAffinity – This Cookie is set by websites that run on the Windows Azure Cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session, and this cookie is strictly necessary
• Analytics cookies: These cookies are used to collect information about how you use our site and what keywords you used to arrive at our site, which websites you have visited, as well as the way you reached our site. We use this information to compile reports, to help us improve our site, and generally to tailor product and service offerings for you. In this category, our site use:
  The _utma Cookie – This cookie collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they have visited.
• Third – party integration cookies: These cookies are used to integrate third – party functionality in our site, such as YouTube videos, feedback forms or social media icons that allow you to share our content. Cookies in this category may be set by third – parties and include, without limitation, cookies set by the following domains: YouTube.com, Twitter.com, Linkedin.com and facebook.com.
• Enabling/disabling cookies via your browser – There are various ways to manage cookies and other tracking technologies. By changing your browser settings, you can accept or refuse cookies or decide to receive a notification message before accepting a cookie from the websites you visit. We would like to remind you that by completely disabling cookies in your browser you might no longer be able to use all of our interactive functions. If you use several computers with different settings, ensure that every browser is set up in such a way as to meet your preferences.
  You can delete all the cookies installed in the cookie folder on your browser. Every browser has different procedures for managing settings.

You will find information on disabling cookies on your browser in this section. We would like to remind you that some parts of the website might not function correctly if you disable cookies. Click on one of the links below to get specific instructions for most common browsers:

• Internet Explorer
• Google Chrome
• Mozilla Firefox
• Safari
• Opera

If you do not find your browser listed below, please consult the instructions given on your browser concerning cookie management.

Users are informed that if they do not authorize technical cookies, it may no longer be possible to use the website, to view its contents and to use the relative services. Disabling cookies may result in certain services or functions of the website not being available or not working properly, and users may be forced to change or manually re-enter certain information or preferences each time the site is visited.

Security

We are mindful of the importance of upholding the security of information under our control. All data collected through our site that is stored electronically, is stored on secure servers, and we have stringent security and confidentiality procedures covering the storage and disclosure of such information, in accordance with the Data Protection Act 1998. We endeavor to take all reasonable steps to protect the privacy of your personal information.

CCE is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it with the use of encryption.

We treat your personal data as required by law. We require that our partners successfully pass security assessments and prove their compliance with applicable laws and industry standards.
Only a limited number of CCE employees have access to the data we collect. We review and update our working procedures regularly to improve your privacy and ensure that our internal policies are followed. We immediately correct any non-conformance regarding these policies.

Our commitment to your privacy does not extend to third-party products and services you may access from CCE products and services. We encourage you to read the privacy statements of the third-party products and services you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.

If you do not agree to any of the provisions of this Privacy Policy, you should not use the Website, the Apps or any of the Services.

If you have any questions or concerns, you can contact us by sending email to info@comingce.com.