Comm100 Privacy Policy

TRUSTe

Last Updated on August 21st, 2018

Comm100 Network Corporation (herein referred to as “We”, “Comm100” or the “Company”) is committed to protecting the privacy of your information. This Privacy Policy describes Comm100’s information practices.

This Privacy Policy tells what Comm100 will and will not do with personal data collected by Comm100 or provided to Comm100 by other entities (“Organizations”) or by individuals interacting with this website, www.Comm100.com, or Comm100’s Services (“Users”) (collectively referred to as “Services”). Please read this Policy carefully to understand our policies and practices.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

If You Do Not Agree with Our Policy

If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this Policy.

What Does Comm100 Do?

Comm100 is the leader in customer service and communication software. Comm100 focuses on developing and managing fully integrated customer support solutions to enable businesses to communicate with their customers more effectively through multiple communication channels, including live chat, ticket, email marketing, knowledge base, help desk and more.

Personal Data Collected

We collect personal data from you in several ways while we market Comm100 Services, interact with our customers, and provide Comm100 Services. You provide us with personal data when you ask to learn more about our products and services, request a demo or evaluation, sign up for newsletters, enter promotions, interact with us on our social media channels, order products or services, talk with us on the phone, have a live chat with us, send us email, request white papers, ebooks, reports or other resources, watch training videos, sign up for or attend events, trade shows or seminars. We may collect personal data from you when you register for, download, access, and submit information to the Comm100 Services or otherwise use our Services. We collect certain information automatically as you interact with our Services, and when you provide comments and suggestions, or send us feedback request and use support services. We may get information about you from Organizations or collect information about you on behalf of organizations that use our services. If you do not want us to collect this personal data directly from you, please do not provide it.

Direct collection of personal data
  • Consumer personal data: We collect and process personal data about Consumers (e.g., chat visitors) on behalf of Organizations when interacting with Comm100 Services to facilitate the communications between the agents of Organizations and Consumers.
  • User personal data: We collect personal data about users who are tasked by Organizations to interact with Comm100 and who have account login credentials to access the Comm100 Services. These users use our Services on behalf of their Organizations and communicate with Comm100 for business purposes, including without limitation billing, payment and support. Examples of User personal data include, but are not limited to, name, login user name, email, phone, password, Organization details (e.g., Organization name, address, phone number, website address and billing information), organizational role, system information, and other information used to access all or part of the Comm100 Services or to contact Comm100 about its contract for products or services or need for support and when requesting information about the status of the Comm100 Services.
  • Business personal data: This means business-contact personal data which is not Consumer or User personal data, such as name, title, job function, business name, business address, business e-mail address, and business phone number that we collect about people we serve or work with, including actual and prospective customers, alliance and channel partners, contractors, vendors and other parties interested in Comm100 or its products and services. This includes visitors to our website, individuals who fill in forms requesting us to contact them or requesting any resources, individuals who attend any events where we demonstrate our Services, including industry events such as tradeshows and seminars, and other individuals with whom we interact for business purposes, including without limitation marketing. We also purchase information about potential leads from third parties and we use publicly available personal data.
Information We Automatically Collect from You When You Use the Services

The personal data we collect automatically is statistical information and may include personal data, or we may maintain it or associate it with personal data we collect in other ways or receive from third parties. If you do not want us to collect this personal data, please do not use the Services.

  • Information collected through our cookies, web beacons and other tracking technologies. Comm100, or service providers on our behalf, may use technologies, including “cookies,” “web beacons” and other tracking technologies to automatically collect personal data from you when you use the Services. We collect this personal data to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits. We use these cookies and tracking technologies to analyze trends, administer the Comm100 website and Service, track users’ movements around website and Service, track the Web Site Navigational Information, to gather demographic information about our user base as a whole, to remember users’ settings and for authentication purposes. Cookies are small amounts of data that are stored within your Internet browser, which saves and recognizes your browsing habits. Comm100 uses both session cookies (which track a user’s progression during one site visit) and persistent cookies (which track a user over time). Web beacons (also called pixel tags or clear GIFs) are web page elements that can help deliver cookies, count visits, track browser type, identify your IP address, understand usage and marketing campaign effectiveness, recognize certain types of information on your computer, in your email or on your mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked, and similar information.
  • Visitor information. As is true of most websites, we gather certain personal data (collectively referred to as “Visitor Information”) automatically and store it in database. This personal data may include internet protocol (IP) addresses and usage data such as browser type, browser language, device identifier, Internet service provider (ISP), referring/exit pages, length of visit, pages viewed, operating system, date/time stamp, clickstream data, crashes, system activity, hardware settings, the date and time of requests, referral URL and other usage data. We may combine this automatically-collected information with other information we collect about you. If you reach out to us over the telephone, facsimile, email, our contact form on our website or via any other mechanism, we may also log telephony information such as your phone number, forwarding calls, SMS routing information and types of calls and other details of your communications to us for us to respond to your questions, improve our products and services and to develop new products and services.

Use of Personal Data Collected

We may use personal data collected from or about you for any of the following purposes:

  • Consumer personal data. Comm100 uses Consumer personal data to provide the Comm100 Services requested by Consumers and/or contracted for by Organizations, including transmitting Consumer personal data from Comm100 software to applications used by the Organization. We also use Consumer information to provide support for Organizations. For example, a reservation requested by a Consumer through Comm100 Live Chat may cause Consumer personal data to be transmitted to a reservation management system of a Hotel through Webhooks to finalize the reservation and enable the Hotel to provide services to the Consumer.
  • To respond to your requests or to tailor content. We may use your personal data to respond to your requests or the requests of Organizations and Users, which may include processing orders, sending confirmations, providing invoices, responding to requests for information about our products and services, assisting you in downloading resources or product demonstrations or evaluations. We may also use your personal data to customize your interaction with our website and our Services and to provide you with more relevant information regarding our products or services.
  • To provide services to you. We may communicate with you about our Services. These may include reports, consulting, services (including without limitation education, training, maintenance and support) for which you have inquired or contracted. For instance, as part of support services, our technical staff may require access to user data to troubleshoot. We may provide technical support and related product information via email, phone call, or a customer support portal. For On-premise deployment clients, we may require access to your systems to implement our Services. Any temporary copies of data accessed, used or created as a necessary part of these services are only maintained for time periods relevant to those purposes. As part of these services, we may be required to remotely access your systems or an individual computer to troubleshoot a support issue. We may also use this data to provide you service and product updates and notices. We may keep a record of your communications and ours to provide improved customer service to you and others. We also share information with our third party payment processor.
  • To market and improve our products and services and to create new products and services. We may inform you about our products, services, events, promotions and otherwise perform marketing activities. Further, we may use personal data for analytics purposes and to operate, maintain and improve our products and services. We may also use personal data to create new products and services.
  • To operate and improve the Web site. Comm100 uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with other information collected to provide personalized information about the Company.
  • To investigate abuse complaints. Consumer personal data may be viewed or accessed only for the purpose of investigating an abuse complaint in Comm100 Email Marketing, resolving a problem, support issues, or suspected violation of the Comm100 Hosted Service Agreement, or as may be required by law. To prevent spamming in Comm100 Email Marketing, the Company’s customer service representatives may look into the content of your emails to decide if Comm100 Email Marketing system will send out your emails.
  • Prevent improper or illegal activity. We may use personal data to protect, investigate and deter against fraudulent, unauthorized or illegal activity.
  • To meet legal requirements. The Company may be required to provide personal data to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
  • Verify users. We may use personal data to manage and verify your account and the identity of consumers and users of the Services.
  • Contests and rewards. We may use personal data to process contest entries and deliver rewards.
  • Other purposes. We may use personal data for any other legal, business or marketing purposes that are not inconsistent with the terms of this Policy.

Lawful Basis if Subject to GDPR

If our processing of your information is subject to the General Data Protection Regulation 2016/679 (“GDPR”), we use your information according to the following lawful bases for processing. However, it should be noted that these are examples of processing under lawful basis, not an exhaustive list of processing under lawful basis and do not limit any current, past or future processing under lawful basis that we may use to process your information if subject to the GDPR.

  • Pursuant to a Contract. We will use your information when it is necessary for us to perform a contract we are about to enter into or have entered into with you, including without limitation when we respond to your requests about entering into a contractual relationship, to help you create an account, to process your orders, to manage our relationship with you.
  • Pursuant to a Legal Obligation. We will use your information where needed to comply with a legal or regulatory obligation, including without limitation to manage our relationship with you by providing this Notice and any changes and updates thereto.
  • Pursuant to a Legitimate Interest. We will use your information where necessary for our legitimate interests or those of a third party’s, and your interests and fundamental rights do not override those interests, including without limitation to process and deliver your orders, to manage our relationship with you, to enable you to participate in a contest, sweepstakes, reward or prize, to administer and protect our business and our Services, to deliver the Services, content and advertisements to you and to evaluate the effectiveness of the Services, content and advertising, to tailor the Services, content and advertising, to use data analytics and other automated processing to evaluate and improve the Services and to make recommendations to you. We will also use your information where necessary to prevent fraud. We will also use your information where necessary to respond to your requests. For example, if you request to delete your information from our database, we may continue to use your information to respect your request and prevent further use of the account. This can include deactivating your account by removing your username from the permitted usernames and disallowing any account creation under your email address.
  • Pursuant to Consent. We will use your information when we have provided you with notice of processing and obtained your consent in a manner compliant with the requirements set forth in GDPR, including without limitation allowing you to opt-in and opt-out of marketing our Services to you.
  • Pursuant to One or More Lawful Basis. We may rely on more than one lawful basis for processing your specific information described in Section 1 of this Policy for the uses set forth above. To our knowledge, we do not process special category data or criminal offence data, and we require you to refrain from providing any such data in the information you share with us. Please contact us if you have any questions about the specific lawful basis we are relying on to process your information.

“Do not track” Requests

Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” requests are sent to the websites you visit. We do not process “do not track” (DNT) signals. Our third party service providers may also not respond to DNT signals.

Sharing of Personal Data Collected

We will share your personal data with third parties only in the ways that are described in this privacy policy.

  • As directed by organizations. Comm100’s Services are used to assist Organizations in communication between its agents and the Consumers. But in some situations, Organizations and its agents may use a feature of Comm100’s Services that involves a third party, which may result in the transmission of Consumer personal data to that third party. (A very common example is when an Organization uses Webhooks to automatically push such Information into a reservation software system hosted by a third party company. Another example is when an Organization uses Salesforce Integration feature to transfer information between Comm100 Services and Salesforce. ) Users and Organizations should carefully consider the privacy policy and practices of such third parties before using such a feature and instructing Comm100 to transfer the Consumer personal data. It is the responsibility of the Organization to enter into contractual arrangements to comply with all applicable privacy and data security laws and to ensure that the third party provides appropriate privacy and data security protections.
  • Business partners and subcontractors. Comm100 may disclose personal data to business partners and subcontractors (such as resellers, vendors, suppliers and other service providers), who may use the information solely at Comm100’s direction, including without limitation to fulfill product orders, contact you about product orders or in connection with the performance, operation, and support of the Services or solutions, performing marketing or consulting services, or as otherwise appropriate in connection with a legitimate business need. For example, Comm100 currently works with service providers for cloud computing, co-location, project management, data storage, email marketing, search engine optimization and related services among others. Further, we may disclose personal data to service providers who host or facilitate the delivery of online training, seminars and webinars; email-delivery services and other technology providers; and third parties that may assist in the delivery of marketing materials, technical support services, or other products, services or other information. These companies are authorized to use your personal data only as necessary to provide these services.
  • Third party analytics providers. Comm100 may disclose User and Comm100 Business personal data to third parties who conduct marketing studies and data analytics, including those that provide tools or code which facilitates our review and management of our Services, such as Google Analytics or similar software products from other providers. For example, we use Google Analytics to analyze site traffic to our website. For more information about how Google collects and processes data when you visit websites or use apps that use Google technologies, please see “How Google uses data when you use our partners’ sites or apps” at www.google.com/policies/privacy/partners.
  • Transfer or assignment in connection with business transfers or bankruptcy. In the event of a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your personal data and other information we have collected from users of the Services to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
  • Response to subpoenas or court orders; Protection of our rights; Safety. As required or permitted by law, regulation, legal process or other legal requirement, or when we believe in our sole discretion that disclosure is necessary or appropriate, to respond to an emergency or to protect our rights, protect your safety or the safety of others, investigate fraud, comply with a judicial proceeding or subpoenas, court order, law-enforcement or government request, including without limitation to meet national security or law enforcement requirements, or other legal process and to enforce our agreements, policies and terms of use.
  • References to user’s logo and website. Comm100 may make references to User, User’s logo and Website URL in Comm100’s user list located on the Comm100 web site and press releases published by Comm100. If you do not want your information to be displayed on our site, please contact us and we will reply to your request in 10 business days.
  • Publicly posted content. Comm100 may provide bulletin boards or blogs on the Company’s Web sites. Any personally identifiable information you choose to submit in such forums may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Comm100 is not responsible for the personally identifiable information you choose to submit in these forums. To request removal of your personally identifiable information from our blog or community forum, contact us at privacy @comm100.com. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.
  • With your consent. We may share some or all of your information to any other third party with your affirmative consent. For instance, we may display personal testimonials of satisfied customers. With your consent we may post your testimonial along with your name. Of course, if you wish to update or delete your testimonial, you may contact us at privacy @comm100.com.

Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by Comm100 and our website analytics service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies to remember users’ settings, for authentication and to track users’ navigation paths. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

We use local storage, such as HTML5, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit. Third Parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Widgets: Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Surveys or Contests

From time-to-time we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code).

We use this information to notify contest winners and award prizes, to monitor site traffic and to send participants email newsletters.

We may use a third party marketing service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with other third parties unless we give you prior notice and choice.

Preferences and Opt-Out

If your personal data is Consumer personal data, please contact the applicable Organization with your preferences and to opt out of any data processing.

With respect to User personal data, if you have an account you may terminate your account or opt out of marketing communications. Visitors to our website and individuals to whom we market our Services may request to opt-out of receiving specific types of communications from us at the point where we request information to send you the communication or contained within the communication itself. If you have previously signed up to receive information about our Services, you may unsubscribe or opt out of all future marketing communications from us by (a) sending an email to privacy@comm100.com; or (b) clicking the unsubscribe link on any email marketing communication you receive.

Please note that generally Users cannot opt out of receiving transactional emails related to their account with Comm100 or the Services. If you really do not wish to receive them, you can contact us at privacy@comm100.com.

Comm100 will remove Users or Visitors from the Company’s mailing list(s) in 10 business days upon receiving Users or Visitors’ unsubscribe requests.

We partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies to provide you advertising based upon your browsing activities and interests. Most Internet browsers allow you to block or delete cookies from your browser. If you do not agree to the use of these cookies, please disable or delete them by following the instructions for your browser set out here: http://www.allaboutcookies.org/, or use automated disabling tools where available. You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) (https://www.networkadvertising.org/choices/) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (https://www.aboutads.info/choices/) by visiting the opt-out pages on the NAI website and DAA website. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. You can also delete cookie files from your hard drive, or avoid them altogether, by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. Not all features of the Services will function as intended if you reject cookies.

Accessing/Correcting/Updating/Transferring/Restricting/Removing and Retaining the Personal Data

Upon request, Comm100 will provide you with information about whether we hold any of your personal data. We will respond to any request to access your personal data within 30 days. You have the right to access your personal data and to correct, amend, or delete such personal data if it is inaccurate (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to your privacy or the rights of other persons).

If you have an account with Comm100, you can access, correct, update, or request deletion of your personal data by logging into your account or contacting support by sending email to privacy@comm100.com. If we communicate with you for marketing purposes, you may use the unsubscribe link in any email communication to ask us to discontinue emailing you for marketing purposes. Other requests for access, correction, amendment, restriction on use or deletion should be sent to privacy @comm100.com. If your personal data is information provided to us by an Organization, you should direct your requests or questions about processing of personal data to the Organization. If you contact us directly about Consumer personal data, we will communicate to you and request you to directly contact the applicable Organization.

Comm100 supports access to and correction of Consumer personal data by the Organization using Comm100’s standard update mechanisms. The affected individual, including without limitation, must provide such changes to the Organization, and the Organization will have access to the Comm100 update mechanisms. Comm100 may assist its Organizations in transferring data from Comm100 Services to another software application and may use the data provided to transform the data from one software application as necessary to work with the Comm100 Services.

We will retain Consumer personal data we process on behalf of Organizations as instructed under our agreements with each Organization. If Organization has no additional agreement with Comm100, Comm100 will retain Consumer personal data depending on the “Save Time of Customer Data” defined in EULA. Once an Organization has requested that we process your personal data and send it to a third party software application, we immediately process it and cannot delete it from the third party software application. We retain User personal data for one year post termination of an account or last use of an account. We retain Business personal data so long as it is necessary to fulfil the purposes for which it was collected and to comply with applicable law or regulations.

We will retain and use all personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes. If your account becomes inactive, or if we close or suspend your account, we will continue to adhere to the then current Policy when we collected your personal data so long as we retain it in our databases. We may delete any or all of your personal data at any time without notice to you for any reason or no reason unless otherwise required by law or contract to retain it.

Security

Comm100 takes commercially reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data.

Organizations use Comm100’s Services to transmit personal data between software applications used by the Organization. This personal data will include Consumer personal data. Comm100 will only transmit data to and receive data from systems that have been authorized by the Organization. Comm100 has no ability to control the security of Consumer personal data in another entity’s system, including without limitation any Organization which provides us with your personal data or any provider of a software application with whom we process your personal data at the direction of an Organization.

User names and passwords are used as credentials for Users and Comm100 employees with a need and proper authorization to access the Comm100 Services. When using Comm100 Services to share Consumer personal data between software applications, we encrypt the transmissions. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about our security, you can contact us at privacy@comm100.com.

In the event that any Personal Data under our control is compromised as a result of a breach of security, Comm100 will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised or notify the company responsible for the personal data of those individuals and take other action in accordance with any applicable laws and regulations. Comm100’s preference is an email notification of a breach.

No Use by Children

We do not knowingly collect User or Comm100 Business personal data directly from children under the age of 16 without verifiable parental consent. We assume Users are 16 or over since they are employees of customers, or are companies. If we become aware that we have collected User or Comm100 Business personal data from an individual under the age of 16 without verifiable parental consent, we will remove his or her information from our files. If there is a concern about our processing of Consumer personal data of child under the age of 16, please directly contact the Organization as we are providing our services at their instruction and their privacy policy would govern such processing.

Links to Third Party Websites

Our website includes links to other websites whose privacy practices may differ from those of Comm100. If you submit personally identifiable information to any of those websites, your information is governed by their privacy policy. We encourage you to carefully read the privacy policy of any website you visit.

Requirement for Providing Comm100 Information about Others

If you provide any other individual’s personal data to Comm100, we will process the personal data to fulfill the purpose that you provided it to us. You agree that you are responsible for providing any notices and obtaining any consents required by applicable law necessary for Comm100 to access, and use, process, and disclose that personal data for the purposes you provided Comm100 with the data.

Changes to This Privacy Policy

If we decide to change our privacy policy, we will post a notice on the home page, and in other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the changes taking effect.

Contacting US About Privacy

If you have a specific privacy question or complaint or you want to object to or restrict any processing of your information, please contact us at:

  • Comm100 Network Corporation
  • Email: privacy@comm100.com
  • Tel: 1-778-785-0464
  • Address: Suite 238 – 1027 Davie Street, Vancouver, BC, V6E 4L2, Canada

If you are located in the EU, you have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, but we would appreciate the opportunity to speak with you first and resolve your issues.