This CommTrade Data Privacy Policy was updated on January 1, 2022


CommTrade is committed to protecting your privacy. This Data Privacy Policy tells you about CommTrade's policy and practice for the collection, use, processing, storage, transfer, protection, and disclosure of information that we may collect about you through our website, commtrade.io, or any subdomains, CommTrade websites, marketing events or our partners.

Before you access and use our websites or submit your personal information to us, you will be asked to provide your authorization and consent by agreeing to the terms and conditions of this CommTrade Data Privacy Policy and consenting to the collection, your submission (if applicable), and processing of information about you as described herein, in compliance with relevant data protection laws.

The collection, use, processing, storage, transfer and disclosure of your Personal Information (as defined below) will be limited to the terms under which you provide CommTrade your authorization. CommTrade is committed to compliance with all relevant country-specific data privacy laws, including EU Standard Contractual Clauses, model contracts / transfer agreements, privacy statements and policies, and country-specific filings if applicable. This Data Privacy Policy covers commtrade.io and all other CommTrade websites.


Collection of Your Personal Information


Personal information ("Personal Information") is data that can be used to identify, either directly or indirectly, an individual to whom the information applies. The information that we may collect from you includes your name, mailing address, phone number, email address, contact preferences, occupation, login information (account number, password), marketing preferences, social media account information, and as applicable, IP address.

CommTrade will not collect any Personal Information about you unless you voluntarily choose to provide it to us or our partners (e.g. to obtain a newsletter subscription, white papers, participate in surveys, generate product downloads, register for marketing events, promotions, or job applications), you provide your explicit consent, or unless it is permitted by applicable laws and regulations. You can always "opt-out" at any time by visiting your subscription preferences page, clicking the "unsubscribe" link in any email, or visiting the CommTrade unsubscribe page.


Use of Your Personal Information


When you do voluntarily provide us with Personal Information, we will use it to provide you information about our products, process your order, register you for an event, create an account, provide customer service, respond to a specific question, offer you the opportunity to participate in contests, register for courses, manage a job application, or provide access to additional information or offers. We also use the information we collect to improve the content of our website, to notify customers of updates to our website, products, and also to contact customers for marketing and sales purposes, including renewals, that are related to a customer's specific needs and interests.
Disclosure to Third Parties, Service Providers, and Others


In order to support and enhance the customer relationship with you, CommTrade may store, process, or share your Personal Information with our worldwide partners and affiliates (e.g. channel partners, credit card processors, data hosters, and service providers) to perform a function, provide you with information that you may be interested in or complete a transaction related to your purchase or interest in purchasing CommTrade solutions.

CommTrade also leverages its worldwide partners and affiliates to provide valuable services on our behalf. To provide these services to you we need your explicit consent to share your Personal Information with them. Third parties with whom we share your Personal Information are all bound by all relevant and applicable data privacy laws, terms of confidentiality and CommTrade's Privacy Policy.

CommTrade may also share non-personal summary information with our worldwide partners and affiliates. In the event CommTrade shares any information with a worldwide partner or affiliate, CommTrade also does so with your explicit consent and CommTrade ensures that all worldwide partners or affiliates who do receive information protect the information with the same care and policies as CommTrade does. For purposes of this Privacy Policy, non-personal information combined with personal information is treated as Personal Information.

There are times when CommTrade may be required to disclose your Personal Information by law, legal process, litigation, and/or requests from public and governmental authorities. CommTrade may also disclose your Personal Information for purposes of investigations of threats to national security, compliance with requests from law enforcement, or other issues of public importance, or when we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.


Purpose Limitation


CommTrade will collect, use or disclose Personal Information supplied by you, for the purposes disclosed to you, unless the disclosure is a use of the Personal Information for an additional purpose related to the original purpose, is necessary to prepare, negotiate and perform a contract with you, is required by law or competent governmental authority, is necessary to establish or preserve a legal claim or defense against a legal claim, or is necessary to prevent fraud or other illegal activities.

Cookies and Other Technologies


CommTrade's websites, advertisements, emails, and online services may use certain automatic data collection technologies such as cookies, web beacons, and pixel tags to collect data, including personal information, about you while you use our website, our products, and when you interact with us. Collection of user data helps us to understand our users' behavior, web searches, and where on our websites users have visited. Our website uses cookies to distinguish you from other users of our website, helps us to provide you with a good experience when you browse our website and allows us to improve our website. A cookie is a piece of information that is stored on your computer's hard drive by your web browser. When you visit commtrade.io (or any of the CommTrade websites), our server recognizes the cookie, giving us information about your last visit to the website. Many browsers accept cookies automatically, but you can adjust the settings in your browser to disable automatic acceptance of cookies. If you choose not to use cookies, you may experience limited functionality of our website. This Data Privacy Policy only covers CommTrade's use of cookies and does not cover the use of any propensity management by advertisers. CommTrade complies with global regulations including the EU Cookie Directive. Visitors to our websites are advised of our use of cookies upon landing on our website.

A "web beacon" (also known as a clear gif and pixel tag) helps us better manage the content of our website by informing us of what content is effective. A web beacon is incorporated into a web page or an email to keep track on a user's activity on the page or the email. Just like a cookie, a beacon tracks a user's visit and sends the data to the server, however, unlike cookies, a web beacon cannot and is not used for identification purposes, nor can it store any data on your computer as it is not browser-based.

Information collected by cookies and similar technologies is treated as non-personal information except to the extent under local law that IP addresses (or like identifiers) are otherwise considered Personal Information.


Accuracy and Retention of Personal Information


CommTrade strives to make it easy for you to keep your Personal Information up to date and to help us maintain its accuracy. Your Personal Information will be stored only for the time period necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required or permitted by law.
Communications and Subscription Preferences


You have the choice to determine what information you receive from CommTrade about products and services, and how such information is received by specifying your communication preferences by your subscription details at the subscription preferences page. If you wish to discontinue receiving marketing and/or non-transactional e-mails from us, you may do so in the "My Account" section of our website or use an "unsubscribe" link in any email or the CommTrade unsubscribe page. We would like to emphasize that this provision does not apply to transactional emails related to users' business relationship with CommTrade.

In the event you choose not to provide certain personal information, we may not be able to respond completely or adequately to your questions, provide updates, and/or information about our products and services. You can always "opt-out" of receiving certain communications at any time by updating your subscription preferences page, click the "unsubscribe" link in any email, or visit the CommTrade unsubscribe page. We will however continue to use your Personal Information for the limited purpose of sending you important notices relating to information about your purchases and changes to our policies and agreements, or for other reasons permitted by applicable law.


Data Security


CommTrade takes the security of Personal Information seriously. To protect your Personal Information that you have provided us against accidental or unlawful destruction, loss or alteration, CommTrade uses technical and organizational security measures to prevent any unauthorized disclosure or access.
Data Security Breach


CommTrade has implemented strict security controls, intrusion detection software and processes to alert us in the case of a potential or actual intrusion of our information systems. CommTrade has a Data Breach Notification Policy and an established Incident Response Team that will react immediately and execute a Remediation Plan in response to any unauthorized access to our information systems or databases. If any data security breach occurs and it may impact your Personal Information, you will be notified as soon as possible once the breach has been determined.
Collection and Use of Non-Personal Information


When you access commtrade.io (or other CommTrade websites), we may automatically collect non-Personal Information even if you don't register. For example, this information may include the operating system used, the domain name of the website that directed you to our website, the number of visits, average time spent on a page and what pages you viewed. We may use this data and share it with our worldwide affiliates to monitor the content and relevancy of the content on our websites to improve the performance, content or your experience on our websites.

Through your use of services to access our website, your communications data (for example, Internet Protocol Address, or IP Address) or utilization data (information on the telecommunications services you accessed) may be technically generated and could, depending on the applicable law, constitute Personal Information. To the extent it is a necessity, the collection and processing of your communications or utilization data, and the subsequent use of such data will only occur and be performed in accordance with the applicable data privacy protection framework and laws.


Forums, Blogs, Third-Party Websites, and Links


CommTrade is only responsible for the privacy practices of CommTrade and its websites. CommTrade's website may contain links to other websites for additional information and convenience. CommTrade does not control those other websites, endorse or make any representation about other websites, and is not responsible for the privacy practices of those other websites. Some of CommTrade's websites contain interactive elements such as discussion forums and blogs that allow users to publish their own content. Any information posted on these blogs and forums becomes public, which means it could be read, collected or used by other users in any manner. CommTrade is not responsible for any Personal Information you choose to submit in forums.

Consent to Transfer, Process, and Store Personal Information


CommTrade is a global organization so the information you provide to CommTrade may be transferred or accessed by CommTrade corporate entities in US and other countries around the world, each of which are responsible for the Personal Information which it collects and protects your Personal Information in accordance with this Privacy Policy. Personal Information of individuals who reside in a member state of the European Economic Area is controlled by CommTrade Inc. CommTrade uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. CommTrade abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.

Career Page and Apply for a Job with CommTrade

If you browse or apply for a job in the careers portion of our website, your application and any additional information that you provide may be used to assess your skills and interests against career opportunities at CommTrade. CommTrade may retain this information for reporting purposes that may be required by applicable law.

Right to be Forgotten

CommTrade is committed to taking reasonable steps to ensure that any Personal Information requests to be forgotten can be erased with our existing technology will be done so in a reasonable time of the request. However, this doesn't apply to information that you have made public by posting on our forums, blogs, or have made available to third parties yourself, this is beyond the reach of what CommTrade can erase. CommTrade will do everything possible to erase your Personal Information if you withdraw your consent (opt-out) from receiving information for us and request the right to be forgotten. However, CommTrade will not be able to erase all of your Personal Information if it is technically impossible due to limitations to existing technology, or for legal reasons (CommTrade is mandated by local law to keep the Personal Information).

Children's Privacy

CommTrade will not knowingly collect Personal Information from any person that is not a legal adult, as defined by local law, without insisting that they seek prior parental consent, if such consent is required by applicable law. CommTrade does not target children in connection with its products, services, and websites. In the event CommTrade uses or discloses the Personal Information of a person that is not a legal adult, CommTrade will seek parental consent pursuant to local laws and regulations in order to protect the person that is not a legal adult.

Changes to this Privacy Policy

As a technology company, our systems will mature and change as will this Data Privacy Policy. Changes to this Data Privacy Policy with the most recent revision date will be posted at commtrade.io. We will take the steps to notify you of the material changes to this Data Privacy Policy by posting the changes here or contacting you by e-mail.

Questions

CommTrade is committed to responding to reasonable requests to review any of your Personal Information we may have and to amend, correct, or delete any inaccuracies. To have your information amended, corrected, or deleted, or if you have any questions that weren't answered in this Data Privacy Policy, you can contact us email us at contact@commtrade.io