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Privacy Policy

Privacy Policy

Comlink Total Solutions. respects your privacy and feels it is important for you to know how we handle the information we receive via our website at www.comlinkprogram.com (the “Site”) and through our on-demand business productivity software, our support platform, mobile applications and tools and services offered on the Site and mobile application (the “Service”). This Privacy Policy explains our information practices, the kinds of information we may collect, how we use and share that information, and how you can opt-out of a use or correct or change that information. This Privacy Policy is incorporated by reference into Comlink’s Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.

Scope

As used in this Privacy Policy, the term “Personal Information” shall mean any information relating to an identified or identifiable natural person. This Privacy Policy applies to Personal Information that Comlink collects and processes in the course of our business, including on the Site and the Comlink platform. This policy also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. The use of information collected through our service shall be limited to the purpose of providing the service for which Comlink’s client has engaged us. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Comlink complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Comlink corp. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

This Policy applies to all of Comlink’s operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield and any additional subsidiary, affiliate, or branch of Comlink that we may subsequently form.

Types of Information We Collect and How We Use It

Information Clients Provide

When you create an account, use the Services, respond to surveys, request services or information, or contact us directly, we may ask you to provide some or all of the following types of information:

Account Information: When you register to use the Service with an email address, we collect your full name, company or organization name, email address and password you create. When signing up for a paid plan, Comlink will also collect credit card information and use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information except for the sole purpose of credit card processing on Comlink’s behalf.

User Contacts. You can import your basic contact information from your Google Contacts using Comlink’s automated contact import wizard. You can import other email account address books into Comlink using a manual import process. For Google, we authenticate your Google email address book using your Comlink user email address. We do not collect the username and password for the email account you wish to import your contacts from.

Communications With Us. When you contact us inquire about the Services, request customer service or technical support, or request other information, we may collect your name, email address, phone number or mailing address.

Surveys. We may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.

Posting on the Site. Comlink offers a community forum in which you may post information on a publicly accessible site. If post information on the community forum, it will be publicly accessible.

Registration for Sweepstakes or Contests. Occasionally, Comlink may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.

Automatic Data Collection. As is true of most web sites and mobile applications, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, mobile device identifiers, and advertising identifiers. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal information.

Information Related to Data Collected for our Clients

Comlink provides customer relationship management services to its clients, and collects and processes information under the direction of its clients. Comlink has no direct relationship with the individuals whose personal data it processes.

Cookies and Tracking Technologies

We, as well as third parties that provide content, analytics, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.

Cookies. Cookies are small text files placed in visitors’ computer browsers. 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. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. Pixel tags allow us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Local Storage. We use Local Storage (LS) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LS such as HTML5 to collect and store information. Various browsers

may offer their own management tools for removing HTML5 LS.

Behavioral Advertising/Re-Targeting. We partner with a third party to either display advertising on our Web site 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 site and other sites in order to provide you advertising based upon your browsing activities and interests.

How Comlink Uses the Information We Collect

We acquire, hold, use, and Process Personal Information for a variety of business purposes, including:

  • To Provide Services or Information Requested by Clients. Comlink may use Personal Information to provide the Service, fulfill requests for products, Services, or information, including information about potential or future Services.

  • Administrative Purposes. Comlink may use Personal Information about you for its administrative purposes, including to:

    • Measure interest in Comlink’s Services;

    • Develop new products and Services;

    • Ensure internal quality control;

    • Verify individual identity;

    • Send email to the email address a Client provides to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;

    • Process payment for products or services purchased;

    • Process applications and transactions;

    • Prevent potentially prohibited or illegal activities;

    • Enforce our Terms.

  • Marketing Comlink’s Products and Services to Clients. Comlink may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. sYou may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.

  • Research and Development. Comlink may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.

  • Anonymous and Aggregated Information Use. Comlink may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Comlink’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Comlink may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Comlink and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

  • Sharing Content with Friends or Colleagues. Comlink’s Services may offer various tools and functionalities. For example, Comlink allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Comlink or any other Third Parties for any other purpose.

  • Other Uses. Comlink may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent

      How Comlink Shares the Information We Collect

      Comlink does not sell or otherwise disclose Personal                        Information about you, except as described in this Policy or as        you explicitly consent to. We may share your information as            described in this Privacy Policy:

  • Vendors and Service Providers. We may share Personal Information we receive with vendors and service providers only as necessary to provide the Services to us. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Comlink has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

  • Business Partners. Comlink may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Comlink may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Comlink. Comlink requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Comlink provided them.

  • Displaying to Other Users. If you post content to the community forums, it may be displayed publicly on the Site.

  • User Testimonials. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at [email protected]

  • Interest-Based Advertising and Third Party Marketing. Comlink may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Comlink related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost as described below.

  • Social Media 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 web site. Your interactions with these features are governed by the privacy policy of the company providing it.

  • Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Comlink policies or contracts; (v) to collect amounts owed to Comlink; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Comlink will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

  • Privacy Shield. With respect to transfers to third parties that process Personal Information pursuant to our instructions, Privacy Shield requires that Comlink remain liable should its vendors and service providers process Personal Information in a manner inconsistent with the Privacy Shield Principles.

     Data Transfers

      We may store all Personal Information we collect anywhere in        the world, including but not limited to, in the United States, in          the cloud, on our servers, on the servers of our affiliates or the        servers of our service providers.

     Data Retention

     Comlink will retain your information for as long as your                   account is active or as needed to provide you services. We will         also retain personal data we process on behalf of our clients           for as long as needed to provide services to our client. We will         retain and use your information as necessary to comply with           our legal obligations, resolve disputes, and enforce our                     agreements.

     How to Opt-Out

  • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. You will continue to receive transaction-related emails regarding products or services you have requested and administrative communications, such as updates to the Terms or this Privacy Policy. We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

  • Mobile App Push Notifications and Location Data. Our mobile app may occasionally send you push notifications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Comlink may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

  • “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asphttp://preferences-mgr.truste.com/, and www.aboutads.info/choices/ (or if located in the European Union at http://www.youronlinechoices.eu/). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

      Rights of Access, Rectification, Erasure, and Restriction

      Clients. You can modify, update, or delete your account                    information at anytime by clicking on the Settings icon in the          global navigation bar at the top right of the screen or by                  contacting us at [email protected]. You may inquire            as to whether Comlink is Processing Personal Information              about you, request access to Personal Information, and ask              that we correct, amend or delete your Personal Information            where it is inaccurate by contacting us

      [email protected] Please include your full name,                email address associated with your Account, and a detailed              description of your data request.Such requests will be                      processed in line with local laws. We will respond to any                  requests for access to personal information within 30 days.            Data Controlled by Clients. We process information at the                direction of our clients. An individual who seeks access, or who        seeks to correct, amend, or delete data that is processed by              Comlink for its client should direct his query to the                            Comlink client (the data controller). If the client requests                  Comlink to remove the data, we will respond to their                        request within 30 business days.

      Children’s Personal Information

      The Service and Site are not intended for, nor does Comlink            knowingly collect any personal information from children                under the age of 16.

      Protection of Information

      The security of your personal information and our clients’                information is important to us. Comlink maintains reasonable        security measures to protect your information from loss,                  destruction, misuse, unauthorized access or disclosure. When          you enter sensitive information, such as a credit card number,        on our order forms and login credentials on our platform                login page, we encrypt the transmission of that information            using secure socket layer technology (SSL). These                            technologies help ensure that your data is safe, secure, and              only available to you and to those you provided authorized              access. However, no data transmission over the Internet or              information storage technology can be guaranteed to be

      100% secure due to the nature of the distributed network that

      is the Internet. Therefore, we cannot guarantee its absolute              security. if you have any questions about security on our Web          site, you can contact us at [email protected].

      Comlink is SOC 2 compliant and maintains reasonable                    security measures to protect your information from loss,                  destruction, misuse, unauthorized access or disclosure.

     Links to 3rd Party Sites

     Our site includes links to other web sites whose privacy                     practices may differ from those of Comlink. If you submit                 personal information to any of those sites, your information is       governed by their privacy policies. We encourage you to                   carefully read the privacy policy of any web site you visit.

     Single Sign-On

      You can log in to our site using sign-in services from Google.          These services will authenticate your identity and provide you          the option to share certain personal information with us such          as your name and email address to pre-populate our sign up          form.

     Accountability

     In compliance with the Privacy Shield Principles, Comlink                 commits to resolve complaints about our collection or use of           your personal information. European Union individuals with           inquiries or complaints regarding our Privacy Shield policy               should first contact Comlink at the address listed at the bottom       of this privacy policy.

     Comlink has further committed to cooperate with EU data               protection authorities (DPAs) and the Swiss Federal Data                 Protection and Information Commissioner (FDPIC) with regard       to unresolved Privacy Shield complaints. If you do not receive         timely acknowledgment of your complaint from us, or if we             have not addressed your complaint to your satisfaction, please       contact the EU DPAs or Swiss FDPIC for more information or         to file a complaint. The services of EU DPAs and Swiss FDPICs       are provided at no cost to you.

    Comlink is subject to the investigatory and enforcement powers      of the US Federal Trade Commission (FTC). In certain                      circumstances, the Privacy Shield Framework provides the right      to invoke binding arbitration to resolve complaints not resolved      by other means, as described in Annex I to the Privacy Shield          Principles.

   Changes to Privacy Policy

    Comlink may update this policy from time to time. You can              review the most current version of this privacy policy at any              time at www.comlinkprogram.com/privacy-policy. Your                    continued use of the Site or Service constitutes your agreement      to be bound by such changes to the privacy policy. Your only          remedy, if you do not accept the terms of this privacy policy, is        to discontinue use of the Site and Service. If we make any                material changes we will notify you or our client by email sent          to the e-mail address on your account or by means of a notice        on the Site prior to the change becoming effective.

   Business Transactions

   Comlink may assign or transfer this privacy policy, and your           user  account and related information and data, to any person       or entity that acquires or is merged with Comlink, you will be           notified via email and/or a prominent notice on our web site of       any change in ownership or uses of your personal information,       as well as any choices you may have regarding your personal           information.

  Terms of Service

   When you access and use the Service, you are subject and               bound to the Comlink’s Terms of Service.

  Contact Us

   If you have questions regarding this privacy policy or about the       security practices of Comlink, please contact us by email                   at [email protected] We would love to hear from you.

   Comlink Total Solutions.
1705 Colonial Blvd Unit A-4

   Fort Myers FL, 33907