Privacy Policy

Comecero, LLC is an ecommerce provider and makes every effort to protect the privacy of users who interact with our web sites, applications, and electronic communications. The purpose of this privacy policy (the “Privacy Policy”) is to advise you of what type of personal information Comecero collects about you as a result of the use of Comecero’s websites and applications, if any, and describe the limited purposes for which Comecero uses, processes, and shares such collected information.

Collection of Personal Identifiable Information

Comecero may request that you provide certain Personal Identifiable Information (later referred to as "PII") in order to use certain services, make purchases or engage in business activity. "PII" is defined as any information that identifies you as an individual, including but not limited to your name, mailing address, and/or e-mail address. We may also collect other information, such as your Internet Protocol ("IP") address, browser type and version, and the pages you visited while on Comecero’s websites and applications.

Any PII that Comecero receives from third party service providers or partners will thereafter be treated in accordance with this Privacy Policy. Further, if Comecero receives any PII from distribution partners and resellers of Comecero services, such PII will be treated in accordance with this Privacy Policy.

You decide, in your sole discretion, whether you want to proceed with any activity (by filling out forms, clicking on submission buttons and/or other means by which you voluntarily provide your information to Comecero, its appications or systems) that asks or requires you to provide PII to Comecero. Please note, however, that if you choose not to provide the requested information you may not be entitled to pursue the requested activity or otherwise use the full functionality of the Comecero website or applications.

Data that May Be Collected

Below is a list of the data that may be collected as you use the services provided by Comecero:

  • Your name
  • Your mailing address
  • Your email address
  • Payment details, such as a credit card number
  • Account credentials
  • Other information or data requested by Comecero to provide services to you, that you expressly provide to Comecero
  • IP Address
  • Time zone
  • Operating system name and version
  • Device type
  • Meta data from your requests, such as headers, language preferences, and other information from your device

Use of Personal Information

Comecero will use and process your PII for the following purposes:

  • To provide you with the services that you have requested from Comecero.
  • To provide a business record of purchase or purchase attempts you have made through Comecero.
  • To provide fulfillment of the product or service you have purchased, either directly or indirectly through third party providers.
  • To provide you with customer service before, during and after a transaction.
  • To enable the manufacturer of the product or service you have purchased to provide fulfillment, customer serivce, and to maintain a proper business and customer records.
  • To provide you with important service bulletins related to the products and services you have purchased.
  • To provide you with promotional communication about products and services related to the items you have purchased, if you provide consent to receive such communication.
  • To monitor for abuse of the system and fraud.
  • To comply with industry regulatory requirements.
  • To comply with the law.

Sharing of Personal Information with Third Parties

Comecero will not share your PII with any third party except as set forth in this Privacy Policy or if Comecero receives your prior permission.

  • Where Comecero acts as the technology provider, facilitator of a transaction or reseller of a product or service, the manufacturer of the goods and/or services you purchase may have access to your PII, as contractually agreed between Comecero and manufacturer. For more information on how the manufacturer uses and protects your PII please see their Privacy Policy as described on their website. If you have any questions obtaining or finding the privacy policy of the product manufacturer, please contact us for assistance. Please note that Comecero does not control, does not review, and has no responsibility for the privacy policies of the manufacturers whose products and services you purchase through Comecero. Comecero therefore encourages you to thoroughly read the privacy policies of the manufacturers of the products you purchase through Comecero before you submit any PII to Comecero.
  • Comecero engages with external service providers and partners to provide services and fulfill its business obligations. In some cases, some of these service providers and partners may receive your PII but are contractually restricted in how they may utilize and protect the PII obtained from Comecero. Comecero's service providers and partners have no rights to use any such PII in any way other than for the purpose for which it was received from Comecero. Accordingly, the service providers are not allowed to use any PII received for direct marketing purposes or to share the PII with other third parties, except as necessary to fulfill their contractual obligations to Comecero and comply with applicable law. Further, the Comecero service providers are required to adopt appropriate security measures in order to protect such PII from unauthorized access, disclosure and alteration.
  • In the event of a sale, acquisition, or transfer of Comecero's business entity, assets (or substantially all assets) of Comecero, a liquidation, merger, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors (or other similar transaction or change of control), Comecero may disclose your PII to the receiving entity or entities as part of the transaction.
  • If Comecero is under a duty to disclose or share your PII in order to comply with any legal obligation or legal request, such as a subpoena, or in connection with required governmental filings or submissions, or in order to enforce or apply Comecero’s terms of use or terms and conditions and other agreements; or to protect the rights, property, or safety of the Comecero websites, applications, our customers, or others, including to take precautions against liability or harm, or to protect the security or integrity of the Comecero websites and applications, or to investigate and respond to third-party claims or allegations, and to protect the rights, property or safety of Comecero, our users or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • We may share information in other situations with your consent.

Public Information

Please note that any and all information, discussions, or other communications and materials of any kind that you submit or otherwise make available within the various forums, centers, and communities on the Comecero websites will be considered public information and will not in any way be treated as confidential information.

Statistical Information

Comecero may further share with third parties aggregate statistical information, i.e. information that does not identify you as an individual, but refers to certain Comecero users in aggregate. Examples of such aggregate statistical information include the number of users that purchased a specific product or number of users that viewed a particular page. Any such information is anonymized by removing or redacting PII and by breaking any connection back to PII such that the aggregate information can not be used to associate PII.

Security of Personal Information

Comecero takes reasonable technical, physical, administrative and managerial procedures, and employs security measures and safeguards to protect PII that is stored on Comecero’s servers. Once we have received your PII, we will use commercially reasonable technical, physical, administrative and managerial procedures, security measures and safeguards to try to prevent unauthorized access to, and to preserve the integrity and security of, your PII.

California Privacy Rights

We do not provide your PII to third parties for marketing purposes. However, if you are a California resident, California Civil Code Section 1798.83 permits you to request, once a calendar year, information regarding the disclosure of your PII by Comecero to third parties for the third parties’ direct marketing purposes. If applicable, this information would include the categories of PII and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To make such a request, please contact us.

Children’s Privacy

Comecero further recognizes the particular importance of protecting the privacy of children and Comecero is committed to protecting children’s privacy on the Internet. Comecero does not generally target children and does not knowingly collect PII from children under the age of thirteen (13). For residents of a country, which is member of the European Union, this age is sixteen (16). If Comecero would discover that a child under the age of thirteen (13) (or, for European Union residents sixteen (16)) has provided PII through the Comecero websites and applications or if Comecero is contacted by a verifiable parent or legal guardian about his or her child’s participation on the Comecero websites and applications, Comecero will delete the PII about the child from Comecero‘s active user records.

Links to Other Sites

On the Comecero websites you may find various links to the web sites of certain Comecero partners as well as offers for such partners’ products and services, which direct you to such partners’ web sites. For the avoidance of any doubt, Comecero is not responsible for the content, business practices or operations of such web sites. Please note that these partners have their own privacy policies. If you link to our cooperation partners’ websites from any of the Comecero websites we encourage you to read such partners’ privacy policies before you submit any PII on their sites. The presence of a link to Comecero partners’ websites does not constitute or imply Comecero‘s endorsement, recommendation, or sponsorship of the content, goods, or services available through, or contained on, such partners’ websites.

Cookies

Comecero uses cookies to provide services to users, such as account logins, shopping cart sessions and other features. Additionally, Comecero uses cookies to understand how the Comecero websites are being used with the purpose of improving the content and offerings of the Comecero websites. “Cookies” are minor text files that are placed in your computer’s browser with the purpose of storing your preferences, session identifiers and other meta data about your use of Comecero's services. Cookies do not provide or contain PII, however, if you provide Comecero with PII through the Comecero websites or elsewhere, such PII may be linked to the data stored in the cookie. For example, a cookie may store a shopping cart identifier, and that identifier may connect to a customer profile that contains your name or email address. Comecero may use cookies to personalize your experience at the Comecero websites (e.g. to recognize you when you return to our site). Cookies are also used to analyze and record data about how you use and interact with the Comecero website, using internal alogrithms and exeternal service providers. Through your browser settings, you may disable the use of cookies on Comecero websites, but doing so may degrade your user experience or prevent you from accessing many portions of the Comecero website and service.

Access, Corrections and Deletions of Personal Information

In order to keep your PII accurate, Comecero depends on you to amend your user account(s) to contain correct data. Registered users may update their user accounts by accessing them electronically through the Comecero websites. If you wish to ascertain which of your PII Comecero maintains about you, please make a data request. Comecero will make efforts to respond to such requests quickly. In the event any incorrect or false PII has been stored relating to you, you may further request Comecero to correct, block or delete any such incorrect or false PII. Please note that if you request that Comecero delete certain PII relating to you, you may no longer be entitled to continue to pursue certain activities at the Comecero websites and applications and/or to otherwise use the full functionality of the Comecero websites and applications.

Please note that in some cases it may not be possible to immediately redact or delete your PII or some elements of your PII. For example, if Comecero has legal, regulatory or business reasons to maintain your information for a period of time beyond your request, it will delay the redaction or deletion of PII data until such reasons to maintain the data have been completed, at which point Comecero will proceed with the redaction or deletion request. In the event that Comecero is unable to perform a redaction or deletion of your PII, Comecero will respond to your request indicating the need to maintain your data and an estimate of when your request will be fulfilled.

EU General Data Protection Regulation

The European Parliament of the European Union has passed the General Data Protection Regulation (“GDPR”), which came into force on May 25, 2018. The GDPR replaces the 1995 Data Protection Directive 95/46/EC. If you are an individual and a resident of a country, which is a member of the European Union, then the GDPR permits you, in addition to your other rights described in this Privacy Policy, to do any of the following:

  • Data portability: if you want to electronically transfer the PII about you that you have provided to us directly (such as the information you provided while purchasing via Comecero websites and applications), to another third party service provider, you can make a data request. We will, within thirty (30) days of receipt of your request, send you a copy of the PII about you that we have and you may then make an additional data request to correct or request redaction or deletion of your PII data, as per the "Right to Erasure" section.
  • Right to Erasure: If you want Comecero to delete PII about you, you can make a data request. We will, within thirty (30) days of receipt of your request, confirm that Comecero has redacted or deleted your PII. Comecero reserves the right to extend this time period by an additional sixty (60) days, if Comecero receives a large number of requests to redact or delete your data, or the nature of the request or data is technically complex. Comecero will inform you if this delay is required. If Comecero has shared your PII with external parties as per the terms of this agreement, Comecero will forward your request to these parties in order to inform them that you requested that Comecero delete your PII and request them to remove your PII that Comecero has provided to each of them, unless your written instructions to us are not to do so. Please note that if you request that Comecero redact or delete certain or all PII relating to you, you may no longer be entitled to continue to use Comecero websites and applications or pursue certain activities at the Comecero websites and/or to otherwise use the full functionality of the Comecero websites and applications.
  • Right to Object: If you have previously provided consent to Comecero to use your PII to engage in promotional correspondence with you, you can change your preference at any time using the "unusubscribe" instructions included in the correspondence, or by making a data request.

Requests to redact or delete your information will be processed according to the provisions of the "Access, Corrections and Deletions of Personal Information" section in this agreement.

Amendments of this Privacy Policy

Comecero will update this Privacy Policy on a regular basis. We therefore recommend that you check this Privacy Policy periodically for modifications. Comecero will indicate when the Privacy Policy has been updated by noting the "Last updated" date at the bottom of this Privacy Policy.

Contacting Us

If you have any questions about this policy or your information, please contact us by visiting our website https://comecero.com and accessing the "Contact Us" portion of the website.

Last updated: October 19, 2018