Privacy policy

Person responsible

ComSIT USA & Mexico HQ & Logistics Center:
ComS.I.T. Inc.
30 Log Bridge Road, Buidling 200, Suite 205,
Middleton, MA 01949, USA

Remit to:

ComS.I.T. Inc.
41 S. Main Street, PO BOX 865
Middleton, MA 01949, USA

Phone: +1 978 539 8600
E-mail: info-usa@com-sit.com
Internet: www.com-sit.us

Imprint

INTRODUCTION

WEBSITE OVERVIEW
• The company has conducted a review of the entire website to ensure there are no inconsistencies in language; all content is presented in English with no unintended German terms.
• Our contact form includes a notice that by submitting their information, users consent to the processing of their personal data. Therefore, the checkbox previously included for consent has been removed.
• A fixed icon is included at the bottom left of the Website to allow users to manage their data collection preferences. This icon is now clearly labeled as “Manage Privacy Preferences” to ensure accessibility and clarity for users.

ComS.I.T. Inc., along with our subsidiaries and affiliates (“ComSIT,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your Personal Information. This privacy policy (“Privacy Policy” or “Policy”) describes how we collect, use, and disclose Personal Information we receive in the course of providing our products and services (the “Services”), which includes when you visit our website www.com-sit.us/ or any of our product-specific Website that link to this Privacy Policy (collectively, the “Website”), or otherwise interact with us directly or indirectly.

INFORMATION COLLECTION

“Personal Information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. The Personal Information we collect about you depends on the nature of your interaction with us. We may collect Personal Information directly from individuals, indirectly via tracking technologies on our Website, or when a user posts about us on social media. The Personal Information we may collect includes the following:
  • Contact details such as name, email address, phone number, and address
  • Website tracking data such as IP address, device type, user interactions, log data, or browsing history
  • Account details such as username and password
  • Payment and billing information
  • Inferences drawn from any of the information listed above to create a profile about an individual reflecting their preferences, characteristics, behavior, or attitudes
We may also collect Personal Information automatically using various tracking technologies, such as cookies, on our Website. The information collected by these tracking technologies may include IP address, precise geolocation, referring URL, device ID, web browser characteristics, and date and time of activity. See further information in the Cookies & Marketing Tools section below. If you provide us Personal Information relating to other individuals, you warrant that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy.

INFORMATION USE

We process Personal Information for a variety of purposes, including to:
  • Respond to your questions and communicate with customers and prospective customers.
  • Operate, manage, and run our business and maintain records.
  • Provide, develop, improve, and maintain our products and Services.
  • Analyze and better understand consumers’ needs, preferences, and interests and conduct analysis and research.
  • Collect and analyze information about characteristics and behavior of visitors to our Website.
  • Undertake quality and safety assurance measures and conduct risk and security controls and monitoring.
  • For any other purpose you may agree to at or before the time your Personal Information is collected.

§1 Web analysis tools and advertising

INFORMATION USE

We use cookies and similar technologies such as tracking pixels and web beacons (collectively referred to as “cookies”) to collect user activity information, including your browsing activities and preferences. We may use the following types of cookies:

  • Essential cookies. These are cookies that are required for the operation of the Website.
  • Functionality cookies. These cookies remember choices you make and are used to recognize you when you return to the Website.
  • Analytics cookies. These cookies collect information about how you use the Website. They measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. We may also use these types of cookies to gauge how you interact with our marketing emails.
  • Targeting or Advertising cookies. These cookies collect information about your browsing activities in order to understand your interests for marketing purposes. We, or third parties, may place these cookies on your browser when you visit certain websites for the purpose of serving you with advertisements regarding our products and services that may be of interest to you (i.e., retargeting).

 

Analytics cookies, targeting and advertising cookies, and the user activity information generated from these cookies, are created, stored and/or managed by third party service providers that provide us with web traffic analytics, sales engagement and marketing automation services, such as Google Analytics and others. The user activity information collected by these tracking technologies may be stored and used by these third parties.

Social Media Features and Widgets.  Our Website may include social media features. These features are usually recognizable by their third-party brand or logo and may collect your IP address, which page you are visiting on our Website, and set a cookie to enable the feature to work properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it. Currently, we use the features and widgets (“Plugins”) of Facebook, Google, Twitter, LinkedIn, Instagram, YouTube, Pinterest, WordPress, Hotjar, Vimeo, and XING offered by the below companies (“Providers”):

  • Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). You will find an overview on Facebook’s Plugins and what they look like here: https://developers.facebook.com/docs/plugins
  • Google+ is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). You will find an overview on Google’s Plugins and what they look like here: https://developers.google.com/+/web/
  • Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). You will find an overview on Twitter’s Plugins and what they look like here: https://twitter.com/about/resources/buttons
  • LinkedIn is operated by LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale CA 94085, USA (“LinkedIn”). You will find an overview on LinkedIn’s Plugin and what they look like here: https://developer.linkedin.com/plugins
  • Instagram is operated by Instagram Inc, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”).  You will find an overview on Instagram’s Plugin and what they look like here: https://developers.facebook.com/docs/instagram-platform
  • YouTube is operated by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (“YouTube”). You will find an overview of YouTube’s Plugins here: https://developers.google.com/youtube
  • Pinterest is operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”).  You will find an overview on Pinterest’s Plugins and what they look like here: https://developers.pinterest.com/docs/overview/welcome/
  • WordPress-Stats is part of a plugin from Jetpack, operated by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110-4929, USA (“WordPress”). You will find an overview of the WordPress and Jetpack cookies and what they look like here: https://jetpack.com/support/%20cookies/
  • Hotjar is operated by Hotjar Ltd Level 2, St Julian’s Business Centre 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe (“Hotjar”). You will find an overview of the Hotjar software and what it looks like here: https://www.hotjar.com/
  • Vimeo is operated by Vimeo Inc, 555 West 18th Street, New York, New York 10011, USA (“Vimeo”).  You will find an overview of the Vimeo Plugin here: https://help.vimeo.com/hc/en-us/categories/12385938115345-Integrations-and-third-party-apps
  • XING is operated by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany (“XING”).  You will find an overview of the XING Plugin here: https://dev.xing.com/plugins/share_button

 

DO NOT TRACK & GLOBAL PRIVACY CONTROL
Some browsers offer a “Do Not Track” (DNT) or Global Privacy Control (GPC) signal. Our Website does not currently respond to DNT or GPC signals. However, you can manage cookie preferences in your browser settings.

INFORMATION DISCLOSURE

We do not sell or share Personal Information for monetary consideration. We disclose Personal Information in the following ways:

  • To affiliates and subsidiaries within our corporate family.
  • To service providers who process Personal Information on our behalf, including service providers who provide order fulfillment and returns processing, data hosting, information technology support, email hosting, marketing, and analytics services, and other services for the operation of our business.
  • To third parties when legally obligated to do so.


We may also disclose your Personal Information as part of business negotiations or transactions in connection with a proposed sale or divestiture of assets.

NEWSLETTER

If you have provided us with your e-mail address through the link on our Website, we will regularly send our newsletter to your e-mail address. You can opt out of receiving our newsletter and communications from us  at any time by sending us an e-mail at info-usa@com-sit.com or by using the “Unsubscribe” option contained in the newsletter.

DATA SECURITY

We use reasonable administrative, technical, and physical safeguards designed to ensure that the Personal Information we collect is protected from accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of Personal Information, however, no data transmission or storage system is guaranteed to be 100% secure in all circumstances.

RETENTION OF PERSONAL INFORMATION

We retain the Personal Information we collect for the time period required to fulfill the legitimate business purposes for which it was collected and to engage in the use and disclosure practices outlined in this Privacy Policy, unless a different retention period is required by applicable law, or otherwise to fulfill a legal obligation or protect our legal rights. We may also maintain for an indefinite period of time certain Personal Information that has been de-identified. This information is no longer considered Personal Information, and we commit not to attempt to reidentify such information.

THIRD PARTY LINKS

For practical reasons and for your information, our Website may contain links to other Website, such as links to our profile pages on social media sites. ComSIT exercises no control over such other Website and is not responsible for the content thereon. This Privacy Policy does not apply to third party Website, and we recommend that you review the online privacy policy of any website you visit to determine how the operator handles Personal Information collected through its website.

CHILDREN’S PRIVACY
Our Services are not directed to children under the age of 13 (or 16 in certain jurisdictions), and we do not knowingly collect Personal Information from such children. If we become aware that a child under the applicable age has provided us with Personal Information, we will delete it from our records.

RIGHT TO LODGE A COMPLAINT
If you are subject to the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with your local supervisory authority if you believe our processing of your Personal Information violates applicable law.

YOUR PRIVACY RIGHTS

Depending on you reside, you may have the following rights with regard to your Personal Information.  Please note that these rights are not absolute, may apply only in certain circumstances, and we may decline your request to exercise them as permitted by law.

  • Right to Confirm / Access / Know. You may have the right to request access to Personal Information that we hold about you, including details relating to the ways in which we collect, use, and share your information.
  • Right of Portability. You may have the right to receive a copy of the Personal Information we hold about you and to request that we transfer it to a third party.
  • Right to Delete. You may have the right to request that we delete Personal Information we maintain about you.
  • Right to Correct. You may have the right to request that we correct inaccurate Personal Information we maintain about you.
  • Right to Withdraw Consent. You may have the right to withdraw your consent to the processing of your Personal Information.
  • Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to limit the processing of your sensitive Personal Information.
  • Right to Opt-Out. You may have the right to opt-out of certain uses of your Personal Information.
  • Right to Appeal. You may have a right to appeal our decision if we decline to process your request in part or in full. You can do so by replying directly to our denial. If you are not satisfied with our response to your appeal, you may contact your state Attorney General.


Requests to exercise these rights may be made using the contact information listed at the end of this Privacy Policy, or as otherwise described in this section. Only you, or as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably confirm that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

STATE LAW APPLICABILITY
• Massachusetts Law: As ComSIT operates in Massachusetts and collects data from its residents, we have developed and implemented a Written Information Security Program (WISP) in compliance with 201 C.M.R. 17.00.
• Other State Privacy Laws: At this time, ComSIT does not meet the threshold requirements (revenue or data collection volume) for most U.S. state privacy statutes such as the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), or similar laws. Should this change, our privacy policy will be updated accordingly.
• Texas, Nebraska, and Minnesota: These states do not require thresholds for data collection or revenue for their privacy statutes to apply. However, ComSIT qualifies for a small business exemption under the U.S. Small Business Administration guidelines as it has under $10 million in annual revenue. We will revisit this classification as the business grows.
• Future Considerations: We continuously monitor changes in data privacy legislation. Should ComSIT expand to meet thresholds applicable to larger enterprises (e.g., $25M revenue or collection of data on 100,000+ consumers), we will update this Privacy Policy and make all required adjustments to our privacy practices.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this page. We may change this Privacy Policy from time to time. When we make changes to this policy, we will post the updated version on our Website and indicate the date the policy was last updated. We encourage you to review this page periodically to check for any updates.

CHANGES TO THIS PRIVACY POLICY

If you have questions regarding this Privacy Policy or wish to exercise your privacy rights, please contact us at:

ComS.I.T. Inc.
41 S. Main Street, P.O. Box 865
Middleton, MA 01949, U.S.A
info-usa@com-sit.com
www.com-sit.us