PURPOSE AND SCOPE

This Privacy Policy statement (the “Policy”) provides information on the practices and policies of Comba Telecom inc., its affiliates, and associated companies (referred to as “Comba USA”, "the Company", “we”, “us” and “our”) and applies to information collection and use including but not limited to our websites and publications that display or provides link to this Policy. 

For the purpose of the relevant data protection laws in force in places including but not limited to the United States of America (“U.S.”), the European Union (“EU”) and any other applicable and relevant jurisdictions, Comba USA are the data controller and/or data user which control the collection, holding, processing, sharing or use of individually identifiable data about visitors, contact persons of our customers, prospects, distributors, sales representatives, vendors, investors, suppliers, and individual end-users of the Company’s products or services ("Personal Data") that we collect through our public website, mobile applications, emails, publications or through any Comba USA products or services that link to this Privacy Statement (collectively, the "Sites"). 

Comba USA takes individuals' privacy seriously. We respect your privacy and we shall: 

• • protect the security and confidentiality of the Personal Data we collect; 
  • limit the Personal Data collected to the minimum required to provide services requested by you; 
  • permit only authorized employees to access Personal Data; 
  • not to disclose your Personal Data to external parties unless you have agreed, we are required by law or we have previously informed you; and 
  • process your Personal Data as necessary to comply with and fulfill legal obligations.

1. COLLECTION AND USE OF PERSONAL DATA 

For the purpose of carrying on the Company's business, including registration, content or publication subscription, product enquiry and administration of the Company's products and services (including relevant online services), you may be requested to provide Personal Data such as, but not limited to, the following, without which it may not be possible to satisfy your request: 

• personal and/or company information such as, your name, your company name, your job position, address, telephone number, mobile phone number, fax number, email address, company website, nature of business and product/service details etc. When you register with us, use our services, attend our functions, or communicate with us. 
• personal identification data such as your identification type and passport or identity card number, date of birth and/or nationality for security and verification purposes;
• account details, including account numbers, service numbers, or user accounts, and/or payment details, including credit card and banking information for payment purpose; 
• in connection with an account sign-in facility, your log-in and password details; 
• the content of any communications you send to us, for example, to report a problem or to submit queries, concerns or comments regarding the website content or anything related to the company; 
• mobile phone numbers only when you voluntarily provide them to us. Your mobile phone numbers are primarily used to provide you with our products, technical support and services promotions, and marketing updates via SMS related to the Company’s business. SMS messaging charges may be applied by your mobile carriers.  Messaging frequency may vary. Rest assuring that we only share your mobile phone numbers with our platform providers, SMS providers, and/or other vendors who assist us in the delivery of text messages subject to their privacy policy, and will not share your mobile phone numbers to any SMS short code campaign with any third party for purposes unrelated to supporting you in connection with the Company’s business. If at any time you wish to stop receiving marketing SMS from us, you can opt out by texting "STOP." at any time or deleting the mobile phone numbers provided to us within the Sites.  For assistance, text "HELP" and one of our representatives will assist you;
• SMS opt-in and Phone Numbers collected for SMS purposes will not be shared with third parties and affiliates for marketing purposes; and 
• information from surveys that we may, from time to time, run on our websites for research purposes, if you choose to respond to, or participate in, them. 

You may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalized service, or provision of a product is dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data may include, but is not limited to: 

• your age; 
• gender; 
• education and profession; 
• social media accounts; 
• other related products and services subscribed to; and 

When you browse our Sites, the Company's web servers may also automatically collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server's usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to: 

• the browser type; language and version; 
• operating system; and 
• the IP address and/or domain name. 

The Company may also collect data by recording how you interact with our Sites, products, or services. For example, to provide personalized services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our websites. At all times, every care is taken to protect such recordings from inadvertent and/or unauthorized access. 

Also, the Company's Sites may use technologies like cookies or receive use data from software running on your device and automatically collect some statistical data, including but not limited to visitors’ Geo/location/language or the numbers/duration of visits to our Sites, for the purpose of understanding how users use our Sites, products, and services so that we can improve our services and better satisfy your needs. The Company may collect, use, process, transfer, or disclose non-Personal Data for other purposes at its own discretion. Further information on cookies is set out below. 

Following the requirements of applicable laws on an appropriate legal basis, the purposes for which information may be used by us in and outside the U.S. include but not limited to: 

• processing applications or creating an account; 
• providing services and information as per your request; 
• providing services to facilitate between our Company and international offices and providing enquirers with contact and business information; 
• analyzing our business operations and evaluating market share, e.g., analysis, research; 
• notification of or customer activities, promotional events or trade fairs around the world (and similar activities, events or trade fairs organized by third parties); 
• distribution of our publications and research materials (and those of our business partners and counterparts); 
• marketing our services or products (and those of our business partners and counterparts engaged in similar or peripheral activities, such as business matching services, sourcing and conferences); 
• complying with laws, regulations or codes of practice in or outside the U.S.; 
• legal proceedings, including collecting overdue amounts; 
• other purposes directly relating to the activities identified above; 
• prevention or detection of crime, and protection of the security and safety of our events and trade fairs; and 
• verification of identity in events organized by us where it is necessary to verify your identity. 

We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication whether now or hereafter known, or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent. 

2. COOKIES AND SIMILAR TECHNOLOGIES 

Cookies are small text files, sometimes encrypted text files that are stored on computer or mobile hard drives by websites that you visit. They are used to help you navigate websites efficiently as well as to provide information to the owner of the website. 

We may use cookies to find out more about the use of our Sites and user preferences to improve our services and user experience. Cookies allow websites to remember your settings such as language, font size on your computer or mobile device, or other browser preferences. This means that a user does not need to reset preferences for every visit. We note traffic, pages visited and time spent. We store your wish list for your later use. We may link the information to you, so that you may receive information more suited to your interests. 

The cookies we use and the use purposes are: 

Strictly necessary cookies: These are necessary to help make the website usable by enabling basic functions like, session management, page navigation and access to secure areas of the website. The website cannot function properly without these cookies. 

Statistics cookies: These are used to collect information about how visitors use our Sites, helping us to understand how visitors interact with the Sites. 

Functional cookies: These are used to remember choices users make to improve their experience. 

Marketing cookies: These are used to track visitors across websites or create user profiles to send advertising, to make our site and ads on it better meet your interests. Information collected may share with third parties who we advertise with. 

We will not use cookies for any purposes not stated in this Policy. Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Sites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org. Cookies are necessary for some features of the website to work, e.g., to maintain continuity during a browser session. 

We use an email delivery and marketing company to send emails that you have agreed to receive. In addition to cookies, pixels tags and web beacons may also be used in those emails to help us measure the effectiveness of our advertising and how recipients interact with our emails. For example, when you receive an email from us, it may contain a click-through URL that links to other websites. If you click the link, it will track your click to help us learn about your preferences for content and improve our customer service. A web beacon is a transparent graphic image embedded in the email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from our mailing list at any time if you do not want to be tracked in this manner. 

By using our Sites or subscript to our e-newsletter, you consent to the use of cookies, web beacons and pixel tags as described above. 

3. RETENTION OF PERSONAL DATA 

The Company will destroy any Personal Data it may hold in accordance with our internal retention policy. Such policy states that: 

• Personal Data will only be retained for as long as is necessary to fulfill the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law; and 
• Personal Data are purged from the Company's electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company's internal procedures.

4. DISCLOSURE OF PERSONAL DATA 

All Personal Data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties: 

• any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company; 
• any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided; 
• any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; and 
• Companies and individuals to perform functions on our behalf. Examples include fulfilling orders for products or services, delivering packages, sending postal mail and e-mail, analyzing data, providing marketing assistance, providing search results and links, processing payments, transmitting content and providing customer service. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Policy and as permitted by applicable data protection laws. 

We may provide your Personal Data as required or permitted by law to comply with a summons, subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including but not limited to advisers, law enforcement, judicial and regulatory authorities in or outside the U.S. We may also transfer your Personal Data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise. 

5. TRANSFER OF PERSONAL DATA OUTSIDE OF HONG KONG 

We will generally hold your data on our servers hosted in the U.S. However, we may transfer it to our overseas offices elsewhere in the world for the purpose of processing into our database or to any of the people listed above, who may be located elsewhere. If you are located in the European Economic Area (“EEA”) your Personal Data may be transferred to countries located outside the EEA which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Such transfers will only be made in accordance with applicable laws. We will take all steps reasonably necessary to ensure that any Personal Data are treated securely and in accordance with this Policy. 

6. SECURITY OF PERSONAL DATA 

Physical records containing Personal Data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a "need to know" basis that is commensurate with an individual's Company responsibilities and their training. Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate and complies with the applicable laws. Audit records may be produced to validate data modifications in order to verify the data's integrity. There may be violations of logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online. 

7. DIRECT MARKETING 

The Company will honor an individual's request not to use his or her Personal Data for the purposes of direct marketing. Should you wish not to receive direct marketing material from the Company, please write to the Company's Privacy Compliance Officer. Any such request should clearly state details of the Personal Data in respect of which the request is being made. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for marketing purposes. 

8. HYPERLINKS TO THIRD-PARTY 

Our Sites may, from time to time, contain links to the external websites operated by third parties for your convenience. We have no control of and are not responsible for these third-party sites or the content thereof. Once you leave the Sites, we cannot be responsible for the protection and privacy of any information which you provide to these third-party websites. You should exercise caution and look at the privacy statement for the website you visit. 

9. UPDATES AND CHANGES 

The contents of this Policy may be amended from time to time. Please approach the Company and/or visit the Company's websites regularly for the Company's latest Privacy Policy. 

10. YOUR DATA PRIVACY RIGHTS 

By using our services, making applications or visiting our Sites, you acknowledge the collection and use of your Personal Data by us as outlined in this Policy. If you do not agree with the use of your Personal Data as set out in this Policy, or the Terms of Use, please do not use our Sites, submit any applications or subscribe any publications of the Company. 

11. NOTICE TO CALIFONIA CONSUMERS

If you reside in the U.S. in the state of California, we are required by California law to provide you with additional information about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

CA Personal Information. Consistent with the "Collection of Personal Data" section above, we collect certain categories and specific pieces of information about individuals that are considered "Personal Information" in California ("CA Personal Information"). Specifically, we may collect the following types of CA Personal Information:

• Identifiers:name, address, telephone number, email address, age, date of birth, username and password for our websites, IP address;
• Commercial information: products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies, payment information, transaction history;
• Professional or employment-related information;
• Internet or other electronic network activity information: computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information; and
• Geolocation information: physical location information through the use of our website, services and/or products.

Sources. We collect certain categories of CA Personal Information from you and other third parties as described in the "Collection and Use of Personal Data" section above. The categories of third parties from whom we collect CA Personal Information include the following:

• Third-party partners (e.g., distributors, certified installers);
• Third party applications (including blogs, chat rooms, or support centers);
• Advertising networks; and
• Other companies or organizations, such as market research firms or data aggregators.

Purposes. We collect the CA Personal Information for the business and commercial purposes described in the " Collection and Use of Personal Data" section above. We also share and/or disclose your CA Personal Information as follows:

Sharing your CA Personal Information for business purposes: As described above in the "Disclosure of Personal Data" section, we may share the following categories of your CA Personal Information with third party partners, public or government authorities and future business partners for our business purposes:

• Identifiers,
• Commercial Information,
• Professional or employment-related information,
• Internet or other electronic network activity information,
• Geolocation information.

As described above, examples of business purposes include product and service fulfillment, internal operations, prevention of fraud and other harm, and legal compliance.

Sharing your CA Personal Information for other purposes: We may share the following categories of your CA Personal Information with third party partners in a manner that constitutes a "sale" under California law:

• Identifiers,
• Commercial Information,
• Professional or employment-related information,
• Internet or other electronic network activity information.

This information may be shared for the following purposes: marketing, analytics, product or service performance measurements.

We do not knowingly share the CA Personal Information of individuals under 16 years of age, in a manner that constitutes a "sale" under California law.

California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to: (i) request access to your CA Personal Information; (ii) request deletion of your CA Personal Information; (iii) request information about the CA Personal Information about you that we have disclosed and/or "sold" (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the "sale" of your CA Personal Information, as detailed above.

Do Not Sell My Information. To opt-out of the "sale" of your CA Personal Information as described in this section, please contact our Data Privacy Officer.

Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your CA Personal Information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. You also have the option of designating an authorized agent to exercise your rights on your behalf. For authorized agents submitting requests on behalf of California residents, please contact us as described below, with any evidence you have that you have been authorized by a California consumer to submit a request on their behalf.

Individuals in the EU also have the right to lodge a complaint about the processing of their Personal Data with their local data protection authority. 

12. CONTACT DETAILS 

If you wish to exercise one of the above-mentioned rights, cease marketing communications, and/or raise questions or complaints please contact us at: 

Data Privacy Officer 

COMBA TELECOM INC. 

568 Gibraltar Drive

Milpitas, CA 95035Tel: +1 408. 526.0180 Fax: +1 408.526.0181

Email: privacy@combausa.com

Last updated on August 20^th, 2024