(Revised August 7, 2019)

                                                                                                                                                                                                                

Please read this entire privacy notice (“Privacy Policy”) carefully before using our websites, email notifications, mobile applications, social media applications, widgets, and our other online services (the “Services”) because it will help you understand what data we collect, how we use and share it, and what your choices are with respect to that data.

                                                                                                                                                                                                                

OVERVIEW

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comTECH, Inc. is a technology solutions provider that offers technology hardware products, professional and managed services.  This Privacy Policy describes how comTECH and its subsidiaries and affiliates that link to this Privacy Policy (“comTECH,” “our,” “us” or “we”) may collect, use and share information about you (“Personal Information”) and what privacy choices we may offer you when you use our Services.

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The Services of comTECH and its subsidiaries and affiliated companies are each owned, operated and provided by such subsidiaries and companies. However, this Privacy Policy ONLY governs the use of comTECH Services that specifically link to this Privacy Policy.  Any other comTECH Services may link to or otherwise provide their own, separate notice.

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Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

 

By using the Services, you are accepting and consenting to the practices described in this Privacy Policy.

                                                                                                                                                                                                                

INFORMATION COLLECTION AND USE

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Through your use of the Services, we may collect Personal Information from you if you choose to provide it, including without limitation:

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• Your name, email, username, phone number, company and address, (“Contact Information”);

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• Your job function, salary, and status of your employment;

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• Your credit card number, billing address, shipping address, security code and other payment transaction and verification details (“Payment Information”);

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• Pages and products viewed, ads that you clicked on, emails from us that you opened, browser type, operating system (“OS”), Internet Protocol (“IP”) address and device information (collectively, “Analytical Information”);

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• Publicly available information about you from third-party sources, such as the postal service for shipping address verification;

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• Your mobile OS, a mobile device identifier embedded by us, or other commonly used mobile device identifiers.

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We may collect your Personal Information or usage data from third parties, including without limitation:

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• Your email address and other collected Personal Information about you may be forwarded to comTECH by a third-party website when you request for comTECH to contact you through such third-party;

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• Your Personal Information may be forwarded to comTECH when you choose to participate in a third-party application or feature, such as live chat, one of our social media pages or a similar application or feature on a third-party website;

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• Additional Personal Information may be forwarded to comTECH from third parties to combine with the Personal Information we collect through your use of the Services in order to enhance our ability to serve you, to focus content we provide to you and to offer you opportunities to purchase products or services that we believe may be of interest to you based upon the information we have collected.

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• We will apply the terms of our Privacy Policy ice to any Personal Information received from a third party, unless we have disclosed to you otherwise.  comTECH is not responsible for these third parties’ dissemination of your Personal Information.

 

We may use your information for the following purposes:

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• Customer Service: We may use your Contact Information to receive and respond to your questions about products, services or warranties and to communicate with you about contests, surveys or sweepstakes. To address your questions, we may also request your industry and/or the name and address of the dealer that sold you our product.

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• Website Registration: We may use your Contact Information when you create an account through any of our Services in order to provide you a more personalized user experience.

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• Analytics: When you use the Services, we automatically collect and use Analytical Information in order for us to continually improve your experience with our Services and to target marketing and advertising to you.

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• Marketing: We may use your Personal Information to determine what products may be of interest to you, provide you with marketing communications (unless you have opted out of such communications) and to conduct market research. We may also use information you provide us, including your industry, whether you own our product, experience with our products, and user-generated content, for these marketing purposes.

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• Location-Based Services: We may use your current location, provided address and/or zip code to provide you the location of the retailer of our products or other appropriate information.

 

We may also use your Personal Information in other ways that are consistent with the above-described purposes and to otherwise administer our websites and provide our Services to you.

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For Citizens of the European Union:

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If our use of your data is governed by the European Union’s General Data Protection Regulation (“GDPR”), you should know that we rely on the following legal grounds to process your personal information:

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• Performance of a contract – To the extent you have purchased a product or service from comTECH, we may need to collect and use your personal information to perform the services which you have purchased. For example, we may use your personal information to respond to requests you make via our website and provide you with such services.

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• Compliance with law – In certain circumstances we may be required to process your data to comply with legal obligations to which comTECH is subject.

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• Consent – Some of the personal information We collect is provided by you voluntarily, for example when you sign up to join a mailing list or register for an event, and is therefore collected and used with your permission. To withdraw your consent to such use, you can contact us at support@comtech.solutions.

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• Legitimate interests – We may use your personal information for our legitimate interests, such as to improve our products and services and the content on ComTECH websites. We may also use your contact information to keep you and others who have provided us with their contact information up-to-date on recent product and service developments. It you wish us to stop using and/or delete your contact information in this manner, you can contact us at support@comtech.solutions.

                                                                                                                                                                                                                

NOTICE TO EMPLOYMENT APPLICANTS

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Certain pages of our websites include the ability for people interested in working for comTECH or one of its subsidiaries or companies to find out more information about employment opportunities at comTECH, its affiliates and/or subsidiaries. To apply for open positions using our website, you must create an employment profile through our website here, which includes the information that comTECH requests you to provide, and that you may choose to provide, to be considered for employment (the “Employment Applicant Information”).

Prior to creating an employment profile, you affirmatively consent to the privacy terms herein governing the submission of your information to comTECH for employment purposes. The terms that you agree to in order to create an employment profile shall govern comTECH’s use of the information you provide to apply for employment. comTECH will use Employment Applicant Information for evaluation and hiring purposes, and communication in furtherance of the evaluation and hiring purposes.

                                                                                                                                                                                                                

SECURITY

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We maintain appropriate technical and organizational measures to protect your Personal Information, including assuring that third-party service providers who access or handle Personal Information on our behalf and affiliates maintain such safeguards.  However, no method of Internet transmission or electronic storage is 100% secure or error-free, so it is not possible to guarantee absolute security. You must protect against unauthorized access to your password and to your computer, and be sure to sign off when finished using a shared computer. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please immediately notify us by email support@comtech.solutions. 

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If we have given you or you have chosen a password which enables you to access certain portions of our websites, you are responsible for keeping this password confidential. You should not share your password with anyone.

                                                                                                                                                                                                                

NOTICE TO EUROPE ECONOMIC AREA RESIDENTS

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If you are a resident of a country in the European Economic Area (“EEA”), the Personal Information we collect from you may be transferred to and stored at a destination outside the EEA. The Personal Information may also be processed by staff operating outside the EEA that work for us or one of our subsidiaries, affiliates, or third-party service providers. By submitting your Personal Information, you agree to this transfer, storing and processing. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, including utilizing the European Union Standard Contractual Clauses to safeguard the transfer of data outside the EEA.

                                                                                                                                                                                                                

COOKIES

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We use “cookies,” a small text file transferred to your device, along with similar technologies (e.g., internet tag technologies, web beacons and embedded scripts) to help provide you with a better, more personalized user experience. These technologies are used to:

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• Make the user experience more efficient;

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• Remember your preferences (e.g. browsing language, account login information);

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• Help us understand and improve how visitors use our website, including which of our pages and products are viewed most frequently.

 

The options/settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable such technologies. You can disable our cookies or all cookies through your browser settings. Please be advised that disabling cookies through either method may impact many of our websites’ features.

We may also allow third parties to place cookies on your device through the Services to:

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•  Help us understand and improve how visitors use our websites, including which of our pages and products are viewed most frequently;

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• More effectively market our products and services and advertise other products and services that may be of interest to you;

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• Obtain your feedback on our products and the Services;

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•  Allow you to engage in our social media offerings.

 

The use of third-party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies. If you continue to use our websites, we will assume you agree to the use of these cookies. You may visit the third-party links below to opt out of their tracking and learn about their privacy practices. However, we are not in control of the location of the instructions and information provided by the third parties below and, therefore, you may have to locate the particular instructions and information for the respective third party if these links are no longer current.

Although not all cookies and similar technologies that we use are required for you to use the Services, disabling these technologies altogether could prevent the Services from working properly and disable features that allow you to take full advantage of the Services we offer.

                                                                                                                                                                                 

INFORMATION SHARED WITH THIRD PARTIES

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We only share your Personal Information with companies, organizations and individuals outside of comTECH as described below:

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• Affiliates and Third Parties. We may share your Personal Information with comTECH’s affiliates and other companies worldwide, including our unaffiliated dealers, manufacturers, and suppliers in order for these companies to contact you about their products, services or other offerings that may be of interest to you. By accessing our websites, registering for an account or service with us, or otherwise providing us with your Personal Information, you consent to this transfer of your Personal Information worldwide as provided in this Privacy Policy. To choose to opt out of such disclosures, please email us at support@comtech.solutions. This Privacy Policy does not govern unaffiliated third-party websites or any other website that does not link to this Privacy Policy

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• Service Providers. We may share your Personal Information with affiliated and unaffiliated companies that perform tasks on our behalf related to our business. Such tasks include locational services, analyzing website or mobile application usage data, customer service, electronic and postal mail service, contests/surveys/sweepstakes administration, marketing services, social commerce and media services (e.g., Facebook, reviews, forums). Third-party service providers receive your Personal Information as necessary to perform their role, and we instruct them not to use your Personal Information for any other purposes.

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As Required or Appropriate by Law. We will use and disclose your Personal Information as necessary or appropriate, including without limitation:

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• Under applicable law, including laws outside your country of residence, to comply with legal processes and to respond to requests from public and government authorities, including public and government authorities outside your country of residence;

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• To enforce our terms and conditions, including investigations of potential violations thereof;

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• To detect, prevent or otherwise address fraud, security or technical issues;

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• To protect our operations or those of any of our affiliates; to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.

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• Business Transfers. As we continue to develop our business, we might sell or buy brands, stores, subsidiaries or business units. We may share and/or transfer your Personal Information with a third party in such transactions (including without limitation, any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets). Customer information generally is one of the transferred business assets, but remains subject to any preexisting applicable Privacy Policy.

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• Based on Your Consent. We may share or disclose your Personal Information at your direction. We may share aggregated data that has been anonymized (so that you are not identified) with third parties – like publishers, advertisers or connected websites – and may make this data publicly available.  For example, we may share information publicly to show trends about the general use of our services or products.

                                                                                                                                                                                                                

PUBLIC FORUMS

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Our websites may offer publicly accessible blogs, message boards, or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You may request removal of your Personal Information from any comTECH blog, message board, or community forum by contacting us at support@comtech.solutions. We will make commercially reasonable efforts to remove your Personal Information from the identified blog, message board, or community forum. If we are unable to remove such Personal Information, we will notify you and provide the reason we are unable to take such action.

                                                                                                                                                                                                                

LINKS TO SOCIAL NETWORKING AND OTHER THIRD-PARTY WEBSITES

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Our Services may contain links to social networking and other websites and mobile applications that are operated and controlled by third parties. While we try to link only to websites that share our high standards and respect for privacy, we do not take responsibility for the content or the privacy practices employed by other websites. Unless otherwise stated, any Personal Information you provide to any such third party website will be collected by that party and not by us, and will be subject to that party’s privacy policy (if any), rather than this Privacy Policy. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the Personal Information you provide to them.

                                                                                                                                                                                                                

ACCESSING THE SERVICES FROM OUTSIDE THE UNITED STATES

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Personal Information collected through the Services may be stored on servers inside the United States or in countries outside the United States. By using any of our Services, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy, including the transfer of your information to comTECH in the United States and other countries where comTECH and its affiliates and subsidiaries operate. You may withdraw your consent at any time by contacting us at support@comtech.solutions. Prior uses and disclosures will not be affected unless required by applicable law, and we may otherwise continue to process your Personal Information in accordance with our statutory obligations and internal policies and procedures.

                                                                                                                                                                                                                

YOUR CHOICES

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If you have created an online account with comTECH or one of its subsidiaries or companies and would like to update the information you have provided in your online account, you can access your account on this website to view and make changes or corrections to your information. If you do not want to receive marketing or other communications from us, please use the unsubscribe method provided in our communications. We will retain your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer period is required or allowed by law.

                                                                                                                                                                                                                

ACCESS TO YOUR PERSONAL INFORMATION

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If you are a resident of the EU, you have the right to access information held about you. Any access request may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.  You can make such a request by emailing us at support@comtech.solutions 

                                                                                                                                                                                                              

CHILDREN

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In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, our website does not permit children under 13 years of age to become users, and we do not intentionally collect information from children. By using our website, you represent that you are 13 years of age or older.

                                                                                                                                                                                                                

CONTACTING US

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If you have any questions about this Privacy Policy, please write to us by mail at comTECH, Inc., Attn: Website Inquiries, P.O. Box 589, Crystal Beach, FL 34681, or email us at support@comtech.solutions.

                                                                                                                                                                                                                

CHANGES

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We may update this Privacy Policy from time to time. Please check the “Effective Date” at the top of this page to see when this Privacy Policy was last revised. Unless otherwise noted, any changes we make to this Privacy Policy will become effective immediately once posted on this page. Your continued use of the Services following any changes to this Privacy Policy indicates your consent to the practices described in the revised Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.