This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PII in accordance with our website.

YOUR CONSENT TO THE TERMS OF THIS PRIVACY POLICY CREATES LEGAL OBLIGATIONS FOR YOU AND FOR US. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE.

You indicate your consent to the terms of this privacy policy in various ways, depending on your use of the services offered by the website located at www.comsagroup.com (the “website”). By accessing and using the website as a site visitor, you are acknowledging that you have read and understood this privacy policy and agree to be legally bound by it. If you register as an Investor on our website, during the registration process you will be asked to confirm that you have reviewed this privacy policy and that you agree to its terms. Such confirmation constitutes your agreement to be bound by this privacy policy. You are permitted to register only in your capacity as an individual, and we do not allow Investors to register on behalf of a group or organization.

What personal information do we collect from the people that visit our blog, website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.

When do we collect information?

We collect information from you when you submit our form or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase or investment commitment, sign up for our newsletter, respond to a survey or marketing communication, browse the website, or use certain other site features in the following ways:

• To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To quickly process your transactions.
• To send periodic emails regarding your order or other products and services.

How do we protect visitor information?

We do not use vulnerability scanning and/or scanning to PCI standards. We use periodic Malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order or enters, submits, or accesses their information to maintain the safety of your personal information.
We do not process credit card or payment transactions on our servers nor do we store any personal financial information.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user’s preferences for future visits.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled and some of our services will not function properly.

However, you can still browse investment opportunities and place investment orders.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. 

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

We have implemented the following:

• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration

We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf.  If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by contacting them in writing at 400 R Street, Sacramento, CA 95814, or by telephone at (800) 952-5210. Other States may provide similar avenues for lodging complaints. Please check with your State’s consumer protection authority.

According to CalOPPA we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.  Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

Users will be notified of any privacy policy changes:

• On our Privacy Policy Page

Users are able to change their personal information:

• By logging in to their account

How does our site handle do not track signals?

We will still collect and use your browsing data to improve security, to provide content, services and recommendations and to generate reporting statistics.

Does our site allow third party behavioral tracking?

It’s also important to note that we allow third party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email

• Within 7 business days of the date upon which we become aware of any such breach

We will notify the users via in site notification

• Within 7 business days of the date upon which we become aware of any such breach

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process investment orders and to send information and updates pertaining to investment orders.
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Changing or Removing Information; Opting Out

Applicable law places certain obligations on investors to keep information current, including, for example, Form W-9 Information. It is particularly important for you to keep your financial information current and to report to us any material change in this Information. We use this information to provide you with investment opportunities and financial distributions due to you as an equity or debt holder in an investment opportunity in which you have invested through our website. Without current information, you receive information in error or that you are not eligible to receive or act on. To allow appropriate control over PII, you can access your account (after supplying your user name and password) to change or update discretionary information that you have previously submitted. You are entitled to decline to participate in certain Services and to decline to give us permission (or to revoke that permission in your discretion) to use your PII for certain purposes. We provide you with the ability to opt-out of receiving communications concerning, or being included in, these activities. To opt-out of Services for which an opt-out right is available, please email us at [email protected]. We can also answer questions or assist if you contact us as provided herein. You will not be allowed to opt–out of required notices or other legal and related notices concerning your relationship to the website. If you request, we will remove your name and all other PII from our databases. It may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, ownership in an investment opportunity in which you have invested through our website and the rights thereof, data backups and records of deletions. If you request deletion of your information, you will be unable to use certain features of the website and any associated Services. You may not remove de-identified, anonymous, or aggregate data from our databases.

Third Party Access to PII

We may employ or retain other companies (“Service Providers”) to perform functions on our behalf, such as maintaining the website, providing services related to the website, collecting information, responding to and sending e-mail or other functions to facilitate our business, broker-dealer services, and escrow services. We may need to share your PII with Service Providers. We will share with our Service Providers only that information necessary for them to perform their functions, and we require them to commit to refrain from using your PII for any other purpose. We may reveal your PII to attorneys, private investigator organizations or law enforcement agencies if we believe (i) that you are in risk of harm from another, (ii) that you are harming or interfering (or will harm or interfere) with others, or (iii) that you are violating (either intentionally or unintentionally) our Terms of Use and Service or are otherwise violating legal rights. We will take all reasonable steps to disclose only so much of this Information as is necessary, limiting the disclosure, for example (and where applicable), to contact information only. We will reveal your PII to the extent we reasonably believe we are required to do so by applicable law. If we receive legal process calling for the disclosure of your PII, we will attempt to notify you at the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted. We are entitled to transfer to a third party information we collect, including any PII, in connection with a sale of all or substantially all of our assets, provided the acquiring third party has agreed to safeguard your PII with protections that in all material respects are the same as, or more protective than, those set out in this Privacy Policy.

Anonymous, Aggregate Information

We use anonymous information to analyze the effectiveness of our website, to improve our Services and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors to our website and may share anonymous information with third parties, including advertisers. Anonymous information provided to third parties will not allow anyone to identify you or determine anything personal about you. We may collect anonymous information through features of the software that supports our Services, through cookies, and through other means. We may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser, referrer addresses, and other generally-accepted log information. We may also record page views and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our website is being used, and for security and monitoring purposes. None of this data contains PII. We may include cookies on our website and use them to recognize you when you return to our website. You may set your browser so that it does not accept cookies. However, cookies must be enabled on your web browser if you wish to access certain personalized features of our Services. We may compile records of visits with respect to certain pages or information that are available on our website. We might also compile information and other metrics concerning Investors’ interactions with respect to our Services and other features of our website. We might compile site metrics of a page of interest or other data. Such records do not contain any PII, and all such data and information is subject to our Privacy Policy. We may use “pixel tags” to tell us what parts of our website have been visited or to measure the effectiveness of searches users perform on our website. Pixel tags also enable us to send email messages in a format users can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our Investors. None of this data includes PII, and you can “opt-out” of receiving these types of emails from us. If any PII is collected using such tools, it will be subject to the terms of this Privacy Policy.

Notice of Security Incident

If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of PII, we will (i) notify affected users of the intrusion if we determine that the information at issue is sensitive; (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each affected user in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent Applicable Law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.

Relationship to Terms of Use; Incorporation of Terms of Use

This Privacy Policy must be read in conjunction with our Terms of Use and Service, and the provisions of our Terms of Use and Service are incorporated herein. To the extent the Terms of Use and Service conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

Contacting Us

If there are any questions regarding this privacy policy please contact us.