Privacy policy

Privacy policy of ComatReleco AG

This privacy policy explains ComatReleco’s practices, including our choices regarding the collection, use, and disclosure of certain information, including your personal information.

This document is applicable in relation to the ComatReleco Messaging system CMS-10R, i.e. both CMS-10R-D/.. , CMS-10R-DA/.. and CMS-10R-DAC/.. devices and the ComatReleco IoT portal.

 

Contacting us

If you have general questions about your account or how to contact customer service for assistance, please visit our Support Center or contact us directly via e-mail at support@comatreleco.com or via phone at +41 31 838 55 10. For questions specifically about this privacy policy, or our use of your personal information, please contact our Data Protection Privacy Office by e-mail at support@comatreleco.com.

The data controller of your personal information is ComatReleco AG. Please note that if you contact us to assist you, for your and our safety, we may need to authenticate your identity before fulfilling your request.

 

Collection of Information

We receive and store information about you such as:

Information you provide to us:
We collect information you provide to us, which includes:

  • your name, e-mail address, address and postal code, payment method, and telephone number. In certain countries, we collect a government identification number for purposes such as billing and tax compliance. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions;information when you choose to provide preferences, account settings (including account or device settings within the ComatReleco IoT portal), or otherwise provide information to us through our service support or elsewhere.
  • information when you choose to provide preferences, account settings (including account or device settings within the
    ComatReleco IoT portal), or otherwise provide information to us through our service support or elsewhere.
  • information we collect automatically: We collect information about you and your use of our service, your interactions with us and the people or companies you selected to manage your device, as well as information regarding your computer or other devices used to access our services.

This information includes:

  • your activity on the cloud as device installation details;
  • your interactions with our e-mails and texts and with our messages such as SMS, e-mail and through online messaging channels (push messages via Android app or iOS app);
  • details of your interactions with our customer service, like the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number, address and call recordings;
  • device ID or other unique identifiers;
  • resettable device identifiers, such as those on mobile devices and tablets;
  • device and software characteristics (such as type and configuration), connection information, IP address (which can also tell us your general location), browser and standard web server log information;

Information from other sources:
We also obtain information from other sources. We protect this information according to the practices described in this privacy policy, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:

  • service providers that help us to determine a location based on your IP address in order to customize our service and for other uses consistent with this privacy policy;
  • payment service providers who provide us with payment information, or updates that information, based on their relationship with you;
  • online and offline data providers, from which we obtain general and technical cluster specific interests and/or online advertising related data;
  • publicly-available sources such as open government databases.

 

Use of information

We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to:

  • determine your general geographic location, provide localized content, provide you with customized and personalized recommendations for improved use we think will be of interest to you and help us quickly and efficiently respond to inquiries and requests;
  • prevent, detect and investigate potentially prohibited or illegal activities, including fraud and to enforce our terms (such as determining free trial eligibility or ownership change of registered devices);
  • analyze and understand our customers, improve our product including the service and optimize functionalities, content selection, system usability, recommendation and service delivery;
  • collect feedback from you and other users with the aim of analyzing existing system malfunctioning or limitations, targeting the improvement of the system and generally our marketing offer
  • communicate with you concerning our service so that we can send you news about the devices, details about new features, technical advice for simplified usability, special offers, promotional announcements, consumer surveys and to assist you with operational requests such as e.g. password reset requests. These communications may be by various methods, such as e-mail, push notifications, text message, online messaging channels, but also through traditional mails and phone calls.
    Our legal basis for collecting and using the personal information described in this privacy policy will depend on the personal information concerned and the specific context in which we collect and use it.
    We will normally collect personal information from you where we need such personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our marketing activities in accordance with your interests), or where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity). For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), please refer to the next sections of this privacy policies. For any additional question, please contact our ComatReleco Privacy Office by e-mail at support@comatreleco.com.

 

Disclosure of Information

We may disclose your information for certain purposes and to third parties, as described below:

Service Providers: We use other companies, distributors or contractors („Service Providers“) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to complete and optimize our service to you, to process credit card transactions or other payment methods, to provide customer support, to collect debts, to analyze and enhance data (including data about users‘ interactions with our service) and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information.
We do not authorize them to use or disclose your personal information, except in connection with providing their services.
Please consider that these third parties are responsible for their own privacy practices.

Partners: We may share certain information with one or more of our Partners (i.e. external companies which took or take part to the messaging system development and/or maintenance), with the purpose of coordinating with them to improve ComatReleco’s service to you and to other users. For example, depending on the type of needed improvement, we may share information about your settings you defined in the ComatReleco IoT portal, details of your installation and evidence of your past operations details and signals and so on.

Protection of ComatReleco and others: ComatReleco and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of ComatReleco IoT portal and and overall related services, its users or the public, as required or permitted by law.

Business transfers: In connection with any reorganization, restructuring, merger or sale of ComatReleco, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our privacy policy. Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this privacy policy and as permitted by the applicable laws on data protection.

 

Access to user account

For an easy access to your account, after its creation, you may choose in your web browser to save your user name and password. Doing so, you’ll log in automatically, without requiring reentry of your password and user identification, as soon as your browser revisits the ComatReleco IoT portal. However we recommend you to save neither the password nor your user account in your browser, so to avoid any misuse of your account in ComatReleco IoT portal, especially in case your PC or tablet is shared among different users.

You must be aware that many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more.

Where possible, users of public or shared computer or tablet should log out at the completion of each visit of ComatReleco IoT portal. If you sell or return a computer device, you should log out and cancel all personal information stored on that device.

If you do not maintain the security of your account password or user name, or fail to log out without cancelling the log in details, subsequent users may be able to access your account, including your personal information.

If you share or otherwise allow others to have access to your account, they will be able to see your information (including in some cases personal information) such as your user history and account information (including your e-mail address or other information in the account area of our ComatReleco IoT portal).

 

Promotional offers and interest-based Ads

We may inform you about marketing promotions, special offers and interest-based ads, only in case you have accepted the specific option when defining your account in the ComatReleco Iot portal.
We may send to you interest-based ads, which are online ads or mail or e-mail ads that are tailored to your likely interests, based on your use of the device and the setting in the ComatReleco IoT Portal and apps.
Please consider that the default choice for promotional offers and interest-based apps is set as «I d not agree» in the IoT portal, for all users. It means that any user must read and proactively accept this option if he wants to receive such notifications by ComatReleco. However be aware that you can change anytime this choice directly in the IoT portal. For any additional question, please contact our ComatReleco Privacy Office by e-mail at support@comatreleco.com.

 

Remove of user’s data

To remove your personal data from ComatReleco IoT portal, you need to perform the following actions: in case you are the owner of one or more devices, perform the steps (a) and (b) as below described. Otherwise only step (b) shall be performed.

(a) log in the ComatReleco IoT portal and, for each device you own, you shall either:

  • define a new device owner, thus transferring to her/him full device ownership including the capability of selecting the preferred service profile (i.e. the subscription plan) for the next operating period of your device,
  • unpair the device in the ComatReleco IoT portal from your account and finally delete your device account on the ComatReleco IoT portal.

These actions shall be repeated for all your devices, which you are the owner of.

You may find additional details and instructions in the user manual, whose link is available in the ComatReleco IoT portal, specifically regarding how to define a new device owner and/or how to unpair the device.

(b) send an e-mail at support@comatreleco.com with the request to delete your account and all your user’s data.

Note 1: please consider that the deletion of your data may not occur immediately.

Note 2: please be aware that the deletion of your data will prevent you from using your devices in the future and it cannot be undone.

Note 3: in case you were the device installer, please be aware that your link will be deleted when recalling the ComatReleco IoT portal overview of all devices you’ve installed.

Note 4: please be aware that in case you were the message receiver for one or more devices, the deletion of your data will prevent that those devices send messages to you. Thus we recommend you to share this information directly with the owners or managers of those devices, allowing them to eventually replace yourself with other message receivers.

 

Your Choices

You define your choices in the ComatReleco IoT portal during your account registration and device configuration, as below described.

By defining your account in the ComatReleco IoT portal
When defining your account in the ComatReleco IoT portal you shall read the present privacy policy and proactively select «I agree», since it is set as default to «I do not agree», for all users. Please consider that you cannot proceed with your account setting and later with the configuration of your device in case you haven’t agreed with this privacy policy.

At the same time when defining your account in the ComatReleco IoT portal, you may also enter your choice related to «Promotional offers and interest-based ads» (see specific setion). Please consider that this choice is optional: without any specific input from your side, you will not receive any offer or ads by ComatReleco.

By configurating the device in the ComatReleco IoT portal
During the device configuration in the ComatReleco IoT portal, you or your installer defines the messaging parameters which will be used by the device during the operation, in case specific operating conditions are matched (e.g. if an input signal exceeds a pre-settable threshold). Namely it defines the messaging receivers, the messaging content and the messaging type or types to be used. Among the latters, following choices (1) or (2) are selectable.

(1) E-mail or SMS with text messages. These messages are sent to message receivers and may be repeated if properly set in the device configuration in the ComatReleco IoT portal. You can choose or be selected by other users to receive such messages, if the latter applies you have always the chance to accept or reject the invitation.

If you no longer want to receive such messages from the ComatReleco IoT portal via e-mail or SMS, simply contact the device owner or installer and agree with him/her to deactivate you as message receiver for his/her device. If this request hasn’t been processed and implemented by the installer or the owner, please send an e-mail at support@comatreleco.com with the request to stop sending e-mails and/or SMS, including the following data: (a) the device ID, (b) the device name, (c) the owner name. (d) the installer name, if defined and (e) the date when you have asked the owner and/or the installer to remove you as message receiver.

Please note that you cannot unsubscribe from service-related correspondence from us, such as messages or information regarding how to improve the usage of the devices, until you are still a user for at least one device.

(2) Push Notifications. You can choose or be selected by other device owners or installers to receive mobile push notifications from the ComatReleco IoT portal. This is valid for both iOS and Android app notifications. These push notifications are sent to receivers and may be repeated if properly set in the device configuration within the ComatReleco IoT portal. You can choose or be chosen by other users to receive such notifications, if the latter applies you have always the chance to accept or reject the invitation.

If you no longer want to receive certain push notifications, simply contact the device owner or installer and agree with him/her to deactivate you as message receiver for his/her device. If this request hasn’t been processed and implemented by the installer or the owner, you have also the possibility to use your mobile device’s setting functionality and to turn them off, provided that your mobile operating systems allows you to do so. Otherwise if any of the previous actions was successful, please send an e-mail at support@comatreleco.com with the request to stop sending push notifications to you, including the following data: (a) the device ID, (b) the device name, (c) the owner name. (d) the installer name, if defined and (e) the date when you have asked the owner and/or the installer to remove you as message receiver.

By defining the payment methodology
ComatReleco AG has appointed some specialized third party companies to support the online payments on the ComatReleco IoT portal, if a credit card is chosen by you as payment method. All these companies are specialized in this online transactions and ensure smooth operations and full safety protection of your personal data. These companies are fully compliant with the EU General Data Protection Regulation (GDPR) and are as well recognized by the main credit card companies (VISA, Mastercard, etc.) as payment provider.

These companies are sending to ComatReleco AG a privacy protective identifier, we use these identifier either to finalize a spot payment or to enable recurrent automatic payments, the latter only if you choose to perform those periodic payments automatically with your credit card. A privacy protective identifier is a safety code that links each of our customers to his/her credit card data (if provided), these data are stored in the secured database of those companies only, for safety purposes.

ComatReleco AG hereby declares that does not hold any specific datum regarding credit cards that have been used or are currently used by any customer for any payment, except this privacy protective identifier. ComatReleco will use this identifier only for recurrent payments, provided that those have been selected by you and you have chosen the payment methodology via your credit card on the ComatReleco IoT portal.

 

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you.

You can most easily do this by visiting your account settings in the ComatReleco IoT portal, you’ll be able to access and update a broad range of information about your account, including your contact information, your payment information, and various information related to your account. You must be signed in to access the account section, thus privacy is granted provided that you follow the advice stated under «Access to user account».

To make requests, or if you have any other question regarding our privacy practices, please contact our Data Protection Privacy Office by e-mail at support@comatreleco.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you want to reset your payment method by avoiding the payments via your credit card in the future, simply select the invocing payment methodology for all future payments and all your devices, directly in the ComatReleco IoT portal. No other actions are necessary, since ComatReleco does not hold any information about your credit card, but your privacy protective identifier only.

You can object to process your personal information, ask us to delete your personal information; please refer to the «Remove of user’ s data» section, however you acknowledge that this action will interrupt the functionality of your device.

We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this privacy policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

 

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

 

Other Websites, Platforms and Applications

The services may be provided through and/or utilize features operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. These websites and platforms may have separate and independent privacy or data policies, privacy policies, notices and terms of use: in this case you will get a notification and we therefore recommend you to read them carefully.

 

Children

You must be 18 years of age or older to subscribe any service profile as the device owner and to manage any CMS-10R device. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age in order to manage or be the owner of a device.

 

Changes to this privacy policy

We will update this privacy policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the ComatReleco IoT portal and related services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this privacy policy, you may cancel your user account. In this case please refer to the «Remove of user’ s data» section, however you acknowledge that this action will interrupt the functionality of your device.

To see when this privacy policy was last updated, please see the “Last Updated” section below.

 

Last updated

Worb – Switzerland | 22. December 2022