We are committed to protecting and respecting your privacy in connection with your enjoyment of our services whether through www.combaterra.com, applications and/or other products and services we provide (the “Platform”). This Privacy Policy sets out the basis on which any personal information we collect from Users, or that Users provide to COMBATERRA, in connection with enjoyment of the Platform will be processed by us. Please read the following carefully to understand our practices regarding User personal information.

Please note that all terms used herein are, unless stated otherwise, defined and used in the same manner as in the ​Terms ​and Conditions.

Information we collect from Users

We may collect and process the following information about Users:

• Personal information including, for example, name; email address; telephone; short
  message service or text message address or other wireless device address; credit or debit card or other payment information; demographic information or other information that may identify Users as an individual or allow online or offline contact with Users.
• Information that Users provide by filling in forms including uploading text, photo, audio and video necessary to enjoy the Platform. This includes information provided at the time of registering to use the Platform, purchasing services, and posting content to the Platform.
• If Users contact us, we may keep a record of that correspondence.
• We may also ask Users to complete surveys that we use for research purposes, although these are never obligatory.
• Details of transactions Users carry out and of the fulfilment of purchasers of any of the services.
• Details of visits to the the Platform including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise.
• Facebook and Google profile information if Users choose to log in to the Platform by these methods.

In collecting information we abide by the following principles.

• Transparency: When collecting and processing your personal data, we will communicate all information to you and inform you of the purpose and recipients of the data.
• Legitimacy: We will collect and process your personal data only for the purposes described in this policy.
• Relevance and accuracy: We will only collect personal data that is necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.
• Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
• Access, rectification, opposition: You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information. This is done through the app settings, unsubscribe links or by sending an email to support@combaterra.com.
• Confidentiality and security: We will ensure reasonable technical and organizational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.
• Sharing and international transfer: We may share your personal data with third parties (such as commercial partners and/or service providers) for the purposes set out in this Privacy Policy. We will take appropriate measures to guarantee security when sharing or transferring such data.

Basis on which we process personal data

Personal data we hold about you will be processed because the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security; or because you have consented to the processing for the specific purposes described in this notice; or because the processing is necessary in order for us to comply with our obligations under a contract between you and us.

Use of this information

The table below sets out how we process your data and the lawful basis for the processing:

Disclosure of personal information

We may also disclose personal information to third parties as follows:

• In some circumstances, based on specific requests, we may need to disclose Users’ personal information to a third party so that they can provide a service a User has requested from such party, or fulfil a request for information from such party. It is the responsibility of any such third party to protect that information in accordance with applicable laws, and use it only to provide the services or information Users have requested.
• If COMBATERRA’s service providers (like hosting or payment service providers) require information to provide services to COMBATERRA. COMBATERRA requires each of its service providers to agree to maintain the confidentiality of personal information disclosed.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
• If COMBATERRA or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of COMBATERRA, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where we store, process and secure User personal information

The data that we collect from you may be transferred to, and stored at, a destination inside or outside the European Economic Area (“EEA”). It may also be processed by staff operating inside or outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. Access to your information is limited to those who have a need to manage it. Where your information is transferred from the EEA to a country that is not subject to an adequacy decision by the EU Commission, we will seek to ensure that it is adequately protected by (i) ensuring that EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules are in place or (ii) relying on derogations (e.g. contractual necessity). A copy of the relevant mechanism can be provided for your review on request, using the contact details provided below.

Security

The security of your personal data is important to us. When you enter personal information (such as login, profile or bank account details) through the Platform, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Platform, you can contact us at support@kindeo.com.

Single Sign-On

You can sign up or log in to our Platform using our sign-in service or a sign-in service such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate our sign up form. Services like Facebook and Google may give you the option to post information about your activities on our Platform to your profile page to share with others within your network.

Cookies and Local Storage

We use cookies or local storage to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our sites and other services and also allows us to improve our Platform. These cookies cannot be used to identify you personally.By continuing to browse and access any of our services, you are agreeing to our use of cookies. Cookies and local storage contain information that is transferred to your computer’s hard drive.

We use and store the following data as follows:

• Strictly necessary data: This is data that is required for the operation of our Platform. It includes, for example, authorisation information that enables you to use secure areas of COMBATERRA.
• Analytical/performance data: This allows us to recognise and count the number of users/visitors and to see how they interact with COMBATERRA. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality data: This is used to recognise you when you return to our Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies or local storage, over which we have no control. These cookies are likely to be analytical or performance cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of COMBATERRA.

Log files

Log files allow us to record the the use of our Platform. Our Platform collates log file information from all interactions with the Platform, which we use to make improvements to the Platform and debug technical issues that may arise. Log files do not contain any personal information about Users.

Newsletters

If Users sign up to receive email newsletters from us we will use the information given to provide the requested service only. Users may unsubscribe or contact us if they wish to cancel email newsletters and we will remove them from our mailing list and the details will be deleted from our records.

While a User of the Platform, you will continue to receive messages relating to the Platform and your account if you unsubscribe from our newsletters. If you choose to delete your account, you will no longer receive these emails.

Your privacy rights

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Ask us to correct ny information that we hold about you which is incorrect, incomplete or inaccurate.
• Ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it.
• Object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes.
• Ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it.
• Ask us to transfer your personal information to another person or organisation.

If you have given your consent to us processing your personal information (for example, consent to receive information about our services and events), you have the right to withdraw your consent at any time. To withdraw your consent, please contact support@combaterra.com. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your data securely (although we may in some circumstances need to continue to process your data, if so then we will confirm the reasons for this).

Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, which in some cases involving the collection and processing of financial data may require a retention period of 7 years (or longer if required by law).

Other Sites

We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Platform and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you linked to this Platform from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Children’s Privacy

The Platform is designed for persons 16 years of age and older. Children between the ages of 16 and 18 (or the age of majority in their jurisdiction of residence) (“Minors”) may use the Platform, but use by such Minors shall only be done with the guidance, supervision, and consent of their parents or guardians. We rely on parents and guardians to ensure Minors only use the Services if they can understand their rights and responsibilities as stated in the Terms of Use. If you are a parent or guardian and you provide your consent to your child’s use of the Platform, you agree to be bound by this Privacy Policy and the Terms of Use.

Changes to our privacy policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Platform prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@combaterra.com.