Source of Collected Personal Information
You: You provide Personal Information directly to us, for example when you:
- Register for an account
- Send messages through our services
- Send email messages or contact us
Third Parties: We also may receive Personal Information from or through a third-party service. For example, we may provide the option for you to log in and access our Services using your credentials from a third party service (for example LinkedIn or Google). If you choose to log in using this feature, we may obtain Personal Information such as your email address or profile information from the third party service. We abide by this Privacy Policy when we use Personal Information provided to us by third parties. We do not control the information that third parties collect or how they use that information. You should review the third parties’ privacy policies for more information about how they collect, use, and share this information, including what information they may disclose to us.
Cookies and Tracking Pixels: When you visit a website, it may ask your browser to store a “cookie” on your device to remember information about you, such as your language preference or login information. We cookies to assign a unique number that automatically identifies your computer when you visit our websites. Some cookies remain on your computer until you delete them; others, like session ID cookies, expire when you close your browser. We may also use tracking identifiers (such as Clear GIFs, pixels, web beacons) to track the online movements of web users. Unlike cookies, tracking identifiers are tiny graphics that are embedded invisibly on web pages or in HTML-based emails.
We use cookies and other tracking technologies for the following purposes:
- Customizing use of our Sites;
- Analyzing your use of our Services, counting visits, collecting aggregated user data, and traffic sources; and
- Tracking our promotional and marketing efforts.
Third Party Cookies
Some of our cookies come from third party advertisers or analytics providers. These cookies improve your experience by helping us better tailor our websites to our audience. We work with third party advertising and analytics providers for collecting information about users and their usage of our Services. We may share non-personal or anonymized information about your use of our websites with those third party providers. The third party providers use cookies and tracking identifiers to collect demographic and interest-level information and usage information from users that visit our websites, including information about the pages where users enter and exit the websites and what pages they view and visit on the websites. We do not link information we receive from our third party providers with Personal Information.
Browser Settings
You may set your browser setting to attempt to reject the cookies and tracking identifiers, and you may still use our websites. However, you may be limited in some areas of our websites, or you may have to enter passwords or identifying information more than once.
Why Personal Information is Collected
Limited Purpose: We use Personal Information for the purpose for which you provided it, for example:
- We may use contact and identification information like phone number or address to contact you about our Services or for customer support.
- We use bank information for processing payments and customer support requests.
Lawful Basis: We only collect, use, or store your Personal Information if:
- You voluntarily provide it to us with your specific and informed consent (for example, by agreeing to this Privacy Policy) ;
- To comply with a statutory or contractual requirement, or a requirement necessary to enter into a contract (for example, processing your personal data to ensure that your wages and taxes are paid correctly); or
- We have a legitimate business interest that is not outweighed by your privacy rights (for example, to enhanced security).
We may need, and may require from you, certain Personal Information to provide our Services to you. You understand and accept that we will collect, use, and store your Personal Information based on the business purpose of fulfilling your requests and maintaining records of our Services to you. If you do not provide the Personal Information we need, we will not be able to provide the requested Service.
What Personal Information Is Shared and With Whom
Third Parties
To provide you with access to our services, we may share your Personal Information with the following types of third parties:
- Fraud detection and management services
- Server providers and email providers
- Third-party analytics services such as those of Google Analytics
We do not disclose Personal Information that we collect about you, except as described in this Privacy Policy. We may share Personal Information with third parties who perform services on our behalf based on our instructions. We do not authorize these third parties to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We may disclose your Personal Information to law enforcement or other appropriate third parties in connection with criminal, fraud, infringement, other investigations related to suspected illegal activities, as may be required by applicable law, or to protect the legitimate legal and business interests of Commoneo, LLC.
We sometimes share Non-Personal Information with third parties about our user base. Except as described in this Privacy Policy, we will not give any of your Personal Information to any third party without your express approval.
Third Party Precautions
We take reasonable precautions before sharing your Personal Information with third parties and require that they provide adequate protections.
If third parties are collecting, using, or storing your Personal Information on our behalf, we require that they have a legitimate basis for doing so, reasonably limit their retention and use, and use appropriate security measures regarding your Personal Information.
While we review the privacy and security policies of the third parties we work with, some third parties may provide additional terms in their privacy policies, which may control their use and storage of your Personal Information.
How Personal Information is protected when transferred out of the EU
Place of Business
We may store or process your Personal Information outside of the country where we collect it. Commoneo, LLC has its place of business in the United States of America, and by agreeing to this Privacy Policy, you understand that we will transfer some of your Personal Information to the United States of America.
Transfer Mechanisms
When transferring Personal Information out of the EU, we implement safeguards to protect your Personal Information. We use European Commission approved standard contractual clauses, Binding Corporate Rules, or implement other similar measures required by applicable law.
Data Protection Officer
In compliance with applicable privacy laws, Commoneo, LLC has appointed a Data Protection Officer to monitor whether we are following this Privacy Policy and are able to address any concerns about how we handle your Personal Information.
How Personal Information is Protected
We protect your Personal Information through a combination of collection, security, and retention policies.
We only keep your Personal Information for as long as we need it, unless you agreed to allow us to use it for some other purpose or to comply with any statutory, regulatory, or business obligations. We respect requests to stop processing your Personal Information. This includes keeping a record of your stop processing request indefinitely so that we can respect your request in future.
We use all reasonable methods to keep the Personal Information we collect and use in a secure environment, and we have implemented technical, administrative, and physical security measures that are designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes we review these security procedures regularly to consider new technology and methods. All Customer Data that is taken off-site uses Advanced Encryption Standard (AES) and a digital signature. AES is a state-of-the-art encryption standard developed by the U.S. National Institute of Standards and Technology (NIST) with industry experts and the cryptographic community.
We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In order to ensure adequate security and confidentiality of the personal data, we may apply the following security measures as appropriate:
- Encryption of data in transit;
- Strong user authentication controls;
- Hardened network infrastructure; and
- Network monitoring solutions.
Rights to Personal Information
Right to Access, Correct, Delete, or Restrict Processing
You have the right to:
- Access to and correct or erase Personal Information;
- Restrict processing of your Personal Information;
- Object to processing of your Personal Information;
- Object to your Personal Information being processed based on our legitimate business interests; and
- Lodge a complaint with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred.
You can contact us about any of the rights described in this paragraph, or if you have any questions regarding this Privacy Policy. In some cases, you can review or update your Personal Information stored with Commoneo, LLC by accessing your account online. You may also request that we delete or anonymize your Personal Information. If you choose to have your Personal Information removed from our active databases, we will do so within a reasonable time after your request and we will take reasonable steps to ensure that your Personal Information is not used (except as may be required by law) by Commoneo, LLC after you request such removal or deletion. You have the right to withdraw your consent regarding our use or storage of certain Personal Information.
Special Categories related to Personal Information
Minors
If you are under 13, you may not use our Services. Commoneo, LLC will not knowingly collect, maintain, or disclose any Personal Information from children under the age of 13.
California
California Civil Code Section 1798.83 permits California residents to request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes and the identity of those third parties. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, you may contact us.
Contact
Commoneo, LLC reserves the right to change this Privacy Policy at any time by notifying registered users via email of the existence of a new Privacy Policy, providing a pop-up notice on the Services, posting the new policy on the websites, or any other notification method that is appropriate based on the nature of the change. All changes to the Privacy Policy will be effective when posted, and your continued use of any of the Services after the posting will constitute your acceptance of, and agreement to be bound by, those changes.
Our mailing address is:
Commoneo, LLC
50170 Schoenherr Rd
Shelby Township, Michigan 48315
Our customer service email address is [email protected]
