Updated: 01.01.2023
At Сombo.tools we recognize that privacy is very important and value your privacy. You will find below the important information about your rights in relation to your personal data and the explanation of the choices that you have with respect to that information, so please read this Privacy Policy (“Policy”) carefully.
ORISTANE MANAGEMENT LTD (“Сombo.tools”, "Company", “us”, “our”, “we”) provides web-based advertising network, affiliate tracking, targeting, reporting and analytic services (“Services”). Сombo.tools also operates its corporate website https://combo.tools/ (“Site”).
Throughout this Privacy Policy , when we use the words “you”, “your”, or “user”, we mean an individual end user of our Clients (“End users”) viewing ads displayed using Сombo.tools Software (“Software”). Сombo.tools’ Site visitors are referred to as “Visitors”.
By accessing the Site or using our Software, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to your employees, if any.
We are a “data processor” or “service provider” that collects and analyzes End user data at the specific request of our Clients, the “data controllers”. This Privacy Policy explains how Сombo.tools processes
(1) data from End users on behalf of Сombo.tools Clients (“Clients”);
(2) Site Visitor Information.
The data processing within the Demo Version of the Software and the subsequent use of the Software, if the Client chooses to continue access and use of the Software, is governed by the data processing agreement executed between Сombo.tools and the Client. Clients determine the data that they provide to and collect through Сombo.tools; their use, collection, exportation, or any other use of End User data is subject to their respective privacy policies and applicable laws, and regulations.
This Policy does not state the use practices of End User data or policies of our Clients, of the websites or apps on which ads are shown, or of other parties.
Сombo.tools is solely a technology and tools provider. The Clients use the Software and collect and process End User personal information and data, including Collected Information (as defined herein), for the purpose of marketing to individuals (“Personal Data”). For clarification, Personal Data includes Collected Information and Visitor Information (as defined herein).
The Clients own the Personal Data that they provide to and collect through the Software. The collection, retention, processing and other uses of data by the Clients, whether or not in connection with the Software, is governed by their own privacy policies and applicable laws, rules, or regulations. Сombo.tools does not control those Client activities.
Your use of our Services, and any dispute over privacy, is subject to this Policy, the respective terms of use (the “Terms”), between you and Сombo.tools, such as our Terms of Use and any other relevant agreements. The applicable Terms are incorporated by reference into this Policy, including their applicable limitations on liability and the resolution of disputes. By disclosing your personal information to us or using our Services, you understand and agree that Сombo.tools may collect, use, and disclose your personal information in accordance with this Policy and the applicable Terms.
At the instruction of the Clients, Сombo.tools collects the information from End Users (“Collected Information”). We generally collect information in the following ways: if and when you provide information directly to us, automatically through our Services, and from third-party sources. Let’s go over the information that we collect below.
The amount and type of information that we collect information that you provide to us depends on how you interact with our Services. Here are some examples:
Basic Account Information: While you can browse parts of our website without registering, we ask you to sign up for a Сombo.tools account to access certain parts of the Services (e.g., to have access to one of our courses). When you sign up for a Сombo.tools Account, we may ask you for basic personal information such as your email address, first name and last name, organization name, phone number, country/city, state and zip code or other similar contact details to process your registration request, to contact you regarding it and help you with your experience. You can also sign up to receive email newsletters and promotional offers from us by submitting your email address.
Billing Information. When purchasing Services, you will be required to provide additional information that may include a credit card number or other banking or payment information. This information is required by us to verify your identity, to establish your company’s account, to set up your Services and to enable payments for the Services to be made or to invoice you for them.
Service Information. In order to provide our Services to you, to improve them and to enhance your experience, we may collect information that is created or provided by you in connection with your use of the Services, including order information, chat logs, email logs and information about your actions in various client areas on the Site.
Third Party Information. We may obtain information about you from third party or public sources and add it to your account Contact Information. This combined information may be used by us to enhance our ability to provide Services to you, to ensure that we are paid for Services.
We will use your Contact Information and Billing Information to provide Services and to provide you with access to the Services you have ordered, as well as support services, technical updates or updates on changes in our usage policies. The legal basis for us to use your Contact Information, Billing Information and Service Information is the agreements you enter into with us in connection with the Services and performance of these agreements as well as taking steps at your request prior to entering into them.
We may also use any information collected from you: (i) to personalize user’s experience; (ii) to improve our Services in order to better serve you and/or to provide Services more effectively; (iii) to allow us to better service you in responding to your customer service requests, (iv) to ensure continuous improvement and development of the Services; (v) to administer the Site and to diagnose possible problems; (vi) to administer a contest, promotion, survey or other Site feature; (vii) to send periodic emails regarding your order, your use of Services or similar Services you might be interested in.
We may also collect personal information about how you use the Services (e.g., using cookies and pixel tags), such as IP address, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services. We may also use pixels in HTML emails to understand if individuals read the emails we send to them (“Usage Data”). We may combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. (For more information, see the Cookies and Tracking Information section below.)
We use information about you as mentioned above and for the purposes listed below:
To provide and maintain our Services—for example, to set up and maintain your account; to host your profile; to fulfill your transactions; to authenticate users; to perform technical operations, such as updating software; and for other customer service and support related purposes.
To provide you with the information or services that you have requested; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
To further develop and improve our Services—for example, by adding new features that we think our users will enjoy or will help them to create and manage their profiles more efficiently.
To communicate with you, for example through an email, about newsletters, offers and promotions offered by Сombo.tools and others we think will be of interest to you, solicit your feedback, or keep you up to date on Сombo.tools and our products.
To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.
To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Сombo.tools and others.
To personalize your experience using our Services, provide content recommendations, and target our marketing messages to groups of our users.
To conduct audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions. These purposes are based on our legitimate interest in operating our business and maintaining adequate internal records and safeguards.
To protect our business operations and secure our network and information technology assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend Сombo.tools’s legal interests and rights.
To comply with the law or legal proceedings, including responding to subpoenas, court orders, and other lawful requests by regulators and law enforcement, or to national security or law enforcement disclosure requirements.
We may also use your personal information for other purposes, where you have consented.
We may also use aggregate and deidentified information for various research, development, product improvement, analytics and other purposes.
We may disclose information about you as spelled out below:
Subsidiaries and Affiliates: With our affiliated companies whose use and disclosure of such personal information is subject to this Policy.
Service Providers: We may share information about you with our third-party service providers who need to know information about you in order to provide their services on our behalf, or to provide their services to you or your site. This group includes, for example, vendors that help us provide our Services to you (like auditors, advisors, consultants, customer service and/or support providers, payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, our hosting providers, and those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you.
Third Parties: With third parties that provide advertising, campaign measurement, online and/or mobile analytics and related services. These third parties may receive or access browsing history and/or other data about your use of the Sites, in order to help us better reach individuals with relevant ads, measure our ad campaigns and/or to better understand how individuals interact with our Sites over time and across devices.
Legal Requests: We may disclose information to comply with the law or legal proceedings, for example, in response to a subpoena, court order, or other governmental request.
To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Сombo.tools, third parties, and/or others, and/or as evidence in litigation in which we are involved
Aggregated and De-identified Data: We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and/or other purposes.
Sharing for business purposes only: We may provide personal information to third parties to improve our products and services, to operate our business, and to help us market to potential customers. We may share all of the categories of information listed in this Privacy Policy with other companies:
No sale of personal information: We do not and will not sell or allow our service providers to process your personal information for their own use without your express consent, unless the processing of that information is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, protect our property or operations, or enforce the rights and protect the property or operations of our business partners and customers.
Advertising: We may use third parties to send advertisements on our behalf. We may only share a very limited set of personal information required to deliver our advertisements to you (such as an email address to deliver the message to you), and we do not permit these third parties to use or share your personal information to advertise unaffiliated products or services to you. These third parties may also use cookies or similar tracking tools to identify you through your browser usage. While you may disable these tools in your browser settings, you may still receive non-targeted advertisements we sent as part of a general marketing campaign.
Financial and business partners: We may share personal information to facilitate the services we provide to you with our business and financial partners.
Card issuing partners: We partner with third party banks to issue cards to you. Сombo.tools owns and controls the transaction data and other personal information we share with card issuing partners. We share the personal information you provide in your application for a Сombo.tools Account with our card issuing partners to comply with our contractual obligations and to facilitate compliance with their and our regulatory obligations. Our card issuing partners do not sell or use your personal information or use any related data to market or to develop products and services, or for any other purpose not authorized by us.
Credit reporting agencies: We share information about you and your account with credit reporting agencies to verify information about your business, to report on your business’s performance, and to report late payments, missed payments, or other defaults, which in some cases may contain personal information.
Card network partners: Mastercard separately processes information related to your use of your cards. For more information on how Mastercard and Visa handle your personal information, please visit Mastercard’s Global Privacy Notice and Visa’s Global Privacy Notice, respectively.
Сombo.tools partners: We may share transaction data and personal information about you with its financial institution partners and service providers, including banks that we use to help process transactions, to comply with contractual obligations, and allow us to execute on your transaction or investment instructions. We own and control the transaction data and other personal information we share with these partners.
Partnerships and referrals: We may share personal information to facilitate referral partnerships. For example, if you were referred to us through an organization we may provide confirmation to that organization that your company opened a Сombo.tools Account with us, and information relating to your Сombo.tools Account activity solely for the purpose of calculating any referral fees we owe related to the referral.
Sharing authorized by you, your users, or authorized representatives: We continually enhance our products and services by integrating with products and services provided by other companies. For these integrations to work and with your explicit consent, we may need to share your personal information with them. Information we share with these companies will be used and disclosed according to that company’s privacy policy. You should review the privacy policy of any company that has access to your personal information related to the integration with your Сombo.tools Account.
Accounting and expenses integrations: We may offer integrations with many popular accounting services (such as QuickBooks Online, Xero, and Netsuite). We may share information with those services solely as directed by you, your users, or authorized representatives.
Corporate transactions: In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal information and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Сombo.tools may continue to process personal information consistent with this Privacy Policy.
Compliance and compelled disclosure: We may share personal information:
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.
Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
You can block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our Sites may not be available or function properly if you block or disable cookies. Our Sites currently do not respond to “do not track” signals.
GDPR compliance is a shared responsibility between data controllers and data processors.
Combo.tools Сlients are data controllers. Combo.tools serves as a data processor under GDPR, and adheres to the principles and rules of GDPR. Specifically, Combo.tools implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with subprocessors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners. (In addition to GDPR, Combo.tools respects and adheres to similar data privacy laws in other jurisdictions, such as the California Consumer Privacy Act.)
To end users who access the Sites: Combo.tools retains your information for as long as your account is active or as needed to provide you Combo.tools services. Combo.tools applies data retention rules to abide by data minimization principles; such rules are outlined at the of Combo.tools’s secure data support document available here. In most cases, reliance on Combo.tools’s existing data retention rules will satisfy the end user request within a reasonable period of time. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law.
Your data will be processed on the following legal bases:
Under GDPR, you have the right to:
We offer a Data Processing Addendum for all Сombo.tools Сlients and partners that process personal data in the EU, available here. Generally, this Data Processing Addendum should be signed by the Сlients who act as a data controller with regard to Сombo.tools.
If you wish to access, amend, correct, remove, or limit use of your information as it is used for access to the Sites, please contact us at [email protected].
We may work with third-party ad networks, channel partners, measurement services, and others (“third-party ad companies”) to display advertising on our Services and to manage our advertising on third-party sites and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, other identifiers, and general location information; we and these third-party ad companies use this information to provide you more relevant ads and content and to improve and evaluate such ads and content.
You can learn more about the information collection practices and “opt-out” procedures of many third-party ad companies by visiting networkadvertising.org/optout_nonppii.asp. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites from companies that do not participate in the above programs.
Our Services may link to other websites or online services (including those operated by our parent, affiliates, or others) that are not covered by this Policy. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
We may process and store personal information for the purposes described in this Privacy Policy in the Republic of Cyprus, or any other country in which we, our subsidiaries, affiliates, or service providers operate. We will store this information while we continue to provide products and services to you, to operate our business, comply with contractual obligations, and for as long as required by law.
If you ask us to delete specific personal information (see section “Your Rights and Choices About Your Personal Information” below), we will honor your request unless deleting the information prevents us from billing for our products and services, calculating taxes, conducting required audits, or carrying out other legitimate business functions, or we are required by law or contractual obligation to keep that information.
In this section we describe the choices you have regarding our collection, use and handling of your personal information.
Marketing Communications: You may opt out of receiving email marketing communications from us by using the unsubscribe link in any such email we send to you. Please note that we may still send you non-promotional messages relating to material or transactional information about our products and services such as updates to our platform agreement, privacy notices, security alerts, and other notices relating to your access to or use of our products and services.
Application rejection: To comply with legal and regulatory obligations, we retain certain personal information associated with rejected applications for Сombo.tools Accounts.
Exercising your rights and choices: To exercise your choices about your personal information, please contact us at [email protected]. We will need to verify your relationship to the Сombo.tools Account (for example, if you’re an administrator of a Сombo.tools Account) and verify your identity. Verification will require that you verify your email and phone number and provide a copy of a government issued ID to us. We may take additional steps to verify that you are authorized to make the request.
Sale of personal information: We do not sell your personal information.
We use organizational, technical, and administrative measures designed to protect personal information; however, no data security program is entirely secure. Please contact us at [email protected] immediately if you believe that your personal information or any other confidential information that you have provided to us is no longer secure or has been lost or stolen. If we confirm that there has been a breach of personal information or confidential data related to you, we will notify you.
If you are under the age of 18, you may not have a Сombo.tools Account or use our products or services. We do not knowingly process any information from, or direct any of our products or services to children under the age of 18. Please do not provide us with any personal information related to children under the age of 18. If you believe we have inadvertently collected personal information about a child under the age of 18, please contact us and we will take steps to delete this information.
In some circumstances, we may require you to provide us with personal information relating to another person (such as providing us with personal information about your authorized persons or representatives). Do not provide us with any personal information unless you have obtained consent of these persons or you are sure the disclosure of the personal information is otherwise permitted by law or contract. You must inform all other persons whose information you share with us how we process personal information and all other terms of this Privacy Policy.
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically to be aware of and review any updates. We will post any changes to this Policy on our Services.
If you have a question about this Policy, or you would like to contact us about privacy, please contact us at [email protected].
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