Privacy Policy

Published 2023-01-13

The protection of your privacy is important to us, Commend Inc. Therefore, we treat your personal data confidentially and in accordance with the applicable legal provisions, in particular the EU General Data Protection Regulation (GDPR). On this page, we would like to inform you in accordance with Art 13 GDPR about the processing of your data when you visit and use our website www.commend.com ("Website"). "Personal data" is any information relating to an identified or identifiable natural person; such as name, address and e-mail address.

1. Controller

Responsible for the processing of your personal data on our website is:

Commend Inc. (hereinafter: "we", "us")

63 Ramapo Valley Road, Suite 201
Mahwah, New Jersey 07430
Phone: +1-201-529-2425
E-mail: office@commendusa.com

2. What data do we process, for what purposes, and on what legal basis?

2.1 cLibrary

On our website you have the option to register for the cLibrary, where you can access software and documentation related to our products and systems. Once you have registered, we will send you a confirmation e-mail with a link to confirm your registration. After that, your registration will be reviewed by an administrator and approved or rejected. Finally, you will also receive the information about the approval or rejection by e-mail.

For the registration, we need your following personal data for access authorization, since the access is reserved only for customers, dealers and partners.

Access data (user name and password)
Title (gender)
Name (first and last name/ company affiliation)
E-mail address
City (town)
Country

If you want to change your data, you can do it after logging in under "Edit profile" or you can send us an e-mail – Contact.

The provision of the above-mentioned personal data is voluntary, but is necessary for providing access to the cLibrary and thus for the fulfillment of our (pre-)contractual obligations to you (Art 6 para 1 lit b GDPR).

Furthermore, we collect the following usage data in order to analyze the use of cLibrary and to continuously improve our offer and the functionalities:

Last login
Number of logins
Page views
Duartion of use
Downloads

The analysis of usage data is based on our legitimate interests (interest in the analysis to optimize cLibrary and satisfy our customers, Art 6 para 1 lit f GDPR).

2.2 Newsletter

You have the possibility to subscribe to our newsletter via our website. The newsletter is published approximately every one to two months and contains news from the world of security and communication solutions.

All we need for this is your e-mail address. If you voluntarily provide "additional information" about yourself, we will process it for the purposes listed below:

If you also provide your first and last name and title, we will process this data for the purpose of addressing you personally in the newsletter.
In order to provide you with targeted information in the newsletter, we also collect and process information voluntarily provided by you on companies, areas of interest and industry classification.

If you don't provide the "additional information" we will of course still be happy to send you the newsletter. As soon as you have registered for the newsletter, we will send you a confirmation e-mail with a link to confirm your registration.

The processing of your data is based on your voluntary consent (Art 6 para 1 lit a GDPR). We will retain your consent confirmation us for documentation and evidence purposes.

You can revoke your consent at any time and without giving reasons free of charge, for example, by clicking the unsubscribe link located at the end of each newsletter or by sending us an e-mail – Contact. Please note that the the processing carried out on the basis of the consent until the withdrawal is not affected by your withdrawal.

Due to our legitimate interests (Art 6 para 1 lit f GDPR), we record the opening and click behavior anonymously for the purpose of "performance measurement". Specifically, the following information is tracked and generated by the system: Time of delivery, time of opening, duration of opening, email program used (mail client), which link was clicked and the time of the click.

2.3 Contacting us

If you contact us using the form on the website (Contact, Technical Support, Certified Partners) or by e-mail or telephone, the data you provide (name, e-mail address, telephone number, company, address, if applicable, and the content of your message to us) will be processed by us for the purpose of answering your inquiry.

The processing of your data is carried out for the fulfillment of (pre-)contractual obligations (Art 6 para 1 lit b GDPR).

2.4 Registration for training courses and events

You have the possibility to register for trainings and events via our website. For this purpose we need the following information:

Name (first and last name)
Company affiliation
E-Mail address
Number of registrations/ seats
If applicable, address, telephone number and remarks

We process your data exclusively for the purpose of organizing the training or event as well as issuing of participation certificates or the like, if applicable.

The processing of your data (name, company affiliation, email, number of registrations / seats) is necessary for the fulfillment of (pre-)contractual obligations (Art 6 para 1 lit b GDPR).

2.5 Applications

You have the opportunity to apply for a position via our website. For this purpose we process your name, e-mail address and your message to us in the online application form. In addition, you can also upload file attachments (e.g. CV).

We process your data exclusively for the purpose of reviewing your application (Art 6 para 1 lit b GDPR).

3. Web Server Logs

In the course of using our Internet service, connection information is stored in server log files. This information includes:

IP address of the calling system
browser information such as operating system used and screen resolution
accessed website
originating website
time of the visit

We use the log data only for statistical analysis for the purpose of operation, security and optimization of the Website, thus on the basis of our legitimate interest (Art 6 para 1 lit f GDPR). However, we reserve the right to subsequently review the log data if there is a justified suspicion of unlawful use based on concrete indications.

The log data is recorded for the first 3 days incl IP address for development purposes and security-related analyses, such as in the event of hacker attacks. After 3 and up to 30 days, the log files are anonymized and then deleted, unless their retention is required by law or for the defense of legal claims.

4. Cookies

4.1 What is a cookie

A cookie is a small text file that stores internet settings. Almost every website uses cookie technology. It is downloaded by your internet browser the first time you visit a website. The next time you visit that website with the same terminal device, the cookie and the information stored in it is either sent back to the website that generated it (first party cookie) or sent to another website (third party cookie). As a result, the website recognizes that you have been visiting before with this browser and, in some cases, varies the content displayed.

Some cookies are extremely useful, as they can improve the user experience when you return to a website that you have already visited several times. If you use the same terminal and the same browser as before, cookies remember, for example, your preferences, share how you use a page, and adapt the offers displayed more relevant to your personal interests and needs.

4.2 Legal basis for the use of cookies

There are cookies that require your consent before they can be activated on your device and cookies that can be used without your consent because they are technically necessary for the provision of our service ("absolutely necessary cookies").

Absolutely necessary cookies are required for the operation of the website and cannot be disabled in your systems. Typically, these cookies are only set in response to actions you take that correspond to a service request, such as setting your privacy preferences, logging in, or filling out forms. You can set your browser to block these cookies or to notify you about these cookies. However, some areas of the website will then not work. The data processing is thereby necessary for the purpose of data security measures, to prevent misuse and to optimize the website and is therefore based on our legitimate interests pursuant to Art 6 para 1 lit f GDPR in conjunction with Sec 96 para 3 Austrian Telecommunications Act.

We use all other cookies on our website exclusively on the basis of your prior explicit consent pursuant to Art 6 para 1 lit a GDPR. You can give your general consent at the start of using the website by clicking on the button "Accept all cookies" on the cookie banner or separately after clicking on [to be added] where you can select or deactivate each individual type of cookie. If you deselect all cookies, no cookie-based services requiring consent will be loaded.

In the Cookie Manager, you can find specific details about which cookies are activated for which purposes and on what legal basis. The Manager will be displayed when you first visit our website. In addition, you can call it up at any time via the "Cookie Settings" button and change your preferences: Cookie Settings. Here you will also find a daily updated list of cookie providers.

4.3 Manage and delete cookies via the browser

If you want to block or delete cookies, you can make these changes in the browser settings. To manage cookies, most browsers allow you to accept or reject all cookies or accept only certain types of cookies. You can also require the browser to ask you each time a website wants to store a cookie. The procedures for managing and deleting cookies vary depending on which browser you use. To find out how to do this in a particular browser, you can use the browser's built-in help function or, alternatively, visit http://www.aboutcookies.org. This website explains step-by-step how to manage and delete cookies in most popular browsers.

5. to whom do we transfer your data

We transfer your personal data to the following external service providers (processors) to the extent necessary:

to IT service providers and/or providers of data hosting, processing or similar services;
to other service providers, providers of tools and software solutions that also support us in the provision of our services and act on our behalf (incl providers of marketing tools, marketing agencies, communication service providers).

All our processors process your data only on our behalf and on the basis of our instructions for the provision of the services above.

In addition, we transmit your personal data to the following recipients to the extent necessary:

to external third parties to the extent necessary on the basis of our legitimate interests (e.g. auditors, insurance companies in the event of an insurance claim, legal representatives in the event of an incident, etc);
to authorities and other public bodies to the extent required by law (e.g. tax authorities, etc).

If we process your data in a third country outside the European Union (EU) or the European Economic Area (EEA), or if this is carried out in the context of using third-party services, this is only carried out if it is necessary to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. We have implemented suitable and appropriate safeguards to ensure that the transfer of your data to the respective third country complies with data protection requirements (e.g., adequacy decisions, Binding Corporate Rules or conclusion of Standard Contractual Clauses). Upon your request, we will provide you with a copy of these appropriate safeguards if we process or have your data processed in third countries. If there is no sufficient guarantee for a data transfer, the transfer may take place in individual cases based on your voluntary consent for specific purposes.

6. Retention periods

We process your data for as long as it is necessary for the specific purposes. Specifically, we store data related to your registration for cLibrary for the duration of your membership. Your data will be deleted upon termination of the business relationship or if access has not been used for more than three years.

If you have signed up for our newsletter, we will store your data until you revoke your consent or for three years after the last contact. We will store your consent declaration and withdrawal for a period of three years from receipt of your withdrawal.

Data in connection with contacting us will be deleted six months after the contact request has been completed. A contact inquiry is completed when it is clear from the circumstances that the matter in question has been conclusively clarified.

If you register for a training course or event, the data will be stored for different periods depending on the organizer and the event: If, for example, you participate in a progressive certification program over several training courses, which also require recurring recertification in subsequent years, then your data will be retained as long as the certification is upheld. If it is a one-time training or event, your data will be automatically deleted within 30 days after the training or event takes place. If we also require your data for accounting purposes, we will store it for a period of seven years based on our corporate and tax storage obligations.

If you send us an application and we unfortunately have to reject you, we will continue to store your data for eight months (calculated from the date of rejection) for documentation and evidence purposes (Art 6 para 1 lit f GDPR). Your data will then be deleted. If we accept your application, the storage period of your data transmitted to us as part of the application is based on the duration of the subsequent employment relationship.

In addition, we can store your personal data also beyond the periods mentioned, as long as legal claims from the relationship between you and us can be enforced or until the final clarification of a specific incident or legal dispute. The longer retention period is based on our legitimate interests in the enforcement, clarification and defense of legal claims.

7. Your rights

You have the right of access, rectification, erasure and restriction of processing of personal data as well as the right to data portability.

You have the right to revoke any consent you have given for the processing of your personal data. The lawfulness of the processing of the personal data until the withdrawal is not affected by the withdrawal.

You have further the right to object to the processing of your personal data.

If you believe that the processing of your data violates data protection law or your data protection rights have otherwise been violated, please feel free to send us a message. Furthermore, and independently of any prior notification to us, you have the right to lodge a complaint with a supervisory authority.