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Data Protection Policy and Terms of Use

Protecting your privacy is important to us. This is why we treat your personal data confidentially and in accordance with applicable legal requirements as set forth in the EU’s General Data Protection Regulation (GDPR). This page on data protection is to inform you about essential aspects regarding the processing of personal data on our web site.

By “personal data” we mean all data pertaining to the personal or material circumstances of a natural person. Personal data collected on our web site are used exclusively for company-internal purposes.

To use services provided on our web site, you may be asked to provide personal details. However, whether or not you want to provide this information is up to you. By providing your personal details – e.g., to log into the Customer section (cLibrary) or to subscribe to our newsletter – you consent to Commend storing and using your personal data for these purposes. In doing so, you also have the option of consenting to the sharing of your personal data with third parties specified in the declaration of consent. If you do so, your data may be transferred to these third parties. Otherwise your personal details will not be made available to third parties. Your consent is voluntary and can be revoked at any time.

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1. Controller

Commend Business Hub Asia is responsible for processing your personal data. See the “Contact” page for our contact details.

2. cLibrary

2.1. General Information

Our web site offers you the opportunity to register for access to the cLibrary, our repository of software and documentation on our products and systems. Once you have completed your registration, we will e-mail you a confirmation message with a link for confirming your subscription. Your registration will be reviewed by an administrator, who will either approve or decline it. You will then be notified by e-mail whether or not your application has been approved.

2.2. Consent

To register, we would ask you to provide the following personal details so we can verify your access permission, as access is restricted to customers, dealers and partners.

  • Access credentials (user name and password)
  • Salutation (sex)
  • Name (first, last / company affiliation)
  • E-mail address
  • City
  • Country

By registering you consent that the data you provided may be used in connection with managing your access to the cLibrary. Should you wish to change your data, you can do so under “Edit Profile” after logging in, or by e-mailing us – Contact.

You are also welcome to sign up for and consent to receiving our newsletter. However, this consent is not necessary to register for cLibrary access.

2.3. Withdrawing consent

You may withdraw your consent at any time and without giving reasons by going to “Edit Profile” and deleting your existing profile, or by e-mailing us – Contact. We will then delete your data without delay. 

2.4 Analysis and processing of personal data

To be able to optimise our services, the following details will be collected while you use our web site: last login, number of logins, page impressions, time spent on page, and downloads. In case your last login dates back more than three years, we will assume that you no longer require access and will delete your data automatically.

Your data will be stored and processed exclusively for the purpose of accessing the content of our cLibrary. Note also that these data will be processed exclusively within the European Union and that they will not be shared with third parties or cross-referenced with other data.

3. Newsletter

3.1. General Information

You are welcome to subscribe to our newsletter via our website. Once you have completed the subscription process, we will e-mail you a message with a link for confirming your subscription.

3.2. Consent

All we need is your e-mail address and your consent to receiving the newsletter. To be able to provide you with relevant information, we also collect and process volunteered details.

  • Volunteered information: Title, name (first, last), sex (female, male) company, areas of interest, and industry affiliation

By subscribing to the newsletter, you consent that all the data your provided for receiving the newsletter may be used for advertising purposes. 

3.3. Withdrawing consent

You may revoke this consent at any time and without giving reasons by clicking the Unsubscribe link provided at the end of each newsletter. Alternatively, you may e-mail us – Contact. We will then instantly delete your data pertaining to your newsletter subscription.  If you want to change your data, you can do so by clicking the “My data” link provided at the end of each newsletter, or by e-mailing us – Contact.

3.4. Analysis and processing of personal data

We use the mailworx software for sending our newsletters and analysing reader response. Mailworx tracks page impressions and clicking behaviour. The following information will be tracked: Time of delivery, time and duration of page impression, IP address, e-mail software (mail client).

These details will be captured and processed for the exclusive purpose of sending recipients tailored and relevant content provided by Commend. Note also that these data will be processed exclusively within the European Union and that they will not be shared with third parties or cross-referenced with other data.

4. Contact form

Whenever you contact us by completing a form on our web site (Contact, Technical Support, Certified Partners) or by e-mailing us, the details you provide will be stored on our servers for a maximum of six months to enable us to respond to your query and possible follow-up questions. We will not forward these data without your consent. 

5. Registering for trainings and events

5.1. General Information

On our web site you have the opportunity to sign up for training courses and events. 

5.2. Consent

For this purpose, we need the following details and your consent that all data provided may be processed in the context of organising the training course or event:  

  • Name (first, last / company affiliation)
  • E-mail address
  • Number of participants/reservations
  • Volunteered information: Address, post/ZIP code, city, country, telephone, remarks

The data retention period will vary depending on the event and the organiser. For example, if you register for a multi-level certification programme that spans several training courses and requires a regular annual re-certification, your data will be retained until you withdraw your consent. In case of one-time training courses or events, your data will be deleted automatically within 30 days after that training course or event.

5.3. Withdrawing consent

You may withdraw your consent at any time and without giving reasons by e-mailing the event organiser (see the Events page for contact details). After the event, the organiser will immediately delete your data pertaining to the event. Note also that these data will be processed exclusively within the European Union and that they will not be shared with third parties or cross-referenced with other data.

6. Job applications

The data you have specified or provided to us will be kept strictly confidential and will be used exclusively within our company for purpose of processing your job application. Your data will never be shared with third parties.

You may withdraw your consent to the storage and use of your data at any time by e-mailing us – Contact.

7. What is a cookie?

A cookie is a small text file used for storing Internet settings. Cookie technology is used on virtually every web site on the Internet. A cookie is downloaded via your Internet browser when you visit a website for the first time. Whenever you visit that web site with the same device, the stored cookie and its content will be transmitted either to the web site that created it (first-party cookie), or to an associated web site (third-party cookie). This allows the web site to detect that your browser has loaded it before. In some cases, a different content may be displayed based on that information. 

Some cookies are quite useful, as they may improve your user experience when you re-visit the same web site. If you are using the same device and browser as during your first visit to the web site, the cookies will identify your preferences or the way you use a web page, so that the offers shown on the page can be customised to suit your individual needs and interests. 

Some cookies (also known as “strictly necessary” cookies) enable functions that are needed to use the web site properly (e.g. download basket). These cookies are used exclusively by Commend and are therefore called ‘first-party cookies’. The use of strictly necessary cookies does not require your express consent.

NameDescriptionExpires
pxa_cookie_warningWhen visiting our web site for the first time, you will be notified at the bottom of the page about our privacy policy. The cookie called “pxa_cookie_warning” prevents this notification from being displayed every time you visit the Commend web site to provide a user-friendly, uninterrupted surfing experience.1 year
ipandlanguageredirect_preferenceBased on your IP address, the appropriate country page will be suggested to you. If you select this or any other country page, this selection will be stored in this cookie for one month for future visits.1 month
fe_typo_userThis cookie will be set for the time of your visit every time you log into our website cLibrary Online to access software and documentation and is needed for the functionality of this space (e.g. download basket).Session

Cookies which by legal definition are not strictly necessary to use the web site can serve many important purposes. Without these cookies, certain functions intended for your surfing convenience – such as automatically filling in web form details – would not be available.

This web site also integrates third-party content, such as Youtube videos. These third parties may also store cookies while you are visiting our web site. They do so to provide them with certain information, e.g., that you have visited a Commend web page. Please see the web sites of the respective third parties for further information about their cookie usage policies. If you decline to provide or withdraw your consent to the storage of consent-requiring cookies, you will only have access to those functions on our web site that can be accessed without these cookies. In this case you will not be able to access the sections of our web site which integrate third-party content that requires third-party cookies. You will be notified of this by an information message to that effect. In case you do want to access such third-party web content after all, you can do so, provided you consent to the use of consent-requiring cookies. If you wish to completely suppress the use of any cookies, you can do so via your browser’s configuration settings. 

Managing and deleting cookies

If you want to block or delete cookies on your computer, you can do so via your browser’s configuration settings. As for managing cookies, most browsers offer an option to accept or decline all cookies, or only specific ones. You also have the option of being prompted every time a web page wants to store a cookie on your system. The methods for managing and deleting cookies may vary depending on your particular browser. To find out how to manage or delete cookies on your browser, we suggest you check your browser’s help function or visit http://www.aboutcookies.org, where you will find step-by-step instructions on how to manage cookies on the most common browsers. 

If you delete all of your stored cookies, you will have to repeat the opt-out process. This also applies if you are visiting our web site using a different computer. 

In case your local Internet security settings are set to a high level where cookies are blocked, we will not be able to process your opt-out request. In that case, you will be notified accordingly; you can then re-try the opt-out procedure with lower security settings where cookies are accepted.

8. YouTube Videos

The web site contains embedded videos and plugins provided by service provider YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is legally represented by Google Inc. at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Whenever a YouTube video is played or a still frame of a video is shown on our web site, a communication connection will be established with the corresponding YouTube server to exchange various data. These include the IP address of your computer, as well as previously stored cookies and information stored during previous contacts with YouTube. If no data has been stored before, the service will set an initial cookie on your computer. Whenever you contact a YouTube service, that service will also receive information about your YouTube account, in case you have one. When you interact with the video (e. g., by clicking the start, pause or stop button), details about these interactions will also be transmitted to the provider. You can terminate the data processing session by visiting a page that has no video content and deleting all cookies from your computer.

Further information about YouTube’s data processing and data protection policies is available at https://policies.google.com/privacy.



9. etracker – Statistical analysis of the use of this website

The provider of this website uses the services of etracker GmbH, Hamburg, Germany (www.etracker.com) to analyse usage data. Here, cookies are used which enable the statistical analysis of the use of this website by its visitors as well as the display of usage-relevant content or advertising. Cookies are small text files that are stored by the Internet browser on the user's device. etracker cookies do not contain any information that could identify a user.

The data generated with etracker is processed and stored by etracker solely in Germany by commission of the provider of this website and is thus subject to strict German and European data protection laws and standards.In this regard, etracker was checked, certified and awarded with the ePrivacyseal data protection seal of approval.

The data is processed on the legal basis of Art. 6 Section 1 lit f (legitimate interest) of the EU General Data Protection Regulation (GDPR).Our legitimate interest is the optimization of our online offer and our website. As the privacy of our visitors is very important to us, etracker anonymizes the IP address as early as possible and converts login or device IDs into a unique key with which, however,no connection to any specific person can be made with. etracker does not use it for any other purpose, combine it with other data or pass it on to third parties.

You can object to the outlined data processing at any time provided it is related to your person. Your objection has no detrimental consequences for you.

Further information on data protection with etracker can be found here.

10. Google reCaptcha

To prevent computers from filling in our web forms, we are using Google’s reCaptcha service. With this service Google checks the following data to determine if the input is coming from a human or computer: IP address of the terminal device, reCaptcha enabled web page being accessed, date and display time (duration), browser and operating system used, Google account details (if you are logged in via Google), mouse movements within the reCaptcha areas, and image identification tasks. We have a legitimate interest in having this data processed in order to ensure the security of our web site and to protect us against automated input and cyber attacks. 

11. Web server logs

11.1 Purpose and legal basis

When accessing our Internet content, the corresponding connection details will be documented in the server log files. 

These details include:

  • IP address of the accessing system
  • Browser details, such as operating system and screen resolution
  • Web site being accessed
  • Referring web site
  • Time of access

We use log files only to enable statistical analyses for purposes of providing, securing and optimising our web content. However, we reserve the right to inspect log files retroactively in case of reasonable suspicion of illegal use based on concrete evidence.

11.2 Storage time

The details, including the IP address, will be logged for the first three days and will be used for development purposes and to enable security-relevant analyses, as in the case of cyberattacks. After three days the log files will be stored in an anonymised format for up to 30 days and then deleted.

12. Your rights

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

You also have the right to withdraw your previously given consent to the processing of your personal data. The lawfulness of the processing of personal data up to the time of your withdrawal will remain unaffected by the withdrawal.

You further have the right to object to the processing of your personal data for direct mailing purposes. If you do so, your personal data will no longer be processed for direct mailing purposes. 

Should you have reason to assume that the processing of your data might violate data protection laws or that your right to data privacy has been otherwise violated, you have the right to appeal to the supervisory authority. 

13. General legal notice

Commend is a registered trademark of Commend International GmbH. All other products or company names mentioned on this web site are brands or registered trademarks of their respective owners. 

All texts, technical data, images, and other material provided on this web site represent non-binding information and can at no time and under no circumstances whatever form the basis, content or subject matter of a contract. Any technical or other changes, including changes in the availability of individual products, are expressly excepted. 

Commend takes great care to ensure that the content on this web site is correct and up to date. However, Commend accepts no liability for the completeness, accuracy or up-to-dateness of the content.

14. You are welcome to contact us at the following address

Entity responsible for data processing in accordance with Article 4, No. 7, DS-GVO: 

Commend Business Hub Asia

TKH Security & Airport Solutions Asia Pte Ltd
25 Tai Seng Avenue
Office #05-01
Singapore 534104

Tel: +65 6272 2371
E-mail: order@tkhsaa.com.sg