Privacy Policy

Comen and its affiliates and subsidiaries ("Comen", "our", "we" or "us") respect your rights to privacy and personal data protection. Comen appreciates the interest you have shown in our company, products and services by visiting our websites such as en.comen.com or other related communication channels, including, but not limited to, our social media pages, channels, mobile apps and/or blogs (together "Comen Pages"). This Privacy Notice applies to all the Personal Information Comen collects online and offline when you interact with Comen, such as when you visit Comen Pages, when you use the products or services offered by Comen, when you purchase products of Comen, when you subscribe to newsletters and when you contact our customer support, either as a visitor, a customer or a potential customer, or an agent of our suppliers or business partners, etc.

We may also provide you with separate privacy notices to inform you how we collect and process your Personal Information for some specific circumstances like products, services or projects offered by Comen. Such separate privacy notices shall in principle prevail over this Privacy Notice if there is any conflict or inconsistency between the separate privacy policies and this Privacy Notice, unless mentioned or agreed otherwise.

The term “Personal Information” in this Privacy Notice refers to information relates to you or allows us to identify you, either directly or in combination with other information that we hold. We encourage you to keep your personal settings and Personal Information complete and current.

We may obtain personal information through the Channels. The types of personal information we may obtain include:

• Contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
• Biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
• Location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;

We collect this Personal Information to help you complete your purchase and/or registration of your product and/or services. We may contact you via email, SMS and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with the best, personalized experience, we may analyze and combine all information associated with your Data and data about your interactions with Comen. We also use this information to track the effectiveness of our marketing efforts.

We may use the personal information we obtain to:

• Communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
• Conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
• Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
• Engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• ▪Provide customer support;
• Process, evaluate and respond to requests, inquiries and applications;
• Administer and register participants in our courses;
• Provide investor services;
• Conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• Operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• Verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use);
• Maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

The legal basis for Comen processing your personal information as described above will typically be one of the following:

• Your consent;
• Performance of a contract with you or a relevant party;
• Our legitimate business interests; or
• Compliance with our legal obligations.

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection. We may share your Personal Information with our affiliates and subsidiaries within the Comen Group for the purposes described in this Privacy Notice.

• We may share your Personal Information with our service providers, in accordance with this Privacy Notice and applicable laws, in order for them to assist us in providing certain services, such as website hosting, information technology and related infrastructure provision, cloud service, order fulfilment, customer service, email delivery, auditing and other services. We will require these service providers to protect your Personal Information that they process on our behalf with contract or other manners.
• We may share your Personal Information with third parties, for them to send you marketing communications, if you agreed to receive marketing communications from them.
• We may also share your Personal Information with our business partners where it is necessary for the purposes listed in this Privacy Notice, for example where we may sell a product or offer certain services to you together with our business partners.
• We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
• In addition, Comen may also share your Personal Information to a third party (including any agent, auditor or other service provider of a third party) in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Subject to applicable laws and regulations, you may have the following rights in relation to your Personal Information we hold: access, rectification, erasure, restriction on processing, objection to processing, withdrawal of consent, and portability. More specifically, you could submit a request to access certain Personal Information we maintain about you; request us to update, correct, amend, erase or restrict the processing of your Personal Information. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your Personal Information on legitimate grounds relating to your situation, and we will apply your preferences going forward as appropriate. Besides the options available in various Comen Pages, such as the unsubscribe option contained in promotional emails, to request to exercise these rights, you may also directly contact Comen as indicated in the Contact Us section of this Privacy Notice.

We will respond to your requests in accordance with applicable laws and we may need to ask you to provide additional information to verify your identity. Please also understand that under some circumstances we may not be able to respond to your requests for some lawful grounds under applicable laws, for example where the response to your requests may make us violate our legal obligations.

In your request, please make clear what Personal Information you would like to access or have changed, whether you would like to have your Personal Information limited from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

Contact us at info@szcomen.com if you have any questions, comments, concerns or complaints related to your Personal Information held by us or in case you wish to exercise any of your data privacy related rights. Please note that this email address is strictly for privacy related queries.

Alternatively, you always have the right to approach the competent data protection authority with your request or complaint.