The latest edition of the Policy can be found by the following address at any time: https://comewel.com/en/privacypolicy
1. The Personal Information of the Users collected and processed by the Company
1.1. The Company collects, processes and stores only the essential information required to provide services in full, including:
1.1.1. Email address (may be stored in the company’s database)
1.1.2. Last 6 digits of your payment card (not stored in the company’s database)
1.2. The Company does not check the authenticity of the personal information provided by users. The Company assumes that the user provides all the necessary accurate personal information about himself/herself.
2. The User’s Payment Card Information
2.1. The Company receives, but NOT stores the user’s payment card information.
3. Why and how the Company uses the collected and processed Personal Information
3.1. Under the Policy, the Personal Information of the users may be used for the following purposes:
3.1.1. To authenticate the User and store the user preferences.
3.1.2. To provide Service Support, in particular, to cancel the subscription or provide the purchase details.
3.1.3. To protect the interests of the Application and the Application users.
4. Sharing and Disclosure of Personal Information
4.1. Except as provided by law, the Company undertakes not to sell, rent, trade, or otherwise disclose Personal Information, traffic data or content of conversations to third parties without explicit consent of the user.
4.2. The Company may disclose the user's Personal information to third parties unrelated to the Company in the following cases:
4.2.1. The User has expressed explicit consent to transfer his Personal Information to third parties.
4.2.2. The transfer of Personal Information is required to provide services to the user and/or to process his Personal Information.
In such cases, the Company claims the third parties to respect the confidentiality of user’s Personal Information while the user gets notified of the transfer of Personal Information to a third party.
4.2.3. Transfer, use, storage or disclosure of Personal Information is reasonably necessary to (а) comply with any applicable laws, other regulations, court decisions, and actual requests from the state security bodies; (b) detect and prevent any fraudulent and criminal activities, security problems and/or assist in resolving operating failures; (c) protect the interests of the Application, the Application Users or third parties in case of an imminent threat of causing any kind of damage.
5. Providing Personal Information by the User
5.1. By filling out the form, you express your consent to provide your Personal Information to the authorized representatives of the Company. In case you don’t agree to provide your Personal Information, please refrain from filling out the form.
6.1. The Company shall inform the user about the application status and may request additional information required to provide the services indicated in Paragraph 3.1.2 of the Policy.
6.2. The Company shall not send any notifications or emails to users except of those indicated in Paragraph 7.1 above.
7. Protection of Personal Information
7.1. The Company shall take all the necessary measures to protect the Personal Information of the users. However, the Company cannot ensure the safety of the devices a user uses to access the Internet (PC, mobile device, etc.) and the confidential information stored on these devices (passwords, account information, etc.)
7.2. The Company strongly recommends that users ensure the safety of the devices they use to access the Internet, and securely store all the sensitive information regarding their accounts.
7.3. You acknowledge and agree that you are solely responsible:
7.3.1. For the safety of the device you use to access the Internet.
7.3.2. For storage of your confidential information.
7.4. You acknowledge and agree that neither the Company nor any of the Application users, nor any other third parties shall not be liable for losses incurred by you due to the fact that you didn’t make sure to keep safe the device you use to access the Internet, disclosed/entrusted to others or improperly stored your confidential information.
8.1. The Company reserves the right to make changes to the Policy at any time without notice. The changes take effect from the date when the latest version of the Policy is published at https://comewel.com/en/privacypolicy