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Privacy Policy

Last updated: 13 Dec 2021

This Privacy Policy tells you about how Comments.sh collects, uses, discloses and protects data relating to you in connection with our Service (as defined below), as well as your choices regarding our collection and use of this data.

1. INTRODUCTION
a. Overview. Comments.sh offers an online public comment sharing platform where users login and create profiles to participate in conversations with peers and enjoy an interactive experience. Use of our platform and software (collectively the “Service”) is subject to the terms of this Privacy Policy. You further understand that the Service is a public platform and that we or others may search for, see, use, or re-post any of your User Content (as defined in our Terms of Use) that you post through the Service.

b. Applicability and third-party websites and services. This Privacy Policy only applies to the data we collect when you use the Service or view the comments and does not apply to any website that uses the Service or other website linked to from the Service. We are not responsible for the practices employed by websites linked to or from the Service, including Partner Sites. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer applicable, it also does not apply to the Partner Site on which you are commenting. Your browsing activity and interaction with any other website, including those that you link to from the Service, is subject to that website’s privacy policy.

c. Children’s Privacy. The Service is not intended for use by children under the age of 16. We do not knowingly collect or sell personal information from children under 16 or knowingly allow such persons to register for an account. In the event that we learn that we have collected personal information from a child under the age of 16, we will delete it. If you believe that we might have collected personal information from a child under 16, please contact using the information below.

2. THE DATA WE COLLECT ABOUT YOU
a. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data that cannot be linked back to a specific person (anonymous data).

b. We may collect, use, store and transfer different kinds of personal data about you which we have categorized as follows:

  • i. Identity Data includes first name, last name, username or similar identifier, date of birth, email address, telephone number, and mailing address.

  • ii. Technical Data includes internet protocol (IP) address, unique Cookie ID, Device ID, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Service.

  • iii. Usage Data includes information about how you use the Service, and the content of comments that you post.

  • iv. Aggregated Data includes statistical or demographic data for any purpose.

  • v. Special Data We do not intentionally collect any personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, or information about criminal convictions and offences. However, if you make comments using the Service that include such data about yourself it will be publicly available and may be processed by Comments.sh or others.

3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

Direct interactions. This includes personal data you provide when you create an account or leave a comment.

Automated technologies or interactions. As you interact with our Service, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

Log File Information:These server logs may collect Technical Data such as your IP address, browser type, and information about the number of clicks and how you interact with links on the Service, Partner Sites, domain names, landing pages, pages viewed, and other such information.

4. HOW WE USE YOUR PERSONAL DATA

a. We will use your personal data in the following circumstances; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, where we need to comply with a legal or regulatory obligation, where you have provided your consent to such use.

b. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

c. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose: To use data analytics to improve our Service
Type of Personal Data: Technical, Usage
Source of Personal Data: Direct Interactions, Automated technologies, Cookies, Log File
Basis of Processing Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose: To send you newsletters and promotional emails that may interest you
Type of Personal Data: Identity, Technical, Usage
Source of Personal Data: Direct Interactions, Automated technologies, Cookies, Log File
Basis of Processing: (a) Consent. When you have provided explicit consent to our use of personal data to provide you with relevant and personalized content. (b) Necessary for our legitimate interests (to develop our Service and grow our business)

Purpose: To administer and protect our business and this Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of Personal Data: Identity, Technical, Usage
Source of Personal Data: Direct Interactions, Automated technologies, Cookies, Log File
Basis of Processing: (a) necessary to comply with legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers user our Service)

Purpose: To register you as a new customer
Type of Personal Data: Identity, Contact, Technical
Source of Personal Data: Direct Interactions, Automated technologies, Cookies, Log File
Basis of Processing: (a) Performance of a contract with you

5. DISCLOSURES OF YOUR PERSONAL DATA

We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We may also do some limited data sharing in order to evaluate and test our potential data partners. Where such testing takes place, the data is encrypted and hashed before it is shared. Furthermore, such sharing is subject to appropriate contractual provisions and the data is promptly deleted after the testing is completed.

In addition to the above, we may access, preserve, and disclose your personal data, including your Identity, Contact, or Technical data, if we believe doing so is required or appropriate to comply with law enforcement requests and legal process. We may also access, preserve, and disclose such personal data if we believe in good faith that disclosure is necessary to protect yours’, ours’ or others’ rights, property, or safety, or to investigate fraud.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. YOUR CHOICES REGARDING COLLECTION OF YOUR INFORMATION.

a. Your Account. All registered users may review, update or correct the Identity, Contact and Profile data by changing their “user preferences” in their account.

b. Opting Out of Our Newsletters and Promotional Emails. You may opt-out of Newsletters and promotional emails from us at any time by using the opt-out mechanism contained in such emails (also referred to as “unsubscribe”). You may also unsubscribe or manage your email subscription from your account. You will still receive transactional emails necessary for the Comments.sh service to function, these include, but may not be limited to, emails confirming you created a new account, emails helping you reset your password etc.

c. Declining Cookies. If you do not want to accept our cookies, you can adjust your browser settings to decline cookies. You should note, however, that certain areas of the Site may not operate properly if you decide not to accept cookies.

7. DATA RETENTION.

a. We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

b. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. SECURITY.

a. Comments.sh uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Comments.sh. Comments.sh is not responsible for the functionality or security measures of any third party.

9. Your Rights.

Under certain circumstances and depending on where you are based, you have rights under privacy laws such as the CCPA (California), GDPR (Europe, Brazil), PIPEDA (Canada), or others in relation to your Personal Data. This section describes these rights and explains how to exercise them. Note that Comments.sh allows any person to exercise the rights listed below and Comments.sh will not take any action against you for exercising your privacy rights.

You have the right to:

i. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you in a readable format.

ii. Request correction of the personal data that we hold about you that is inaccurate.

iii. Request erasure of your personal data. This enables you to ask us to delete or remove personal data from our systems.

iv. Object to processing of your personal data (we will treat this as a request for deletion).

v. Request restriction of processing of your personal data (we will treat this as a request for deletion).

vi. Request the transfer of your personal data to you or to a third party (we will treat this as an access request).

vii. Withdraw consent at any time (we will treat this as a request for data deletion).

How To Make a Valid Request If you wish to exercise any of the above rights please click here . You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must contain information that permits us to reasonably verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a consumer request to verify the requestor’s identity or authority to make the request. This is a security measure to ensure that personal data is not disclosed to an unauthorized person. Furthermore we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. If your request cannot be fulfilled, we will inform you of the reason.

10. GENERAL

a. Contact. If you have any questions about this Privacy Policy, please email us at [email protected]

b. Changes to Privacy Policy. Comments.sh may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the bottom of this page. Your continued use of the Site following the posting of any changes to this policy means you accept such changes.