This Privacy Policy (“Privacy Policy”) describes how Composz LLC having its registered office at 121, HAUT BRION AVE, NEWARK, DE 19702 (hereinafter referred to as “Composz”, “we”, “our” or “us”) collects, uses, stores, shares and protects the user information in connection with the user’s (hereinafter referred to as “you”, “your” or “user”) use of our services throughout the Platform. By accessing our website or using our Services, or by signing up with us, you agree to our Terms and Conditions (HyperLink) and Privacy Policy, both of which are electronic record in the form of electronic contract and do not require any physical, electronic or digital signature and is a legally binding agreement between You and our Company. Further, by sharing your details with us, you also agree to receive e-mails including newsletter, campaign updates, advertisements, inter-alia with regard to our Platform. IF YOU DO NOT AGREE TO BE BOUND BY THIS AGREEMENT YOU MAY NOT ACCESS OR USE THE PLATFORM.
What does this policy cover? Summary: This policy sets out how Composz collects, stores, shares and uses the information that we collect about you when you use the Composz Services. This policy also explains the choices that you can make about the way that we use your information. This Privacy Policy covers our usage of material as mentioned in the policy that is shared by you with us in furtherance of using the Service. This policy also covers treatment of any personally identifiable information shared with us. This policy does not apply to the activities of organizations not owned or controlled by us, or to people who are not employed or managed by us.
1. Information we collect and its use We may collect the following types of information about you: a. Information you provide us directly - Personally Identifiable Information
In order for you to use our Platform and Services, we might require you to input on our Platform certain personal information which may include without limitation your location, name, address, contact details, professional details, payment details, bank account numbers, in certain cases, your Personal Account Number and other personal information that may be required for the use of the Platform from time to time. If you communicate with us by, for example, e-mail or letter, any information provided in such communication may also be collected by us. We collect messages you send us through the Service, and may collect information you provide in User Content you post to the Service (such as text and photos you upload to use in your designs). We use this information to operate, maintain, and provide the features and functionality of the Service to you, to correspond with you, and to address any issues you raise about the Service. In case you don’t wish to provide your personal identifiable information to us, you might not be able to access our Platform or use our Service.
b. Non-Personally Identifiable Information
We also collect non-personally identifying information that your browser makes available whenever you visit the Website. This information includes without limitation your IP Address, Domain Servers, hardware specs, browser type, browser language, the date and time of your query and one or more cookies that may uniquely identify your browser, inter-alia, COOKIES. A cookie is a text file stored by a web server on a computer or mobile device to collect standard internet log information and visitor behaviour information. Cookies are unique to the browsers or mobile application you use, and enable websites to store data such as your preferences or items in your shopping cart. Cookies allow websites/platforms to remember your settings such as language, font size on your computer or mobile device, or other browser preferences. We may collect information from you automatically through cookies or similar technology when you visit our website to improve user experience. If you want to disable cookies you need to change your website browser setting accordingly. The settings depend upon the browser you are using.
c. Location Data
We receive information from you that helps us approximate your location. We may, for example, use an address submitted by you while setting up your profile, IP Address, domain servers or hardware MAC address received from your browser or device to determine your approximate location and other information with respect to your device, interaction of Your device with the Platform (“Traffic Data”). We may also collect location information from devices in accordance with the consent process provided by your device.
d. Log file information Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
2. How do we use your collected Information? Any of the information we collect from you may be used in one of the following ways:
a. Creating an Account: We use your personal data such as your name, Date of birth, email address and so on, to help set up your account and, if necessary, to contact you (according to your preferences) via your registered contact information in connection with the management and operation of your account.
b. To improve our Platform: We continually strive to improve our Platform offerings and develop new Service offerings for the Platform, this enhancement is based on the information and feedback we receive from you and further we may use the information for the further development of growth and business strategies and data collection.
c. Providing you with the required Service: We use the information that you provide us to provide the Service to you. This includes allowing you to log in to Composz, operating and maintaining the Service, giving you access to your designs and billing you for transactions that you make via the Service. We may also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.
d. To monitor and analyse use of the Service/Platform: This is done to ensure smooth running of the Services technical administration and to increase the Service functionality and user-friendliness and to provide you with a reliable environment.
e. For data analytics: We use information about you to help us improve the Composz Service and our users’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.
f. To improve customer service: Your information helps us to more effectively respond to your user service requests and support needs and to easily communicate with and keep you updated of our latest updates to our Services and special offers.
g. To promote and drive engagement: We use your contact information to get in touch with you about features and offers relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences.
h. We may use the information to manage our relationship with our partners, investors and advertisers, if required ,however, the user can reach out to us at privacy@composz.com if it wants us to cease sharing its information to send periodic emails: The email address as provided by you, may be used to send in information and updates pertaining to the Platform and Services, in addition to receiving occasional Company news, updates, related service information, etc. to be able to tailor the Services to one’s specific needs if feasible, for convenience of users and communication with them, and as may be required by law.
i. User Security: To maintain privacy and security of your account and its details thereof.
j. For matters that we are required to use your information by law: Composz will use or disclose your information where we reasonably believe that such action is necessary to: comply with the law and the reasonable requests of law enforcement; to enforce our Terms of Use or to protect the security or integrity of our Service; and/o to exercise or protect the rights, property, or personal safety of Composz, our Users or others.
k. Dispute Resolution: We may also need to process Personal Data about you to meet our internal administration requirements and for matters such as dispute resolution.
3. Disclosing your information a. We reserve the right to disclose personally identifiable information and/or non-personally-identifiable information which we believe, in good faith, is appropriate or necessary to enforce our terms of use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our web site, and to protect the rights, property, or personal safety of ours, our users or others.
b. We do not transfer your personally identifiable information to outside third parties, unless, such transfer is essential to the usage of services by you on the Platform.
c. The information may be shared, only to the extent required, with trusted third parties including without limitation, our group and other affiliated companies, payment service providers, auditors, event collaboration partners, Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations, auditors, financers and any party/entity who assists us in operating our Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
d. We may use and disclose to third parties, information we collect in aggregated, non-personally identifiable form for research and informational purposes and to help us make sales, marketing and business decisions for marketing, advertising, or other uses.
e. We may share Personal Data with third parties (which will also be acting as controllers in respect of that Personal Data) with whom we are under a legal duty to do so or if it is required to enforce or apply our contracts or to protect the operation of our website, or the rights, property or safety of us or others.
f. We do not sell or trade your personal information.
g. Some of the third parties that Composz may share your personal information with include providers who assist Composz with functions such as: Billing; Customer support and customer management; Email services; Hosting and storage; Analytics etc.
h. We might also share your information with third parties in certain circumstances, such as in a situation where we are required to do so as a result of a court order, subpoena or other legal requirement;
4. Change of Control In the event of the change of control of the Company or a business transition, such as, reorganization, merger, demerger, acquisition, or sale of assets, your information may be transferred to the successor organization. You will be notified of any such deal and your information would remain subject to the commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.
5. Information Storage a. Permission to Use Information: By submitting your personal information, you agree to its transfer, storage or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
b. Data Retention: We only retain your personal data for as long as your account is active or otherwise for a limited period of time as long as we need to fulfil the purposes for which we had initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes and enforce our agreement as required by the applicable law.
c. Password: Where we have given you (or where you have chosen) a password which enables you to access certain Services or specific areas of the Platform, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.
d. Disclaimer: Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us via the Internet; any such transmission is at your own risk.
6. Keeping your information safe Composz cares about the security of your information, and uses appropriate 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 Composz, at all times. However, Composz cannot ensure or warrant the security of any information you transmit to Composz or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Composz Service, such as social networks. Composz is not responsible for the functionality or security measures of any third party.
7. Retention, Modification and Deletion of Personally Identifiable Information a. Retention: If you have registered with an account on our Platform, we will retain your Personal Information during the period your account is active. In addition, we will retain your Personal Data for additional periods, to enable us to meet our legal obligations under applicable laws or regulations, such as the applicable regulations, Know-Your-Customer and Anti-Money Laundering regulations. In addition, we may retain your Personal Information for longer periods, provided that retaining such information is necessary for our legitimate interests, such as fraud prevention and record keeping.
b. Deletion: In order to delete the personally identifiable information including but not limited to the contact details, passwords among other things that you submitted, you can notify us that you wish to delete your personally identifiable information or any part thereof contained at our databases.
c. Modification: If you wish to modify or update your personally identifiable information, use the application interface.
Please note that deletion of your personally identifiable information from the Company’s database will not prevent the Company from using gathered anonymous information.
8. Control on your information You may control your account information by logging into your account and changing your personal information. You can also choose to stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications or by writing to us on our mail. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices)
9. Third Party Links Occasionally, at our discretion, we may include or offer third party products or services along with our services and products. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked third-parties. Nonetheless, we seek to protect the integrity of our product and services, and welcome any feedback about these. 10. How long we keep your information
Following termination or deactivation of your User account, Composz will retain your profile information and User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, Composz will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.
11. Terms and Conditions
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our Website and which complements the Privacy Policy at www.composz.com
12. California users’ Privacy Rights
Californian users of Composz have additional rights afforded to them under the California Consumer Privacy Act (CCPA).
Categories of personal information collected by Composz For more details about the personal information Composz has collected in the past year, please see section 1 “Information we collect and its use”. For details on how we use that information, and who we share it with, please see section 2 “How we use your information” and section 3 “Sharing your information”.
Composz does not “sell” (as defined in the CCPA) the personal information of Composz users.
Making a request in relation to your personal information
The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):
• Request to access the personal information Composz has about you; and • Request that Composz delete all of your personal information.
California users may make a request by contacting us at privacy@Composz.com. We will authenticate your request using the email address associated with your Composz account and if necessary, proof of residency.
13. User Rights Depending on the applicable law you may have the following rights in relation to your personal data:
a. Right to access your personal data being processed by us.
b. Right to rectify any discrepancy, inaccuracy in your personal data or complete any incomplete details.
c. Right to delete or remove your personal data in certain circumstances.
d. Right to restrict or object to processing of your personal data in certain circumstances, such as data being used for marketing purposes or for any other activities, we will comply with your request unless we have reasons for lawfully retaining data about you. With respect to the right to withdraw your consent, however, please note that exercise of any right will not affect the lawfulness of processing based on your prior consent.
14. Change in Privacy Policy We reserve the right to change this Privacy Policy at any time and if we decide to change our privacy policy, we will update the same on our website. Furthermore, please note that any changes made to this Privacy Policy are effective as of the stated “Last Updated” date, and your continued use of the Platform and Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you with a notice on our website and/by sending an email to the email address associated with your Composz account. We recommend that you check this page from time to time to inform yourself of any changes.
15. Applicable Law and Jurisdiction By visiting this Platform, you agree that the laws of Delaware without regard to its conflict of laws principles govern this Privacy Policy and any dispute arising in respect out of or in relation to this Agreement shall be submitted to the sole jurisdiction of the courts of law at Delaware.
16. Be Vigilant and Circumspect Even the best policy can't protect your online privacy and security in all circumstances. Unscrupulous advertisers, hackers, and scam artists are constantly searching the Internet looking for new targets. Your best protection is to understand the limits to privacy on the Internet and be vigilant in all of your online activities. Beware of scams in which persons unknown to you request your screen name, password, or credit card information. Make sure you verify the identity of anyone asking for personal information. Always monitor your children's online activities and educate them as to the rules for safe Internet use. As always, if you have any questions, please feel free to contact us with further questions.
17. Contact us
If you have any questions or concerns about this Privacy Policy or the Service, or wish to make a complaint please write to us at: privacy@composz.com
This statement of the aforementioned Privacy Policy is effective March 1st, 2022.