Effective date: June 29, 2021
By using or accessing our Services, you acknowledge that you accept the practices and policies outlined below.
Table of Contents
- Information We Collect
- How We May Share Your Information
- Retention of Information
- Your Rights in the Personal Data You Provide to Us
- Deleting Your Data
- Contact Information
Information We Collect
We collect the following categories of information, some of which might constitute personal information:
- Account Information. In order to use Comm, you will be required to create an account, and in doing so, will be required to provide a username and password to us. We only store salted and hashed versions of your password – we never store the plaintext version. No other information is required to create an account and we do not want you to provide any other information.
- Updates About the Services. If you choose to receive updates on Comm’s progress, you will be required to provide your email address to us. These email addresses will not be associated with any accounts, and will not be used for any purpose other than to provide updates on Comm.
- Time Zone Detection. When responding to a web request, we use the requester’s IP address in order to determine which time zone to render timestamps in. We do not store these IP addresses or associate them with specific accounts.
- Security, Fraud and Abuse. In order to detect and prevent abuse of our Services and cyberattacks, we keep track of request metadata, which includes requests made by IP addresses as well as the frequency of those requests. This data is only stored on a short-term basis and is never associated with specific accounts, even if the requests themselves originate from or are associated with specific accounts. Additionally, we may view and block certain IP address ranges as necessary to comply with applicable United States export control laws and regulations.
- Crash Reports. If you choose to send us a crash report, we may collect data from such reports for purposes of debugging and system maintenance. These reports contain operational information such as telemetry data (e.g., information with respect to the recent connection between the client and server), metadata (e.g., time stamps from messages sent in a conversation or chat), and device data (e.g., your device’s operating system) but never contain the content of your messages.
- Push Notifications. If you choose to allow push notifications to your device, your device’s operating system’s provider will know that you are using the Services and may be able to see the content of the messages you transmit using the Services. We only collect push tokens required to send you such notifications and these tokens do not permit us to access or view the content of your messages.
- Contact List. If you allow us to do so, we can discover which contacts in your address book are Comm users by using technology designed to protect the privacy of you and your contacts. If you opt to discover other Comm users in your contact list, phone numbers from the contacts on your device, as well as your own phone number, will be hashed and transmitted to Comm in order to match you and your friends on the Services. Since this contact information is hashed, Comm cannot view or access the plaintext version.
- Cookies. We only use a single cookie per user in order to authenticate a user as being logged in to Comm. Most browsers allow you to decide whether to accept these cookies and whether to remove any cookies already on your device. If you disable these cookies, you will not be able to stay logged into Comm.
- Content. Other Comm users may have access to all or some of the Content owned by you. However, as this Content is end-to-end encrypted, we have no ability to access, view or control your Content. For more information on how Comm works, please click here.
- Anonymized Data. We may create aggregated, de-identified or anonymized data from the information we collect from you, including by removing information that makes the data personally identifiable to you. We may use such aggregated, de-identified or anonymized data for our own lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not use such data in a manner that could identify you.
How We May Share Your Information
We have no access to your Content and therefore have no ability to share it. As for the very limited information we do collect, we would never sell, rent or monetize that information. However, we may share this information with third parties for the following reasons:
- To fulfill our legal obligations under applicable law, regulation, court order or other legal process.
- To protect the rights, property or safety of you, Comm Technologies or another party as required or permitted by law.
- To enforce any agreements with you.
- Pursuant to a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Retention of Information
For any of your personal information that we collect, we retain such personal information for as long as you have an open account with us or, only with respect to the association between your username and public key, as otherwise necessary to provide our Services.
Your Rights in the Personal Data You Provide to Us
Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to:
- Access. You can request more information about the personal data we hold about you and request a copy of such personal data.
- Rectification. You can correct any inaccurate or incomplete personal data we are holding about you.
- Erasure. You can request that we erase some or all of your personal data from our systems.
- Withdrawal of Consent. You have the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability. You can ask for a copy of your personal data in a machine-readable format and can also request that we transmit the data to another data controller where technically feasible.
- Objection. You can contact us to let us know that you object to the further use of your personal data.
- Restriction of Processing. You can ask us to restrict further processing of your personal data.
- Right to File Complaint. You have the right to lodge a complaint with national data protection authorities regarding our processing of your personal data.
Exercising Your Rights
If you wish to exercise any of these rights, please contact us using the details below.
Deleting Your Data
If you would like to delete your account, you can do this either by deleting your account within the app, or by contacting us using the information below. Deleting your account removes all personal information that you provided to us.
Termination of your account may or may not result in destruction of Content associated with your account, and other Comm users may continue to have access to and control over your Content.