Privacy policy

Welcome to ComFit Europe’s Data Privacy Policy

Your privacy matters to ComFit Europe (“ComFit Europe,” “us,” or “we”). When you use our databases, website or services (collectively, the “ComFit Europe Products” or “Products”), you’re trusting us with your data. We understand that this is a responsibility and we are dedicated to protect your data and put you in control. Whether you are new to ComFit Europe or a long-time contact, please do take the time to get to know our practices – and if you have any questions, contact us as set under Questions or Comments in this document.

This privacy policy applies to information we receive when you use ComFit Europe Products. This privacy policy is an agreement between ComFit Europe and you, as the user of ComFit Europe Products. This agreement tells you what information we collect from you through our interactions with you and through our Products, and how we might use that data, how you can review or update the personal information you provided to us, and the steps we take to ensure that your personal information is protected. We share your personal information only with your consent or as described in this policy.

Personal Data That We Collect

We collect information in the following three ways:

1. Personal Information you give us

You provide some of your personal data directly, such as when you fill in the datasheet in your account in our software or contact us for support. You are required to provide certain personal information to access or use ComFit Europe’s softwares. Your name, a valid email address, securely encrypted password and telephone number are necessary to identify you and to create and maintain an account for you at https://app.comfiteurope.eu or http://www.vigintelligence.com.

Besides name and contact data, the information we collect can include the following:

• Other contact data. Personally identifiable information may include, but is not limited to your name, phone number, email address. For further details, please have a look at your account in our databases.
• Payment and Billing information. If you wish to establish a paid account or receive payment for your work, you are also asked to give information, otherwise we are not able to pay you.
• E.g. if you are a client user, we record and store your search criteria in your account, so that the reports or communications we send to you are to your interest. If you are a reviewer, we ask your specialisations.
• Official Documents If you are a reviewer or employee, we store your CV, diploma copy, training results under your account.

For details, please have a look at your account in our software databases. You have choices about the data we collect. When you are asked to provide personal data, you may decline it. However, if you choose not to provide data that is necessary to provide a Product e.g. your email address to send you a report, we may not be able to provide you with the use of our Products. The mandatory information is marked with *

2. Information we get from your use of our Products

We collect information about how you and your device interact with our Products. The data we collect can include the following:

• Product use data. We collect data about the features you use and the software configurations you use most. This data includes your search queries or commands to ComFit Europe databases.
• Click Stream Data. When you use the ComFit Europe Product we may collect “click stream data” (server address, domain name, etc.). This information can be combined with information you have provided to us, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis, to determine which features within the Products are most or least effective or useful to you.
• Error reports and performance data. We collect data about the performance of our Products and any problems you experience with them. This data helps us to diagnose problems in the Products you use, and to improve our Products and provide solutions. Depending on your product and settings, error reports can include data such as the type of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred.
• Troubleshooting and Help Data. When you engage us for troubleshooting and help, we collect data about you and your hardware, software and other details related to the incident. Such data includes contact and the content of your communications with us, and registry data about software installations and hardware configurations.
• Device data. We collect device-specific information about your device and the network you use to connect to our Products. Such information may include information recorded by our server logs from your browser such as your Internet Protocol (IP) address (which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network like the internet). It includes data about your hardware model, the operating systems and other software installed on your device, including product keys.

3. Survey Information

From time to time, ComFit Europe may ask its registered users to participate in surveys. These surveys are purely optional and help us improve our Products and provide aggregate information which we think may interest our registered users. We may use the information that you voluntarily provide as part of your survey response in the manner outlined in this Privacy Policy. We may also use the information you provide in the aggregate to help us generate statistics regarding use of the ComFit Europe Products. If you would not like your information to be used in this way, please do not participate in our surveys or, if participating, please provide us only with information you consent to our use of in accordance with this Privacy Policy.

How We Use Personal Data

We use the data we collect for the following purposes:

1. to operate our business

If you are a reviewer or a colleague, we need your personal data to pay your work, to follow the quality of your work and hence ensure the quality work of ComFit Europe to our clients. If you are a client user, we need your personal data to perform our contract with your company.

2. to improving our Products we offer to you

We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions and report on the performance of our business. We use data to give customer care and support services.

The field of expertise ComFit Europe work in dictates regular audits and quality checks of our operations. Personal data of our employees and reviewers are integral part of our work, in that way it is inevitable to share with auditors.

3. to offer you personalised experience

We analyse your content (including emails) to provide you personally relevant product features, such as customised search results. By analysing visits to the website and use of ComFit Europe databases we learn about the interests of our users in the aggregate and also on a personal level to better understand your interests and needs, so we can improve our Products and services and deliver to you the type of content, features, and promotions that you are most interested in.

4. to send communications, including promotional communications

We use data we collect to communicate with you and personalise our communications with you. For example, to inform you when a subscription is ending, let you know when security updates are available, update you or enquire about a service or repair request, invite you to participate in a survey.

When you contact ComFit Europe, we keep a record of your communication to help solve any issues you might be facing or to let you know about upcoming changes, improvements or news we think might interest you.

For information about managing your data we collect, or if you no longer wish to receive any emails from us, or if you want your personal data to be deleted from our database please read How to access, control your personal data or cancel your account section of this privacy statement.

The legal basis on what we process your personal data

We need to process your personal information in order to:

• Perform our contract with you (see Article 6.1.b of the GDPR)
• Pursue legitimate business interests of our own related to operating the Website and databases and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
• For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)

Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.

In circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.

You have the right to object to how we process your personal information, or ask us to restrict the processing. Please see below at Questions or Concerns.

If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) at the email address dataprotection@comfiteurope.com

Reasons We Share Personal Data

We do not share personal information with companies, organisations and individuals outside of ComFit Europe unless one of the following circumstances applies:

1. For business operation purposes

We provide personal information to other trusted businesses or persons who need to know that information in order to process it for us. For example, we share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention. We also share personal data with auditors who investigate if our operations are in compliance with the regulations.

We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to promote our business or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.

2. For legal reasons

we will access, transfer, disclose and preserve personal data, including your content when we have a good faith belief that doing so is reasonably necessary to:

• comply with applicable law or meet any valid legal process or enforceable governmental request;
• detect, prevent or otherwise address fraud, security or technical issues
• protect the rights or property or safety of ComFit Europe, our employees, our users or others
• operate and maintain the security of our Products, including to prevent or stop an attack on our computer systems or networks; or
• disclose personal or general information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions.
• report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion.

3. For Business transfers

ComFit Europe may be involved in a merger, acquisition or asset sale. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if ComFit Europe or substantially all of its assets were acquired, user information would likely to be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of ComFit Europe may continue to use your personal information as set forth in this policy. We will give affected users notice if personal information becomes subject to a different privacy policy.

Retention of Your Information

We will only retain your information to the extent: (a) it is needed for the purposes which we have conveyed to you; (b) we are required by law to maintain such information; or (c) it is needed for us to address any issues or inquiries that you may have. When your information is no longer required, we will dispose of such information by destroying it or erasing it.

Security Measure for Protection of Your Personal Data

We work hard to protect ComFit Europe and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold. In order to protect both the personal information and the general information that we receive from you through your use of our Products, we have implemented various security measures.

• We encrypt our services secure socket layer technology (SSL). We also follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
• We offer you verification when you access your ComFit Europe account
• We review at least yearly our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
• We restrict access to personal information to ComFit Europe employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.

We use the most updated means available to provide security to the access and use of our Products, hence to protect also your Personal Information. However, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to do all that we can to protect your Personal Information, we cannot guarantee its absolute security.

How to access, control your personal data or cancel your account

You may modify your personal information, by logging in and visit your account in Comfit Europe databases following the instructions provided on the user interface. We encourage you promptly to update your personal information when it changes.

If you wish to cancel your account or opt out of email, please get into contact with us via email  dataprotection@comfit.hu. In case you put an end to your account, information concerning your past behavior with the Products may be retained by ComFit Europe as long as necessary for the purposes set out above.

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We are ready to work with the appropriate regulatory authorities to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes to This Privacy Policy

This Privacy Policy (2^nd version) is effective as of 24^th May 2018 and will remain in effect except until any changes in its provisions in the future. We reserve the right to update or change our Privacy Policy at any time. We review it yearly.

If we make any material changes to this Privacy Policy, we will notify you. Your continued use of ComFit Europe Products after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Questions or Comments

If you have any questions, comments or concerns relating to this privacy policy, please feel free to contact us at: dataprotection@comfiteurope.com or write to us at:

ComFit Europe Kft.
Kerepesi út 1-5. E. ép. 1. em. 18.
Budapest
1087
Hungary

Our Data Protection Officer (DPO) will make every effort to resolve your questions and concerns.