COMBO INNOVATION LTD - PRIVACY POLICY
                                                             
                                                                                                                  Overview
Personal data collected by Combo Innovation Ltd are processed in accordance with the law on legal protection of personal data and other legal acts of every country we aim to do business. All personal data collected from this site complies with the principles of the EU GDPR data protection act 1998 and May 25, 2018, and the California consumer protection act (CCPA). By accessing this site you agree to the terms of this privacy policy and consent to the collection, processing, use or transfer of data as set out in this policy.
For the purpose of the processing personal data, Combo Innovation Ltd may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Combo Innovation Ltd. In such cases, Combo Innovation Ltd shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of Combo Innovation Ltd and applicable legislation. Combo Innovation Ltd shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, Combo Innovation Ltd shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
Combo Innovation Ltd services is responsible for safeguarding your personal information (information you have voluntarily disclosed to us) and using this information only for the purpose for which it was collected for (as explained to you prior to collection and agreed by you).
The following is general information on Combo Innovation Ltd privacy practices. Please read our privacy statement and let us know if you have any questions.
This policy (together with our terms and conditions and any other documents referred to in it) sets out:
1-Overview
2-Personal information we collect about you PIPEDA
3-Types of data collected
4-How we collect your data
5-Payment processing and Payment Processor
6-Cookies and other technologies.
7-How we use your information.
8-Website and app Analytics
9-Advertising
10-California / Delaware Do Not Track Disclosures
11-Our promotional updates and communications.
12-Who we give your information to.
13-Where store your information
14-Additional EU Disclosures
15-Provision of Personal Data and failure to provide Personal Data
16-How is personal information disclosed?
17-How long we keep information
18-Marketing information:
19-How to access and control your information
20-Consent to provide personal information
21-Transfer to third parties
22-Your rights as a data subject
23-Privacy shield
24-Legal bases for processing (for EEA users):
25-Our COPPA policy towards children
26-How we protect your information
27-California Notice of Collection under California Consumer Privacy Act of 2018
28-Your California Privacy Rights (CCPA)
29-Your right to withdraw consent
30-Opting out
31-Data Privacy Regulatory Frameworks and Requirements
32-Data portability
33-California Privacy CCPA
34-Your CA privacy rights
35-Notice for California consumers – your privacy rights under the (CCPA)
36-About security and personal Information
37-Complaints to a data protection authority
38-Contact us
39-Privacy policy changes
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the platform you acknowledge you have read and understood this privacy policy.
Personal information we collect about you (PIPEDA)

According to the personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Combo Innovation Ltd is considered personal information it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you.
If information cannot be related to an identifiable individual it is considered anonymous information. Whenever possible, Combo Innovation Ltd works with anonymous information. This privacy statement does not apply to anonymous information.
Types of data we collect from you
Personally Identifiable Information (PII). We acquire PII from you when you register for a User or corporate entity Subscriber account and user account for a Combo Innovation Ltd Service, these PII may include, in certain contexts, your name, postal address, zip code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or Device if it were combined with other identifying information.
Sensitive PII. In certain circumstances, such as when subscribing for our service, you may provide a credit, debit, or payment account number, or other payment information to our payment gateway provider which we recognize as more sensitive than other PII.
Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.
Cookies and other tracking technologies: Combo Innovation Ltd and our third-party partners, such as our User or Corporate entity partners, advertising, data collection and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different services and devices. For more information, please see our cookies and tracking notice, which includes information on how to control or opt out of these cookies and tracking technologies.

Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data, may be considered and specifically named "Non-Public Information" or "Personal Data" in certain jurisdictions, including the European Union ("EU"), including but not limited to:
Personal Information that it considers necessary for it or its related bodies corporate to provide the range of services they offer. The information we collect generally falls into two categories:
1- Information supplied by visitors to the website and app when they:
    a-Create a new account
    b-Login to their account
    c-Place an order for a service or product 
    d-Enter a sweepstakes or other promotional contest
2- Information we collect as visitors use our website and app.
You need to sign up to use certain products, services, and tools on our website and app that require you to provide information about yourself, such as your name, physical address, email address, and phone number. For example, you may provide such information if you sign up for a new account, newsletters, complete our "Feedback" form, or use a social media tool. We may use such information in order to provide you with the products, services, or tools you have requested.
When you list a vehicle or equipment for sale, we ask for information about the vehicle and on how you can be contacted by potential buyers (including information like your phone number and email address).
In addition to the above, we may collect information, and/or use the information we collect, in the following specific ways:
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION "ADDITIONAL EU DISCLOSURES" THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW

Sweepstakes and Other Promotions
From time to time, we may offer sweepstakes or other promotions on our website and app. If you enter a sweepstakes or promotional contest, we will ask you to provide information about yourself (such as your name, phone number, address, date of birth, and email address). Among other things, we will use this information to contact you if you win, and we may also use this information for marketing purposes. We may share this information with any co-sponsor of the contest or sweepstakes; we will identify the co-sponsor in the contest rules. We may also share this information with shipping or fulfilment companies or other third-party service providers that help administer our promotions, such as by conducting drawings, and/or delivering prizes to winners. If you do not want us to collect the information requested in the contest or sweepstakes registration form or to provide it to co-sponsors, please do not enter the contest or sweepstakes. 
Online Surveys
From time to time, we survey our users to measure their satisfaction with our website and app and other sites and to help us learn more about our audience and how they interact with our website and app. Third-party research firms often conduct these surveys on our behalf. We use the survey results to help us improve the services we offer to you. We will take the information you provide and aggregate it on an anonymous basis with data collected from other survey participants. We may use and disclose that pool of anonymous information as we see fit, without identifying you personally.
How we collect your data
My Account. In order to use our services you will be required to sign up for an account. During this process we may collect your PII, such as your name, email, phone number and your desired course or service you wish to participate. We also collect your system information, such as your browser type, IP, and device information. When you log in your account or sign up for an account with us
Data You Provide. We mostly receive PII because you provide it to us. For instance, when you enter a contest, complete a survey, register for a Combo Innovation Ltd account, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Data such as your age, gender, an avatar, and preferences may also be requested. In addition, we may acquire your Data when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire information that you provide about other people, for example, when you use our “refer-a-friend” email feature.
Payment Information: We collect certain payment and billing information when you purchase certain paid Services through our payment gateway partners (PayPal or Stripe). You might also provide payment information, such as payment card details, which we collect via secure payment processing partners.

Data Automatically Collected. The Service may also automatically collect Data about you, your online behavior and your Device. The Data collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect your Data even if the Service is not open on your Device or you’re not logged in.
Data Acquired Elsewhere. We may also acquire your PII or other Data offline or otherwise outside of the Service. For example, we may purchase or otherwise acquire such Data from third party data suppliers. We reserve the right to merge or co-mingle this other Data with your PII and Data collected on or through the Service.
Clickstream Data: As you use the Internet, a trail of electronic information is left at each website and app you visit. This information, sometimes referred to as "Clickstream Data," can be collected and stored by a website and app’s server. For example, Clickstream Data can tell the type of computer and browsing software you use and the address of the website and app from which you linked to the website and app. The Website and app may collect and use Clickstream Data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website and app, how visitors navigate throughout the Website and app and how we may tailor our website and app to better meet the needs of visitors. This information often will be used to improve our Website and app and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any Personal Information.
Location Data: When given permission, we will collect the latitude and longitude coordinates of your device when you are searching a listing availability. We use this information to help us improve the relevance of search results and streamline the listing processes and is only collected while the app is running. We also use geo-IP data to identify the city a user is visiting the website and app in order to set the website and app to the relevant city. If you would like to opt-out of location, tracking, please see the Opt-Out section below.
Be Careful Publicly Posting PII. Please be aware that Content and PII that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all PII, especially sensitive PII, that you may wish to post.
Cookies and other technologies
Our platforms use cookies and similar technologies to distinguish you from other users of our platforms. This helps us to provide you with a good experience when you browse our platform and also allows us to improve our services.
Most browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen will tell you how to do this. We also give you information about disabling cookies. However, you may not be able to take full advantage of our web site if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the app. Others are used to remember you when you return to the platform and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

Payment processing and Payment Processor
Payments made on the Combo Innovation Ltd website and app are made through our designated payment gateway provider (PayPal or Stripe). You will be providing credit or debit card information directly to them who operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to our payment provider is not within our control and is subject to their own privacy policy and terms and conditions.
Note your payment card details are not shared with Combo Innovation Ltd by the provider
How we use your information
Subject to the section titled "Additional EU Disclosures", we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:
- To perform a contract with you;
- To perform specific services that you have requested;
- To respond to your direct inquiries;
- For joint marketing with other financial companies;
- For our affiliates’ everyday business purposes;
-Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
- To send you Combo Innovation Ltd marketing materials;
- To send you marketing materials for our affiliates’ products and services;
- Where we need to comply with a legal or regulatory obligation; and
- In other ways as required or permitted by law or with your consent.
- generate statistics in relation to the Combo Innovation Ltd Network,

Subject to the section titled "Additional EU Disclosures", we will not disclose information that we collect about you to third parties without your consent and except as provided by this privacy policy. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- To use certain services on our Website and app, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our Website and app, to the extent permitted by applicable law, you expressly consent to the sharing of your information with User or Corporate entity, third-party payment processors, and other third-party service providers.

- If you provide feedback about your website and app experience through us, we may share with User or Corporate entity your survey feedback.
- To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control.

- To third parties to whom we need to share your information to investigate suspected fraud, abusive or unlawful uses or activities, harassment or other violations of any law, rule or regulation, or the policies for the Website and app, or to protect the security or integrity of the Website and app.

- To our affiliates.

- To third party service providers to provide website and app, application development, hosting, maintenance, and other services for us. These third parties  may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

- To respond to requests from law enforcement authorities and our regulators, or to respond to requests if we are involved in a legal proceeding.

- To third parties as necessary to investigate and correct technical problems and malfunctions in the Service or the computer systems that support the Service.
If your account is closed, we may take steps to delete certain information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose information in accordance with this privacy policy
Please keep in mind that Combo Innovation Ltd does not trade or sell your personal information.

Website and app Analytics
We may collect, or have a third party collect on our behalf, data on how visitors use and navigate through the Websites, such as the number of users who visit various pages within the Websites, what they click on, whether they scroll up or down on particular pages, fill out forms, etc. We use this information to improve the Websites and learn about users, and may disclose it to our affiliates (including, among others, the members of the Combo Innovation LTD corporate family), or to third parties.
Advertising
The Site has relationships with certain third-party advertising networks, Advertisers, and advertising services ("Advertising Services") that collect data, target and serve some of the advertisements, promotions, or other marketing messages you see on our website and app and other websites and mobile applications, including websites owned and/or operated by our affiliates.
Such Advertising Services may, including through processes that we do not control, use Data Technologies from third party companies to collect data from your activities on these websites, on other websites owned and/or operated by our affiliates, or with other websites. These technologies may be used to track user behavior, how our products and services are offered, conduct consumer research and possibly to serve you relevant ads and content. These companies may also obtain information, including personally identifiable information, from services you use from other companies, including without limitation, other websites, mobile websites or applications, and combine the information they obtain through these Data Technologies with information obtained through our products and services. Their collection and use of this data is subject to their own privacy policies
California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Combo Innovation Ltd do not monitor or take any action with respect to these signals or other mechanisms.

Where we store your information
Combo Innovation Ltd has a data privacy officer who is responsible for ensuring that your personal information is collected, used, disclosed (shared) and retained in compliance with applicable privacy regulations.
However, the data that we collect from you may be transferred to, and stored at, a destination outside the European economic area ("EEA") that may not be subject to equivalent data protection law.
Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
In order to store it
In order to enable us to provide products or services to you and fulfil our contract with you. This includes Web Related Services fulfilment, processing of, and the provision of support services.
                                                                            How we store and secure information we collect
Information storage and security
We use industry standard technical and organizational measures to secure the information we store.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

If you use our server or data center services, responsibility for securing storage and access to the information you put into the services rests with you and not Combo Innovation Ltd. We strongly recommend that server or data center users configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage points used.
Additional EU Disclosures
We generally act as the data controller of your information submitted through our website and app; however, under certain circumstances, User or Corporate entity may engage us to provide them with certain processing services related to information owned or controlled by the User or Corporate entity. We are not responsible for any User or Corporate entity's use of information for which it is an owner or controller. As processor for a User or Corporate entity, we only act under their instruction with respect to the processing of your information. To learn more about how a User or Corporate entity may use such information, you should review its privacy policy.
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to address your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you are situated in the EU and have a complaint, please contact our privacy team at support@comboinnovation.com
Provision of Personal Data and failure to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you
How is personal information disclosed?
The Site may use your Personal Information for any purpose which the Site may deem fit in its sole discretion.
Individuals and/or organizations to which we may disclose personal information include:
- the public if you advertise with Combo innovation Ltd or use publicly available Communications Services

- Individuals and organizations that advertise with Combo innovation Ltd if you submit an enquiry with Combo innovation Ltd. If you do not want Combo innovation Ltd to disclose your personal information to these individuals and organizations, please do not submit enquires.

Depending on your enquiry these may include

-operators of Linked Sites
-financial service providers
-insurance service providers
-outsourced service providers who assist Combo innovation Ltd to provide its services including:
-information technology providers
-professional advisers
-organizations involved in a sale/transfer of Combo innovation Ltd assets, business, or shares
-government and regulatory authorities as required by law
Except as provided herein and as required by law, your Personal Information will not be made available to third parties without your consent.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Marketing information:
if you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an email from us or ceased using your Combo Innovation Ltd materials. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
Consent to provide personal information
We inform you when we need to collect your personal information and why we are collecting it.
Combo Innovation Ltd only collects information from you after you give us your consent. The only exception is when the law requires the collection, use or disclosure of a person’s information without consent.
Providing us with personal information is entirely voluntary. By giving us your personal information, you consent to allow us to use and disclose your personal information as described to you. If you do not agree with the use and disclosure of your information, please do not provide us with your personal information.
Some of our services can only be offered if you provide personal information so, if you choose not to provide your information, we may not be able to provide you with those services.
You may withdraw consent at any time. You will be informed of the effect that withdrawing your consent will have.
Your withdrawal of consent will only apply from the point that you withdrew consent. Your withdrawal of consent is not retroactive.
This means we will not remove information that has already been disclosed.
Transfer to third parties
To facilitate the purposes of Web related Service, personal data may be shared in the normal course and scope of business with third parties to whom Combo Innovation Ltd has chosen to outsource work. In the event that personal data is transferred to a third party, Combo Innovation Ltd requires in its agreements with third parties that adequate privacy precautions are taken that provide the same level of privacy protection as is required by the principles of the privacy shield. In certain circumstances, Combo Innovation Ltd may remain responsible and liable under privacy shield principles if such third parties process the personal data in a manner inconsistent with the privacy shield principles
Your rights as a data subject
In some jurisdictions (for example, the member states of the European Union) you may be entitled to certain rights in and to your personal data, subject to certain conditions and exceptions contained in applicable law. These rights may include the following:
- Request us to confirm whether your personal data is processed by us, and if we do, to obtain access to your personal data and certain information about it.

- Require the correction of your personal data if it is inaccurate or incomplete.

- Direct us to stop processing your personal data under certain circumstances.
- Erase or delete your personal data, for example, where the data is no longer needed to achieve the purpose for which it was collected.
- Restrict the further processing of personal data
- Request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such processing and will notify you prior to doing so).

- Request to receive your personal data for transmission to, or to directly transmit to, another data controller in a structured, commonly-used and machine-readable format.

- To protect your privacy and the security of your personal data, we will take reasonable steps to verify your identity before complying with such rights requests.
Privacy shield
Combo Innovation Ltd adheres to the seven privacy shield principles of notice, choice, and accountability for onward transfer, security, data integrity, access, and recourse, enforcement and liability as they relate to personal data. Combo Innovation Ltd verifies compliance to the principles through self-assessment. The privacy policy covering human resources data can be accessed on our intranet web site by all employees.
Legal bases for processing (for EEA users):

If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;

-It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
-You give us consent to do so for a specific purpose; or

-We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
Our COPPA policy towards children
The services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. Combo Innovation Ltd complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. While children under the age of Sixteen (16) may use the Site only with the consent of his or her parent or legal guardian, please be advised that this Site is not directed or otherwise promoted for use by children under the age of thirteen (16).
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS 1.3 (a strong protocol), x25519 (a strong key exchange), and aes_128_gcm (a strong cipher). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 our platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
California Notice of Collection under California Consumer Privacy Act of 2018
This Combo Innovation Ltd Privacy Notice for California Residents supplements the information contained in this Policy and the rights mentioned below apply solely to visitors, users, Sellers and others who reside in the State of California. We share this notice of collection to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
Your California Privacy Rights (CCPA)
We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes.
If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2016 will receive information about 2015 sharing activities).
To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: support@comboinnovation.com, with “California Privacy Rights” as the subject line
Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us support@comboinnovation.com**. You can also change your marketing preferences at any time as described in 'our promotional updates and communications' section.
You can also exercise the rights listed above at any time by contacting us at support@comboinnovation.com.
If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, his email is support@comboinnovation.com
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Opting out of messages from us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at support@comboinnovation.com. We will process your request within a reasonable time after receipt.
Opting out of sharing with third parties for marketing
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to support@comboinnovation.com. Please note that if you opt out in this manner, certain aspects of the Website and app may no longer be available to you. We will process your request within a reasonable time after receipt.
Opting out of interest based advertising
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance ("EDAA"). You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. EU residents who have provided their consent to our use of cookies and similar technologies can use the EDAA’s opt out tool.
                                                             Data Privacy Regulatory Frameworks and Requirements
GDPR Data Privacy User Rights
If you are an EU resident and Combo Innovation Ltd is processing, and/or transmitting your personal data, then you - as an “EU data subject” – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):
Right of Access: you have the right to obtain from us, as controllers, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the following personal data and information:
1-the purposes of the processing;

2-the categories of personal data concerned; i.e name, email, phone number etc
3-the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations’;
4-where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

5-the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; (f) the right to lodge a complaint with a supervisory authority (for a list of supervisory authorities, see https://edpb.europa.eu/about-edpb/board/members_en);

6-where the personal data are not collected from you, any available information as to their source;
7-The existence of automated decision-making, including profiling, along the lines indicated by Article 22(1) and (4) GDPR, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
Right to Rectification: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerned, provided during registration by him or her. Taking into account the purposes of the processing, the user have the right to have request his incomplete personal data be completed, including by means of providing a supplementary statement. 

* Right to Erasure (“Right to be Forgotten): you have the right to obtain from us the erasure of your personal data without undue delay, and we have the obligation to erase personal data without undue delay when: a) your data are no longer necessary for the purposes for which they were collected; b) you had consented to the processing; c) you have objected to the processing, as per below; d) your persona data had been unlawfully collected; e) your personal data need to be erased as a matter of compliance with a legal obligation.

* Right to Restriction of Processing: you have the right to obtain from us the restriction of processing if you: a) contest the accuracy of the personal data, until this is verified; b) the processing is unlawful but you don’t want erasure; c) we no longer need the personal data, but you require them to establish, exercise to defend a legal claim; d) you have objected to processing but there is a need to verify whether our legitimate grounds override your rights to object.

* Right to Data Portability: where your personal data have been provided on the basis of your consent or for the performance of a contract, and their processing occurs in an automated way, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data– or have directly transmitted - to another controller.
* Right to Object: you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.
Data portability
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces you under your sole control, like your personal bitbucket repository
California Consumer Privacy Act (CCPA)
This section of the privacy policy provides information to California (“CA”) residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), whether through the Website and app or offline. It describes the categories of Personal Information that Combo Innovation Ltd collects, and the purposes for which that information is collected.
This section does not apply to Personal Information that is protected under federal financial privacy laws. Personal Information does not include information that is publicly available or that has been de-identified or aggregated.
Your California privacy rights
As a California resident, beginning after January 1, 2021, you may have certain rights over the Personal Information we have about you, depending on the type of relationship you have with us.
We do not offer an opt out of sale link on our homepage for the purposes of the CCPA and CALOPPA. We may share Personal Information with our service providers, with third parties with whom we jointly offer products or services, with third parties from whom you request a product or service through us, in the context of a merger, acquisition, bankruptcy, or other corporate transaction, or as otherwise permitted by the CCPA
Notice for California consumers – your privacy rights under the (CCPA)
Under California’s “shine the light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship
A list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and
The names and addresses of all such third parties. To request the above information, please e-mail us at support@comboinnovation.com
We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each user once per calendar year.
Security and personal Information
The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the Site cannot guarantee that such precautions would render the Site and its servers immune to security breaches.
Complaint to a data protection authority
You have the right to submit a complaint concerning our data processing activities to our data protection officer
Contact us
If you have any queries regarding our data collection and protection practices or your rights, please do not hesitate to contact our data protection officer, at support@comboinnovation.com
Privacy policy changes
We may revise this privacy policy from time to time, and will post the most current version on our web site. If a revision meaningfully reduces your rights, we will notify you.











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