Privacy Policy for Comobaco
1. Introduction
At Comobaco, accessible at comobaco.com, we are committed to protecting the privacy and personal data of our users. We honor the trust you place in us and are dedicated to being transparent about how we collect, use, store, and share your personal information. This Privacy Policy outlines our data protection practices in accordance with global regulations, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”).
We adopt a privacy-first approach to data processing, meaning we strive to collect the minimum data necessary for the proper functioning of our services and we provide mechanisms for users to understand and control their personal data.
2. Scope of the Policy and Data Controller
This Privacy Policy applies to all users accessing and interacting with our services through comobaco.com. For the purposes of applicable data protection laws, Comobaco is the “data controller” for any personal data collected through our website or related services.
Should you have any questions or concerns regarding our data practices or this Privacy Policy, you may contact us at [email protected].
3. Categories of Data Processed
We may collect and process the following categories of personal information:
3.1. Usage Data
Includes information about how you use our website and services, such as browser type, IP address, access times, pages viewed, referring URLs, and session duration.
3.2. Account Data
Includes personal identifiers (such as your full name, billing and shipping address, phone number, and email address) that are provided when you register for an account or make a purchase.
3.3. Profile Data
Includes preferences, product interests, purchase history, and behavior on the website that allows us to personalize your experience.
3.4. Communication Data
Includes records of correspondence with our customer support team, inquiry forms, live chat history, and any other communication shared with us.
3.5. Technical Data
Includes information about your device such as operating system, hardware version, device identifiers, and browser configurations used to access comobaco.com.
3.6. Transaction Data
Includes details of any payments made through the site (e.g., payment method, transaction ID, delivery address) and order fulfillment information.
3.7. Preference Data
Includes your marketing and communication preferences, opt-in status, and data related to your subscriptions or product alerts.
4. Legal Bases for Processing Personal Data
In accordance with applicable data protection laws, we rely on the following lawful bases for processing your personal data:
– Consent: Where specifically provided by you (such as for marketing communications).
– Contract: Where processing is necessary for the performance of a contract (such as fulfilling your orders).
– Legitimate Interests: Where processing is necessary to support our legitimate business interests, such as improving user experience or preventing fraud and abuse. This will never override your fundamental rights.
– Legal Obligation: Where processing is necessary to comply with legal or regulatory obligations.
5. Your Rights
Under GDPR and CCPA, you are afforded several rights regarding your personal data. These include:
– Right of Access: You have the right to request a copy of the personal data we hold about you.
– Right to Rectification: You may request corrections to inaccurate or incomplete personal data.
– Right to Erasure: You may request that we delete your personal data, subject to legal obligations.
– Right to Restrict Processing: You can request that we limit processing under certain circumstances.
– Right to Data Portability: You may request to receive data you provided in a structured, commonly used, and machine-readable format.
– Right to Object: You may object to the processing of your personal data where we rely on legitimate interests.
– Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights under CCPA.
To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before fulfilling your request.
6. Security Measures
We implement robust technical and organizational safeguards to ensure the integrity and confidentiality of your personal data. These include:
– Data encryption in transit and at rest
– Multi-factor authentication and role-based access control
– Regular security audits and monitored intrusion detection
– Secure data backups and recovery assessments
– Staff privacy and security training
7. International Transfers
We may transfer your personal data to third-party processors or service providers located outside your jurisdiction. When data is transferred internationally, we ensure adequate protection through appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or compliance with the U.S.-EU Data Privacy Framework where applicable.
8. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy, including to comply with legal, accounting, or reporting obligations. Specific retention periods include:
– Account and transaction data: Retained for seven years from the last activity for regulatory compliance.
– Communication and support records: Retained for two years to ensure service continuity and training.
– Consent and preference records: Retained until you update or withdraw consent.
– Analytics and technical data: Retained for up to two years, aggregated and anonymized where possible.
When data is no longer necessary, it is securely deleted or anonymized.
9. Cookie Policy
We use cookies and similar tracking technologies on comobaco.com to enhance usability and functionality. These include:
– Essential Cookies: Necessary for the operation of our website and to allow you to use its basic features.
– Functional Cookies: Remember user preferences and settings.
– Performance Cookies: Collect anonymous data on how users interact with the site to improve functionality.
– Analytics Cookies: Help us understand site usage through tools such as Google Analytics.
– Marketing Cookies: Used to deliver content and advertisements that are more relevant to you, based on your interests.
10. Cookie Management and Compliance with GDPR & CCPA
During your first visit, and periodically thereafter, you will be presented with clear options to accept or customize your cookie preferences, in compliance with GDPR and CCPA standards. You can change or withdraw your consent at any time via the website’s cookie management panel.
You may also configure your browser settings to reject or disable cookies, though doing so may affect site functionality.
11. Special Protections for Children
comobaco.com is not intended for, nor do we knowingly collect personal data from, children under the age of 13. If we become aware that personal data from a child has been collected without verified parental consent, we will take immediate steps to delete that information. Parents or guardians who believe we may have collected data from a child may contact us at [email protected].
12. Policy Updates
We reserve the right to update this Privacy Policy to reflect changes in our data practices, applicable laws, or technological advancements. Should substantive changes be made, we will notify users through the website or other appropriate channels.
13. Contact
Should you have any questions, requests, or concerns about this Privacy Policy or your personal data, you may contact us via email at:
We take privacy inquiries seriously and aim to respond promptly and thoroughly.
Compliance Assurance
Comobaco is committed to full compliance with all applicable data protection laws, including GDPR and CCPA. Your trust is critical to us, and if you have any concerns regarding the use or protection of your data, we encourage you to reach out directly at [email protected].