1. General

Comtec Enterprises Ltd together with any group companies (“we” “us” “our”) are
committed to protecting and respecting your privacy. For the purposes of data
protection legislation, we are the data controller and we will process your personal data
in accordance with the General Data Protection Regulation (EU) 2016/679 and national
laws which relate to the processing of personal data. Please read the following carefully
to understand our views and practices regarding your personal data and how we will
treat it.

2. Visitors To Our Website

2.1 We may collect and process personal data about you in the following circumstances:

2.1.1 when you complete forms on our website (“Site”). This includes your name, address,
email and telephone number, which is provided at the time of registering to use our
Site, where you ask us to contact you about our goods or services, subscribe to our
mailing list, or subscribe/request our goods and services;

2.1.2 whenever you provide information to us when reporting a problem with our Site,
making a complaint, making an enquiry or contacting us for any other reason. If you
contact us, we may keep a record of that correspondence;

2.1.3 details of your visits to our Site including, but not limited to, traffic data, location
data, weblogs and other communication data, whether this is required for our own
billing purposes or otherwise, and the resources that you access (see section 2.2.2 on
Cookies below); and

2.1.4 whenever you disclose your information to us, or we collect information from you
in any other way, through our Site.

2.2 We may also collect data in the following ways:

IP Address

2.2.1 We may collect information about your device, including where available your
Internet Protocol address, for reasons of fraud protection. We may also collect
information about your device’s operating system and browser type, for system
administration and to report aggregate information to our advertisers. This is statistical
data about our users’ browsing actions and patterns, and does not identify any
individual.

Cookies

2.2.2 Our Site uses cookies to distinguish you from other users of our Site. This helps us
to provide you with a good experience when you browse our Site and also allows us to
improve our Site. For detailed information on the cookies we use and the purposes for
which we use them see our Cookie Policy.

2.3 We may use your personal data for our legitimate interests in order to:

2.3.1 provide you with information, or services that you requested from us;

2.3.2 allow you to participate in interactive features of our Site, when you choose to do
so;

2.3.3 ensure that content from our Site is presented in the most effective manner for
you and for your device;

2.3.4 improve our Site and services;

2.3.5 process and deal with any complaints or enquiries made by you; and

2.3.6 contact you for marketing purposes where you have signed up for these (see
section 6 for further details).

Website Links

Our Site may, from time to time, contain links to and from the websites of third parties.
Please note that if you follow a link to any of these websites, such websites will apply
different terms to the collection and privacy of your personal data and we do not
accept any responsibility or liability for these policies. When you leave our Site, we
encourage you to read the privacy notice/policy of every website you visit.

3. Customers

3.1 We will collect details such as your name, address, phone number and email address
when you order goods or services from us either via our Site or linked social media
sites / other third party partner sites. We will use this information to process your order
and comply with our contractual obligations.

3.2 In order to perform our contract with you, we may also need to share personal data
with third parties such as payment providers and postal service organisations to assist
in the delivery of goods or services you have ordered; this could include third party
couriers or warranty providers.

3.3 We may also advertise your feedback on our website and marketing materials
(subject to obtaining your prior consent where necessary);

3.4 We will retain your information as long as we require this to provide you with the
goods or services ordered from us and for a period of 6 years afterwards. Where you
have subscribed to receive marketing correspondence from us we will keep your
personal data for the period of time described in section 6 below.

4. Suppliers

We will collect details such as your employee names, telephone numbers and email
addresses in order to contact you about goods or services ordered with you, to place
further orders and to pay you for the goods and/or services supplied. We will keep the
personal data for 6 years further to being provided with the goods/services.

5. If You Fail 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 the 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 goods or services). In this case, we may have to cancel a product
or service you have with us but we will notify you if this is the case at the time.

6. Marketing

6.1 In addition to the uses described in sections 2-4 above, where you indicate you
would like to receive marketing correspondence from us, subscribe to our mailing lists
or newsletters, enter into any of our competitions or provide us with your details at
networking events, we may use your personal data for our legitimate interests in order
to provide you with details about our goods, services, business updates and events,
which we think may be of interest.

6.2 You have the right to opt-out of receiving the information detailed in section 6.1 at
any time. To opt-out of receiving such information you can:

6.2.1 tick the relevant box situated in the form on which we collect your information;

6.2.2 clicking the unsubscribe button contained in any such communication received;
or

6.2.3 email us at marketing@Comtec.com or call us providing us with your name and
contact details.

6.3 Where you have subscribed to receive marketing correspondence from us we will
keep personal data 10 years from when you last interacted with us.

6.4 From time to time we may market on behalf of other companies, for example by
adding banners to our website pages. Clicking on these links will direct you to a third-
party site, where you should consult their privacy policy. We will not share your
personal data with any third parties without your prior consent.

7. Monitoring and Recording

We may monitor and record communications with you (such as telephone
communications and emails) for the purpose of training, fraud prevention and
compliance. We also have CCTV cameras installed in our premises for the purpose of
crime prevention and for health and safety reasons. Please refer to our Data Retention
Policy for details on how long we store this information for.

8. Automatted Processing

8.1 We may occasionally consult with third party marketing organisations who use
automated processing of anonymised personal data to make recommendations on
economic or predictable consumer purchasing behaviours. We do not make decisions
which affect an individual based purely on automated processing activities.

8.2 We occasionally carry out a credit checks on customers:

8.2.1 so that we can make credit decisions about you; and

8.2.2 to prevent fraud and money laundering.

8.3 Our search may be recorded on the files of the credit reference agency.

8.4 If further to undertaking a credit check you receive a low credit score, we reserve
the right not to supply you with goods or services on credit and/or require upfront
payment for the goods or services you wish to purchase. In this case a member of our
team will notify you.

8.5 If you provide false or inaccurate information and we suspect fraud, we will record
this. if you want to see your credit file, please contact our Customer Services team
who will provide you with contact details for the Credit Agency used.

9. Legal Basis For Processing Your Data

9.1 We will only use your personal data where the law allows us to. Most commonly,
we will use your personal data in the following circumstances:

9.1.1 for performance of a contract we enter into with you;

9.1.2 where necessary for compliance with a legal or regulatory obligation we are
subject to;

9.1.3 where necessary to protect your vital interests; and

9.1.4 for our legitimate interests (as described within this policy) and your interests and
fundamental rights do not override these interests.

10. Disclouse Of Your Personal Data To Third Parties

10.1 In addition to the third parties mentioned above, we may disclose your information
to third parties for our following legitimate interests as follows:

10.1.1 to staff members in order to facilitate the provision of goods or services to you;

10.1.2 to our affiliated entities to support internal administration;

10.1.3 IT software providers that host our website and store data on our behalf;

10.1.4 professional advisers including consultants, lawyers, bankers and insurers who
provide us with consultancy, banking, legal, insurance and accounting services;

10.1.5 HM Revenue and Customs, regulators and other authorities who require reporting
of processing activities in certain circumstances; and

10.1.6 third parties who we may choose to sell, transfer or merge parts of our business
or assets. Alternatively, we may seek to acquire other business or merge with them. If
a change happens to our business, then the new owners my use your personal data in
the same way as set out in this privacy policy.

10.2 We may disclose personal data to the police, regulatory bodies, legal advisors or
similar third parties where we are under a legal duty to disclose or share personal data
in order to comply with any legal obligation, or in order to enforce or apply our website
terms and conditions and other agreements; or to protect our rights, property, or
safety of our customers, or others. This includes exchanging information with other
companies and organisations for the purposes of fraud protection and credit risk
reduction.

10.3 We will not sell or distribute personal data to other organisations without your
approval.

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