Effective Date: [September 15, 2023]

Introduction

cumbo Digital (“we,” “us,” or “our”) is committed to safeguarding the privacy of our website visitors and customers. This Privacy Policy outlines how we collect, use, disclose, and protect your personally identifiable information (PII) when you visit our website, use our services, and communicate with us. This policy applies to all individuals, regardless of their location.

Data Covered by this Privacy Policy

This Privacy Policy applies to personally identifiable information (PII) that we collect and process as a data controller. PII refers to information that identifies or can be used to identify an individual. Examples of PII include your name, email address, phone number, address, and payment details.

Please note that when you provide PII to us for your own benefit or business purposes (e.g., sending emails containing PII), you are acting as the “controller,” and we may act as the “processor” in processing that data according to your instructions or as required by law.

Core Privacy Rights

As a data subject, you have certain core privacy rights, including:

1. The right to know what PII we hold about you.
2. The right to access, correct, or delete your PII.
3. The right to data portability, allowing you to transfer your PII.
4. The right to set your marketing and advertising preferences.

We promptly review requests to exercise these privacy rights. If we are unable to fulfill your request, we will provide an explanation for the denial, information on how to appeal the decision, and details about filing a complaint (if applicable).

Collection of PII

We collect PII in the following ways:

1. PII You Provide: We collect PII when you create an account, use our services, or contact us. This may include your name, email address, phone number, address, and payment information.

2. PII Collected Automatically: We automatically collect PII when you interact with our website, services, emails, and advertisements. This may include device IDs, IP addresses, website usage information, and more.

3. PII from Other Sources: We may obtain PII about you from publicly available sources, social media platforms, and lawful third-party data providers.

Use of PII

We use PII for various purposes, including:

• Managing user accounts.
• Processing purchase requests.
• Providing customer support.
• Securing, improving, and updating our services.
• Detecting and preventing fraud and illegal activity.
• Customizing marketing and personalized advertising.
• Contacting you for service offers.
• Measuring website traffic and performance.

No Sale of PII

We do not sell PII to third parties.

Disclosure of PII

We may disclose PII to:

• Processors for operating our business and delivering services.
• Business partners for certain services.
• Marketers and advertisers for personalized marketing.
• Law enforcement and legal requests to protect our rights, prevent harm, and comply with laws.
• In the event of a merger or asset sale, we may transfer relevant PII to the acquiring entity.

Cookies, Web Beacons, and Other Tools

We use various tools, including cookies, web beacons, and scripts, to enhance your experience and provide personalized services. These tools help us measure website performance, deliver advertisements, and improve our services.

You can manage these tools through our Manage Privacy Settings page or through your customer account settings. Some cookies are essential for the functionality of our website and services. Blocking all cookies may affect your ability to use our services.

Marketing and Advertising Preferences

You can manage your marketing and advertising preferences through our Manage Privacy Settings page or your customer account settings.

Storage and International Transfers

We store PII on our systems and with trusted service providers, including Amazon Web Services. International transfers of PII are made in compliance with applicable laws. Please see our European Data Protection Disclosures for information on transfers from the EU/EEA, Switzerland, and the UK.

Length of Retention

We retain PII for business purposes and legal compliance. If PII is no longer needed, we may delete or de-identify it.

Security

We implement security measures, including controls and employee training, to protect PII. Our service providers and partners are also required to use appropriate security measures.

Collection of PII about Children

We do not knowingly collect PII from individuals under 18 without parental consent. If you believe we have collected information from a child without consent, please contact us at support@cumbo.com.

Legal Basis for Processing

We process PII based on your request, consent, contractual obligations, legitimate interests, or other lawful bases, depending on the services, data, and your location.

Non-Discrimination and Financial Incentives

We do not discriminate against users who exercise their privacy rights, and we do not offer financial incentives for providing PII.

Policy Changes

We may update this Privacy Policy at any time. Changes will be communicated through our website, services, or email notifications.

For any privacy-related inquiries or to exercise your privacy rights, please contact us at support@cumbo.com.