1. Does this Privacy Notice apply to you?

This Privacy Notice applies to you if you are a customer of Comtrol Solutions, a supplier of Comtrol Solutions, or if you contact Comtrol Solutions via any communications means (contact Us form, email, call etc)

2. What information does Comtrol Solutions collect?

In the course of its business activities and providing the services, Comtrol Solutions will need to process personal data. “Personal Data” is any information that can directly or indirectly be used to identify a natural person. You provide most of your Personal Data directly to Comtrol Solutions, for instance:

• Contact information. Such as your name, address, e-mail address and phone number.
• Financial information. Such as your bank account number, payment status, invoices.

3. Purposes for collection, use and processing of Personal Data by Comtrol Solutions

The above mentioned Personal Data shall be collected, used, stored or otherwise processed if necessary within the framework of responsible, efficient and effective business management of Comtrol Solutions. We process Personal Data because it is necessary to perform our contractual obligations with you, or it is necessary for us to comply with our legal obligations, or for other legitimate business interests of Comtrol Solutions to provide quality services. More specifically, Comtrol Solutions uses Personal Data for the following activities:

• Improvement of Comtrol Solutions services. 
• Performing agreements. This includes communication with individuals and other parties regarding services, responding to requests for (further) information, dispute resolution and preparing agreements.
• Relationship management and marketing for commercial activities. Comtrol Solutions may process Personal Data as necessary for the development and improvement of Comtrol Solutions products and/or services, account management, client service and the performance of (targeted) marketing activities in order to establish a relationship with a client and/or maintaining as well as extending a relationship with a client, business partner or supplier and for performing analyses with respect to Personal Data for statistical and scientific purposes.
• Business process execution, internal management and management reporting. This includes addressing activities such as managing company assets, conducting internal audits and investigations, finance and accounting, implementing business controls, provision of central processing facilities for efficiency purposes, managing mergers, acquisitions and divestitures and Processing Personal Data for management reporting and analysis.
• Safety and security. Personal Data may be included in the processing for activities such as those involving safety and health, the protection of Comtrol Solutions and customer, supplier or business partner assets and the authentication of customer, supplier or business partner status and access rights.
• Protecting the vital interests of individuals. This includes processing data when necessary to protect the vital interests of an individual (e.g. for urgent medical reasons).
• Compliance with legal obligations. This addresses the processing of Personal Data as necessary for compliance with laws, regulations and sector specific guidelines to which Comtrol Solutions is subject (e.g. matching names of clients, suppliers and business partners against denied parties’ lists).

The following paragraph describes our commitment to the protection of Personal Data as it applies to the Comtrol Solutions website (www.comtrolsolutions.com) or any of its subpages through which Comtrol Solutions may obtain Personal Data automatically.

This Personal Data is obtained through the use of cookies or similar technologies.

Some of the examples (non-exhaustive) where we may collect personal data of a user are:

• When a user signs up for alerts or newsletters;
• When a user visits Comtrol Solutions’ website;
• When a user (or someone on his/her behalf) contacts Comtrol Solutions for queries, requests or feedback;
• When a user participates in Comtrol Solutions’ marketing or promotional events; or
• When our client places an order.

Comtrol Solutions uses this Personal Data for the following purposes:

• help us and third parties obtain information about your visits to the sites
• process your orders
• deliver advertising, communications and content from us and third parties, on our sites and those of third parties, specific to your interests
• help you obtain information you are looking for
• measure how many people use our sites, and how they use them, to keep our sites running efficiently and to better understand our audiences
• system administration and troubleshooting

4. Who has access to your Personal Data?

Comtrol Solutions may share your Personal Data with third parties in the following circumstances:

• Comtrol Solutions may share your Personal Data with its affiliates, subsidiaries, or with third parties if such is necessary for the purposes as listed above. If appropriate, Comtrol Solutions will require third parties to conduct activities in a manner consistent with Comtrol Solutions policies and guidelines in relation to data protection.
• Comtrol Solutions may share your Personal Data if required to do so by law, court order, or other legal process, for example, with law enforcement agencies or other governmental agencies, to establish or exercise our legal rights or in connection with a corporate transaction, such as a divesture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Comtrol Solutions will not sell, rent or give away Personal Data to third parties for commercial purposes without the Customers/Partners’ consent.

5. How long will Comtrol Solutions process your Personal Data?

Comtrol Solutions retains your Personal Data for a limited amount of time and will delete your Personal Data as soon as it is reasonable to assume that: 

(a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and

(b) retention is no longer necessary for any other legal or business purposes. 

The exact period of time is based on the type of the Personal Data and the legal obligations or business purposes for retaining it.

6. What measures does Comtrol Solutions take to protect your Personal Data?

Comtrol Solutions has taken appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful processing, including by ensuring that:

• your Personal Data is protected against unauthorized access;
• the confidentiality of your Personal Data is assured;
• the integrity and availability of your Personal Data will be maintained;
• personnel is trained in information security requirements; and
• actual or suspected data breaches are reported in accordance with applicable law.

7. Transfer of data to other countries.

Comtrol Solutions may need to transfer your Personal Data to locations where we are required to fulfil our contractual obligations to you. In any case where we transfer Personal Data, Comtrol Solutions shall ensure that such a transfer is subject to appropriate safeguards. 

8. What rights can you exercise in relation to your Personal Data?

Based on the law applicable to the use of your Personal Data, you may be able to exercise a number of rights in relation to your Personal Data. Note that in many cases, your rights are not absolute and we may not be required to comply with your request. You may write to us at wk_goh@comtrolsolutions.com.

9. Will there be updates to this Privacy Notice?

Comtrol Solutions may update this Privacy Notice from time to time.  The updates will be reflected on this page.