Privacy

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by MetaComet Systems, Inc. (“MetaComet Systems”, “We”, “Us”, or “Our”) with respect to the www.metacomet.com and www.royaltytracker.com sites, their subdomains, and various related services (together referred to as the “Services”). This Policy applies when you visit the Services, including where we are acting as a Data Controller with respect to the personal data of Our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. If you are an employee, customer or other user of one of Our business customers (“End User”), we process your personal data on behalf of the business customer. Our processing of End Users’ personal data is also governed by Our agreement with that business customer.

We are committed to safeguarding the privacy of Our website visitors and users of Our Services. We will never sell, share, or use your personal data other than as described here.

By using Our Services and agreeing to this Policy, you consent to Our use of cookies in accordance with the terms of this Policy. If you do not agree to this Policy, you may not use the Services.

About This Policy

This Policy sets out how we will use and share the information that you give us or that we collect about you. This Policy describes your relationship with MetaComet Systems.

The General Data Protection Regulation (“GDPR”) describes how organizations must collect, handle, process, and store personal data. Personal data (under some laws, personal information), means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal data must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than is necessary
• Processed in accordance with the rights of the data subjects
• Be protected in appropriate ways
• Not be transferred outside the UK, unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously; this document describes Our approach to data protection. This Policy helps to protect us from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Who We Are And How To Contact Us

We are registered and do business in the United States of America. The Data Protection Lead is Ann Regan. You can contact us in any of the following ways:

Email: [email protected]
Phone:  +1 413 536 5989
Address: 29 College St., 3rdFL, South Hadley, Massachusetts 01075

OUR ARTICLE 27 REPRESENTATIVE

We have appointed EU and UK Representatives under Article 27 of the EU GDPR and UK GDPR respectively. Our appointed representatives are:

Our UK Representative:

Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as Our data protection agent. Our nominated UK Representative is:

GDPR Local Ltd.
Adam Brogden
[email protected]
Tel +44 1772 217800
1st Floor Front Suite
27-29 North Street, Brighton
England
BN1 1EB

Our EU Representative

Under Article 27 of the GDPR, we have appointed an EU Representative to act as Our data protection agent. Our nominated EU Representative is:

Instant EU GDPR Representative Ltd.
Adam Brogden
[email protected]
Tel +35315549700
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland

Who this Policy applies to

This Policy relates to data subjects of MetaComet Systems including clients, customers, employees, and all other individuals who visit or use the Services. Processing of your data is required in order to offer you Our products and services. This Policy applies to individuals who have shared their data with MetaComet Systems as either a customer, client, employee, supplier or in any other capacity.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR.

How we collect information

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect.

We do not collect or process sensitive data about you, as that is defined in the GDPR.

1. Information you provide

Account Setup

We collect information when you create or update your account. This may include business name, a contact person’s name, mailing address, phone numbers, a valid email address, payment information (for certain paid services), demographic information, and certain other information indicated as required during account creation.

If you choose certain paid services, you will be required to identify merchant banking information. In connection with your account registration, We may also ask for additional information, including the number of employees in your company (if an entity), your annual revenues, your industry and other similar information. We use all such information to provide the Services to you, including to contact you, confirm your identity and, if applicable, to invoice you.

Information created when you use Our site, Services, Contact Us, Request a Demo, Sign Up for Information, or Request Support

If you contact Us by one of the phone numbers on the Services, We collect your phone number and may record call audio. From chat support users, We collect personal data as well as information about the device and browser you use, your network connection and your IP address. From forum users, We collect certain personal data, including your name, email address and website URL. We also collect personal data such as your name, email, phone number, and company when you complete forms on the Services, including when you request a demonstration, sign up for our newsletter, or use our contact or service request forms.

2. Information from other sources

Automatically Collected Information

We automatically collect certain information and analytical data related to your visits to and use of the Services (see “Cookies and Third-Party Technologies” below). Such automatically collected information may include the date and time of your visit, page navigation, the IP address of your computer or mobile device, your computer or mobile device browser information, the Internet address that you visited prior to and after reaching the Services, the name of the domain and host you used to access the Internet, the type of mobile device you use, your mobile device’s unique device ID or other unique identifier and the features of the Services which you accessed.

Our Partners

We collect personal data from Our partners, which include individuals and businesses that have entered into a business agreement with Us. Our partners can include referral partners, developers, technology partners and solution partners. We also collect personal data about your customers from Our partners in accordance with their applicable privacy policy. We use all such information to provide the Services to you, including to contact you and confirm your identity and to improve the Services.

Social Media

The Services may use social media features, such as the Facebook “like” button (hereinafter referred to as the “Social Media Features”). These features may collect your IP address and which page you are visiting on the Services, and may set a Cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Service to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Service. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

3. Cookies and Third-Party Technologies

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive (“Cookie”). Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve Our Services in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better Services by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Services.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit Our site, you are presented with the ability to accept Our terms of use, including the storage of cookies on your machine. Should you not accept, then you are free to leave Our website, at any time.

Clear Gifs

When you use the Service, we may employ clear gifs (a.k.a. Web Beacons) which are used to track the online usage patterns of Our users anonymously. No personal data from your account is collected using these clear gifs. In addition, we may also use clear gifs in HTML-based emails sent to Our users to track which emails are opened by recipients. The information is used to enable more accurate reporting, improve the effectiveness of Our marketing, and make the Services better for Our users.

Types of Cookies

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide you with services available through the Service and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of Cookies on the Service.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Service, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Service.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Us and Third-Parties

Purpose: These Cookies are used to track information about traffic to the Service and how users use the Service. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Service. We may also use these Cookies to test new pages, features or new functionality of the Service to see how Our users react to them.

Cookies We Use

Cookie declaration last updated on 7/2/22 by www.cookiebot.com

How your information will be used

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Internal Usage

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	(a) Identity, (b) Contact	(a) Performance of a contract with you (b) Consent
To process and deliver the products and services you request including digital signages, and to manage payments, fees and charges.	(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications	(a) Performance of a contract with you, (b) Necessary for Our legitimate interests to recover debts owed to us (b) Consent
To manage Our ongoing relationship with you which will include notifying you about changes to Our terms, services or privacy policy, to maintain Our records	(a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications	(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for Our legitimate interests to keep Our records updated and to study how customers use Our services (d) Consent
To administer and protect Our business and Our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity, (b) Contact, (c) Technical	(a) Necessary for Our legitimate interests for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation (c) Consent
To use data analytics to improve Our website, services, marketing, customer relationships and experiences	(a) Technical, (b) Usage	(a)Necessary for Our legitimate interests to define types of customers for Our services, to keep Our site updated and relevant, to develop Our business and to inform Our marketing strategy (b) Consent
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile	(a)Necessary for Our legitimate interests to develop Our services and grow Our business (b) Consent

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

• Service providers who provide IT and system administration services. For example: Samsung and Curry’s
• Third parties including equipment providers, and other third parties as required to run Our business
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of Our business or Our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with Our instructions.

How to change your preferences

We operate in line with UK GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal data and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office [for UK companies]. Any requests or objections should be made in writing to the Data Controller, or you can visit Our website, call, or email us to contact us to change your preferences at any time.

Scope of Agreement

By submitting your personal data on this site or as required for us to provide services to you, you are affirming your agreement for such information to be used in accordance with this Policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.

We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR and other applicable laws. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data may be collected, stored and processed in the UK, however we may also collect, store, process, or transfer your data outside the UK where the parties involved in the processing of data are located, including without limitation, to the United States. This means that this information may be transferred to, processed, and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. We will ensure we take appropriate precautions to protect this data. Your data will normally be stored for up to 7 years to ensure we have records of service and other interactions.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal data without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend Our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in Our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data.

You will only receive marketing communications from us if you have:

• Requested information from us;
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and,
• You have not opted out of receiving marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Our obligations

We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR and other applicable privacy laws in the way we use and share your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

MetaComet Systems as a Data processor

When MetaComet Systems acts as a data processor, we will store and process the data provided to us by Our clients, in order to allow us to provide the services as agreed in the contract with the controller.

During the process we will ensure we meet Our obligations as defined in Our contract and in any associated Data Processing Agreement.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on Our instructions, and they are subject to a duty of confidentiality.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our website, we encourage you to read the privacy notice of every website you visit.

Legitimate Interests

Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

Your Age

Our Service is not intended for use by people under 18 years of age and we do not knowingly collect information from people under the age of 18. No one under the age of 18 may provide information on the Service. By using or accessing the Service, you acknowledge that you are 18 years old and have all rights necessary to conclude an agreement with Us and to provide Us with consent for the processing of your personal data. We shall not be liable for any consequences if it becomes clear that you have not reached the age of 18 at the moment of the agreement is being concluded or the consent is being provided.

If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at [INSERT PRIVACY EMAIL ADDRESS].

Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of the Website or Services that are California residents to request and obtain from us a list of what personal data (if any) we have shared with third parties or corporate affiliates for those entities’ direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

If you are a California resident and would like a copy of this notice, please submit a written request to the following address: [INSERT ADDRESS]. For all requests, you must put the statement “California Privacy Rights Notice” in the body of your request, as well as your name, street address, city, state, and zip code. You also need to attest to the fact that you are a California resident and provide a current California address for Our response. Please note that we will not accept requests via telephone, email or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not contain complete information.

California Do Not Track Disclosures

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (DNT) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, please visit: www.allaboutdnt.org.

Updates to the Privacy Policy

We may occasionally update this Policy. If We make significant changes, We will notify you of the changes on the Services or through others means, such as email. To the extent permitted under applicable law, by using the Services after such notice, you consent to Our updates to this Policy.

We encourage you to periodically review this Policy for the latest information on Our privacy practices.

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: [email protected] at MetaComet Systems, Inc. We will process data protection requests within 30 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk