Privacy Policy

Last Updated: March 25, 2024

This privacy policy of Comet ML Inc. (“Comet,” “we,” “us,” or “our”), details our policy and efforts on protecting user information. We are the “Data Controller” and will manage the data in accordance with this policy. The website and our products and services, including any of our data inspired features and APIs, are collectively referred to as “Services”. This Service does not require you to enter any information to view the website or the products and services, however, in order to become a Member of Comet certain Personal Information may be required to provide services to you. The Personal Information you provide is governed by the Privacy Policy.

This Privacy Policy does not apply to the privacy practices of third parties whose links may appear on or through the Services. We are not responsible for the content or privacy practices of third parties or other users.

We recommend that you exercise caution before you voluntarily disclose personally identifiable information, on publicly accessible or displayable parts of the Service, to other users or through third-party links on third-party websites or platforms. If you have questions about this policy, including deleting or correcting your personal data please contact our Support team at privacy@comet.com.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. In some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

If you are a California resident, please also review our California Resident Privacy Notice (<link>) for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law.

What we Collect and How we Use your Information Collection

a) Definition of Personal Information.

Personal Information shall mean any data about an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal information includes both directly identifiable information such as a name, identification number or unique job title, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, or telephone number.

b) Registration of Comet Account.

In order to become a member with a Comet Account, we require certain identifying information that will be linked to your Account, including your name and email address. If you do not provide this information we can not create an account for you. We encourage you to exercise caution before voluntarily disclosing other types of personally identifying information about yourself. We expressly prohibit you from disclosing any personally identifying information about another person, whether a member or not.

c) Email Addresses.

We do not and will not send spam, sell or rent your email address or any social media login account information to third parties. We do not disclose, sell, share, trade or give away a user’s personal information to third parties, except as needed for completing payment and billing transactions through the services of payment processing vendors, if applicable.

d) Logging Statistics.

Like most website operators, our servers automatically collect certain types of non-personally-identifying, technical information, such as the browser type, language preference, referring site, and the date and time of each visitor request. We use this information to better understand how our visitors use our website, and to maintain Services, it is not use for any other purpose such as to profile those who access this Site.

e) Data Aggregation.

In addition to the other uses described in this Policy, you agree that we may extract and use information from the information you disclose for the purposes of aggregating data in a non-identifiable method. This aggregated data may be used internally to improve services, add new features or make refinements. In addition this aggregated data may be used, without limitation, to develop, analyze, combine, or publish the aggregated data for commercial purposes.

f) IP Addresses.

Internet Protocol addresses indicate the location of a user’s computers or mobile device on a network connected to the Internet. Providing Services to you may result in the logging of IP addresses for systems administration and troubleshooting purposes. We do not log IP addresses to track your session, nor do we link IP addresses to anything personally identifiable.

g) Cookies.

Your use of the Services may result in the assignment and storage of session cookies to recognize your access privileges. A cookie is a text file that is placed on the hard disk of your computer or mobile device by a server. Session cookies expire when you end your session and close your browser interface. Cookies cannot be used to run programs or deliver viruses to your computer or mobile device. Cookies are uniquely assigned to you, and can only be read by a server in the domain that issued the cookie to you. We use cookies to help us identify and track visitors, their usage of and preferences on our website. Visitors who do not wish to have cookies placed on their computers or mobile devices should set their browsers to “Refuse Cookies” before using our Services, with the drawback that certain features of our Services may not function properly without the aid of cookies.

h) Legal Bases for Processing European Information.

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your information when we have a valid legal basis for such processing, including as set forth below.

• Consent. You have consented to the use of your information. For example, we may process your information to send you marketing communications or to use cookies where you have consented to such use.
• Contractual Necessity. We need your information to provide you with our Services. For example, we may need to process your information to respond to your inquiries.
• Compliance with a Legal Obligation. We have a legal obligation to use your information. For example, we may process your information to comply with tax and accounting obligations.
• Legitimate Interests. We or a third party have a legitimate interest in using your information. Specifically, we have a legitimate interest in using your information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

When you contact us such as through e-mail or via the contact form, the information you provide will be processed for the purpose of processing your request and for the event that follow-up questions arise. If you are contacting us in relation to your purchase, our legal basis for the processing of your personal data is that it is needed to fulfill our contract of sale with you. If you are contacting us in relation to other matters, our legal basis for the processing of your personal data is our legitimate interest to address your concern and to enable you to contact us quickly and easily. The legal basis is Article 6(1)(f), UK GDPR. The personal data collected by us in this context will be deleted when the request associated with the contact has been completely clarified and it is also not to be expected that the specific contact will become relevant again in the future, unless legal storage obligations stand against this. If you receive a newsletter, notification, and/or marketing without subscribing, we are doing so on the basis of our Article 6(1)(f), UK GDPR and our legitimate interest for marketing and to inform you about our products and services (See Newsletters and Electronic Communications below).

How we Share your Information

Comet discloses potential personally identifying information only on an as needed (or required) basis as follows:

To Comet employees that: (i) need to know that information in order to process it on our behalf or to provide the Services; and (ii) that have expressly agreed not to disclose it to others. Note; Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Services you consent to the transfer of such information to them.

• As required by law such to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request.
• If Comet becomes involved in a merger, acquisition, or any form of sale of some or all of its assets. In the event of a merger, acquisition, or any form of sale of some or all of Comet assets, we will ensure that the acquiring organization agrees to protect personal information in accordance with the commitments we have made in this Privacy Notice, and that the acquiring organization will provide notice before personal information, customer information, or business information becomes subject to a different privacy notice.
• We may allow others to provide analytics and related services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Comet and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. The services we use for these purposed may include Mixpanel, Amplitude, Google Analytics, Fullstory, and Intercom.
• To any other third party with your prior consent to do so.

We do not sell your personal information to third parties. Comet takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally identifying and personally identifying information.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We also use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, and the dates and times of your visits.

Accessing and Updating your Personal Information

To review, access or update your personal information to review its accuracy, or request deletion please contact our data-removal@comet.com.

We will make commercially reasonable efforts to provide you with reasonable access to any of your personal or other account information we maintain within forty five (45) days of your request. We provide this access so you can review it, make corrections, or request deletion of your information. If we cannot honor your request within the 45-day period, we will tell you when we will be able to provide access. In the unlikely event that we cannot provide you access to your information, we will explain why we cannot do so.

Please note that any changes you make will be reflected in our active user database within a reasonable time, however we may retain information you submit for backups, archiving, prevention of fraud, to satisfy legal obligations, or otherwise we reasonably believe there is a legitimate reason to do so.

If you are a California resident, please also review our California Resident Privacy Notice (<link>) for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law.

Your European Privacy Rights.  If you are located in the EEA or the UK, you have the additional rights described below.

• You may request access to the information we maintain about you, update and correct inaccuracies in your information, restrict or object to the processing of your information, have your information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your information to another company.  You also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your information at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

To exercise these rights please contact support by by e-mailing us at privacy@comet.com or by mailing us at Comet ML, Inc., 228 Park Ave S, Suite 15549, New York, NY, 10003, Attn: Privacy Officer.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Security

To prevent unauthorized access, safeguard data accuracy, and maintain the appropriate use of information, we have put in place appropriate physical, technical, and administrative procedures to protect the personal information data you submit. We make every effort to ensure the integrity and security of our network and systems. However, since the Internet is not 100% secure and as new technology evolves and emerges, we cannot guarantee that our security measures will prevent third-party interferences from illegally obtaining or tampering with your personal information.

We encourage you to help us by also taking precautions to protect your personal data when you use the Services. Change your Account password often, using a combination of letters, numbers, and characters, and make sure you use a secure connection.

Retention

We take measures to delete your information or keep it in a form that does not permit identifying you when your information is no longer necessary for the purposes for which we process it unless we are required by law to keep your information for a longer period.  When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

International Transfers of Data

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the EEA, the UK, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may transfer personal information from the EEA or the UK to the United States based on Standard Contractual Clauses, as needed to perform our Services that you have requested from us, or with your consent. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing. To obtain additional information on the transfers, please contact us using the contact information below.

Newsletters and Electronic Notifications

We may send newsletters, e-mails and other electronic notifications containing promotional information. Our newsletters contain information about our products and our company. For the subscription to our newsletter we use a logged Double-Opt-in procedure. This means that after subscription you will receive an e-mail asking you to confirm your registration. Newsletter subscriptions are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data. To subscribe to the newsletter, it is sufficient to enter your e-mail address. The provision of any  further data is voluntary and is used to address you personally. After your confirmation we will save your e-mail address for the purpose of sending the newsletter. The newsletter dispatch and the measurement of performance are based on your consent if you subscribed. To stop receiving the newsletter, you may withdraw your consent to or object to receiving the same at any time by clicking on the unsubscribe link provided in every newsletter e-mail or contacting us as provided below.

Feedback & Support

If you send us a request (via a support email or one of our feedback channels, as applicable), we reserve the right to publish it (stripped of all personally identifying information, of course) in order to help us clarify or respond to your request or to help us support other users (i.e. create an FAQ database).

We may provide technical support to service your Account(s) with us. In order to do so, we may use certain personally identifying information, with your consent, to access your account for the purpose of troubleshooting, running tests, and/or otherwise providing support. In providing technical support to you, we may potentially see other personally identifying information viewable on your Account pages. As with all other information, we promise to hold any information we encounter in the process of providing support to the highest possible security and protection standards.

Privacy of Minors

We do not promote or offer the Services for use by anyone under the age of thirteen (13) (“minors”). Comet does not knowingly solicit or collect personal information from minors, and we will not knowingly link to any third-party website or platform, or host any of your Sites that solicit or collect personal information from minors. If you believe that a minor has disclosed personal information to us or that we have linked to such a third-party or user website or platform, please contact us at privacy@comet.com.

Contact Us

If you have any questions about this Privacy Policy or data requests pursuant to applicable law, please email us at privacy@comet.com or mail us at:

Comet ML, Inc.
228 Park Ave S
Suite 15549
New York, NY, 10003
Attn: Privacy Officer