KOMMA inc.(hereinafter “KOMMA”, “we” or “us”) is committed to ensuring that your personal data is collected and processed only in accordance with the rights and responsibilities under the applicable data protection laws and regulations, including the European Union’s General Data Protection Regulation (“GDPR”). KOMMA is the controller of the personal data you submit to us and thus responsible for such personal data under applicable data protection law.
What personal data we collect
We may collect the following personal data:
Your contact information including email address and phone numbers,
Your shipping address,
Your payment details,
Any demographic information such as postcode, preferences and interests,
Your social media account names, and
other information relevant to customer surveys and/or offers,
For the exhaustive list of cookies we collect see lower down this text.
What we do with the information we process – Legal ground for processing
For the purpose of fulfilling our obligations and our rights towards you we process the personal data you provide in accordance with the following:
Processing related to the purchase of products: Processing for the purpose of processing orders, performing fraud prevention, performing delivery of the products, providing product warranty, resolving disputes, collecting payments, handling claims, withdrawals and repayment, and for compliance with legal obligations (such as book keeping). KOMMA also reserves the right to process the personal data for contacting you after purchase and ask for your input relating to the purchase experience and a review of the products purchased.
Personal data will be processed for the time needed to fulfil KOMMA’s obligations, including facilitating warranty obligations.
Subscription of newsletters and marketing: Processing for the purpose of sending product information, special offers, running competitions, conducting market research, measuring interest in and improving KOMMA’s website, products and services, sending you newsletters and product information. Personal data will only be processed after receipt of you consent and until withdrawal of such consent.
Registration of product for warranty: Processing for the purpose of registering warranty information related to products you have purchased.
Personal data will only be processed after receipt of you consent and until withdrawal of such consent.
Contact with support or customer service: Processing for the necessary purpose of fulfilling KOMMA’s obligations related to such contact, including handling claims, withdrawals and repayment. Personal data will be processed for the time needed to fulfil KOMMA’s obligations.
Unsolicited personal data: Any personal data that you voluntarily choose to provide to KOMMA, other than what is set out above, are deemed to be given under the consent that KOMMA has the right to process such personal data until withdrawal of such consent. You are informed that such personal data may be available to any other visitors of the website. If you would like to withdraw your consent for such processing, please be aware that KOMMA may have difficulties, or even not being able, to keep track of such personal data and therefore KOMMA may request you to provide information about where such personal data is located to take appropriate actions. Personal data will be processed until withdrawal of consent. Such withdrawal is however subject to KOMMA being able to verify where to find such personal data.
Third parties and personal data transfer: KOMMA may engage with third parties that assist in the performance of the services stated above. Such third parties may receive access to your personal data in order for them to provide the intended services for KOMMA. Such processing include but is not limited to validating your address, sending you order confirmations, warehousing and distribution suppliers in connection with the delivery of your order, payment service providers processing your credit/debit card payments, banks and other financial services providers, social media channels if you engage with us by tagging/mentioning us or contacting us directly, and online marketplaces through which our products and services are made available to you for sale.
The personal data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws.
We never pass on, sell or swap your personal data with third parties for marketing purposes.
Law enforcement and legal processes: KOMMA may disclose your personal data if required to do so by applicable laws, court orders, judicial and government subpoenas or warrants, or otherwise to cooperate with law enforcement or other governmental agencies.
Furthermore, KOMMA reserves the right to disclose personal data that KOMMA deems appropriate or necessary in order to take actions to protect KOMMA and others from fraudulent, abusive or unlawful use or activity, to investigate and defend KOMMA from third party claims or allegations and to protect KOMMA’s business and legal rights, enforce contracts or protect the rights, property or safety of others.
Processing related to your user account: When you create a user account the Personal Data you have provided to us is processed under such account for the purpose of delivering a better customer and user experience. Under such user account you may find the Personal Data provided by you and how its processed related to:
Processing related to the purchase of products, Subscription of newsletters and marketing, Registration of product for warranty and Contact with support or customer service, as set out above, as well as for any other purpose as stated by KOMMA from time to time.
By setting up a user account you consent to us processing such information from the date of receipt of you consent and until withdrawal of such consent, provided however that KOMMA reserves the right to process your Personal data for the time needed to fulfil KOMMA’s obligations, including facilitating warranty obligations.
Right to access: You may at any time request information about your personal data that is processed by us.
Right to rectification: You may at any time request rectification of your personal data processed by us if the information is incorrect, including the right to have incomplete personal data completed.
Right to restriction: You may at any time request that KOMMA restricts the processing of your personal data i) if you claim that your personal data is incorrect, whereby KOMMA shall restrict all processing of such personal data pending the verification of the accuracy of the personal data, or ii) if the processing is unlawful, whereby you can oppose the erasure of personal data and instead request the restriction of the use of your personal data.
Right to erasure: You may at any time request that we delete any of your personal data processed by us. KOMMA does however reserve the right to retain your personal data for backups, prevention of fraud or abuse, satisfaction of legal obligations, or where KOMMA otherwise believes that KOMMA has the legitimate or mandatory reason to do so.
Right to object to processing based on legitimate interest: You may at any time object to processing of your personal data that is based on KOMMA's legitimate interest. KOMMA may then object and demonstrate the legitimate grounds for the processing.
Right to portability: You may at any time request to have a copy transferred to you or to another party of your personal data that we process.
Direct marketing: You may opt out from direct marketing by following the instruction in each marketing email.
How to you exercise your rights
Please contact KOMMA via the contact information provided below and state what right you would like to invoke. Upon contact with KOMMA for this purpose you may need to have access to the same e-mail address as used during purchase or registration with KOMMA in order for KOMMA to have the possibility of verifying your identity and right to access such personal data.
You also have a right to lodge a complaint with the relevant data protection supervisory authority.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable procedures to safeguard and secure the personal data we process. This includes for example firewalls, password protection, and authentication controls. Only authorized employees, agents and service providers, who have agreed to keep information secure and confidential, have access to your personal data. However, you should be aware that there is always some risk involved in transmitting information over the internet.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data, KOMMA will promptly assess the risk such event has on your rights and freedoms and if appropriate inform you and the relevant data protection supervisory authority of such event.
If you believe that your personal data has been compromised, please contact KOMMA via the contact information provided below as soon as possible.
A cookie is a small text file that is saved to, and, during subsequent visits, retrieved from your computer or mobile device.
KOMMA uses automatically collected information – however not any personal data – through cookies and other technologies to personalize your experience of our website and to monitor and analyze your use of the website.
Furthermore, KOMMA may from time to time use analytics technologies to measure and evaluate the access to and traffic on the website, and to generate navigation reports. Such technology is not collecting any personal data. Such analytics technologies are operated independently and has its own privacy policies.
Personal data controller contact information.
Please contact KOMMA if would like to:
- to receive information about your Personal Data that KOMMA is processing
- to correct such Personal Data
- to request that KOMMA either restricts its processing of your Personal Data or deletes such Personal Data, or
GDPR contact Information
1000 Lexington Street,
Waltham MA 02452
Latest update: January 4, 2022