Last updated: May 29, 2018

We appreciate you visiting this website (www.comsec.co.tz). Our visitors’ privacy and trust are important to us. We provide this notice of our Privacy Policy in order to

make sure that your expectations and our practices are aligned, and that you (“you” or “User”) are aware of your choices with regard to our use and disclosure of the

information you provide to us.

SECTION 1 : OVERVIEW

(a) This Privacy Policy applies to your use of:

(i) this website, including related digital publications, bulletin boards, forums, social media and e-newsletters (the “Site”) and, without limitation.

(ii) all other websites owned and/or provided by Comsec.

(iii) all services offered through this Site and/or any other Comsec website.

(iv) all mobile applications, software offerings and applications owned and/or provided by Comsec and/or available on or through this Site or any other Comsec website.

(v) all web pages, data, text, images, photographs, illustrations, graphics, audio, video and documents including articles, marketing materials, press releases and other information and content available on or through this Site or any Comsec website (together with the Site, (i) through (v), collectively the “Services”).

(b) This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources or pursuant to a separate written or electronic agreement with you. This Privacy Policy does not apply to the practices of companies that Comsec does not own or control, or to people that Comsec does not employ or manage.

(c) By accessing and using the Services, you acknowledge that you have read and understand this Privacy Policy, and that you accept them and agree to be legally bound by it. You do not have permission to use the Services if you do not accept and agree to be legally bound by this Privacy Policy. Your use of any of the Services constitutes your acceptance of this Privacy Policy and your consent to any action we take with respect to your information in compliance with this Privacy Policy.

(d) We may change the terms of this Privacy Policy, so Users are encouraged to review this page from time to time. Your continued use of the Services following the posting of changes to the Privacy Policy means that you accept the changes.

(e) This Privacy Policy applies however you access the Services, including, without limitation, via a computer, tablet, smart-phone or other internet-enabled device (“Device”).

(f) We endeavor to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 1998 (DPA) and, on and from 25 May 2018, the European General Data Protection Regulation (GDPR). Terms with meanings under GDPR are identified here:

(i) We are considered a “Data Controller”. Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

(ii) We utilize “Data Processors (or Service Providers)” Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

(iii) You, or any User, would be considered a “Data Subject”. A Data Subject is any living individual who is the subject of Personal Data.

(iv) “Personal Data” is defined below.

SECTION 2 : INFORMATION WE COLLECT AND HOW WE COLLECT IT.

(a) We require you to provide certain information about yourself when you register with certain of the Services. We may receive information about you when you respond to requests for feedback, when you participate in contests and surveys, and when you submit postings to public areas of this Services (e.g., moderated discussions and bulletin boards).

(b) Information we collect may include information from which you may be personally identified (“Personal Data”) which may include:

(i) name, postal address, telephone number, fax number and e-mail address,

(ii) certain business information such as employer name, occupation, industry, job function, job title and buying information (e.g., preferences or history),

(iii) certain optional information such as birth date, birthplace, mother’s maiden name, gender, geolocation information, zip code, biographical information, personal interests,

(iv) Facebook/Twitter/Instagram/Google/ICQ/AIM/Yahoo/MSN/SKYPE user name (or similar user names), and

(v) photos, videos, audio files that may contain your image or voice, when you register with them, use the particular products or services, or post content on a blog site as a guest with authoring rights, as applicable.

(c) Certain data collected automatically either generated by the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit) which is considered “Usage Data” may also be collected. Some examples:

(i) When you visit the Services, we may collect the IP address of your Device.

(ii) We also use automatic data collection technology to record other information that identifies your Device and tracks your behavior on the Services.

(iii) We may automatically receive and record information on our server logs from your browser, including your IP address, cookies, and the pages you request, as well as pages you have visited of our partner and affiliate websites and the products you were interested in on that site.

We do not collect Personal Data in this way, but if you provide us with Personal Data, we may associate that information with the information that is collected automatically.

SECTION 3 : HOW WE USE YOUR INFORMATION.

(a) We use Personal Data collected via the Services for the following purposes:

(i) To provide you with the Services.

(ii) To respond to your inquiries and contact you about changes regarding the Services.

(iii) To provide you with e-mail, fax and other notices (such as expiration and renewal notices) regarding your account and the products or services that you are receiving, and for billing and collection purposes.

(iv) For support for internal operations including, among other things, contextualizing advertising, frequency capping, legal compliance, site analysis and network communications.

(v) For any other purpose disclosed at the time the information is collected or to which you consent.

(vi) As otherwise specifically described in this Privacy Policy or the Terms.

(b) Usage Data may be used for:

(i) Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP.

(ii) Estimate the total number of users visiting Comsec websites from specific geographical regions.

(iii) Help determine which users have access privileges to certain content, services, or resources that we offer.

(iv) Monitor and prevent fraud and abuse.

(v) Estimate and report our total audience size and traffic.

(vi) The Services may display your IP address to the owners or maintainers of certain journals or Blogs when you post to those journals or Blogs and the owner or maintainer has enabled functionality on the sites for this purpose.

(c) We may use your information to better understand our Users and to improve our Services. For example, we may use this information to determine what portions of the Services are most popular and the demographics of our Users generally. Session ID, cookies and persistent cookies which remain on your hard drive for an extended period of time, and other User information also enable us to customize your experience on the Services. We may use IP addresses to help diagnose problems with our servers or to administer our Services.

(d) Unless you opt out, we may use the information you provide us to send you e-mail, fax and other communications on behalf of Comsec and our affiliates, including e-mail newsletters or promotional offers for Comsec services. See our opt out policies below.

(e) We may use your information to send you e-mail and other communications on behalf of third parties. Each of these communications will include instructions for opting out of receiving future third party offers from us. You may opt out of receiving third party offers at any time. See our opt out policies below.

(f) Your information, including Personal Data, may be transferred to — 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. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

SECTION 4 : OUR DISCLOSURE OF YOUR INFORMATION.

(a) We may disclose to third parties aggregated, anonymous statistics about many Users, and individual information that is not Personal Data without restriction as long as no individual is identifiable by the information disclosed. We do not share Personal Data we learn about you from your use of the Site and Services with others, except as described in this Privacy Policy without your consent or except as follows:

(i) Name and/or business name and title (but not information by which you may be contacted i.e. name, postal address, telephone number, fax number and e-mail address) in representative lists of our publication circulation and/or Services membership.

(ii) To third parties engaged to provide services to us under contractual requirement to keep Personal Data confidential and use it only to perform the services.

(iii) Unless you opt out, name, postal address, telephone number, fax number and e-mail address to other third parties to market their products or services under contractual requirement to keep Personal Data confidential and use it only to market and provide their products or services. You may opt out of such disclosures by sending an e-mail to sales@comsec.co.tz with the subject line: “do not disclose” or by such other means as we may from time to time make available to you.

(iv) To any successor pursuant to an asset sale, merger, consolidation, restructuring, reorganization, liquidation or other similar transaction involving Comsec or the Services.

(v) When we believe such disclosure is required by law, regulation or securities exchange requirement or for the protection of persons or property.

(vi) When disclosure is necessary to accomplish the purpose for which you provide it.

(vii) We may share any information (including Personal Data) you provide with other Comsec member companies for any uses consistent with those disclosed in this Privacy Policy.

(b) We may share Personal Data about you under the following circumstances:

(i) In the course of operating our business it may be necessary or appropriate for us to provide access to your Personal Data to others, such as our service providers, contractors, and select vendors so that we can operate the Services and our business. Where practical, we seek to obtain confidentiality agreements that are consistent with this policy and that limit others’ use or disclosure of the information you have shared.

(ii) We may share your Personal Data to respond to subpoenas, court orders, or legal process, to establish or exercise our legal rights or, defend against legal claims, and if in our judgment in such circumstances disclosure is required or appropriate.

(iii) We may share your Personal Data if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our various terms of use, or as otherwise required by law.

(iv) As we continue to develop our business, we may also buy or sell all or part of our business. In such transactions, Personal Data you have shared with us is generally one of the business assets that will be transferred. The transferred Personal Data will remain subject to the promises made in this privacy policy or subsequent policies to which you have consented.

(c) When you post a message, your user ID or alias that you are posting under may be visible to other users.

(d) IF YOU POST PERSONAL INFORMATION ONLINE THAT IS ACCESSIBLE TO THE PUBLIC, YOU MAY RECEIVE UNSOLICITED MESSAGES FROM OTHER PARTIES IN RETURN.

SECTION 5 : RETENTION OF DATA.

(a) Comsec will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

(b) Comsec will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

SECTION 6 : SECURITY.

We use reasonable safeguards to protect Personal Data we collect on via the Services from unauthorized access, use, modification or disclosure. However, due to the design of the Internet and other factors outside of our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties.

SECTION 7 : RIGHTS TO ACCESS AND CHANGE INFORMATION.

(a) Comsec aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

(b) Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

(c) If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

(d) In certain circumstances, you have the right:

(i) To access and receive a copy of the Personal Data we hold about you.

(ii) To rectify any Personal Data held about you that is inaccurate.

(iii) To request the deletion of Personal Data held about you.

(e) You have the right to data portability for the information you provide to Comsec. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

(f) Please note that we may ask you to verify your identity before responding to such requests.

(g) You may view and update information that you previously submitted to this Site by visiting the newsletter or website registration page for this Site, or which you submitted to request a print publication, by sending an e-mail to sales@comsec.co.tz or by such other means as we may from time to time make available to you. However, a request to change information may not be accommodated if the request would conflict with legal requirements or result in incorrect information. Requests to view or change personal information may take a few days to process.

SECTION 8 : OPTING OUT.

You have the right to opt out to any of our Services and communications. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. All email newsletters will provide you with an opportunity to opt out of receiving future issues of the newsletter. All promotional offers will include an opportunity to opt out of receiving future promotions from the brand whose product/service is being promoted. We will not share identifying contact data on our users who have opted out of a specific channel unless they engage and consent through other Comsec opt-in email subscription or lead generation channels. Users that have opted out of a specific channel will be removed from the channel’s deployment list within 10 business days.

You may also opt out of receiving third party offers from a Service at any time by sending an e-mail to sales@comsec.co.tz with the subject line “opt out – third party” or by such other means as we may from time to time make available to you.