Privacy Policy

1. Scope

Comity Inc., together with its subsidiaries and affiliates ("Comity," "we," "us," or "our"), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information when you visit or use our website, including comity.ai, our Insights pages, and any other online service that links to this Privacy Policy.

This Privacy Policy also explains how we use cookies, analytics tools, advertising technologies, and similar tracking technologies, and describes privacy choices that may be available to you.

This Privacy Policy does not replace the terms of any separate written agreement between Comity and its customers, vendors, business partners, or other contracting parties. If you use Comity products or services under a separate agreement, that agreement may include additional or different terms governing data and privacy.

2. Personal information we collect

"Personal information" means information that identifies, relates to, describes, or could reasonably be linked to an individual. We may collect the following categories of personal information.

A. Information you provide to us

We collect personal information that you choose to provide to us, including:

Contact information, such as your name, business email address, phone number, company name, job title, and mailing address.
Inquiry and communications information, such as information you submit through contact forms, demo-request forms, email, or other communications with us.
Marketing information, such as your communication preferences, newsletter signups, event or webinar registrations, and information about Comity products, services, or content that may interest you.
Professional information, such as your employer, business role, industry, and business contact details.
Feedback or submitted content, such as questions, comments, survey responses, or other information you choose to send us.

Please do not submit sensitive personal information to us through website forms.

B. Information collected automatically

When you visit our website or interact with our online services, we and our service providers may automatically collect information such as:

IP address;
device identifiers;
browser type and settings;
operating system;
referring and exit pages;
pages viewed;
links clicked;
date and time of visit;
time spent on pages;
interactions with our Insights content;
approximate location derived from IP address;
website performance information;
cookie identifiers and similar online identifiers;
UTM parameters and other marketing attribution information; and
other information about how you interact with our website, content, and online services.

We may collect this information through cookies, pixels, tags, local storage, web beacons, scripts, server logs, and similar technologies.

C. Information collected through analytics and advertising technologies

We use analytics tools, including Google Analytics and PostHog, to help us understand how visitors use our website and Insights content, measure website traffic and content performance, improve our website and services, and evaluate marketing effectiveness.

We may also use advertising and retargeting technologies to show ads to users who have visited our website and to measure the effectiveness of advertising campaigns.

Depending on how these technologies are configured, they may collect information such as page views, referral sources, browser and device information, IP address, approximate location, session information, clicks, scrolls, event data, and other website interaction information.

We do not intentionally use Google Analytics, PostHog, or advertising pixels to collect sensitive personal information, financial account information, government identification numbers, or the contents of free-text message fields.

D. Information from third parties

We may receive personal information from third parties, including analytics providers, advertising and retargeting partners, marketing and customer relationship management providers, business partners, event or webinar partners, public sources, professional or business directories, and vendors that help us maintain, supplement, or improve our business contact records.

Our website may also link to third-party recruiting platforms or applicant tracking systems. Comity’s website does not itself accept job applications. If you apply for a job through a third-party recruiting platform linked from our website, that platform’s privacy practices and terms will also apply. Comity may receive and process applicant information from that platform in connection with recruiting and hiring.

We may combine information we receive from third parties with information we collect directly or automatically.

3. How we use personal information

We may use personal information for the following purposes:

to operate, maintain, secure, and improve our website and online services;
to provide, evaluate, and improve our Insights content;
to respond to your inquiries, requests, and communications;
to provide information about Comity, our products, services, events, and content;
to send newsletters, updates, invitations, and other marketing communications;
to personalize and improve your experience with our website and content;
to analyze website traffic, usage patterns, performance, and content engagement;
to measure and improve marketing campaigns;
to conduct advertising, retargeting, and ad measurement;
to identify business prospects and understand interest in Comity’s services;
to evaluate and manage recruiting and hiring if you apply for a role through a third-party recruiting platform linked from our website;
to detect, prevent, investigate, and respond to fraud, security incidents, misuse, or unlawful activity;
to debug, repair, and maintain website functionality;
to comply with legal, regulatory, and contractual obligations;
to enforce our agreements and protect our rights, property, users, customers, personnel, and others;
for other purposes with your consent or as otherwise permitted by law.

4. How we disclose personal information

We may disclose personal information to the following categories of recipients.

A. Service providers and vendors

We disclose personal information to vendors and service providers that perform services for us, such as website hosting, cloud infrastructure, security, analytics, marketing operations, customer relationship management, email delivery, recruiting, professional services, and technical support.

B. Analytics providers

We disclose personal information to analytics providers, including Google Analytics and PostHog, to help us understand website usage, content engagement, performance, and marketing effectiveness.

C. Advertising and retargeting partners

We may disclose personal information to advertising and retargeting partners to deliver, personalize, and measure ads, including ads shown to users who previously visited our website. These partners may use cookies, pixels, tags, or similar technologies to collect information about your activity on our website and other websites over time.

Some of these activities may be considered "targeted advertising," "cross-context behavioral advertising," "sharing," or a "sale" of personal information under certain U.S. state privacy laws. Please see the "Your Privacy Choices" section below for more information.

D. Business partners

We may disclose personal information to business partners in connection with events, webinars, co-sponsored activities, integrations, joint marketing, or other business activities, where permitted by law.

E. Recruiting platforms and providers

Our website may link to third-party recruiting platforms, such as Ashby. Comity’s website does not itself accept job applications or application materials. If you apply through a third-party recruiting platform, Comity may receive applicant information from that platform and may disclose applicant information to recruiting-related vendors, service providers, and advisors that help us evaluate and manage recruiting and hiring.

F. Professional advisors

We may disclose personal information to lawyers, auditors, accountants, insurers, consultants, banks, and other professional advisors.

G. Legal, security, and compliance recipients

We may disclose personal information if we believe disclosure is necessary or appropriate to comply with law, legal process, regulatory obligations, or governmental requests; to enforce our agreements and policies; to protect rights, property, safety, or security; to prevent fraud or illegal activity; or to respond to security incidents.

F. Business transaction recipients

We may disclose personal information in connection with an actual or proposed merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets, or similar business transaction.

G. With your consent

We may disclose personal information with your consent or at your direction.

5. Cookies and Similar Technologies

We and our service providers use cookies, pixels, tags, local storage, web beacons, scripts, and similar technologies to operate our website, remember preferences, understand website usage, analyze Insights engagement, improve our services, measure marketing performance, and deliver or measure advertising.

We use the following types of cookies and similar technologies.

A. Strictly necessary cookies

These cookies are required for our website to function. They are usually set in response to actions you take, such as loading pages, submitting forms, setting privacy preferences, securing the website, or enabling basic website functionality.

Because these cookies are necessary, they cannot be disabled through our systems.

B. Analytics cookies

Analytics cookies help us understand how visitors use our website and Insights content. These cookies may collect information such as pages visited, links clicked, referral sources, session duration, browser and device information, approximate location, and other usage information.

We use analytics tools, including Google Analytics and PostHog, to measure website traffic, usage patterns, content engagement, and website performance.

C. Advertising and retargeting cookies

Advertising and retargeting cookies help us deliver, personalize, and measure advertising. These technologies may be used to show ads to users who have previously visited our website, measure ad campaign performance, limit ad frequency, and understand whether users interact with ads.

These cookies may be set by Comity or by third-party advertising partners. Use of these technologies may be considered "targeted advertising," "cross-context behavioral advertising," "sharing," or a "sale" of personal information under certain privacy laws.

D. Functional and embedded content cookies

Functional cookies help enable enhanced website features. Embedded content cookies may be set when our website includes third-party content, such as videos, social media content, maps, or similar embedded features.

These third parties may collect information about your interaction with their content, including if you are logged into their services.

6. How You Can Manage Your Cookies

You can manage cookies through your browser settings. Most browsers allow you to block, delete, or receive alerts about cookies. If you block or delete cookies, some features of our website may not work properly.

Where we make cookie controls available on our website, you may also use those controls to manage certain categories of non-essential cookies.

You may also be able to opt out of certain interest-based advertising through industry opt-out tools and advertising platform settings. These opt-outs may not prevent all advertising, and you may still see ads that are not based on your interests.

7. Google Analytics and PostHog

We use Google Analytics to help us understand how visitors use our website and to evaluate website traffic, referral sources, and content performance. Google Analytics may use cookies and similar technologies to collect information about your use of our website.

We also use PostHog to help us understand how visitors interact with our website and Insights content. PostHog may collect website interaction information such as page views, clicks, scrolls, session events, device information, browser information, and other usage data, depending on how the tool is configured.

We configure our analytics tools to avoid intentionally collecting sensitive personal information, financial account information, government identification numbers, resumes, application materials, or the contents of free-text message fields.

8. Your Privacy Choices

Depending on where you live, you may have certain rights and choices regarding your personal information.

A. Marketing communications

You may opt out of marketing emails by following the unsubscribe instructions in the email, if applicable, or by contacting us at legal@comity.ai.

Even if you opt out of marketing emails, we may still send non-marketing communications, such as responses to your inquiries or legally required notices.

B. Cookies and analytics

You may manage cookies through your browser settings and, where available, through cookie controls on our website.

You may also use tools made available by analytics providers, such as browser add-ons or privacy settings, to limit certain analytics collection. These tools may not prevent the use of other analytics tools or other technologies on our website.

C. Targeted advertising, sale, and sharing

Comity does not sell personal information for money. However, our use of advertising, retargeting, analytics, and similar technologies may be considered a "sale," "sharing," "targeted advertising," or "cross-context behavioral advertising" under certain privacy laws.

You may opt out of these activities by contacting us at legal@comity.ai with the subject line "Privacy Opt-Out Request." Where we make cookie or privacy controls available on our website, you may also use those controls to opt out of advertising and retargeting cookies.

Your opt-out will apply to the browser, device, and information reasonably associated with your request. Because cookie-based opt-outs are generally browser- and device-specific, you may need to submit or enable your choices separately for each browser and device you use.

Your opt-out will not stop all advertising. You may still see Comity ads or other ads, but they may be less relevant to you.

D. Global privacy control

Where required by applicable law, we honor legally recognized opt-out preference signals, such as Global Privacy Control, as a request to opt out of sale, sharing, or targeted advertising for the browser or device that sends the signal.

Because these signals are browser- and device-specific, you may need to enable the signal separately on each browser and device you use.

E. Do Not Track

Some browsers offer "Do Not Track" signals. There is currently no uniform standard for how websites should respond to Do Not Track signals. We do not respond to Do Not Track signals. This does not affect our response to legally recognized opt-out preference signals, such as Global Privacy Control, where required by law.

9. State Privacy Rights

Depending on where you live and subject to applicable law, you may have some or all of the following rights regarding your personal information:

the right to confirm whether we process your personal information;
the right to access personal information we have collected about you;
the right to receive a copy of your personal information in a portable format;
the right to request correction of inaccurate personal information;
the right to request deletion of personal information;
the right to opt out of sale, sharing, targeted advertising, or certain profiling;
the right to limit certain uses or disclosures of sensitive personal information, if applicable;
the right not to be discriminated against for exercising privacy rights; and
the right to appeal a denial of your request, where required by law.

To exercise privacy rights, contact us at legal@comity.ai. Please include enough information for us to verify and process your request.

We may need to verify your identity before fulfilling certain requests. Depending on the request, we may ask you to provide information that allows us to reasonably verify that you are the person about whom we collected personal information. If we cannot verify your identity, we may deny the request.

You may designate an authorized agent to submit a request on your behalf where permitted by law. We may require the agent to provide proof of authorization and may also require you to verify your identity directly with us.

If we deny your request and applicable law gives you a right to appeal, you may appeal by contacting us at legal@comity.ai and including "Privacy Appeal" in the subject line.

10. Notice to California Residents

This section applies to California residents and supplements the rest of this Privacy Policy.

In the preceding 12 months, we may have collected the following categories of personal information: identifiers; California customer records information; commercial information; internet or other electronic network activity information; approximate geolocation information; professional or employment-related information; communications information; and inferences regarding potential interests in Comity content, products, or services.

We collect these categories of personal information from you, your browser or device, cookies and similar technologies, analytics providers, advertising and retargeting partners, service providers, business partners, recruiting platforms, and public or professional sources.

We collect, use, and disclose these categories of personal information for the business and commercial purposes described in this Privacy Policy, including website operation, communications, analytics, marketing, advertising, retargeting, security, recruiting, legal compliance, and business operations.

We may disclose these categories of personal information to service providers and vendors, analytics providers, advertising and retargeting partners, business partners, recruiting platforms and providers, professional advisors, legal, security, and compliance recipients, business transaction recipients, and other parties with your consent or at your direction.

A. Sale or sharing of personal information

Comity does not sell personal information for money.

During the 12 months before the effective date of this Privacy Policy, we did not sell personal information for money. To the extent advertising, retargeting, analytics, or similar technologies are active on our website, those technologies may involve the sale or sharing of the following categories of personal information under California law:

identifiers, such as IP address, cookie identifiers, and online identifiers;
commercial information, such as products, services, or content you have shown interest in;
internet or other electronic network activity information, such as pages viewed, links clicked, and interactions with our website;
approximate geolocation information derived from IP address; and
inferences regarding potential interests.

The categories of third parties to whom this information may be sold or shared include advertising partners, analytics providers, and other third parties that set or access cookies, pixels, tags, or similar technologies on our website.

We do not knowingly sell or share personal information of individuals under 16 years of age.

B. Sensitive personal information

We do not intentionally collect sensitive personal information through our website, and we do not use or disclose sensitive personal information for purposes that require a right to limit under California law.

C. California Shine the Light

California residents may request information regarding our disclosure of certain personal information to third parties for their direct marketing purposes. To make such a request, contact us at legal@comity.ai and include "California Shine the Light Request" in the subject line.

11. Retention of Personal Information

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

The criteria we use to determine retention periods include:

the nature of the personal information;
the purposes for which it was collected;
the length of our relationship with you or your organization;
whether you have requested information, services, or communications from us;
legal, accounting, tax, audit, compliance, and reporting obligations;
security, fraud prevention, and dispute-resolution needs;
applicable statutes of limitation;
contract requirements; and
our legitimate business needs.

We may retain de-identified, aggregated, or anonymized information for lawful business purposes.

12. Security

We use reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information. However, no method of transmission, processing, or storage is completely secure. We cannot guarantee absolute security.

13. International Visitors

Comity is based in the United States. If you access our website or provide personal information from outside the United States, your personal information may be transferred to, stored in, or processed in the United States and other countries that may not provide the same level of data protection as your home jurisdiction.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, our legal bases for processing personal information may include:

your consent;
performance of a contract or steps taken at your request before entering into a contract;
our legitimate interests, such as operating and improving our website, communicating with you, securing our services, conducting B2B marketing, and developing our business;
compliance with legal obligations; and
protection of legal rights and interests.

Where required by law, we obtain consent before using non-essential cookies or similar technologies. Where personal information is transferred internationally, we rely on appropriate safeguards where required by applicable law.

Individuals in the European Economic Area, United Kingdom, or Switzerland may have rights to access, correct, delete, restrict, or object to processing of personal information, withdraw consent, request portability, and lodge a complaint with a supervisory authority. To exercise rights, contact us at legal@comity.ai.

14. Children’s Privacy

Our website and services are intended for business users and are not directed to children. We do not knowingly collect personal information from children under 16.

If you believe a child has provided personal information to us, contact us at legal@comity.ai, and we will take appropriate steps to delete the information.

15. Third-Party Websites and Services

Our website may link to third-party websites, platforms, services, or content, including recruiting platforms and embedded content. We are not responsible for the privacy practices, content, or security of third-party websites or services. Your use of third-party services is governed by their own privacy policies and terms.

16. Accessibility

If you need this Privacy Policy in an alternative format, please contact us at legal@comity.ai.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date above indicates when this Privacy Policy was last revised. If we make material changes, we may provide notice by posting an updated notice on our website or by other means as required by law.

18. Contact Information

If you have questions about this Privacy Policy or our privacy practices, or if you would like to exercise privacy rights, contact us at:

Comity Inc.
Email: legal@comity.ai

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