Privacy Policy

The types of personal information we obtain about you depend on how you interact with us and our products and services. When we use the term "personal information," we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

When we collect any information that does not identify you as a specific natural person, such information may not be deemed personal information under applicable law; such information, unless otherwise prohibited by law, may be used and disclosed for any purpose. Similarly, if applicable law requires that we treat non-personal information as personal information, we will use and disclose this information as personal information in accordance with this Policy.

The following are the categories and specific types of personal information that we collect:

Basic Identifying Information. This may include your full name, postal and billing address, e-mail address, phone number, date of birth, account name, signature, username, social media handle, employer, or other similar identifiers.

Device Information and Other Unique Identifiers. This may include device identifier, internet protocol (IP) address, device type, carrier, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.

Internet or Other Network Activity. This may include information regarding your interactions with our website, mobile application, emails, or advertisements.

Geolocation Data. This may include information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.

Order Information. This may include products or services you have purchased or considered, and your product preferences.

Demographic Data. This includes age and gender, some of which may include characteristics of protected classifications under state or federal law.

User Content. This may include your communications with us, communications with other users, and any other content you provide (such as social media profiles, photographs, images, videos, work experience, portfolio, survey responses, comments, gig listings, reviews, testimonials, and other content).

Inferences. Inferences drawn from or created based on any of the information identified above.

Job Applicant Information. Including professional or employment-related information (such as education and employment history) and any other information you provide in connection with applying and interviewing for employment with us.

Sensitive Personal Information. We only collect sensitive personal information, as defined in applicable data protection laws, with your consent. We do not use sensitive personal information for inferring characteristics about you.

We collect information about you in a range of ways, including the following:

Directly from You. We collect personal information you provide, such as when you register for an account or create a profile, contact us, respond to a survey, or sign up to receive emails or text messages.

Using Online Tracking Technologies and Other Automatic Data Collection Technologies. When you visit our Sites, open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using online tracking technologies such as pixels, web beacons, and cookies. For more information, please see the 'Cookies and Similar Online Tracking Technologies' section below.

From Our Business Partners. We may obtain information from businesses that we have partnered with, collaborate with, or work with.

From Social Media Platforms and Networks. If you interact with us on social media or use features made available by social media platforms in connection with our Sites, we collect information that you disclose to us, or that the social media platforms disclose to us. Please review the privacy policies and settings of the social media platforms that you use.

From Other Sources. We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We may also create information based on our analysis of the information we have collected from you.

We and our third-party partners and service providers (such as advertising and analytics providers) use tags, pixels, web beacons, cookies, and other similar online tracking technologies to gather information when you interact with our Sites and email communications. Some online tracking technologies help us maintain the security of our Sites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Depending on how you interact with our Sites, the personal information we collect and the way in which it is used may vary. We use the information we collect in order to best provide our services. Where you have provided us with your personal information, we may use that information in the following ways:

Providing Services. We use your personal information to provide our services, such as to review your application to use the services; to send notifications to you related to your account; to create, maintain, and otherwise manage your account or profile, including offering functionalities such as the ability to save user preferences and history; and to provide a forum for posting photos, videos, gig listings, and finding and offering work opportunities.

Operate and Improve Site and Services. We use your personal information to operate, maintain, and improve our Sites and services, including to identify and repair errors or problems; to respond to comments and questions and provide customer service; and to send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.

Marketing and Promotions. We use your personal information to send marketing, advertising, and promotional communications by email and text message (such as promotions and event invitations).

Analytics and Personalization. We use your personal information to develop your user profile; to conduct research and analytics; to understand how you interact with our Sites and communications with you; to improve our Sites and marketing campaigns; to personalize your experience with the services; and to provide personalized recommendations.

Promote Security and Prevent Fraud. We use your personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent profiles and security incidents.

Legal Obligations. We use your personal information to comply with our legal and regulatory obligations under applicable Indian laws (including the Information Technology Act, 2000, relevant rules, and the Digital Personal Data Protection Act, 2023, as applicable), to establish or exercise our rights, and to defend against legal claims.

We will not disclose your personal information to third parties except as follows:

We may share personal information with third-party service providers that perform services to support our core business functions, internal operations, and marketing. Their use of your information is not governed by this privacy policy.

We may share personal information through Site features such as plugins, widgets, or other tools made available by social media platforms that may result in information being collected or disclosed between us and such parties. Their use of your personal information is not governed by this privacy policy.

We may share personal information for legal, protection, and safety purposes, such as to comply with laws; respond to lawful requests and legal processes; protect the rights and property of Como, our agents, customers, and others; and enforce our agreements, policies, and terms of use.

We may share personal information with your consent.

If you submit a public review or feedback, we may (at our discretion) store and present your review on our Sites. If you wish to remove your public review, please contact us via the Contact Us form on our website.

We may share information in an emergency, including protecting the safety of our employees and agents, our customers, or any person.

Personal information is maintained on our servers or those of our service providers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Policy.

We may share personal information with our affiliates, or when we do a business deal involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

This Policy applies only to information we collect, process, and use through our Sites. This Policy does not apply to information that we collect through other channels or any third-party websites that you may be able to access from our Sites, which may have data collection and use practices and policies that materially differ from those described in this Policy, or to any services that may be offered by our business partners. We are not responsible for the content or privacy practices of any third-party sites.

Your personal information is primarily stored and processed in India. Where operationally necessary, we may transfer limited personal information to service providers in other jurisdictions for hosting, support, analytics, or security operations, subject to contractual and technical safeguards and applicable Indian law. By using our Sites, you acknowledge such transfer, storage, and processing in accordance with this Privacy Policy.

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as necessary to: respond to any questions, complaints or claims made by you or on your behalf; show that we treated you fairly; or comply with our legal obligations; resolve disputes; enforce our agreements; or protect against fraudulent, deceptive, or illegal activity.

We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

We have put in place reasonable measures and appropriate procedures for implementing these policies and for safeguarding the personal data we collect. However, we cannot guarantee that personal information we collect will never be disclosed in a manner inconsistent with this Policy. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access and make changes to your account. For that reason, we strongly recommend that you take appropriate steps to protect against unauthorized access to, and use of, your account. Please notify us as soon as possible if you suspect any unauthorized use of your account or password.

Consistent with applicable Indian law, including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023 (as applicable), you may exercise certain rights in respect of your personal information.

Access, Correction, Erasure, and Consent Management. Where permitted by applicable law, you may request access to and details of the personal information we maintain about you and how we process it, request correction of inaccurate information, request erasure of personal information, and withdraw consent where processing is based on consent. We may decline or limit certain requests where retention or processing is required to comply with legal obligations, resolve disputes, enforce our agreements, or protect against fraudulent, deceptive, or illegal activity.

To exercise any such rights applicable to you, please contact us via the Contact Us form on our website. We will respond to your request within a reasonable timeframe in accordance with applicable law.

The Sites are not specifically directed at or intended for children under the age of 13, and Como does not knowingly collect personal information via the Sites from anyone under 13. Any user that believes that Como has in its database the personal information of a child under the age of 13 should contact us via the Contact Us form on our website, so that, if necessary, we can remove the applicable information.

Email. You can stop receiving promotional e-mails at any time by clicking on the 'unsubscribe' link at the bottom of any promotional e-mail that you receive from us.

Text Messages. You can opt-out of receiving text messages from us by replying 'STOP' to the text message you receive from us.

In-App Push Notifications. You can stop receiving in-app push notifications by adjusting your notification settings in our application.

We welcome your comments or questions about this Policy. You may contact us via the Contact Us form available in the footer of our website, or by email at privacy@como.app if you have specific privacy-related inquiries.

We reserve the right to revise this Policy from time to time (for example, to keep up with changes in the law or to reflect changes in how we are doing business). We will post the date it was last updated at the top of this Policy and provide additional notice to you via email if we make any changes that materially affect your privacy rights.