Last updated September, 2018

This Privacy Policy applies to personal information collected, processed, or stored by the Comfort Software Group websites and via the desktop and mobile applications of Comfort Software Group, and describes the extent of collection and use of personal information by Comfort Software Group (Hereinafter – COMFORT SOFTWARE). COMFORT SOFTWARE is a data controller of personal data processed in accordance with this Privacy Policy. COMFORT SOFTWARE has the greatest respect for your privacy and gives special attention to the confidentiality of information submitted to us when you visit our websites (current and future websites, owned or operated by COMFORT SOFTWARE, and/or for which COMFORT SOFTWARE currently or in the future provides services and/or products, hereinafter – the "Site" or "Sites") or otherwise communicate or interact with us.

General Provisions

1. This document, Privacy Policy (hereinafter – the Policy), contains our policies and provisions concerning the information collected about the User by COMFORT SOFTWARE.
2. By visiting our Site and downloading, installing, and using the COMFORT SOFTWARE’s software (hereinafter – Applications), you accept all terms and conditions of this Policy.
3. This Policy is a part of a body of documents that set terms and conditions of use of the Site and of Applications respectively. Other documents defining the relationship between the User and COMFORT SOFTWARE are the Terms of Use, and the End User License Agreement (EULA).
4. Unless defined otherwise by this Policy, all terms and definitions used herein shall have the meaning defined in the Terms of Use and EULA.

Personal Information

1. Personal information means information that can be associated with a specific User, including but not limited to: name (pseudonym or nickname), email address, telephone number (e.g., in cases when you request individual technical support or assistance), and information about User’s purchases and activations of Applications (preference categories and other types of preference-related advertising), payment methods, payment currencies or other payment data.
2. For website personalisation, we also gather information about the devices you use to access our sites (desktop and mobile); this may include the IP address and other geolocation data, browser type and version, operating system and system language, referring website, time of access and other data.
3. COMFORT SOFTWARE processes the personal information that the User provides about themselves by filling out respective forms. For example, when downloading a trial version of an Application from the Site, subscribing to email newsletters, contacting COMFORT SOFTWARE for technical support or via feedback forms, etc. COMFORT SOFTWARE may set out the requirements to the information that is mandatory to provide the User with our services. If some information is not marked by COMFORT SOFTWARE as mandatorily required, the User may submit or disclose such information at his own discretion.
4. Our Privacy Policy is based on the following principles:
   • We process user data exclusively for the purposes and according to the methods provided when the data was collected.
   • We use the collected data for purposes in addition to those for which it was released only when the user has expressly consented.
   • We let third parties access the provided data exclusively for the purposes of performing the service requested and within the context of appointing a data controller.
   • We do not disclose the data, assign or transferring it to third parties for their own processing unless the User have been informed in advance and have given their consent.
   • We respond to requests for cancelling, changing, or adding the data provided.
   • We ensure proper and lawful data management.
   • We safeguard the privacy of users and apply appropriate security measures to protect the confidentiality, integrity, and availability of the data provided.
5. If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws, but no longer than reasonably necessary in light of the purposes above. We may need your personal information to establish, bring or defend legal claims. For this purpose, we retain your personal information for 7 years after the date it is no longer needed by us for any transactions, fulfilling a contract purposes or marketing communications.
6. If the information submitted by you contains personal data, by using our Site, services or products or by providing personal information to us, you freely and voluntarily grant COMFORT SOFTWARE written informed consent to process that data for the purposes defined by this Policy. This includes any action (operation) or sequence of actions (operations) performed with or without using automated tools: collecting, recording, sorting, accumulating, storing, specifying (updating, changing), withdrawing, using, transferring (distributing, providing, accessing) information to third parties, including cross-border transfer to other jurisdictions, disclosing or making available, anonymization, restriction, blocking, deleting, and destruction of personal data. The consent can be revoked at any time with immediate effect for the future by emailing us at [email protected].
7. Sensitive information. COMFORT SOFTWARE does not collect sensitive personal data such as sexual preferences, religion, political views, or health conditions. We will not request it from you, and neither do we need it.
8. Data on children. Persons under the age of 13 should not transfer personal information to us unless they have a verifiable permission of their parent(s) or legal guardian(s). Our Site, products and services are intended for users who are 13 years of age and older. We do not knowingly collect such data, but if a parent, guardian or anyone else becomes aware of personal information we have collected from an individual under the age of 13, please contact us.
9. Your personal data is protected by legal rights, which include your right to request access to your personal data; object to or restrict our processing of your personal data; request that your personal data is erased or corrected; export your data in a machine-readable format; transmit those data to another controller. For more information or to exercise your data protection rights, please contact us using the contact details below. You can always update or delete your personal information on our sites. If at any time you would like us to delete or change any of your personal information, just email us at [email protected].

Anonymized Data

1. When you use the Site or Applications, anonymized data may be transmitted automatically to COMFORT SOFTWARE. The data transmitted includes but is not limited to: your IP-address, location (country, area, city), browser version, traffic source, hardware model and other device-specific information, operating system version, unique device identifiers, statistical information about your actions on the Site and Application use, information about the data that is being sent and received via the Application.
2. Anonymized data may be collected and/or processed using the services of the third parties, such as:
   • analytics services;
   • social network plugins;
   • other systems and services that use and process anonymized user data.

Credit Card Purchases

1. If you use a credit card to purchase a COMFORT SOFTWARE product, the credit card number is encrypted as it passes over the Internet. The information about your credit card is not kept in or recorded by COMFORT SOFTWARE, it is simply transferred to your bank, credit card company, and payment processing company. In this respect, an online credit card purchase is similar to a credit card purchase at any store.
2. Such information about the User as the name, email address and purchased product is kept by COMFORT SOFTWARE for further delivery and/or registration of the product.

Use of Personal Information

1. COMFORT SOFTWARE uses Personal information for the following purposes:
   • Execution and performance of License agreements with the User;
   • Identification of the User in the course of fulfilling COMFORT SOFTWARE’s obligations under the agreements with the User;
   • Communication with the User for the purposes of informational support and improvement of the Applications, including notification through third parties;
   • Distribution of advertising materials of COMFORT SOFTWARE and/or third parties among Users as the targeted audience;
   • Targeting of advertising and/or informational materials.
2. COMFORT SOFTWARE may share Personal information with service providers that provide services on our behalf when it is necessary for provision of such services within the limits of the purposes listed above.

Use of Anonymized Data

1. COMFORT SOFTWARE uses anonymized data for the following purposes:
   • Improvement of the Site and Applications;
   • Communication with the User for the purposes of informational support and improvement of the Applications, including notification through third parties;
   • Distribution of advertising materials of COMFORT SOFTWARE and/or third parties among Users as targeted audience;
   • Targeting of advertising and/or informational materials by age, gender or other attributes;
   • Marketing, statistic and other research based on anonymized data.
2. COMFORT SOFTWARE may provide anonymized data to with service providers that provide services on our behalf when it is necessary for provision of such services within the limits of the purposes listed above.

Cookie 和类似技术

COMFORT SOFTWARE 使用 Cookie（下载到您设备中的小型文本文件）和类似的技术来提供我们的网站和联机服务，并协助收集数据。 Cookie 可让我们可以存储您的偏好和设置以及其他一些功能；使您能够登录；提供基于兴趣的广告；打击欺诈行为；分析我们的网站和联机服务的性能。

我们也使用 Web 信号帮助提供 Cookie 和收集用法和性能数据。 我们的网站可能包含来自第三方服务提供商的 Web 信号和 Cookie。

您有各种可以控制 Cookie、Web 信号和类似技术的工具，包括用于阻止和删除 Cookie 的浏览器控件和来自某些第三方分析服务提供商的控件，以通过 Web 信号和类似技术退出数据收集。 您的浏览器和其他选择可能影响您对我们产品的体验。

User’s Consent to Receiving Information from COMFORT SOFTWARE

1. Our Site and Applications offer news and information regarding our products by subscription, including email newsletters. If you decide to subscribe to these services, you may be asked to provide your email address. By doing so, you agree to receive emails from COMFORT SOFTWARE with information about updates and any other information related to the Applications, as well as other types of information from COMFORT SOFTWARE, including advertisements. We may use the information you provide to help develop content that is relevant to our users. You are free to cancel your subscription(s) at any time.
2. To cancel your subscription, follow the instructions in the bottom of the letter or email us at [email protected] and a request deletion of your data from the mailing list. In this case, COMFORT SOFTWARE will keep your Personal information in its database, but will not contact you unless you change your mind on this issue.

Confidentiality of User Information

1. COMFORT SOFTWARE stores information of Users and takes necessary and sufficient organizational and technical security measures of protection from unauthorized access and disclosure in compliance with internal rules and procedures (including GDPR).
2. We maintain administrative and technical safeguards for the protection of personal information. These safeguards include the following:
   • Administrative safeguards: Access to the personal data of users is limited to authorized personnel who have a legitimate need to know based on their job descriptions — for example, employees who provide technical support to end users. All such data is subject to password protection. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed.
   • Technical safeguards: Access to user information in our database by Internet is not permitted except through an encrypted virtual private network (VPN). Other access is limited to our physical premises; the removal of personal data from our location is forbidden. Third-party contractors who process personal data on our behalf agree to provide reasonable physical safeguards.

Third Parties

1. To implement purchases in Applications COMFORT SOFTWARE uses services of third parties.
   Some types of third parties with whom we share your data are:
   • IT companies: COMFORT SOFTWARE works with businesses that support our website and other business systems.
   • Marketing companies: we work with marketing companies that help us manage our electronic communications with you or carry out surveys and product reviews on our behalf.
   • Payment processing: COMFORT SOFTWARE works with trusted third party payment processing providers in order to securely take and manage payments.

   Here is the list of third-party companies we are cooperating with for business purposes:

   2Checkout
   COMFORT SOFTWARE uses 2Checkout Payment Platform (www.2checkout.com) for processing of secured payments for purchases made on the website. The entire purchase process is managed by 2Checkout, who acts as COMFORT SOFTWARE’s authorized merchant and reseller. When you enter your credit card and billing information on the website, personal Information is transferred securely to 2Checkout. By making a purchase on the website via 2Checkout, you authorize COMFORT SOFTWARE to use 2Checkout to process your transactions and to transfer personal information to them, but only to the extent needed to complete the transaction and manage your purchases.
   No credit card information is ever stored on servers controlled by us. 2Checkout has our permission to store, on our behalf, the data pertaining to the executed transactions by customers of the website (including credit card information) with the goal of ensuring a secure method of payment and proof of purchase archive, allowing for the protection of our customers, and for follow-up as needed. This transactional data may be used for validation and registration purposes of our customers, and to trace any fraudulent activities if necessary.

   PayPro Global
   COMFORT SOFTWARE uses PayPro Payment Platform (www.payproglobal.com) for processing of secured payments for purchases made on the website. The entire purchase process is managed by PayPro, who acts as COMFORT SOFTWARE’s authorized merchant and reseller. When you enter your credit card and billing information on the website, personal Information is transferred securely to PayPro. By making a purchase on the website via PayPro, you authorize COMFORT SOFTWARE to use PayPro to process your transactions and to transfer personal information to them, but only to the extent needed to complete the transaction and manage your purchases.
   No credit card information is ever stored on servers controlled by us. PayPro has our permission to store, on our behalf, the data pertaining to the executed transactions by customers of the website (including credit card information) with the goal of ensuring a secure method of payment and proof of purchase archive, allowing for the protection of our customers, and for follow-up as needed. This transactional data may be used for validation and registration purposes of our customers, and to trace any fraudulent activities if necessary.

   Google AdWords & Google Merchant Center
   We use the services of Google AdWords and Google Merchant Center to draw attention to our offers by means of advertising materials and advertising campaigns on external websites. In relation to the advertising campaign data, we can determine how successful the individual advertising measures are. We pursue thereby the interest to show you advertisement, which is of interest for you, to arrange our Website for you more interestingly and to reach a fair calculation of advertising costs.

   Yandex.Direct
   We use Yandex.Direct to display content and search-based ads. This helps us show you advertisements of our products and services which are of interest to you, when searching Yandex and browsing other websites.

   Google Analytics
   Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie is be transmitted to and stored by Google. Google will not associate your IP address with any other data held by Google.
   Google Analytics help us understand the use of our site by our visitors. Because Google Analytics require cookies to function, users who wish to avoid tracking by Google Analytics while on our website can disable cookies in their browser. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

   Google AdSense
   We use Google AdSense to provide advertisements to our users based on previous visits to our site and other sites on the Internet. Users can opt out of this by visiting the Google Ad and Content Network privacy policy and adjusting their preferences.

   UniSender
   We use UniSender for newsletter and marketing emails. Through UniSender, we track emails, including who opens the emails and who clicks on which link.

   If you prefer that we not share your information with third parties for marketing purposes, please contact us by email: [email protected].

2. The Site and Applications may contain links to third-party websites. When the User follows these links he leaves the Site/Application, so COMFORT SOFTWARE takes no responsibility for the safety of User Data during the use of third-party websites. Such websites may have their own privacy policy setting out the rules of collection and storage of User Data. This Policy does not cover the data which is submitted to, stored or used by third-party websites. We recommend that you carefully review the privacy policy of such third parties when using their websites.
3. COMFORT SOFTWARE is not responsible for the use of User data by the third parties that the User interacts with in the course of using the Application.

Other Disclosures of Personal Information

1. COMFORT SOFTWARE may disclose Personal information to third parties in the following cases:
   • At the User’s expressed consent to such disclosure.
   • The transfer of COMFORT SOFTWARE’s assets to possession, use or ownership of a third party including assignment of rights under the executed agreements with the User to such third party.
   • At the request of a court or other authorized governmental agency to the extent required under applicable legislation.
   • For the purpose of protection of COMFORT SOFTWARE's rights with respect to the breach of agreements executed with the User.

Amendments

1. This Policy may be amended or cancelled by COMFORT SOFTWARE at its own discretion without prior notification of the User. We recommend that you regularly read the latest version of the Privacy Policy.
2. A new version of the Policy is effective from the moment of its publication unless specified otherwise by such new version of the Policy.
3. The currently effective version of the Policy is available at https://free-countdown.com/privacy/.

We highly value your trust and are always ready to answer your questions about the handling of your personal data.

If you have any questions or concerns, contact us at [email protected].