Browsing on this site is subject to the laws of Luxembourg and to the terms and conditions set out in this legal notice. By continuing to browse on the site, you state your acceptance of these contractual terms and conditions. 

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Identification 

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COMO DL S.A. (Payment Institution) is a company of COMO Group S.A. 

COMO DL S.A. is a société anonyme, with registered office at 1 Rue De l'Innovation, L-1896 Kockelscheuer, Luxembourg, and registered with the “Registre de commerce et des sociétés” in Luxembourg under number B 208 603. COMO DL S.A. is a regulated Payment Institution supervised by the Luxembourg regulator CSSF (Commission de Surveillance du Secteur Financier, 283, route d’Arlon, L-1150 LUXEMBOURG, www.cssf.lu), license no. Z00000013 with a VAT ID LU28975358.  

COMO DL S.A. shall be referred to as “COMO Digital Life”. 

The Site is defined as all the websites (including any amendments or updates) operated as part of the services offered by COMO Digital Life at the following address: https://www.como-dl.com, as well as at any other Internet address chosen by COMO Digital Life. 

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Protection of Personal Data 

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COMO Digital Life will only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. 

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COMO Digital Life will process or share your data that it holds for the following reasons: 

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• Consent: COMO Digital Life will process your data if you have COMO Digital Life specific consent to use your personal information for a specific purpose. 

• Legitimate Interests: COMO Digital Life will process your data when it is reasonably necessary to achieve its legitimate business interests. 

• Performance of a Contract: Where COMO Digital Life has entered into a contract with you, COMO Digital Life will process your personal information to fulfill the terms of the contract. 

• Legal Obligations: COMO Digital Life will disclose your information where it is legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 

• Vital Interests: COMO Digital Life will disclose your information where it believes it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which COMO Digital Life is involved. 

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More specifically, COMO Digital Life will need to process your data or share your personal information in the following situations: 

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• Business Transfers. COMO Digital Life will share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

• Affiliates. COMO Digital Life will share your information with our affiliates, in which case it will require those affiliates to honor this privacy notice. Affiliates include the parent company of COMO Digital Life and any subsidiaries, joint venture partners, or other companies that it controls or that are under common control with COMO Digital Life. 

• Business Partners. COMO Digital Life will share your information with its business partners to offer you certain products, services, or promotions. Please let COMO Digital Life know if you do not wish to be contacted for these purposes. 

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You are entitled to the following: 

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• The right to access – You have the right to request copies of your personal data from COMO Digital Life. COMO Digital Life may charge you a small fee for this service. 

• The right to rectification – You have the right to request that COMO Digital Life corrects any information you believe is inaccurate. You also have the right to request that COMO Digital Life completes the information you believe is incomplete. 

• The right to erasure – You have the right to request that COMO Digital Life erases your personal data, under certain conditions. 

• The right to restrict processing – You have the right to request that COMO Digital Life restricts the processing of your personal data, under certain conditions. 

• The right to object to processing – You have the right to object to COMO Digital Life’s processing of your personal data, under certain conditions. 

• The right to data portability – You have the right to request that COMO Digital Life transfers the data that COMO Digital Life has collected to another organization, or directly to you, under certain conditions. 

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If you make a request, COMO Digital Life has 1 (one) month to respond to you. If you would like to exercise any of these rights, please contact COMO Digital Life at info at comodigital.life 

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The servers used by COMO Digital Life are located in Luxembourg and the EU. If you are accessing the Site from outside the EU, please be aware that your information may be transferred, stored, and processed by COMO Digital Life in its facilities and by those third parties with whom COMO Digital Life shares your personal information (see above) in other countries. 

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If you are a resident of a country in the European Economic Area, then other countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. COMO Digital Life will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. 

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COMO Digital Life will keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. 

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COMO Digital Life will only keep your personal information for as long as it is necessary for the purposes set out in these notices unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require COMO Digital Life to keep your personal information for longer than 90 days. 

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When COMO Digital Life has no ongoing legitimate business need to process your personal information, COMO Digital Life will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then COMO Digital Life will securely store your personal information and isolate it from any further processing until deletion is possible. 

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Suppose you are a resident of a country in the European Economic Area and you believe that COMO Digital Life is unlawfully processing your personal information. In that case, you have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/board/members_en. 

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If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

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If you are resident in the United Kingdom, the contact details for the data protection authorities are available here: https://ico.org.uk/ 

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Refusal to provide such personal data to COMO Digital Life and prohibiting the processing of such data, although permitted under the regulations, could make it impossible to enter into business relations or continue existing relations. 

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If you have questions or comments about this notice, you can contact our Data Protection Officer (DPO), by email at dpo@como-dl.com, or by post to: 

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COMO DL S.A. 

1 Rue De l'Innovation,

L-1896 Kockelscheuer,

Luxembourg

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Cookies 

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COMO Digital Life uses cookies and similar tracking technologies (like web beacons and pixels) to access or store information. COMO Digital Life uses cookies in a range of ways to improve your experience on the Site, including: 

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• Keeping you signed in 

• Understanding how you use the Site 

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There are a number of different types of cookies, however, the Site uses: 

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• Functionality – We use these cookies so that COMO Digital Life recognizes you on the Site and remembers your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies is used. 

• Advertising – COMO Digital Life uses these cookies to collect information about your visit to the Site, the content you viewed, the links you followed and information about your browser, device, and your IP address. COMO Digital Life sometimes shares some limited aspects of this data with third parties for advertising purposes. COMO Digital Life may also share online data collected through cookies with its advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on the Site. 

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You can set your browser not to accept cookies. However, in a few cases, some features of the Site may not function as a result. 

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Information 

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The information disseminated on the Site, whether general (e.g. market news) or specific (e.g. COMO Digital Life products), is provided on a purely indicative basis. This information is published without any guarantee as to its completeness, accuracy, or currency. The information does not constitute in any manner whatsoever a solicitation to buy or sell. It has no value as legal, accounting and fiscal advice and is only valid at the time when it is given. It is not intended as a substitute for the knowledge and competence of the user and should be used in conjunction with advice from a qualified professional. The Information and its publication are subject to the laws of Luxembourg. Users access information from other jurisdictions at their own risk. The information may be supplied by outside providers. Except in the case of willful misrepresentation or serious misconduct, COMO Digital Life may not be made liable vis-à-vis the user of this information for the use of such information and its direct and indirect consequences. 

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Access to the Site 

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The Site is subject to the laws of Luxembourg. The Site is not intended for persons under jurisdictions where (for reasons of nationality, place of residence, and for any other reason) the dissemination or access to such information is prohibited. 

Suppose the user is not a Luxembourg resident. In that case, it is his/her sole and entire responsibility to verify in advance that the regulations applicable to him/her authorize him/her to use the information published on the Site. 

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Finally, COMO Digital Life reserves the right to refuse, at its own discretion, to open an account. 

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Links to Third-Party Sites 

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COMO Digital Life Site may contain links to third-party sites that are not under its control. Certain links are offered for convenience only and the inclusion of a link in no way implies that COMO Digital Life agrees with the contents of the linked site. COMO Digital Life is not liable for the content, services, products, or material offered at a site linked to that of COMO Digital Life. 

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No link is established with the Site without COMO Digital Life's prior consent. Links to COMO Digital Life Site using framing and/or deep linking techniques are not permitted. COMO Digital Life is under no circumstances responsible for links made to its Site. 

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Copyright 

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COMO Digital Life is the owner of the COMO Digital Life brand names, logos, and other elements featured on the Site and no transfer of such proprietary information is authorized. 

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Any translation, adaptation, partial or full reproduction, using any procedure in any country without COMO Digital Life's prior consent is strictly prohibited. 

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Liability 

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The user accepts responsibility for any access to the Site or any use made thereof. COMO Digital Life will not be liable for direct or indirect losses that may arise out of the use of the Site and in connection with the interruption, stoppage or malfunctioning of the Site especially as may arise out of stoppages for maintenance purposes or in order to update COMO Digital Life IT systems, technical breakdowns, and network overloads, cuts in telephone communications, errors, negligence or fault on the part of Internet service suppliers or third parties or due to a virus spread on the Internet. 

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Luxembourg Law and Luxembourg Jurisdiction 

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The governing law is the law of Luxembourg. 

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The user is notified that only the District Courts of and in Luxembourg have jurisdiction concerning any disputes arising out of the use, interpretation and performance of information and data contained on this Site.