Privacy Policy

This Privacy Policy explains how Commento (“Commento”, “we”, “us”) collects, uses, shares, and protects personal data when you visit our website, create an account, or use the Commento service to give or receive feedback (the “Service”). It also explains the choices and rights you have.

For account holders and workspace owners, Commento is the data controller of the account and billing data described below. For content that customers upload to their workspaces (including any personal data of guest reviewers they invite), the customer is the controller and Commento acts as a processor on their instructions.

By using the Service you acknowledge the practices described here. Capitalised terms not defined in this policy have the meaning given in our Terms of Service.

Information you give us

• Account details: your name, email address, and a password (stored only as a salted hash). If you sign in with Google, we receive your name, email address, and profile picture from Google.
• Verification codes: one-time codes we send to confirm your email address or reset your password, together with the number of attempts made.
• Workspace content: the website URLs, images, videos, and PDFs you add to projects, and the comments, drawings, attachments, assignees, statuses, and priorities attached to them.
• Guest reviewer details: when someone opens a shared review link, they may be asked for a name and email so their comments can be attributed and so they can receive replies.
• Billing details: your chosen plan, billing period, and the subscription and customer identifiers issued by our payment partners. Full payment card numbers are collected directly by Stripe or Paddle and are never stored on our systems.
• Support requests: anything you send us through the support form or by email, including screenshots.
• Workspace settings: integration credentials or preferences you choose to store, which we encrypt at rest.

Information we collect automatically

• Usage and device data: IP address, browser type and version, operating system, referring pages, the pages and features you use, and timestamps.
• Log data: server logs that record requests to the Service, including errors, for security and debugging.
• Approximate location: derived from your IP address, used for security checks on privileged sign-ins and for tax and currency determination at checkout.
• Cookies and similar technologies: described in our Cookie Policy. We do not use third-party advertising or analytics cookies; our own cookie-free page view and click measurement on the marketing site is described there.
• Push notification tokens: if you opt in to browser notifications, a device token so we can deliver them.

We use the information we collect to:

• provide, operate, and maintain the Service, including rendering the pages, images, videos, and documents you review and delivering comments to the right people;
• create and manage your account, authenticate you, and keep your session signed in;
• process subscriptions and payments, send invoices and receipts, and enforce plan limits;
• send transactional messages such as verification codes, invitations, mentions, replies, assignment notices, and billing notices;
• respond to support requests and communicate with you about the Service;
• monitor, secure, and debug the Service, detect abuse and fraud, and enforce our Terms;
• understand how the Service is used so we can improve it;
• comply with legal obligations and establish, exercise, or defend legal claims.

We do not sell personal data, and we do not use your workspace content for advertising or to train machine-learning models.

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

• Performance of a contract: to provide the Service you signed up for, including account management and billing.
• Legitimate interests: to secure and improve the Service, prevent fraud, and communicate with you about your account, where those interests are not overridden by your rights.
• Consent: for optional features such as browser push notifications and any non-essential cookies we may introduce. You can withdraw consent at any time.
• Legal obligation: for tax, accounting, and compliance with lawful requests.

We share personal data only as described below and never sell it.

With people you collaborate with

Your name, avatar, and comments are visible to other members of your workspace and to guests you share a project with. Guest reviewers' names and comments are visible to the workspace that owns the project.

With service providers

We use trusted third parties to run the Service. They process data only on our instructions and under contracts that require appropriate safeguards:

• Stripe and Paddle: payment processing, invoicing, tax calculation, and fraud prevention. Paddle acts as Merchant of Record for orders it processes and is an independent controller of the data it collects at checkout.
• Cloudinary: storage, processing, and delivery of uploaded images, videos, and PDFs.
• Google: sign-in with Google, if you choose it.
• Firebase Cloud Messaging: delivery of browser push notifications, if you opt in.
• Email delivery providers: sending transactional email.
• Cloud hosting, database, and backup providers: including encrypted off-site backups of our database.

For legal reasons

We may disclose information if required by law, subpoena, or court order; to protect the rights, property, or safety of Commento, our users, or the public; or to detect and prevent fraud or security issues.

Business transfers

If Commento is involved in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to this policy.

We keep personal data for as long as your account is active or as needed to provide the Service. Specifically:

• Account and workspace content is kept until you delete it or delete your account. Deleted content is removed from live systems promptly and from backups within our routine backup rotation period.
• Billing records are kept for as long as required by tax and accounting law, typically seven years.
• Verification codes expire within minutes and are then discarded.
• Server logs are kept for a limited period for security and troubleshooting and are then deleted or anonymised.
• Support correspondence is kept for as long as needed to resolve your request and for a reasonable period afterwards.

Accounts that remain unpaid and inactive for an extended period after the free trial ends may be deleted after we notify you by email.

We take the security of your data seriously and use reasonable technical and organisational measures to protect it, including:

• encryption in transit (TLS) for all connections to the Service;
• passwords stored only as salted hashes, never in plain text;
• encryption at rest for sensitive workspace settings and for database backups;
• signed, time-limited upload and download links for media;
• access controls that limit who at Commento can access production systems, and logging of that access;
• additional verification for privileged administrative sign-ins.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at support@commento.net.

Our service providers may store or process data in countries other than your own, including the United States. Where personal data protected by the GDPR or UK GDPR is transferred outside the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or adequacy decisions.

Depending on where you live, you may have the right to:

• access the personal data we hold about you and receive a copy;
• correct inaccurate or incomplete data;
• delete your data (you can delete your account from your settings at any time);
• restrict or object to certain processing, including processing based on legitimate interests;
• port your data to another service in a structured, machine-readable format;
• withdraw consent where processing is based on consent, without affecting processing before withdrawal;
• lodge a complaint with your local data protection authority.

To exercise these rights, email support@commento.net. We will respond within the time required by applicable law, and may need to verify your identity first.

Marketing

We only send marketing email if you have opted in, and every marketing message includes an unsubscribe link. Transactional messages about your account (such as verification codes, invitations, and billing notices) are necessary to provide the Service and cannot be switched off while your account is active.

Guest reviewers

If you commented on a project as a guest and want your details removed, contact the workspace that shared the link with you, or contact us and we will pass your request on and assist where we can.

California residents

If you are a California resident, the CCPA/CPRA gives you the rights above, including the right to know, delete, correct, and to opt out of the sale or sharing of personal information. We do not sell or share personal information for cross-context behavioural advertising, and we do not discriminate against you for exercising your rights.

The Service is not directed at children under 16 and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, contact us and we will delete it.

Commento lets you review third-party websites inside the Service. Those websites are operated by others and may set their own cookies or collect data under their own privacy policies, which we do not control. Our website may also link to third-party sites; this policy does not apply to them.

We may update this Privacy Policy from time to time. If the changes are material we will notify you by email or with a notice inside the Service before they take effect. The date at the top of this page shows when it was last updated.

For any questions about this policy or how we handle your data, email support@commento.net or use our support centre.