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Data Privacy Policy


We, Comba Telecom Systems Holdings Limited and its subsidiaries (referred to as “Comba Telecom”, “the Group”, “we”, “us” and “our”), (collectively the "Data Controller") are providing this Data Privacy Policy to give our clients ("you") whose Personal Data is collected for the use of this website regarding how we collect, store, use, disclose and transfer ("process") your Personal Data in accordance with the applicable laws.


We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. We believe that your interest and the security of your information is our priority and we will try our best endeavour to protect the security of your privacy. We will fully comply with the obligations and requirements of the related privacy and data protection laws, including but not limited to Personal Data (Privacy) Ordinance in Hong Kong and the General Data Protection Regulation ("GDPR") etc., under the applicable jurisdictions. We will, at all times, respect the confidentiality of and keep safe any and all Personal Data processed on behalf of us.


1. What Personal Data do we collect?


You provide information to us when you:

  • visit our website;

  • search for products or services through the website;

  • place an order through the website;

  • search, download, stream, view, or use content on  our website;

  • provide information in your account (and you might have more than one if you have used more than one e-mail address or mobile number when visiting the website);

  • upload your contacts;

  • configure your settings on, provide data access permissions for, or interact with a device;

  • communicate with us by phone, e-mail, or otherwise;

  • complete a questionnaire or a support ticket.


As a result of those actions, you might supply us with and we will receive, collect and store such information as:


your name; company name; job title; address and phone number; location; your age; your gender; your location information; login information, your IP address; your product and service preference. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, e-mail, password, communications), payment details, comments, feedback, product reviews, recommendations, and personal profile.



We use cookies and similar tools (collectively, "cookies") for the purposes described below.


We use cookies to provide our services and understand how our clients use our website and service, for example:

  • Keeping you signed in;

  • Keeping your preferences;

  • To provide you with the service you chose to receive from us;

  • Understanding how you use our website;

  • To monitor and analyze the performance, operation, and effectiveness in order to improve;

  • To understand and improve the impact of our marketing campaigns;

  • For security needs and fraud-protection purposes and in order to identify and prevent  cyber-attacks;


The cookies used on our website fall into one of four categories:

  1. Essential cookies let you move around the website and use essential features like secure and private areas;

  2. Analytic cookies let us understand how you use our website (e.g. which pages you visit), to provide statistics on how our website is used, improve the website by identifying any errors, and performance issues;

  3. Functional cookies are cookies used to remember choices users make to improve their experience (e.g. language);

  4. Marketing cookies are used to collect information about the impact of our marketing campaigns performed in other websites on users and non-users;


2. For what purpose we process your Personal Data?

We Process your Personal Data to provide and improve our service to our clients. These purposes include:

  • Registration Purpose. We use your Personal Data to create a login account for you to access registered pages;

  • Comply with legal obligations. In certain cases, we collect and use your Personal Data to comply with laws in case of any request from the related jurisdictions.

  • Communicate with you. We use your Personal Data to communicate with you in relation to our Services via different channels (e.g., by phone or e-mail) or handle any enquiries from you.



3. How do we process your Personal Data?

The website and the related data (including your Personal Data) is hosted on the platform. provides us with an online platform that allows us to establish this website and provide services to you. Your Personal Data may be stored through's data storage, databases and the general applications, and they store your Personal Data on secure servers behind a firewall. 


We will also store your data in our database. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited.


Unless indicated otherwise at the time of collecting your Personal Data or have your written consent, we will erase your Personal Data if the retention of your Personal Data is no longer necessary (i) for the purpose for which they were collected or otherwise processed or (ii) to comply with legal obligations.


4. How is your Personal Data shared?

The security of your Personal Data is an important part and the priority of our business and we are not in the business of selling your personal information to others. We only share your Personal Data only as described herein, and with our affiliates that either subject to this Data Privacy Policy or follow practices at least as protective as those described in this Data Privacy Policy. We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders for products or services, delivering packages, sending postal mail and e-mail, analysing data, providing marketing assistance, providing search results and links, processing payments, transmitting content and providing customer service. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Data Privacy Policy and as permitted by applicable data protection laws.


Whenever we transfer your Personal Data to countries outside of the European Economic Area, we ensure that your Personal Data is transferred in accordance with this Data Privacy Policy and as permitted by the applicable laws on data protection. We rely on European Commission adequacy decisions or use contracts with standard safeguards published by the European Commission and similar measures under the applicable jurisdiction for such transfers.


5. What security measure we take to protect your Personal Data?

Where we hold, use and/or transmit your Personal Data, the data will be adequately protected from accidental and/or unauthorised disclosure, change and/or destruction with adequate physical, technical and organisational security measures. [Legal-L5]  Encryption technology, such as SSL, allows you to view your site over an HTTPS connection.


Our website may contain links to the external websites operated by third parties for your convenience. We have no control of and are not responsible for these third-party sites or the content thereof. Once you leave the website, we cannot be responsible for the protection and privacy of any information which you provide to these third-party websites. You should exercise caution and look at the privacy statement for the website you visit.


6. How can you manage or delete your Personal Data?

The data protection laws in the jurisdiction in which you reside and apply to you may entitle you to specific rights in relation to your Personal Data. In particular and subject to the legal requirements, you may be entitled to:

  • Access to the website and contact us to check what information is collected;

  • Obtain confirmation from us as to whether or not your  Personal Data are being processed;

  • Obtain from us the correction of inaccurate Personal Data concerning you;

  • Obtain from us the erasure of your Personal Data;

  • Obtain from us restriction of processing regarding your Personal Data;

  • Data portability concerning your Personal Data, which you actively provided; and;

  • Object, on grounds relating to your particular situation, to further processing of Personal Data concerning you.


7. How will we notify you of changes to this Policy?

Our business changes constantly, and our Data Privacy Policy will change also. You should check our website frequently to see recent changes. Unless stated otherwise, our current Data Privacy Policy applies to all information that we have about you and your account under this website. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of your Personal Data collected in the past without the consent of affected customers.


8. How can you contact us with questions?

We provide support with any Personal Data related questions, comments, concerns or complaints or in case you wish to exercise any of your rights. You are welcome to contact us at We will use reasonable efforts to address and settle your requests to protect your rights and interest.

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