The protection of your personal data matters to us.

We are committed to inform you with utmost transparency on how Comet Technologies Canada Inc., operating under the brand name Dragonfly, collects, stores, and processes your personal data.

This Privacy Notice explains in detail which data is collected by Dragonfly, why it is collected, and how you can exercise your rights regarding the processing, the storage, and the use of your data. On each topic, you can expand by clicking on “More information.”

We process personal data in compliance with all laws applicable to data protection based on their provenance. Personal data about persons in Canada are subject to Canadian federal and provincial privacy laws, about persons in the EU to the EU General Data Protection Regulation (GDPR), about persons in the UK to the UK GDPR, and about persons in the US to US state-level privacy laws.

We will update this Privacy Notice regularly to make sure it reflects our actual processing of personal data and meets legal requirements. We encourage you to consult it regularly to have the current information.

This chart provides a summary of this Privacy Notice:

Type of personal data

General Data

Financial Data

Location Data

Source of personal data

Yourself or, with your consent, third parties.

Purpose of processing

Marketing and advertising.

Product and services development and improvement.

With your consent, other purposes without direct connection with the core service such as sending you a newsletter.

Special processes

Personalization of service: We analyse your interaction with our products and services to best meet your needs and interests.

Passing on to third parties

Data Transfers: We may transfer your personal data to other companies who assist us in providing you our services and exclusively for that purpose.

Place of processing

Worldwide: In compliance with applicable legal requirements regarding the cross-border transfer of personal data, we may transfer your personal data outside of your country with all necessary safeguards.

1. What is this Privacy Notice about?

2. What data do we process?

3. For what purposes do we process your data?

4. On what basis do we process your data?

5. With whom do we share your data?

6. Is your personal data disclosed abroad?

7. How long do we process your data?

8 How do we protect your data?

9. What are your rights?

10. Do we use online tracking and online advertising techniques?

11. What data do we process on our social network pages?

12. Contact us

1. What is this Privacy Notice about?

Dragonfly (also «we», «us») collects and processes personal data that concerns you for the purpose of providing you our products and services. We use the word «data» here interchangeably with «personal data».

In this Privacy Notice, we describe what we do with your data when you use https://dragonfly.comet.tech/ or apps (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us, or otherwise deal with us. When appropriate, we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example, in consent forms, terms and conditions, additional privacy notices, forms, and other notices.

2. What data do we process?

We process various categories of data about you. The main categories of data are the following:

Technical data:

When you use our website or other online offerings (for example, free Wi-Fi on our premises), we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We may also assign an individual code to you or your terminal device (for example, as a cookie, see Section 10). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls, or the performance of a contract.

More information
Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use, and the type of browser that you use to access our electronic offerings. This may help us to provide an appropriate layout of the website. We know through which provider you access our offerings (and therefore, also the region) because of the IP address, but usually this does not tell us who you are. However, this changes for example, when you create a user account because personal data can then be linked with technical data (for example, we can know the browser you use to access an account through our website). Examples of technical data include protocols («logs») that are created in our systems (for example, the log of user logins to our website).

Registration data:

Certain offerings and services (such as login areas of our website, newsletters, free WLAN access, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or Registration data may be required in relation to access control to certain facilities, depending on the control system. 

 More information
Registration data includes the information you provide when you create an account on our website (for example, username, password, name, email). However, it also includes the data that we may require from you before you can use certain free services, for example, our WLAN service, which in this case may require: name, email, and telephone number. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges) (see the category «Other data»).

Communication data:

When you are in contact with us via the contact form, by email, telephone, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. Communication data may also be processed by employees other than those to whom the communication was addressed. If we record telephone conversations or video conferences, for example, to preserve know-how and for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example, by an indication during the (video) conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we have to determine your identity, for example, in relation to a request for information, a request for press access, etc., we collect data to identify you (for example, a copy of an ID document). 

More information
Communication data is your name and contact details, the means, place and time of communication, and usually also its contents (i.e. the contents of emails, letters, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID document number, or a password set by you or your press pass. For secure identification, the following required information must be provided for media inquiries: Publisher, name of publication, title, first name, surname, postal address, email address, and telephone number of the reporter.

Master data:

With master data we mean the basic data that we need, in addition to contract data, for the performance of our contractual and other business relationships such as name and contact details and information about, for example, your role and function, your bank details, customer history, powers of attorney, signature authorizations, and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example, as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner. If we contact you as part of marketing and advertising with invitations to events, with newsletters, etc., you will always the opportunity to opt-out. We receive master data from you (for example, when you make a purchase or as part of a registration), from parties you work for, or from third parties, such as contractual partners, associations and address brokers, and from public sources such as public registers or the Internet (websites, social media, etc.). We may process name, email/company email address, country, company/college name) when you connect with the Dragonfly community. We may also collect master data from our shareholders and investors.

More information
Master data also includes personal data about job applicants, such as name, address, email address, telephone number and other contact details, nationality, and with consent, websites, social media profiles, photos, and videos. In relation to customers, we collect details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example from the media), or official documents (for example, excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number, and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.

In relation to contact persons and representatives of our customers, suppliers, and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications, and (where applicable) information about superiors, co-workers and subordinates, and information about interactions with these persons.
 
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity.

Contract data:

This means data that is collected in relation to the conclusion or performance of a contract, for example, information about the contracts and the services provided or to be provided, as well as, data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example, complaints, feedback about satisfaction, etc.). We generally collect this data from you, from contractual partners, and from third parties involved in the performance of the contract, but also from third-party sources (for example, credit information providers) and from public sources. 

More information
Contract data includes information about the conclusion of the contract, about your contracts, for example, the type and date of conclusion, information from the application process (such as the application for the performance of our products or services) and information about the relevant contract (for example, its duration) and the performance and administration of the contracts (for example, information in relation to billing, customer service, technical assistance, and the enforcement of contractual claims). Contract data also includes information about deficiencies, complaints, and changes of a contract, as well as, customer satisfaction information that we may collect, for example, through surveys. Contract data also includes financial data, such as credit information (meaning information that allows to draw conclusions about the likelihood that receivables will be paid), information about reminders, and debt collection. We receive this data partly from you (for example, when you make payments), but also from credit agencies and debt collection companies, and from public sources (for example, a commercial register).

Service personalization data:

Depending on our relationship with you, we try to get to know you better and to tailor our products, services, and offers to you. For this purpose, we collect and process data about your interactions with our products and services to understand your needs and interests. We do so by evaluating information about your visits in our domain, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or respond in a certain way. The data processed for this purpose is already known to us (for example, where and when you use our services), or we collect it by recording your interactions (for example, how you navigate our website). We anonymize or delete this data when it is no longer relevant for the purposes pursued. We anonymize the data if it is relevant to the improvement of our services. 

More information
Service personalization data is information about certain actions, such as your response to electronic communications (for example, if and when you have opened an email) or your location, as well as your interaction with our social media pages and your participation in events. For example, we may collect your location data when you use our website. It also tells us what your needs are, which products or services might be of interest to you or when and how you will likely respond to messages from us. We obtain this information from the analysis of existing data such as interactions data, so that we can get to know you better, tailor our advice and offers more precisely to you and improve our offers. To improve the quality of our analyses, we may combine this data with other data that we also obtain from third parties, such as address dealers, administrative offices, and publicly available sources such as the Internet.
 
Service personalization data may be analysed on a personally identifiable basis (for example, to show you personalized advertising), but also on a non-identifiable basis (for example, for market research or product development). Service personalization data may also be combined with other data (for example, motion data may be used for contact tracing as part of a health protection concept).

Other data:

We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may obtain or create photos, videos, and sound recordings in which you may be identifiable (for example, at events with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data, or lists of visitors, etc.), who participates in events or campaigns, and who uses our infrastructure and systems, and when. Moreover, we collect and process data about our shareholders and other investors in addition to master data, including information for registers in relation to the exercise of their rights and with events (for example, general meetings). 

Much of the data set out in this Section 2 is provided to us by you (through forms, in relation to communication with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except as necessary to receive our services. If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data, and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of service personalization data, you generally have the option of objecting or not giving consent.

More information
We also collect registration data to provide certain services to you because we, or our contractual partners, wish to know who uses our services or has accepted an invitation to an event because it is a technical requirement or because we wish to communicate with you.

Data from public sources :

As far as it is not unlawful, we also collect data from public sources (for example, debt collection registers, land registers, commercial registers, the media, or the Internet including social media) or receive data from other companies within our group, from public authorities, and from other third parties (such as credit agencies, address brokers, associations, contractual partners, Internet analytics services, etc.).

More information
The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and legal proceedings, information in relation to your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your assistance), information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity), information about you that persons related to you (family, advisors, legal representatives, etc.) share with us so that we can conclude or perform contracts with you or involving you (for example, references, your delivery address, powers of attorney), information about compliance with legal requirements such as those relating to fraud prevention and the combating of money laundering and terrorist financing, export restrictions, information from banks, insurance companies, sales, and other contractual partners of us about your use or provision of services (for example, payments, purchases, etc.), information from the media and the Internet about the use or provision of services by you (for example payments made, purchases made, etc.), information from the media and the Internet about you (where appropriate in a specific case, for example, in the context of an application, marketing/sales, press review, etc.), your address, and, with your consent, potential interests and other socio-demographic data (especially for marketing and research purposes) and data in relation to the use of third-party websites and online offerings where such use can be linked to you.

3. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 10 and 11 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 4.

To communicate with you:

We process your data for purposes related to communication with you, in relation to responding to inquiries and with the exercise of your rights (Section 9) and to enable us to contact you in case of queries. For this purpose, we use communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you for training purposes, for quality assurance, and for follow-up inquiries.

More information:
 
The above includes all purposes in relation to which you and we communicate, whether in the context of customer service or consulting, authentication where the website is used, and for training and quality assurance (for example, in customer service). We further process communication data to enable us to communicate with you by email and telephone, messenger services, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example, so that we can provide services or respond to an access request. Our processing also serves to document the communication and its contents.

To manage contracts:

We process data for the conclusion, administration, and performance of contractual relationships.

More information
We conclude various contracts with our customers, suppliers, subcontractors and other parties such as partners in projects or parties in legal proceedings. In particular, we process master data, contract data, communication data and, depending on the circumstances, registration data relating to the customer or the persons for whose benefit the customer has received a service.
 
In the run-up of a business relationship, personal data – in particular master data, contract data, and communication data – is collected from potential customers or other contractual partners (for example, in an order form or a contract) or results from a communication. Again, in connection with the conclusion of a contract, we process data to assess creditworthiness and to open a customer relationship. In some cases, this information is reviewed in order to comply with legal requirements.
 
As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, advertising service providers, banks, insurance companies or credit information providers who may in turn provide data to us), for consulting, and for customer support. The enforcement of legal claims arising from contracts (i.e. debt collection, legal proceedings, etc.) is also part of the performance as are accounting, termination of contracts, and public communication.

For marketing purposes:

We process data for marketing purposes and relationship management, for example, to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example, from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by email or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example, events, etc.) and may also include free services (for example, invitations, etc.). You can object to such contacts at any time or refuse or withdraw consent to be contacted for marketing purposes by exercising that option through the unsubscribe mechanism. With your consent, we can target our online advertising on the Internet more specifically to you (see Section 10). Finally, based on your consent, we may enable our contractual partners to contact our customers and other contractual partners for marketing purposes (see Section 5).

More information
For example, if you consent, we may send you information, advertising, and product offers from us and from third parties within and outside the group (for example, advertising partners) as printed material, electronically, or by telephone. For this purpose, we process communication data and registration data. As most companies, we personalize communications so that we can provide you with customized information and offers that meet your needs and interests. Therefore, we combine data we process about you and use this data as a basis for personalization (see Section 2).

To manage our customer relationships:

Relationship management includes addressing existing customers and their contacts, personalized on the basis of service personalization data. In the context of relationship management, we may also operate a customer relationship management system («CRM») in which we keep the data of customers, suppliers, and other business partners that is required for relationship management, for example, data about contact persons, relationship history (for example, information about products and services purchased or supplied, interactions, etc.), interests, marketing measures (newsletters, invitations to events, etc.), and other information.

All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.

With your consent, we may further process your data for market research, to improve our services and operations, and for product development.

More information
We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We, therefore, analyse, for example, how you navigate through our website or which products are used by which groups of people, in which way, and how new products and services can be designed (for further details, see Section 10). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process master data, service personalization data, but also communication data and information from customer surveys, polls and studies, and other information, for example, from the media, social media, the Internet, and other public sources. We may also use media monitoring services or conduct media monitoring ourselves and process personal data to conduct media monitoring or to understand and respond to current developments and trends.

To secure our systems:

We may also process your data for security and access control purposes.

More information
We continuously review and improve the appropriate security of our IT and other infrastructure (for example, buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We, therefore, process data, for example, for monitoring, inspection, analysis, and testing of our networks and IT infrastructures for system and error checks, for documentation purposes, and in the context of backups. Access controls include electronic system access controls (for example, logging into user accounts), as well as physical access controls (for example, building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example, security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.

To comply with applicable laws:

We process personal data to comply with laws, directives, and recommendations from authorities and internal regulations («Compliance»).

More information
This includes, for example, the implementation of the regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers («Know Your Customer») or to report to the authorities. Disclosure and information or reporting obligations, for example, in connection with supervisory and tax obligations, also require or entail data processing, for example, archiving obligations and the prevention, detection, and investigation of criminal offenses and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations, or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example, by a law enforcement or supervisory authority, or by a mandated private entity. Furthermore, we process data in order to serve our shareholders and other investors and to fulfil our obligations in this regard. For all these purposes, we process master data, contract data, and communication data, but also, under certain circumstances, service personalization data and data from the category of «Other data». The legal obligations may arise under regulations to which we are subject, as well as self-regulations, industry standards, our own «corporate governance», and instructions and requests from authorities.

For risk management:

We also process data for the purposes of our risk management and as part of our corporate governance including business organization and development.

More information
For these purposes, we process master data, contract data, registration data, and technical data, but also service personalization and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyse data for relevant patterns of such activities. We may also proceed to segmentation by category of personal data for trends analysis to improve our services. In the context of planning our resources and organizing our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (for example, outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties. As part of our business development, we may sell businesses, or parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the exchange and processing of data (including from you, for example, as a customer or supplier, or as a supplier representative).

Other purposes:

We may process your data for further purposes, for example, as part of our internal processes and administration or for quality assurance purposes. 

More information
These further purposes include, for example, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and, continuously improving IT infrastructure), protecting our rights (for example, to enforce claims in or out of court, and before government authorities or to defend ourselves against claims, for example, by preserving evidence, conducting legal assessments, and participating in court or administrative proceedings), and evaluating and improving internal processes. We may use recordings of (video) conferences for quality assurance purposes and trainings, in which case you will be informed of your right to decline recording, as the case may be.

4. On what basis do we process your data?

We process your personal information with your consent, either implied when you provide us your personal data to obtain our products and services and all activities related to this purpose, or with your express consent when we offer you to receive advertising or product offers.  In those cases, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by unsubscribing through the unsubscribe function in our emails or by any form of written notice to our contact details at the bottom of this Policy. For withdrawing consent for online tracking, see Section 10. Where you have a user account, you may also withdraw consent by contacting us through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

5. With whom do we share your data?

We may share your personal data to third parties, in particular to the following categories of recipients for the purpose of offering our services:

Group companies:

A list of our group companies can be found here. These group companies may use the data according to this Privacy Notice for the same purposes as we use it (see Section 3).

Service providers:

We work with service providers in various countries who process your data on our behalf or as partners or who receive data about you from us for their own purposes  (for example, IT providers, shipping companies, advertising service providers, login service providers, debt collection companies, credit information agencies, or address verification providers). For the service providers used for the website, see Section 10. Key service providers in the IT area are Microsoft, SAP, Kentico, Pipedrive, and Salesforce.

More information
To be able to deliver our products and services efficiently and focus on our core competencies, we procure services from third parties in various areas. These include, for example, IT services, information transmission, marketing, sales, communication or printing services, facility management, security, organizing and holding events and receptions, debt collection, credit agencies, address verification provider (for example, to update address lists in case of relocations), fraud prevention measures, and services from consulting companies, lawyers, banks, insurers, and telecommunication companies. In each case, we disclose to these providers only the data they require for their services. These providers may also use such data for their own purposes, for example, information about overdue claims and your payment history in case of credit information agencies or anonymized data to improve their services. In addition, we enter into contracts with these providers that include provisions to protect data in compliance with applicable laws. In some cases, our service providers may also process data on how their services are used and other data that is generated in the course of using their services for their own purposes (e.g., for statistical analysis or billing purposes). Service providers inform us about their independent data processing activities in their own privacy statements. More information on how Microsoft processes data can be found here, for the use of Microsoft Teams in particular here.

Contractual partners including customers:

This refers to customers (for example, service recipients) and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate or who conduct advertising for us and to whom we may therefore disclose data about you for our analysis and marketing purposes (these may again be service recipients, but also online advertising providers). We require these partners to send you or display advertising based on your data only with your consent (for online advertising, see Section 10).

More information
If you act as an employee for a company with which we have concluded a contract, performance of this contract may require us to tell the company, for example, how you have used our service.

Partners:

Cooperation partners and advertising partners receive selected master data, contract data, and service personalization data from us so that they can carry out analyses in their fields (for example, about the number of our customers who have viewed their advertising.) With your consent, for example, through accepting third party cookies they can use data for advertising purposes (including targeting you). 

Authorities:

We may disclose personal data to agencies, courts, and other authorities in your country or abroad if we are legally obliged and they have demonstrated their authority to request the data. 

More information
Examples are criminal investigations, police measures, regulatory requirements and investigations, legal proceedings, reporting obligations, and pre-court and out-of-court proceedings, as well as legal obligations to provide information and to cooperate. Data may also be disclosed if we wish to obtain information from public bodies, for example, in order to justify a request for information or because we need to say about whom we require information (for example, from a register).

Other persons:

This means other cases where interactions with third parties follow from the purposes set out in Section 3, for example, service recipients, the media, and associations in which we participate or if you are included in one of our publications.

More information
With your consent, other recipients include, for example, delivery recipients or third-party payees specified by you, other third parties in relation to agency relationships (for example, if we share your data with your lawyer or your bank), or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them, we may seek your consent to share your personal data (for example, photos). The same applies if we publish content (for example, photos, interviews, quotes, etc.), for example, on our website or in our other publications.
 As part of our business development, we may sell businesses, parts of businesses or companies to others, or acquire them from others, or enter into partnerships which may also result in the disclosure of data (including from you, for example, as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In each case, we ensure disclosure meets all applicable legal requirements.
In addition, with your consent, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example, press photographers, providers of tools on our website, etc.).

6. Is your personal data disclosed abroad?

As explained in section 6, we disclose data to other parties. These are not all located in your country. Your data may therefore be processed in any country in the world. In each case, we comply with the applicable laws regarding cross-border data flows. This means we use Standard Contractual Clauses (SCC) to transfer personal data from the EU or the UK to a country that is not formally recognized, by the EU or the UK, as providing an adequate level of protection. In all cases, transferring from any country, whether SCC are required or not, we assess whether the country of destination affords adequate privacy protection. In addition, we impose conditions upon the transfer of personal data  as necessary to preserve an adequate level of protection.

7. How long do we process your data?

We process your data for as long as necessary for the purposes for which you provided it or as required by law.

More information
Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements, and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with it (for example, in case of backups or document management systems).

8. How do we protect your data?

We take appropriate security measures to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

More information
Technical and organizational security measures may include encryption and pseudonymization of data, meaning the replacement of identifiers in a manner that the individual can no longer be identified directly, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely. Residual risks are unavoidable.

9. What are your rights?

To help you control the processing of your personal data, you have the following rights in relation to our data processing: 

  • The right to request information from us as to whether and what data we process from you.
  • The right to request access to your personal data processed by us.
  • The right to have us correct data if it is inaccurate.
  • The right to request erasure of data.
  • The right to request that we provide the personal data you provided us in a commonly used electronic format or transfer it to another organization.
  • The right to withdraw consent where our processing is based on your consent.
  •  The right to receive, upon request, further information that is helpful for the exercise of these rights.

If you wish to exercise these rights in relation to us (or with one of our group companies), please contact our Data Protection Officer in writing, at the contacts below, at section 12. In order for us to be able to prevent misuse, we need to identify you (for example, by means of a copy of your ID card, if identification is not possible by other means).

You also have these rights in relation to other parties that cooperate with us and process your personal data for their own purposes – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 5 and additional information in Section 10.

Please note that conditions, exceptions, or restrictions apply to these rights under applicable data protection law (for example, to protect third parties or trade secrets). We will inform you accordingly where applicable.

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We may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent legally permitted, to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example, by redacting content that concerns third parties or our trade secrets).
 
If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officer (Section 12) know. You also have the right to lodge a complaint with the competent data protection supervisory authority in your province or country.

10. Do we use online tracking and online advertising techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

Essentially, we wish to distinguish access by you (through your system) from access by other users so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example, by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called «cookie»).

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Cookies are individual codes (for example, a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website and that your system (i.e. browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognized even if your identity is unknown.

Other technologies may be used to recognize you with some likelihood (i.e. distinguish you from other users), such as «fingerprinting» or «counting pixel technology». Fingerprinting combines your IP address, the browser you use, screen resolution, language settings, and other information that your system tells each server, resulting in a more or less unique fingerprint. Counting pixel technology involves downloading small graphics from a website, which enables log file recording and log file analysis, often used for statistical analysis for online marketing. This makes it possible to go without cookies.

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Whenever you access a server (for example, when you use a website or an app, or because an email includes a visible or invisible image), your visits can therefore be «tracked». If we integrate offers from an advertising partner or a provider of an analysis tool on our website, they may track you in the same way even if you cannot be identified in a particular case.

We use these technologies on our website and may allow certain third parties to do so, as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

  • Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies only exist temporarily («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example, language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to one year to assist your navigation as you come back to our site.
  • Performance cookies: To optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyse the use of our website potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. You can withdraw consent at any time through the cookie settings here. Performance cookies also have an expiration date of up to 24 hours. Details can be found on the websites of the third-party providers.
  • Marketing Cookies: We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiration period of a few days to one year to assist your navigation as you come back to our site, depending on the circumstances. If you consent to the use of these cookies, you will be shown related advertisements. If you do not consent to them, you will not see less advertisements, but simply any other advertisement.
  • Other technologies: In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage. For example, we may transmit the email addresses of our users, customers, and other persons to whom we wish to display advertisements to operators of advertising platforms (for example, social media). If these persons are registered with them with the same email address (which the advertising platforms determine by a matching process), the providers display our advertisements specifically to these persons. The providers do not receive email addresses of persons who are not already known to them. In case of known email addresses, however, they learn that these persons are in contact with us and the content they have accessed.
  • Third-party offers: We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example, by clicking a button), these providers can determine that you are using our website. If you have an account with the provider, it can assign this information to you and thereby track your use of online offers. The providers process this data for their own purposes.
  • Google Analytics: Google collects information about the behaviour of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals » option. Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles, and link this data with the Google accounts of these individuals for its own purposes. In any event, you can opt-out of Google Analytics. Information about data protection with Google Analytics can be found here and if you have a Google account, you can find more details about Google's processing here.

11. What data do we process on our social network pages?

We also collect personal data when you join the Dragonfly Social community.

Dragonfly Social is an open, peer-driven online community built for scientists, engineers, and imaging professionals who use Dragonfly software. Hosted on Circle SO, the platform offers access to Q&A forums, technical resources, product updates, and collaborative discussions. Users need to register and create account to be a member.

Dragonfly provides a chatbot that will use your comments that are already publicly available to anyone who creates a dragonfly social account to learn and improve its answers. Our chatbot service providers will have access to this content since that is required for them to support our chatbot function. 

When users choose to share resources (such as deep learning models or macros) from Dragonfly software to Dragonfly Social, we collect and store the resource and relevant metadata, including the user’s email address and the resource's details. Before sharing, users are asked to provide explicit consent to make their content available under open-source terms. By proceeding, users confirm that their shared content will be publicly accessible, and may be used, modified, and redistributed by others without restriction.

In addition, we receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences, or are active on them (for example, publish content, submit comments). These platforms also collect technical data, registration data, communication data, behavioural data, and preference data from you or about you, among other things (see Section 2 about these terms). These platforms usually perform statistical analysis of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, «like», forward, etc.), and combine this data with other information about you (for example, information about your age and your gender and other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use this data and profiles to display to you our, or other, advertisements and other personalized content on the platform and to manage the behaviour of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can control the analyses that these platforms generate regarding the use of our online presence to some extent.

We process this data for the purposes set out in Section 3, for communication, for marketing purposes (including advertising on these platforms, see Section 10), and for market research. You will find information about the applicable legal basis in Section 4. We may disseminate content published by you (for example, comments on an announcement), for example, as part of our advertising on the platform or elsewhere. We, or the operators of the platforms, may also delete or restrict content from or about you in accordance with their terms of use (for example, inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects’ rights, and how you can exercise them or obtain further information. We currently use the following platforms:

  • LinkedIn: Dragonfly uses Linkedin as a social platform. Also we do Linkedin Ads from time to time. LinkedIn has its own privacy policy.
  • Youtube: On YouTube we operate the page https://www.youtube.com/@dragonfly_software and other pages of our Group entities. Google LLC is the provider of the service «Youtube». Its privacy notice is available at https://policies.google.com/privacy?hl=en#infocollect. Some of your data will be transferred to the United States. You can object to advertising here: https://adssettings.google.com/authenticated?hl=en

12. Contact us

Comet Technologies Canada Inc. c/o Jaclyn Bainton

Data Protection Officer

460, rue Ste-Catherine Ouest

Suite 600

Montréal (Québec)

Canada H3B 1A7

Last updated: June 1, 2025