Legal

‍COMO Pandemic Protection Services Engagement Letter
Last Updated: 3/16/2021

This Engagement Letter (“Engagement Letter”) is made and entered into by and between Como Catalysts, LLC. (“COMO”) and you (the “Client” or “you”) as of the date this Engagement Letter is executed or otherwise entered into by you in accordance with the terms herein by you (the “Effective Date”).  This Engagement Letter is incorporated into the Terms of Service Agreement available at https://www.comocatalysts.com/terms-of-service.html (the “Agreement”). Capitalized terms used herein, but undefined will have the meaning given to such term in the Agreement.

BY REGISTERING FOR, USING AND/OR RECEIVING THE PANDEMIC PROTECTION SERVICES, OR BY CLICKING THE “I ACCEPT” OR SIMILAR BUTTON, YOU AGREE TO THE TERMS OF THIS ENGAGEMENT LETTER.
1. Term
The duties and obligations of both the Client and COMO shall commence on the Effective Date and continue for a period of one (1) year thereafter (the “Initial Term”). Thereafter, this Engagement Letter will automatically renew for successive one (1) year periods (each, a “Renewal Term”, and together with the Initial Term, the “Term”), unless either party provides at least thirty (30) days’ notice prior to the end of the Initial Term, or Renewal Term, as applicable, of its intent to terminate this Engagement Letter. Notwithstanding the foregoing, COMO may require you to consent to an updated Engagement Letter in a specified manner prior to each Renewal Term before any Pandemic Protection Services for the then applicable Renewal Term may be provided. This Engagement Letter may be terminated by either party by giving a thirty (30) day written notice in accordance with the Agreement. Furthermore, either party may terminate this Engagement Letter for cause in the event the other party breaches any material term and fails to cure such breach within seven (7) days of the non-breaching party’s notice thereof.
2. Scope
Subject to the terms and conditions of the Agreement, including the payment of applicable fees, COMO agrees to provide the following advice services during the Term (“Pandemic Protection Services”):
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One-time: (1) Secure funding from public and private sources in a capital campaign manner to help assist against economic injury resulting particularly from the Pandemic. Consult on all necessary steps for approval, progress maintenance, and closing.
    (2) If a client seeks consultation on the Paycheck Protection Program as detailed in the CARES ACT, COMO Pandemic Protections Services will provide consultation that may or may not result in funding. In the case of funding, COMO guarantees no client financial obligation if government-backing fails to cover completely any loan correctly applying for Small Business Administration and lender forgiveness.
Ongoing: (1) Maintain client services obligations until all requirements of financing have been met or financial forgiveness has been applied.
3. Out of Scope
We are not a PPP loan agent.
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4. Client Obligations
Compensation to COMO Upon Successful Funding Pursuant to Pandemic Protection Services
The CLIENT agrees to compensate COMO the appropriate percentage of the line of credit and/or equity infusion obtained in total by COMO on behalf of the CLIENT, based on the payment sliding scale below. Such funds will be due and payable at the time of closing by lender on the line of credit or the infusion of equity by a capital source. COMO will invoice CLIENT detailing payment due within 24 hours and methods upon which payment may be received.

Loan Amount / Fee (Percentage)
$5,000 - $50,000 / 40%
$50,000 - $100,000 / 30%
$100,000 - $250,000 / 20%
$250,000+ / 10%

Cooperation and Access to Information
Client acknowledges and agrees that COMO’s performance hereunder is conditioned upon Client’s performance of its obligations herein and reasonable cooperation.  Client agrees to provide COMO with any information and permissions reasonably requested by COMO in order to perform the Pandemic Protection Services.  Without limitation, Client will either (i) provide COMO with electronic transaction access to its bank accounts and credit card accounts, or (ii) provide COMO with its monthly statements related to its bank accounts and credit cards. COMO acknowledges information is the confidential information of Client, and will use such information and/or access solely for the purpose of performing its obligations herein.  In the event Client provides COMO with electronic access to its bank accounts and/or credit card accounts, Client represents and warrants that it has all rights necessary to grant COMO access to such accounts, and that COMO’s use of such accounts will not require COMO to pay any fees.

Do Not Commingle Funds
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Client acknowledges that COMO's performance of its obligations herein, and any advice or information provided by COMO in connection with the Pandemic Protection Services is based upon the information provided and made available by Client. Client further acknowledges that in the event Client commingles its business accounts with its or its spouse’s personal accounts and expenses, that COMO cannot accurately perform the  Pandemic Protection Services. As such Client agrees that it shall not commingle any business accounts or expenses with any of Client’s (or its spouse’s or other third party’s) accounts or expenses.

Accuracy of Information
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‍You represent, warrant and covenant to COMO that all information you provide to COMO in connection with the Pandemic Protection Services Services is accurate, complete, current and true, and that if you discover that any such information is inaccurate, incomplete, out-of-date or false, you will immediately notify COMO in writing and promptly correct such information.  You acknowledge and agree that you shall be solely responsible for, and shall hold COMO, its affiliates and their respective officers, directors, employees and contractors harmless from any costs, expenses (including reasonable attorneys’ fees), damages, judgments, liabilities, losses, penalties and settlements arising from or related to your breach of the foregoing representation and warranty. COMO shall not be responsible or liable to you or any other person or entity for any delays, penalties or other consequences arising from your breach of the foregoing representation and warranty.
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5. Treatment of Personal Information
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COMO will collect, store, process and disclose any information you provide in connection with this Engagement Letter in accordance with COMO’s privacy policy available at https://www.COMO.com/privacy-policy.html.
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6. Disclaimer
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The Pandemic Protection Services Services will be provided solely with respect to that business you have identified to COMO in connection with your COMO account.  COMO will not perform an audit or review of your financials or any other related documents you may provide. All advice and information made available by COMO in connection with the  Pandemic Protection Services Services is based on the information you provide to COMO, and the  Pandemic Protection Services Services cannot be relied upon to discover errors, fraud, defalcations or other irregularities, should any exist. We will not audit or otherwise verify the information you submit, although we may ask you for clarification of some of the information. COMO is not responsible for any information or advice given based on any inaccurate, untrue, incomplete or out-of-date information provided by you. You are solely responsible for your acts and omissions related to the  Pandemic Protection Services Services.
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7. No Guaranteed Results or Responses.  
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COMO does not make any representation or warranty that the Pandemic Protection Services will be appropriate for your needs or suitable for your business. COMO does not guarantee and expressly disclaims any particular results.  SINCE THE PANDEMIC PROTECTION SERVICES ARE BASED ON THE INFORMATION YOU PROVIDE, COMO does not warrant that the  Pandemic Protection Services will be timely, accurate, current or complete. COMO may make available third party communication tools, such as Typeform, to enable you to communicate with our staff, but COMO makes no representation or warranty that such tools are secure or that our staff will be able to respond to you in a timely manner.
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8. General
Client acknowledges and agrees that the Agreement https://www.comocatalysts.com/terms-of-service.html is incorporated herein by reference, and that the terms thereof shall apply to the performance of each party’s obligations herein, including, without limitation, the sections relating to Limitation of Liability, Indemnification and Arbitration.

PPP Loan Assistance Terms
Last updated: March 15, 2021

These PPP Loan Assistance Terms (“Additional Terms”) apply to those businesses or entities (“Business”) that have chosen to take advantage of COMO’s Pandemic Protection Services (hereafter the “Program”), which can be used to assist Businesses in applying for Paycheck Protection Program Loans (“PPP Loans”). These PPP Loans are provided by third-party private lenders and are backed by the United States federal government.

These Additional Terms are a part of and subject to the COMO Terms of Service, and all capitalized terms used herein without definition shall have the meaning given to them in such Terms of Service. The Program as serviced by COMO is part of the Services.

By participating in the Program, you agree to be bound by these Additional Terms as well as other terms, policies, and guidelines applicable to the PPP Loans, including, but not limited to, the PPP Loan agreements and all relevant disclosures between you and the applicable Third-Party Partner.

You acknowledge that you are applying for a PPP Loan for business purposes or on behalf of a Business for business purposes. You further acknowledge that you are authorized to accept these terms on behalf of the Business and that the Business accepts these terms.

In order to be eligible to participate in the Program, you must be a Business currently registered for the Services and in good standing. COMO does not offer support with consumer stimulus programs or consumer loans, and consumers are not eligible for PPP Loans.

Any advice or guidance given by or on behalf of COMO in connection with the Program is given solely for informational purposes. This guidance is not legal, accounting, or tax advice. You should contact your lawyer, accountant, or tax professional should you need such advice.

We do not guarantee any particular outcome from your participation in the Program, including whether you will be granted a PPP Loan. We use reasonable efforts to assist all Businesses interested in the Program, but due to a high volume of requests, we cannot guarantee how quickly we can respond to you.

The Program offered at no upfront charge to Businesses. You understand that COMO IS NOT paid a commission by its Third-Party Partners who grant PPP Loans, and COMO does not endorse any particular Third-Party Partner.

As further detailed below, in the context of your PPP Loan application, we may pass your information to one or more Third-Party Services and/or Third-Party Partners in order to determine your eligibility for a PPP Loan, determine your PPP Loan size, accelerate your PPP Loan application, and/or help you get approved. These Third-Party Partners have the right to contact you directly and if you use their services or provide them additional information you understand you will be consenting to their terms, which may be different from these Additional Terms or our Terms of Sergice.

These Additional Terms may be modified as described in the Terms of Service. COMO may discontinue the Program at any time, without prior notice.

You shall perform all acts necessary to authorize and/or enable COMO and each applicable Third-Party Service and Third-Party Partner to release the following information (if requested) for those purposes detailed below.

Bank Information

Collection of Bank Information

COMO uses Third-Party Services (including, without limitation, Plaid Inc.) to gather data. If you link a bank account in connection with the Program, these Third-Party Services will collect data directly from the financial institution you specify. You grant COMO and each of the applicable Third-Party Services and Third-Party Partners the right, power, and authority to act on behalf of you and your Business to access and transmit personal and financial information about you and/or your Business from the financial institution you specify. You agree to such personal and financial information being collected, transferred, stored and processed in accordance with COMO’s Privacy Policy and the applicable Third-Party Partner’s and Third-Party Service’s Privacy Policies (including Plaid’s Privacy Policy, with all such privacy policies collectively referred to as “Privacy Policies”).

When you share or provide access to bank statements, bank data, passwords, usernames, PINs, login information and/or any other personal or financial information about you and/or your Business in connection with the Program (referred to collectively as “Bank Information”), you are licensing that content to COMO and each of the applicable Third-Party Services and Third-Party Partners for the purposes described in these Additional Terms and the Privacy Policies. You agree that all Bank Information will be subject to these Additional Terms and the Privacy Policies. For the avoidance of doubt, Bank Information is considered User Data as defined in the Terms of Service. You represent that you are a legal owner of, and that you are authorized to provide COMO and each of the applicable Third-Party Services and Third-Party Partners with Bank Information on behalf of yourself, your Business and/or any other account owner(s).

Use of Bank Information

You give COMO and each of the applicable Third-Party Services and Third-Party Partners permission to use your Bank Information for purposes of: (i) evaluating your PPP Loan application, (ii) evaluating your Business’s eligibility for any current or future financial services offers and marketing these offers to you and your Business, (iii) servicing and collections activities related to the Program, including but not limited to determining the amount of funds in your bank account available to be debited for PPP Loan repayment as authorized by the PPP Loan agreement between you and the applicable Third-Party Partner, (iv) investigating and reporting fraud or alleged fraud, (v) evaluating your Business for any products or services offered by COMO and marketing these products or services to you and your Business, (vi) compliance with anti-money laundering (“AML”) and OFAC sanctions programs, and (vii) internal analytics, credit modeling and product development. In addition, you give COMO and each of the applicable Third-Party Services and Third-Party Partners permission to use your Bank Information for any purpose specified in the Privacy Policies and any other purpose related to the Program.

Duration of Access

When you link a bank account in connection with the Program, you authorize COMO and each of the applicable Third-Party Services and Third-Party Partners to continue to collect Bank Information from the financial institution you specify for as long as your business continues to be part of the Program or for as long as your PPP Loan is outstanding, whichever is longer. The frequency at which COMO and each of the applicable Third-Party Services and Third-Party Partners will collect Bank Information during this period will vary. You can revoke this authorization by writing COMO at hello@comocatalysts.com.Your revocation will not affect our ability to electronically credit and debit your Program-linked bank account to the extent permitted under any applicable terms and agreements. The Bank Information collected with your consent prior to your revocation will continue to be reviewed, used, stored and shared in a manner consistent with these Additional Terms and the Privacy Policies.

Payroll Information

Collection of Payroll Information

COMO uses Third-Party Services (including, without limitation, Plaid) to gather data from payroll providers. If you link a payroll account in connection with the Services, a Third-Party Service will collect data directly from the payroll provider you specify. You grant COMO and each applicable Third-Party Service and Third-Party Partner the right, power, and authority to act on behalf of you and your Business to access and transmit personal and financial information about you, your Business and your employees from the payroll provider you specify. Payroll providers are considered Third-Party Services pursuant to the Terms of Service. You agree to such personal and financial information being collected, transferred, stored and processed in accordance with our Privacy Policies.

When you share or provide access to payroll information, employment data and records, passwords, usernames, PINs, login information and/or any other personal or financial information about you and/or your Business and its employees in connection with the Services (referred to collectively as “Payroll Information”), you are licensing that Payroll Information (which is considered User Data) to COMO, and each applicable Third-Party Service and Third-Party Partner for the purposes described in these Additional Terms and the Privacy Policies. You agree that all Payroll Information will be subject to these Additional Terms, COMO’s Terms of Service, and the Privacy Policies. You represent that you are a legal owner of, and that you are authorized to provide COMO, the applicable Third-Party Services and Third-Party Partners, and Plaid with Payroll Information on behalf of yourself, your Business and/or any other account owner(s).

Use of Payroll Information

You give COMO and the applicable Third-Party Services and Third-Party Partners permission to use your Payroll Information for purposes of: (i) evaluating your PPP Loan application, (ii) evaluating your Business’s eligibility for financial services offers, (iii) servicing and collections activities related to your PPP Loan, (iv) investigating and reporting fraud or alleged fraud, (v) compliance with AML and OFAC sanctions programs, and (vi) determining your eligibility for forgiveness of your PPP Loan under applicable federal regulations. In addition, you give COMO, the applicable Third-Party Services and Third-Party Partners, and Plaid permission to use your Payroll Information for any purpose specified in the Privacy Policies and any other purpose related to the Program.

Duration of Access

When you link a payroll account in connection with the Services, you authorize COMO and each applicable Third-Party Service and Third-Party Partner to continue to collect Payroll Information from the payroll provider you specify for as long as your business continues to use the Services or for as long as your PPP Loan remains outstanding, whichever is longer. The frequency at which COMO and each applicable Third-Party Service and Third-Party Partner will collect Payroll Information during this period will vary. You can revoke this authorization by writing COMO to hello@comocatalysts.com The Payroll Information collected with your consent prior to your revocation will continue to be reviewed, used, stored and shared in a manner consistent with these Additional Terms and the Privacy Policies.

Credit Reports, Tax Filings, and Public Records

You give COMO and each applicable Third-Party Service and Third-Party Partner permission to access your consumer credit reports, tax filings, and public records for purposes of: (i) evaluating your PPP Loan application, (ii) evaluating your Business’s eligibility for any current or future financial services offers and marketing these offers to you and your Business, (iii) servicing and collections activities related to your PPP Loan, (iv) investigating and reporting fraud or alleged fraud, (v) compliance with AML and OFAC sanctions programs, (vi) internal analytics, credit modeling and product development, and (vii) any other purpose related to the Program. Checking your credit report for any of these reasons will not impact your credit score. You understand that, after evaluating your complete application and checking your credit report, Third-Party Partners may decide not to offer a PPP Loan to your Business.

You understand that if your PPP Loan application is declined based on any information from your consumer credit report, COMO, on behalf of the applicable Third-Party Services and Third-Party Partners, will send a notice of this action to the business email address provided in the PPP Loan application. You acknowledge that such notice may include your personal credit score and information.

You consent to allow COMO to continue to access your consumer credit report, tax filings, and public records for as long as your PPP Loan remain outstanding.

Indemnification

You will indemnify, defend and hold harmless COMO and applicable Third-Party Service and Third-Party Partner (and their respective employees, directors, agents, affiliates and representatives) from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest, and expenses (including without limitation reasonable attorneys’ fees) arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties, or obligations set forth in these Additional Terms or any activity by you in relation to the Program or your participation in the Program; (b) your wrongful or improper use of the Services or Program; (c) your violation of any third-party right, including without limitation any right of privacy; (d) your violation of any law, rule or regulation of the United States or any other country; and (e) any other party’s access and/or use of the Services with your unique name, password or other appropriate security code.

Government Monitoring

To help the government fight the funding of terrorism and money laundering activities, Federal law requires COMO and its Third-Party Partners to obtain, verify, and record information that identifies each person who opens an account. When applying for a PPP Loan from a Third-Party Partner, we will obtain your name, address, date of birth and may ask you for other information that will allow COMO to identify you. We reserve the right to close, suspend, or limit access to the Program in the event we are unable to obtain or verify this information.
Last Updated: 1/13/2021

Como Catalysts, LLC. (“our,” “we” or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our software, website, documentation, and related services (together, the “Services”). Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Service for the Services, which can be found here.
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1. Consent
By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy. You may not use the Services if you are not of legal age to form a binding contract (in many jurisdictions, this age is 18). Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We do not collect Personal Information for the purpose of sale of such information in a way that identifies the individual, i.e. we don’t sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using some or all of the Services.
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2. Collection of Information
Personal Information


When registering for or using the Services, we may require or ask you to provide certain personally identifiable information (these are referred to below as your “Personal Contact Information”). The Personal Contact Information that we require you to provide in order to access the Services may include, but is not limited to, the following:

- Full Name
- Email Address
- Phone Number
- Personal Address
- Company Name
- Company Address

We may also ask for your Social Security Number (“SSN”) solely in connection with the provision of our EIN Service and Business License Service. Once we have helped you obtain an EIN or license for your business, your SSN information is promptly deleted from our system.

When purchasing the Services, we will require you to provide financial and billing information, such as billing name and address, and credit card number (“Billing Information”). A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf. Collective stores elements of your Billing Information, but does not store your credit card number.

Your Personal Contact Information and your Billing Information (together with Data, Diagnostic, Login, Usage and Analytics, and Generalized Geo-Location Information, as defined below, that may be used to identify, contact, or locate you individually) are collectively referred to as your “Personal Information.”

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Data, Diagnostic & Login Information


You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers. If you run into technical errors in the course of using the Services, we may request your permission to obtain a crash report along with certain logging information from your system documenting the error (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version, and your email address, if provided. Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device, i.e. not on a server, in order to streamline the login process (“Login Information”).



Usage and Analytics Information

As you use our Services, we may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons, each as further described below. Collectively, this information is referred to as “Usage and Analytics Information.”
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Cookies

We use cookies to provide you with our Service, to personalize content and ads, and to provide you with the best experience possible on our website. For more information about our use of cookies, please see the section entitled “Cookie Policy” below.

Log Files

As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer the Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve the Services, to track and aggregate non-personal information, and to provide the Services. For example, we use IP addresses to monitor the regions from which customers and visitors navigate the Sites.

Web Beacons

We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We also use web beacons to operate and improve the Services and our email communications.

Geo-location

We do not use GPS technology to collect any information regarding your precise real-time geo-location while using the Services. However, we may use elements of your Usage and Analytics Information (such as your IP address) to determine your generalized location. This information is referred to as “Generalized Geo-Location Information.” Please be aware that some of our 3rd party vendors may utilize applications that require location services'.
3. Use of Information
We use the information we collect in the following ways:

Personal Contact Information

We use this information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement, and to address issues like malicious use of the Services. We may also use Personal Contact Information for limited marketing purposes, namely, to contact you to further discuss your interest in the Services, and to send you information about us or our partners. Any use of your Personal Contact Information for these limited marketing purposes will comply with applicable laws. Note: We do not use your SSN for any purpose other than to provide you with our EIN Service.

Billing Information


We use Billing Information to manage your account, to provide the Services, and to check the financial qualifications of prospective customers and to collect payment for the Services.

Data, Diagnostic Information and Login Information

We use this information for the purpose of administering and improving our Services to you. We may also use this information in a de-identified, anonymous way in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and for other legitimate business purposes.

Usage and Analytics Information


We may use your Usage and Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, to enable more effective responses to support requests, to ensure compliance with customer subscription and service limitations, and to inform company research and development.

Generalize Geo-Location Information

We may use this information for the purpose of administering and improving our Services to you, such as by providing you with relevant advertisements and promotions. We may also use your Generalized Geo-Location Information in an anonymized manner in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, and to increase the Services’ functionality and user-friendliness.

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.
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4. Do Not Track
Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track status or preference.
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5. Disclosures & Transfers
We have put in place contractual and other organizational safeguards with our agents and contractors (see further below) to protect a proper level of protection of your Personal Information (see further “Security” below). Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take  reasonable steps designed to ensure that your data is treated securely and in accordance with this Privacy Policy.

From time to time we may employ third parties as contractors to help us provide and/or improve the Services. These third parties may have limited access to databases of user information or registered member information solely for the purpose of helping us to provide and/or improve the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose. Such agents or third parties do not have any rights to use Personal Information beyond what is necessary to assist us. For additional information regarding our third party contractors, please see Section 12 below.

We may also disclose your Personal Information with your consent.

6. Important Exceptions
We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is permitted or required by and in accordance with the law.

We may also disclose, transfer, sell or otherwise sell some or all of our business or assets, including your Personal Information, in connection with a corporate reorganization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, or in the event of bankruptcy or dissolution. We will provide you notice (which may be by email or notice on our website) upon consummation of any such change of control transaction and whether your Personal Information has become subject to a new Privacy Policy. We will also notify you of choices you may have regarding the information.
7. Security
The security of your Personal Information is important to us. Taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we have and continue to implement commercially reasonable technical and organizational measures designed to ensure a level of security reasonably appropriate to the risk to those whose Personal Information we process. We also use commercially reasonable technical, administrative, and physical safeguards designed to preserve the integrity and security of the Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on our website if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
8. Sharing Information with Other Users Third Parties
You may be able to direct that Personal Information be shared with third parties through use of the Services. We will not permit any such transfer without your express opt-in consent. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. Furthermore, such third parties may store the transferred Personal Jurisdiction in a location with privacy and other laws different than those that apply to us. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.
9. Retention
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, de-identified data, or account recovery. All retained Personal Information will remain subject to the terms of this Privacy Policy. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological, legal, or contractual constraints.

We will retain copies of the records you have supplied to us along with work papers for your engagement for a period of seven years from the original due date of the applicable return. Please notify us within this period if you need copies of any of these materials. After seven years, work papers and engagement files will be destroyed. Your original records will be returned to you at the end of this engagement. Working papers and files that we or the Service Provider maintain are not a substitute for your original records, and you should arrange for secure storage of the originals.
10. Amendment of this Privacy Policy
We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we may post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective on the date the change is emailed to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

If applicable law requires your opt-in consent to any particular amendment to this Privacy Policy, the amendment will not apply to your Personal Information until we receive such consent from you. To the extent we cannot provide some or all of the Services without your consent to such amendment to the Privacy Policy, your decision not to consent may result in our having to limit your ability to use certain aspects of the Services.
11. Access and Accuracy; Correcting Personal Information
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected with respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable efforts to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to correct, amend, delete, or limit the use of your Personal Information. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

In certain circumstances, you have the right:

- To access and receive a copy of the Personal Information we hold about you
- To rectify any Personal Information held about you that is inaccurate
- To request the deletion of Personal Information held about you

You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Information in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests. Please also note that should you request some information deleted, we may need to request this information again to continue providing services. Please note that we will require each individual to request their own information, even in the cases of spouses.
12. Service Providers
We may employ third-party companies and individuals to facilitate our Services (“Service Providers”), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services is used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13. Cookie Policy
What are cookies?

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device.

What are cookies used for?

Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.

What types of cookies do we use?

There are generally four categories of cookies: “Strictly Necessary,” “Performance,” “Functionality,” and “Targeting.” We routinely use all four categories of cookies on the Service. You can find out more about each cookie category below.

1. Strictly Necessary Cookies. – These cookies are essential, as they enable you to move around the Service and use its features, such as accessing logged in or secure areas. Because these cookies are essential, they cannot be disabled.
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2. Performance Cookies. – These cookies collect information about how you have used the Service, for example, information related to the unique username you have provided, so that less strain is placed on our backend infrastructure. These cookies may also be used to allow us to know that you have logged in so that we can serve you fresher content than a user who has never logged in. We also use cookies to track aggregate Service usage in an anonymized fashion and experiment with new features and changes on the Service. The information collected is used to improve how the Service works.

3. Functionality Cookies. – These cookies allow us to remember how you’re logged in, whether you chose to no longer see advertisements, when you logged in or out, and the state or history of Service tools you’ve used. These cookies also allow us to tailor the Service to provide enhanced features and content for you and to remember how you’ve customized the Service in other ways. The information these cookies collect are anonymous, and they are not used to track your browsing activity on other sites or services.
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4. Targeting Cookies. – Us, our advertising partners or other third party partners may use these types of cookies to deliver advertising that is relevant to your interests. These cookies can remember that your device has visited a site or service, and may also be able to track your device’s browsing activity on other sites or services other than ours. This information may be shared with organizations outside of ours, such as advertisers and/or advertising networks to deliver the advertising, and to help measure the effectiveness of an advertising campaign, or other business partners for the purpose of providing aggregate Service usage statistics and aggregate Service testing.

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

How to control your cookie settings.

If you do not want cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section or see www.allaboutcookies.org. Please note that if you use your browser settings to block all cookies (including strictly necessary Cookies) you may not be able to access or use all or parts or functionalities of our Services.

If you want to remove previously-stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Services from placing further cookies on your device unless and until you adjust your Internet browser setting as described above.

For more information on the use of targeting/advertising cookies, please see www.aboutads.info/choices.
14. Contact Us
You can help by keeping us informed of any changes such as a change of email address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at hello@comocatalysts.com

If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures..