PRIVACY POLICY

Last updated January 01, 2026

This Privacy Notice for Comstock Holt (“we,” “us,” or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

  • Visit our website or any website of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any marketing or event

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at info@dutydrawback.com.

SUMMARY OF KEY POINTS

  • We may process personal information depending on how you interact with our Services.
  • We do not process sensitive personal information.
  • We do not collect information from third parties.
  • We process information to provide, improve, and administer our Services.
  • We implement safeguards but no system is 100% secure.
  • Depending on your location, you may have privacy rights.

TABLE OF CONTENTS

  1. What Information Do We Collect?
  2. How Do We Process Your Information?
  3. What Legal Bases Do We Rely On?
  4. When and With Whom Do We Share Your Information?
  5. Cookies and Tracking Technologies
  6. How Long We Keep Your Information
  7. How We Keep Your Information Safe
  8. Information From Minors
  9. Your Privacy Rights
  10. Do-Not-Track Features
  11. US State Privacy Rights
  12. Updates to This Notice
  13. Contact Information
  14. Reviewing, Updating, or Deleting Your Data

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide when you register on the Services, express interest in our products or services, participate in activities on the Services, or contact us.

Examples include:

  • Names
  • Phone numbers
  • Email addresses
  • Job titles
  • Passwords
  • Mailing addresses
  • Billing addresses

Sensitive Information: We do not process sensitive information.
Payment Data: Payments are processed by Stripe. See https://stripe.com/privacy

Automatically Collected Information

We automatically collect certain information when you visit or use our Services, including IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country/location, and usage data.

Log and Usage Data may include system activity, crash reports, timestamps, and hardware settings.

Device Data may include IP address, device IDs, browser type, ISP, and configuration details.

Location Data may be collected via IP or device GPS settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process personal information to facilitate account creation, manage accounts, request feedback, send marketing communications, deliver targeted advertising, protect against fraud, and comply with legal obligations.

3. WHAT LEGAL BASES DO WE RELY ON?

If you are located in the EU or UK, we rely on consent, legitimate interests, legal obligations, or vital interests as lawful bases for processing.
If you are located in Canada, we may rely on express or implied consent and other lawful exceptions.

4. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

We may share personal information in connection with business transfers such as mergers, acquisitions, or asset sales, or when required by law.

5. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, pixels, and similar tracking technologies to maintain security, prevent crashes, save preferences, perform analytics, and deliver targeted advertising.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain personal information only as long as necessary to fulfill the purposes outlined in this notice or as required by law. When no longer needed, we delete or anonymize the information.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We implement reasonable technical and organizational safeguards. However, no online transmission is guaranteed secure.

8. INFORMATION FROM MINORS

We do not knowingly collect data from individuals under 18 years of age. If you believe we have collected such information, contact info@dutydrawback.com.

9. YOUR PRIVACY RIGHTS

Depending on your location, you may have rights to access, correct, delete, restrict processing, withdraw consent, or opt out of marketing communications.

10. DO-NOT-TRACK FEATURES

We currently do not respond to Do-Not-Track browser signals.

11. US STATE PRIVACY RIGHTS

Residents of certain US states may have additional rights regarding access, correction, deletion, and withdrawal of consent.

12. UPDATES TO THIS NOTICE

We may update this Privacy Notice from time to time. The updated version will be indicated by a revised date.

13. CONTACT INFORMATION

Comstock Holt
Email: info@dutydrawback.com
Website: https://www.dutydrawback.com

14. REVIEWING, UPDATING, OR DELETING YOUR DATA

To review, update, or delete your personal information, please contact us at info@dutydrawback.com.

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