Commando LLC

GDPR Privacy Statement

Commando’s Privacy Policy [link], including this GDPR supplement, is intended to inform you about our policies and procedures regarding the collection, use and disclosure of information by Commando LLC,  and any other websites, features, applications, widgets or online services that are owned or controlled by Commando and that post a link to our Privacy Policy (collectively, the “Site”), as well as any information Commando collects offline in connection with the Site. Our Privacy Statement including this GDPR supplement applies to information collected from the effective date forward; information collected while a previous Privacy Policy was in effect remains subject to the terms of that former policy.

International Data Transfers 

Although Commando is headquartered in the United States, it has affiliated entities throughout the world. In the order to perform our contractual obligations with you, if any, as well as for operational and other legitimate interests, we may process, store and transfer Personal Information in a country which may be outside of your own, such as the United States. By providing us with your Personal Information, you acknowledge such transfer of information out of your jurisdiction. By using our services, you also understand that your information may be transferred to our affiliated entities and those third parties with whom we share it as described in the Privacy Policy.

If you do not wish for certain Personal Information to be so transferred, please do not provide your Personal Information to us and/or take such steps described herein to prevent the collection of your Personal Information. Please note in that if you choose not to share Personal Information with us, we may be unable to provide services to you. If you have any questions, please contact Commando.

How we protect your information

Although no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures appropriate to the risk for our use of Personal Data, taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of processing in order to help protect the personal information you provide to us from being lost, used or accessed in an unauthorized way, altered or disclosed, and to maintain its accuracy and integrity. For example, we use encryption when transmitting your personal financial information between your system and ours. For Personal Information, we also take into account the risk of varying likelihood and severity for the rights and freedoms of natural persons.

Minimization, Retention, And Deletion Of Personal Information

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which you process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your date. At your request, when we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Lawful Basis for Processing 

Regardless of your jurisdiction, we will only use your Personal Information when the law allows us to. That said, if you are a resident of the EEA, United Kingdom or Switzerland, our lawful basis for collecting and using your Personal Information will depend on the Personal Information concerned and the specific context in which we collect it. Generally, we will not collect or access any Personal Information other than under the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third Party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal, regulatory, or self-regulatory obligation.

We may also collect or access Personal Information with your consent.

What we mean by legitimate interests is the interest of our business in conducting, managing, and growing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need additional details about the specific legal ground we are relying on to process your personal data.

Where we rely upon your consent to process the Personal Information, you have the right to withdraw or decline your consent at any time. You may withdraw consent to online or offline marketing at any time by contacting us at address or telephone number below. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. If you decide not to provide information required by us, your use and our provision of services may be limited or impossible to facilitate.

Your Data Subject Rights 

Under certain circumstances you have rights under applicable data protection laws with respect to Personal Information we knowingly collected>

  • Choice
  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

We will try to comply with any of these requests pertaining to your Personal Information in accordance with applicable law. Please recognize that we may in certain circumstances be unable to provide the access or information sought, or correction or deletion requested. For example, we may be unable to fulfill a request if it requires us to release commercial confidential information, the disclosure of Personal Information relating to another person that is not the requestor or would result in impracticability, excessive redundancy, and/or unique burden or expense to Commando. We may need to verify your identity before acting on your request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to aid our response.

You will not have to pay a fee to access your Personal Information (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you wish to exercise any of the rights set out above, please contact us at: 

Commando LLC

Attention: Privacy
472 Meadowland Drive
South Burlington, VT 05403