Privacy Policy


Data protection and data security are of utmost importance for Comelite IT Solutions (hereinafter "Comelite" or "we"). In the following we may provide answers to your most frequent questions to what personal data we collect, process and use in connection with our website and what your possibilities are to influence this data usage.

We would like to point out that this privacy statement applies only to our Universal Chat service on and its subpages (hereinafter "Website") but not to websites of third parties that are linked with our Website. As Comelite has no measures to influence data usage of the mentioned third parties, we recommend that you also assess those third parties' privacy statements.

Your Privacy

Comelite follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.


"Non Personal Information" is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.

"Personally Identifiable Information" is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Website. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.

Information We Collect

Automated data usage

For technical reasons, when accessing our Website your internet browser automatically transmits data to us. This applies to the following data:

  • Your date and time of access
  • Your browser type and version
  • The operating system you use
  • URL of your previously visited website
  • Quantity of data transmitted

Such data is collected and processed for technical reasons only, is at no time assigned to any identifiable person.

Live chat

In order to use our live chat at our Website you must register with your name and your email address. We use this data together with the information you transmit via the chat to advise you in the best possible way.

When you start our live chat we temporarily collect and process your IP address. By doing so we are able to identify where your access provider is located which we assume might be also the country where you access our live chat. The purpose of this information is to help Comelite to provide you with a live chat that serves your needs best. The collection of your IP address serves solely this purpose and your IP address is masked, which means we are not keeping the full data.

Our live chat service also accesses the IPs of your visitors. This information is stored in order to show you from which country they are, as well as allow you to blacklist certain IPs. Furthermore, Comelite stores the chat record. This shall not only spare you the inconvenience of recalling the whole chat history of past chats when you ask for our assistance via live chat but shall also ensure an continuous quality control regarding our live chat. If you do not want to have your chat record stored please contact us and we will delete it immediately.

Use of Services

If you decide to make use of our services, we may ask you for further personal data. If you make use of services that are free of charge (e.g. Free Plan) this is the name of your company, your website address and your Telegram number. If you want to use our fee-based services (e.g. Business Plan or Enterprise Plan) you must furthermore provide us with the necessary payment details, depending on the chosen payment method (e.g. credit card details, etc.).

Depending on the individual use of the relevant service we might process further personal data as it is necessary to render our services. This relates for example to the content of chats or chat records that have been conducted and stored by making use of our services and IT infrastructure.

Transfer of personal data

Comelite will transfer data to third parties only to the extent necessary to render its services. For any other purposes we will transfer personal data to third parties only with your prior and explicit consent. That applies in particular to the transfer of personal data for advertising purposes. Exceptions to this rule apply only in the following cases:

  • If required for investigating the illegal use of the services of Comelite or for legal proceedings, personal data will be transferred to the criminal investigation authorities and, if legally obliged, to injured third parties. We are also legally obliged to give certain public authorities information. These are criminal investigation authorities, public authorities which prosecute administrative offences entailing fines and the US finance authorities.
  • Occasionally we depend on contractually affiliated external companies and external service providers to supply services such processing payments (credit card etc.), storing your data and customer service. In such cases, information is transferred to these companies or individuals in order to enable them to process this information further. The service providers may only use the data for the purposes stipulated by Comelite and solely in accordance with US data protection laws.
  • In order to further develop our business, we may alter the corporate structure of Comelite e.g. by changing its legal form. We may also form, sell or buy subsidiaries, divisions or parts of the company. In such transactions, customer information together with the part of the company to be transferred will be passed on. Every time personal data are transferred to third parties to the extent prescribed, Comelite will ensure that this is done in accordance with this privacy statement and the relevant data protection laws.

About our newsletter

Comelite provides a newsletter service, free of charge. These services are used for sharing news about Universal and its services as well as offer you tutorials on how to use any new features or benefits. The newsletter is sent to you by email. To subscribe for our newsletter service you must use the opt-in option during the registration process or use the subscription form.

You can unsubscribe the newsletter service at any time. You may find information on how to unsubscribe with effect for the future in every newsletter in the emails that are sent.

Third Party Tracking Tools

We also use third party tracking tools to improve the performance and features of our Website. These third party tracking tools are designed to collect only Non-Personal Information about your use of our Website. However, you understand that such tools are created and managed by parties outside our control. As such, we are not responsible for what information is actually captured by such third parties or how such third parties use and protect that information.


Comelite makes use of so-called "cookies" in order to be able to offer you a comprehensive range of functions and to make it easier to use our websites. Cookies are small files which are stored on your computer with the help of the internet browser.

If you do not want to use cookies, you can prevent them from being stored on your computer using the corresponding settings on your internet browser. Please note that this may restrict the functional capability and the range of functions of our services.

To opt-out of all web tracking technologies (including Google Analytics and Piwik), using an extension such as Noscript or Ghostery is the safest way: these browser extensions will disable all the known JavaScript trackers and ensure that your browser does not send a request to external tracking servers. If you wish to browse the Internet without your IP address being tracked at all, please consider using Tor Browser which will automatically connect you to the secured and anonymous Tor network. If you wish to send and receive emails that are coded to make sure that a surveillance agent or thief that intercepts your email can't read it, check out the email self defense guide. If you wish to stay completely anonymous online, please see the PDF guide How to remain anonymous online?

Protecting Your Child's Privacy

Our Website is not designed for use by anyone under the age of 13 ("Child"), though we realize we may have a Child attempt to make purchases through our Website. We do not verify the age of our users nor do we have any liability for verifying a user's age. If you are a Child, please seek the permission of a parent or guardian before using our Website. If you are a parent or guardian and believe your Child is using our Website, please contact us to remove your Child's account; we reserve the right to ask you for verification of your relationship to the Child before we honor such a request. If we discover that a Child has created an account on our Website, we will immediately delete the account as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. However, as parent of such a Child, you understand that you are legally liable for any transactions created by the Child.

Our Email Policy

Our affiliates and we fully comply with national laws regarding SPAM. You can always opt out of receipt of further email correspondence from us and/or our affiliates. We agree that we will not sell, rent, or trade your email address to any unaffiliated third-party without your permission.

Privacy Policy Updates

We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the "Last Updated" date at the end of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

Questions About Our Privacy Policy

If you have any questions about our Privacy Policy, please contact us.

Last Updated: January 22, 2017