Privacy Policy

This privacy policy will explain how we use the personal data we collect from you when you use our website.

What data do we collect?

comsim collects the following data:

Personal identification information:

  • Name
  • Email Address
  • Payment data such as credit card or other card numbers

How do we collect your data?

You directly provide comsim with all the data we collect. We collect data and process data when you:

  • register online
  • place an order for any of our products or services.
  • voluntarily complete a customer survey or provide feedback on any of our message boards or via email
  • create a support ticket through our website
  • transmit a radio message in spoken or written form while the "AI Tutor" function is activated
  • transmit a radio message, a DSC call or a chat message in "Live Chat" mode

How will we use your data?

comsim collects your data so that we can:

  • process your order and manage your account.
  • inform you about relevant product or policy changes
  • ensure the continued functionality of the service

We will not sell your data to third parties for the purposes of advertising or tracking.

When comsim processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

How do we store your data?

comsim securely stores your data at a data center in Helsinki, Finland.

Payment related data will be stored by Stripe Inc. according to their privacy policy.

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.

If you delete your user profile, comsim will delete the user data stored on our servers immediately.

comsim may have to keep your payment related data for an extended period, depending on your location, the product selected, payment type used and other factors. Please contact us directly for information on how long we store this particular data and how to request deletion.

With who do we share your data?

comsim relies on the service of third-party vendors and service providers that require access to to your personal data to perform their service.

Payments, Invoicing and Billing

Stripe, Apple Pay* and PayPal*

*) Your data will only be disclosed to these parties if selected as the payment method

Hosting Service Providers

Hetzner

Customer Support

GitLab

Email

Scaleway, Apple

We also may need to share your personal information in the case that the business is transferred to, sold to, acquired by or merged with another company.

LLMs / "AI"

Anthropic, Mistral AI

In order to offer the tutor function, we transmit radio messages recorded and/or written in the tutorial or in "Scenarios" as well as some data required for a realistic simulation (such as the selected ship name or the simulated location) to the AI Service. The "Sparkle" icon indicates that such a transmission is active. The transmission takes place without any further personal identification features and is always routed via our servers.

This function can be deactivated in the user settings.

Marketing

comsim would like to send you information about products and services of ours that we think you might like. We will never send you marketing information from third parties and never provide your data to third parties for marketing purposes.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop comsim from contacting you for marketing purposes.

You may opt out of marketing emails by clicking "unsubscribe" in a marketing email or by updating your profile.

What are your data protection rights?

comsim would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request comsim for copies of your personal data.

  • The right to rectification – You have the right to request that comsim correct any information you believe is inaccurate. You also have the right to requestcomsim to complete the information you believe is incomplete.

  • The right to erasure – You have the right to request that comsim erase your personal data, under certain conditions.

  • The right to restrict processing – You have the right to request that comsim restrict the processing of your personal data, under certain conditions.

  • The right to object to processing – You have the right to object to comsim’s processing of your personal data, under certain conditions.

  • The right to data portability – You have the right to request that comsim transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at privacy@comsim.

Cookies

Cookies are text files placed on your computer to store website data on your device. When you visit our websites, we may use cookies and your browser's storage to ensure a proper functioning of the website.

How do we use cookies?

comsim uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Remembering your language preference
  • storing other user preferences
  • storing application state locally
  • redirecting you to the expected location after leaving the site and returning

What types of cookies do we use?

We will only ever use functional cookies. We will not use advertising cookies.

comsim uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

How to manage cookies

You can set your browser not to accept cookies. However, our website relies on cookies to provide its functionality when signed in. To simplify this dilemma, we simply do not use any tracking cookies.

Privacy policies of other websites

The comsim website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

comsim keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on April 14th, 2025.

How to contact us

If you have any questions about comsim’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: privacy@comsim.app

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that comsim has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Website: www.bfdi.bund.de

Email: poststelle@bfdi.bund.de

Address: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, Graurheindorfer Str. 153, 53117 Bonn