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Privacy Policy

Last Updated: March 7, 2025

Cosmos (“Cosmos”, “we,” “us,” or “our”) provides a website located at www.cosmos.so (the “Site”) and corresponding mobile application (the “App”) which allows users to upload and share images and other content. To make this Privacy Notice easier to read, the Site, our services, App, and our other online or offline offerings which link to, or are otherwise subject to this Privacy Notice are collectively called the “Services.” This Privacy Notice is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights. 

  1. UPDATES TO THIS PRIVACY NOTICE
  2. PERSONAL INFORMATION WE COLLECT
  3. HOW WE USE YOUR PERSONAL INFORMATION
  4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
  5. YOUR PRIVACY CHOICES AND RIGHTS
  6. INTERNATIONAL DATA TRANSFERS
  1. RETENTION OF PERSONAL INFORMATION
  2. SUPPLEMENTAL NOTICE FOR EU/UK GDPR 
  3. CHILDREN’S INFORMATION
  4. THIRD-PARTY WEBSITES/APPLICATIONS
  5. CONTACT US
  6. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

  1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.

  1. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

  • Account Creation. We may collect information when you create an account, such as your name, email address, username, password, date of birth, country, and other information you store with your account.
  • Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
  • Your Communications with Us. We, and our service providers, may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job, or otherwise communicate with us.
  • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services, including when you comment on other users’ posts, (referred to herein as “User Content”) will be considered “public.”
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 
  • Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
  1. Information Collected Automatically 

We may collect personal information automatically when you use our Services:

  • Device Information. We may collect certain personal information about your device automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, location information (including, as applicable, approximate location derived from IP address), and Internet service provider. 
  • Usage Information: We may also automatically collect personal information regarding your use of our Services, such as pages that you visit before, during and after using our Services, items that you search for, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
  • Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services;
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

  1. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through third-party websites, applications, services, products, and technology (each a “Third-Party Service”) , we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

  1. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

  1. Provide Our Services

We use your personal information to fulfill our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support; 
  • Communicating with you;
  • Sharing personal information with third parties as needed to provide the Services;
  • Processing your financial information and other payment methods for products or Services purchased; and
  • Processing applications if you apply for a job we post on our Services.
  1. Administrative Purposes

We use your personal information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Carrying out analytics;
  • Measuring interest and engagement in our Services; 
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading or enhancing our Services; 
  • Developing new products and Services;
  • Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws; 
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Enforcing our agreements and policies; and
  • Complying with our legal obligations.
  1. Marketing 

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns. If you have any questions about our marketing practices, or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below. 

  1. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
  • Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).
  1. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

  1. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below. 

  • Service Providers. We may disclose your personal information to our third-party service providers who use that information to help us provide our Services. This may include, but is not limited to, service providers that provide us with IT support, AI services, analytics, hosting, payment processing, customer service, and related services. 

Some of the service providers we may use include:

  • Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
  • For Services Improvement through Artificial Intelligence. We may analyze your content (including any personal data you choose to include therein) to train our and our service providers’ algorithms, models and AI products and services, to develop, improve and provide our Services.    
  • Other Users You Share or Interact With. The Services may allow Cosmos users to share personal information or interact with other users of the Services.
  • Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use Third-Party Services.

Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

  • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

  • Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.  
  • APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
  1. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

  1. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be sold or transferred as part of such a transaction.

  1. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below. 

  • Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice). 

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

  • Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below.
  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. Please note you must separately opt out in each browser and on each device. 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
  • Request Correction of your personal information where it is inaccurate or incomplete;
  • Request Deletion of your personal information; 
  • Request Restriction of or Object to our processing of your personal information; and  
  • Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

  1. INTERNATIONAL DATA TRANSFERS 

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

  1. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

  1. SUPPLEMENTAL NOTICE FOR EU/UK GDPR 

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.  

Cosmo’s processing of your personal information may be supported by one or more of the following lawful bases:

Privacy Notice SectionLawful Basis: Performance of a Contract (i.e., to provide the Services to you)Lawful Basis: Legitimate InterestLawful Basis: ConsentLawful Basis: For Compliance with Legal Obligations
Section 3A: Provide Our Services✔✔✔✔
Section 3B: Administrative Purposes ✔✔✔✔
Section 3C: Marketing✔✔
Section 3D: Other Purposes✔✔✔
  1. CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children. 

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below. 

  1.  THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

  1. CONTACT US

Cosmos is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Cosmos Entity, Inc.
401 Broadway
New York, NY 10013
hey@cosmos.so