Effective date: 4th August 2023
Introduction
Cosmos Video is committed to respecting your privacy and protecting your personal data in line with GDPR.
In this privacy policy (this “Policy”), “Cosmos” “we”, “us or “our” means Cosmos Video Limited - a company registered in England and Wales (with company no. 12875387) and with the Information Commissioner’s Office (the UK data protection authority) under no. ZA878308. Our corresponding address is OHS Secretaries Limited, 9th Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN. “You” means you as (a) a user of the free version of Cosmos or (b) a user of the paid version of Cosmos., and “personal data” shall have the meaning assigned to it in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council.
The privacy policy explains the personal data Cosmos Video collects, why the data is collected, and the measures to protect the data. All the data obtained, held and processed is in compliance with this privacy policy. The data protection laws and regulations that apply to Cosmos Video Limited - UK GDPR and Regulation (EU) 2016/679 of the European Parliament.
The terms under which you use and we provide our services are explained in our Terms of Service ("Terms"). In accordance with our Terms, you must be at least 18 years old to use the Platform.
This privacy policy applies to you when you use our products or interact with us - use our website at www.cosmos.video (”Website”) or Cosmos virtual spaces or offices (”Cosmos Spaces”) or collectively the “Services”.
The main establishment of Cosmos Video Limited for the purposes of GDPR is the United Kingdom. To contact us about this privacy policy, please email us at privacy@cosmos.video. Please visit our rights page to learn about your data protection rights under GDPR.
We have appointed a Data Protection Office, who can be contacted at privacy@cosmos.video.
This policy is effective as of the “effective date”, which appears on the top of the policy. At our sole and absolute discretion, we reserve the right to change or modify this policy at any time. Any such changes or modifications will become effective when posted on this page: www.cosmos.video/privacy. Please check this page to ensure that you are happy with any changes or modifications. If we make a change or modification to this policy, we may, at our sole discretion, send you an email regarding the changes to our policies.
You are free to choose to use Cosmos products or services based on the information we provide in our privacy policy, cookie policy and terms of use. Please read the documents carefully and choose what is best for you and your company. Please do not access or use our services if you disagree with any part of this policy, cookie policy and terms of use.
If you have any questions or concerns, or feedback about this policy or its implementation, we request you to contact us at privacy@cosmos.video or write to us at Cosmos Video, 9th Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN.
What personal data do we collect?
We aim to minimise the personal data we collect, obtain and store. We collect and store personal information with the goal of offering great product experience and customer support.
When you signup or register on the Cosmos website:
- Email address and name: When you sign in to the platform
- Your preferences for cookies
When you use Cosmos Office or Space:
- Profile data: Name and email
- Audio and Video data: We only use this data to provide you with the service of audio, video calling with screen share. All audio and video data is encrypted and transmitted during a call. We do not store the data unless the user initiates a meeting to be recorded. When a meeting is recorded, that conversation with the participants is recorded and saved on Cosmos servers.
- Financial data (if paying customer): Name, payment card information, along with billing address which is required to provide you with the service.
- Messages and file data: Cosmos stores message data and files sent to other users via the platform. The sole purpose of storing this data is to offer messaging and file-sharing services to our users. Users can delete individual parts of this data or submit a SAR request for us to remove all the associated data.
When you get in touch
- Contact data: Your email address, name, and logs of the application performance (retained for 15 days). This information is needed to offer you a resolution to the problem and for us to improve our services. All email conversation data is deleted after 60 days.
Logs to help support you and improve our service
We collect server logs and performance metrics to monitor our service performance and help us improve our products and services. The information we collect is:
- Usage data: Logs of application usage which are aggregated to derive product improvement insights.
- Technical Data: Anonymised performance and networking data from the user client: IP address, date and time of access, and “cookie” information, the type of browser and device make you’re using to access our Services, and the page or feature you requested. Anonymised and only retained for a maximum of 15 days.
Do we collect any sensitive data?
Cosmos doesn’t collect any sensitive data from our systems. The only situation where Cosmos can have access to some sensitive data is if users activate meeting recordings or sends messages with sensitive data to others on the platform. We request our users to read the privacy policy, terms of use and voluntarily decide how to use our services.
What do we use the personal data for?
We obtain, store, transmit and process data to:
- Provide our customers with the ability to do audio, video and message-based communication in real-time;
- Assist our customers with customer queries or bugs;
- For the purpose of internal record keeping and general administration billing, accounting and legal compliance;
- To improve our products and services; analyse how users interact with our services to make our products better and understand how to market them;
- For training our employees in respect of providing our service and products to you;
- For our general marketing purposes, if you have consented to receive information about us and our services, products and offers, where required by law;
Who do we share your personal data with?
To accomplish the purposes set forth above, we may share your Personal Information with other parties, which may include the following:
- Cosmos office or space admins that run their teams or sessions on Cosmos Platform that the individuals choose to join
- Service providers and vendors that perform services on our behalf and under our direction or otherwise retained in connection with the Services, including analytics and cloud computing providers;
- Other third parties if we believe doing so is required or appropriate to:
- Protect or defend the interests, legal rights or property of Cosmos Video or any individual;
- Protect the rights, interests and safety and security of the Services, our organisation, or members of the public;
- Respond to your requests;
- Detect or protect against any suspected fraud; Comply with applicable laws or regulations; Cooperate with governmental or law enforcement investigations and legal processes, such as a court order or subpoena; Investigate and prosecute users who engage in behaviour that is illegal or harmful to others or to others’ property;
- A buyer or other successor or organisation (as well as their advisors or other third parties) in connection with an actual or potential merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding;
We may share your personal data with external third parties (list available via security centre) and with parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and treat it according to the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and by our instructions.
How do we use cookies?
“Cookies” are identifiers we transfer to your browser or device that allow us to recognise your browser or device to help us keep you and Cosmos safe and to tell us how and when your users interact with our Services.
Some of the cookies we use are necessary to keep our Services secure and can’t be turned off. Visit our Cookie Policy for information on the cookies we use.
When will we send you Marketing Communications?
You may receive marketing communications from us if you have opted in to receive such material where required by law. Our marketing communications will always include the option for you to unsubscribe from receiving any further marketing communications; alternatively, you can submit an opt-out by contacting us at privacy@cosmos.video.
If you have previously agreed to us using your information for direct marketing purposes, you may change your mind by writing to us at privacy@cosmos.video.
Security, Storage and Transfer
We are committed to ensuring that your personal data are secure at all times. We have suitable physical, electronic and managerial procedures in place to safeguard and secure the personal data we collect online.
All of our employees and suppliers with access to your personal data and who are associated with the processing of that data are contractually obliged to respect the confidentiality of your personal data.
Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third-party data processor(s) appointed by us. The personal data that we collect from you is located in Ireland, in the European Union. Some personal data related to video recordings and message data is held with third parties located in the United States.
We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Notice, the GDPR. We will ensure that adequate measures are in place, such as the use of EU Commission’s standard contractual clauses (Commission Decision (EU) 2021/914 of 4 June 2021) in accordance with Art. 46 of the GPDR, or any contractual mechanism issued by the UK ICO, and any additional measures may be required according to the jurisdiction we are transferring personal data to or based on your explicit consent. If you wish to receive more information, you can do so by contacting us at privacy@cosmos.video.
Retention of your data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a more extended period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
We will retain the information that we collect about you while you are utilising our services and accessing the application, and unless we are required to keep your data for longer to comply with any legal, regulatory, tax, accounting or reporting requirements, We will delete it in accordance with applicable law and regulations.
In certain circumstances, you have the right to ask us to delete your data sooner (see the section "Your Rights" below). Following receipt of such a request, we will delete all the information we are not required to retain.
Your Choices
We provide you with choices with respect to your personal data. For example, you can choose not to give us the personal data we request, as described in the “Personal Data we collect” section of this Privacy Policy. However, in some cases, if you decide not to provide the information we request, we will not be able to provide the service or information you requested.
Other examples of your choices include:
- You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive transactional and administrative messages from us.
- You can browse the Cosmos website without registering or directly submitting any information to us (although we may still collect some limited information automatically, as described above)
- You may change your browser settings or take other steps to block, manage, or delete cookies. In some cases, blocking or turning off necessary cookies may cause the services not to work as intended, and some features may not be available.
Third-Party Links
Our website, mobile applications, and platform may include links to third-party websites, plug-ins and applications. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. You are advised to please check these policies before submitting any personal data to these websites or using these services.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new data you provide to us.
- Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Object to processing of your data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please get in touch with us at privacy@cosmos.video.
Changes to this Privacy Policy
As Cosmos Video’s business constantly evolves, we reserve the right to change the terms of this Privacy Policy from time to time to reflect changes in our Services, how Cosmos Video operates, and regulatory and other requirements.
Any changes to this Privacy Policy will be reflected on this page with the “effective date”. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Services after we post changes is deemed to be acceptance of those changes.
How to Contact Us
If you have any questions or comments about this Privacy Policy, need to report a problem, or would like to exercise one of your rights under this policy, please get in touch with us at privacy@cosmos.video.
Please include your name, contact information, and the nature of your request so we can respond appropriately and promptly.