PRIVACY POLICY AND COOKIES

Last update: January 2019

This Privacy Policy describes how Cosmo Connected collects, uses and processes information the users (“you” or the “User”) of our products provide to us through our website (the “Website”) which can be accessed from the address: website https://www.cosmoconnected.com or our mobile application (“Application”).

As part of our efforts to protect the confidentiality of your Personal Data and operating on the principle of transparency we have drawn up this document so that you can learn about and understand the ways we process the data that you communicate to us.

Cosmo Connected is committed to ensure the highest level of protection and security of your Personal Data complying with applicable European and UK regulations.

The purposes of the Privacy Policy that is formally set out herein are to describe:

  • the data that we collect and the reasons for this collection;
  • the way we use this data;
  • your rights concerning the use of your Personal Data.

You will note that this policy illustrates our contractual commitments, including the General Terms of Use of the Website and the Application.

This Privacy Policy does not apply to mobile applications and websites belonging to third parties, whether or not they are partners of our company, to which our Website or our Application may redirect you.

For any additional information on the protection of your Personal Data, we invite you to consult the ICO’s website: https://ico.org.uk/

 

  1. Data collected

In order to provide better services to all users of our products, we may collect and process various pieces of data collected by the following means:

  1. data collected directly from the user: While using our Website or our Application, you provide us with information that can be used to identify you (“Personal Data”). For example, you provide us with Personal Data when you buy one of our products, when you fill in forms in order to register for our services, when you participate in one of our games, competitions, promotional offers, studies or surveys, or when you contact us by any means whatsoever.

This information includes the following data:

      • your surname, first name, address, date and place of birth, sex, telephone number, email address;
      • details of your vehicle;
      • telephone numbers of your close family members which are communicated voluntarily;
      • banking and financial information, including your credit card number;
      • data concerning your location where you have agreed that we can collect and process this data;

In this regard, you will note that medical data (weight, age and size ) that may be provided by you through the Application is not collected or processed by us and is merely stored on the device on which the Application is installed;

  1. data which is collected automatically: When our products and services are used, we collect various pieces of information on a systematic and automated basis. This information mainly falls under the following categories:
  • data concerning the device that is used at the time of connection or the ways in which our services are consulted and used: we may collect information concerning the devices on which you use our services or the networks from which you access them, such as your IP addresses, connection data, the types and versions of Internet browsers that are used, the types and versions of your browser’s plug-ins, operating systems and platforms, or data concerning your clickstream;
  • local storage: we may collect and store data including Personal Data on the device that you use.

Under all circumstances, we only collect and process data which is strictly necessary for the purpose for which it was collected.

Finally, when we request information from you, we will tell you whether providing this information is optional or compulsory, and we will inform you of the consequences of not providing it. Thus, only the filling of data ranges identified by an asterisk is mandatory to allow us to offer a service, such as placing an order for example.

Children

Our Website, Products and Application are not designed for children under the age of 16, and we ask the affected minors not to disclose Personal Data to Cosmo Connected. If we find that we have collected the Personal Data of a minor under the age of 16, we will take all necessary steps to delete this information as soon as possible.

 

  1. Period for which collected data is stored

As a rule, collected data is stored for up to five (5) years following the last occasion on which our products, the Website or our Application were used.

This retention period can be reduced if you close your account or if you request the erasure of your Personal Data.

However, the period for which some data is stored may exceed the aforementioned period of five (5) years so that we can comply with our accounting and tax obligations and, more generally, our legal obligations. In particular, this includes all transactions and associated financial data.

 

  1. Use of collected data

Collected Data is used:

  1. to provide you with services that you have requested; for example, we can collect, if you want to, the names, email and phone numbers of your 3 emergency contacts that will be notified by SMS and email in case of an incident;
  2. to send you information about our services by any means of communication, such as important security warnings or potentially significant changes to this Privacy Policy and provide you with a quality customer support service;
  3. to collect your payments; when you place an order, we do not display or store your credit card information. The information provided is only used to process your order, comply with the contract and avoid any attempt of fraud against you or us;
  4. to enable you to personalize our services; correct and improve them to always offer you the best service; your purchase history will then help us to better inform you when you visit our Website;
  5. for geolocation functions; we collect your location data only if you authorize us to and for the sole purpose of providing you with the Position Based Services that you request (Assistance Service, the free accident detection and trip-sharing feature). Thus, to access these Services, the User must have launched an itinerary in the Application and accepted the use of the position of his device. You always have the opportunity to remove this access at no cost using the parameters of your mobile phone. In case of the geolocation is disabled, the Application Services linked to the detection of accidents and the Assistance Service will be unavailable.

The history of your trips is only kept for the purpose of improving the quality of our Services. You may at any time request the suppression of your Personal Data.

  1. to enable you to create an Account giving you access to certain services which require pre-registration for example, when you create an Account, we ask for your e-mail address and your name to ensure the security of your Account;
  2. to allow you to log in to your Account with the username you use on a social network; if you choose to do so, when you first log in you will be prompted to give to your social network provider the permission to provide certain information to Cosmo Connected, including your name, email address, profile picture, your posts, comments and other information associated with your account on this social network. All this information will be transferred to Cosmo Connected by the social network as the connection works through a social network. However, we only store and process your email address. If you do not want to do it, you can simply login to your Account using your login information without using the username associated to your social network account;
  3. to provide you with product and customer support and to monitor the quality and nature of this service; when contacting our Customer Support Advisor via email or by phone, we collect Personal Data such as your name, mailing address, phone number, email address and contact preferences, as well as information about the Products you own, such as their serial number and the date of purchase. We can also create event logs that can be used to diagnose performance issues for a Product or Application, and to collect information about an issue related to support or service. In compliance with the applicable law, we can also record and listen to your conversations with our customer support service advisors, as well as analyze any comments provided voluntarily through a customer’s survey, all this for the purposes of improving our customer service. With your agreement -which you can retract at any time- our customer support advisors can log in to your Account if problem resolution requires it.

 

  1. Communication of collected data

In order to bring you the best service we may share information which relates to you, including your Personal Data, with third-party companies which process it on our behalf, in accordance with our instructions, current legislation and this policy. Your Personal Data will only be shared with partners who provide enough safeguards for the implementation of appropriate technical and organizational measures to ensure the protection of your rights and your Personal Data.

More specifically, when our Application is used, we may share data concerning your location and some Personal Data with the emergency services.

We may also share some data, including your Personal Data, if we are legally required to do so or if we believe in good faith that this is necessary (i) to respond to any complaints made against Cosmo Connected, (ii) to comply with any enforceable judicial requests, (iii) to enforce any contract entered into with our users, (iv) in the event of an emergency which endangers public health or a person’s physical integrity, (v) for the purposes of inquiries and investigations, or (vi) to guarantee the rights, property and safety of Cosmo Connected, its users and more generally any third parties.

More generally, we may communicate to third parties all information that you have authorized us to communicate to them

We also reserve the right to share all or part of the Personal Data collected in the course of the transfer of ownership or the restructuring of our business or its assets under the condition that the entity to which we transfer the Personal Data processes it in accordance with this Privacy Policy and the applicable law.

  1. Location of data 

We keep your Personal Data in our secured servers located within the European Union. However, it is possible that, as part of the use of the Services, the data that we collect when you use our Services will be transferred to other countries, especially when using the Application outside your home country.

If this happens, we will ensure that this processing is performed safely and in accordance with this policy and that it is governed by the European Commission’s standard contractual clauses which guarantee an adequate level of protection.

 

  1. Data security 

We take appropriate security measures in accordance with standard practices in order to protect your data from any unauthorized access, alteration, disclosure or destruction.

 

  1. Your Rights

Cosmo Connected has implemented appropriate Personal Data protection mechanisms to ensure that they are used for the purposes described above and to ensure their accuracy and up-to-date and the exercise of your rights.

Right of access: You have the right to obtain the Personal Data that we hold through your account (via the Website or the Application).

Right to rectification: You have the right to request the correction and immediate updating of your Personal Data.

Right to erasure (Right « to be forgotten »): Unless otherwise required by law, we will delete your Personal Data in order to comply with our legal obligations, especially when your Personal Data is no longer needed or when you will demand it.

Right to restriction of processing: You also have the right to limit the processing of your Personal Data if you consider that your Personal Data is inaccurate or that you object to their use.

Right to Data portability: You have the right to request a copy of the Personal Data you have provided to us, in a structured, commonly used and machine-readable format and as soon as the processing is carried out by automated means. When technically possible, you can ask to transmit those data to another controller.

Right to object: In certain circumstances and on grounds relating to your particular situation, you may object to us processing of your Personal Data. When you make this request and it complies with the applicable law, we will no longer process your Personal Data unless we demonstrate the legitimacy and the imperative nature of the processing of your Personal Data which override your interests, rights and freedoms. Likewise, we will be able to process your Data if it is necessary for the establishment, exercise or defence of legal claims.

In order to respond to your request, we may (i) verify your identity and (ii) ask you to provide us with the type of information you wish to obtain.

Please note that we may keep certain pieces of information where we are required to do so by law or where we have a legitimate reason to do so, notwithstanding its deletion by you.

Right to lodge a complaint with a competent supervisory authority: If you think that Cosmo Connected does not comply with this Privacy Policy or that your rights under the applicable law are not properly protected by Cosmo Connected, you have the right to make a claim before a supervisory authority. In any case, we invite you to contact us directly at the following email address: clients@cosmoconnected.com.

Lastly, we will take all the reasonable steps to notify each user to whom the Personal Data have been communicated, of any rectification or erasure of Personal Data or any limitation of the processing performed, unless such communication proves impossible or requires disproportionate efforts.

 

  1. Cookies and similar technologies

"Cookies" are data files stored in the terminal equipment of a User and likely to be used by the Website to send information to the browser of the User or Member, and allowing the browser to return information. to the original site (for example: a session identifier, the choice of a language or a date, etc.). "Cookies" also allow to keep status information when a browser accesses the different pages of a website or when this browser later returns to this website to optimize navigation.

The user is informed that, during his visits to the Website, information related to his browsing is likely to be collected and stored through "cookie" files that can be automatically installed on his terminal equipment.

By browsing the Website you may encounter different types of "cookies":

First-Party cookies.

First-Party cookies have for main purposes:

• the storage of variable and personalized data of a Website user;

• the storage of the various entries made in order to optimize the services that will interest the User or the Member and facilitate the entry of the different forms.

Third-Party cookies.

• tracking cookies;

• analytic cookies;

• technical and functional cookies.

Third-Party cookies have for main purposes:

• to distinguish Users, sessions and new visits;

• to provide statistics on Website traffic and anonymous browsing;

• to record traffic source or a campaign source;

• to memorize the login and password to facilitate the connection of an already registered Member;

• to customize potential commercial offers;

• to ensure the security of the connection of a User / Member on the Website, the memorization of his browsing preferences and to optimize browsing experience;

• the collection of the display parameters of a Website for a better browsing experience.

It is specified that this list is not exhaustive and can evolve at the same time as the Website.

The User may refuse to consent to the installation of “cookies” " on his terminal equipment by configuring his browser following the procedure indicated on the Website.

In this case, use of the Website and access to the Services may be impaired.

 

  1. Changes to the data collection and processing policy

We may amend this confidentiality policy from time to time. In case of substantial modification, we will inform you and/or request your agreement as soon as possible and using reasonable means. We advise you to consult our current policy regularly so that you can be aware of any changes or updates to it.

 

  1. Contact

Any queries or questions related to details of how we use your Personal Data we invite you to contact us at the following address: clients@cosmoconnected.com

You can also contact us by mail at the following address:

 

COSMO CONNECTED

A l’attention du Responsable de traitement des données personnelles

6, rue Saint-Dominique

75007 PARIS - FRANCE