Data protection policy
Cosmo Connected collects, uses and shares various information that users of our Products provide to us through our website (the "Website") accessible from the website https://www.cosmoconnected.com/ or our mobile application (the "Application").
In order to preserve the confidentiality of your Personal Data and in a will of transparency, we have elaborated this document so that you can know and understand the processing that we implement on the data that you provide to us.
Cosmo Connected is committed to ensuring the highest level of protection and security for your personal data in accordance with the applicable European and French regulations.
Thus, the Data Protection Policy, formalised by the present document, aims at describing :
- the data we collect and the reasons for collecting it
- how we use this data;
- your rights regarding the use of your personal data.
You will note that this Policy is an illustration of our contractual obligations, including the terms and conditions of use of the Website and the Application.
For any additional information on the protection of personal data, we invite you to consult the CNIL website: https://www.cnil.fr/
I. Data collected
In order to provide better services to all users of our products, we may collect and process various data collected in the following ways:
(i) data collected directly from the user: When using our Website or our Application, you may be asked to provide us with information that allows us to identify you (the "Personal Data"). For example, you provide us with Personal Data when you purchase one of our Products, when you fill in the registration forms 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 contains the following data
your surname, first name, address, date and place of birth, gender, telephone number, e-mail address;
information about your vehicle;
telephone numbers of your family and friends provided voluntarily;
banking and financial information, including your credit card number
location-related data where you have agreed to us collecting and processing such data;
In this respect, you should note that medical data (weight, age and height) that you may enter through the Application is not collected or processed by us and is only stored on the device on which the Application is installed;
(ii) automatically collected data: In the course of using our products and services, we collect various information on a systematic and automated basis. This information falls mainly into the following categories:
data relating to the device used to connect to or access and use our services: we may collect information relating to the devices on which you use our services or the networks from which you access them, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of browser plugins, operating systems and platforms, or data relating to your browsing habits;
local storage: we may collect and store data including Personal Data on the device you are using.
In any event, we collect and process only the data that is strictly necessary for the purpose for which it was collected.
Finally, when we request information from you, we inform you of the optional or compulsory nature of the information to be provided, and of the consequences of not responding. For example, only the data fields marked with an asterisk are mandatory in order for us to offer you a service, such as placing an order.
Our Site, Products and Application are not intended for children under the age of 16, and we request that such minors do not provide Personal Information to Cosmo Connected. If we become aware that we have collected Personal Information from a minor under the age of 16, we will take all necessary steps to delete that information as soon as possible.
The data controller is Cosmo Connected - 5 rue Saint Joseph, 75002 Paris - France - firstname.lastname@example.org.
II. Duration of the conservation of the collected data
In order to comply with legal obligations or as evidence, some personal data may be kept according to the applicable legal prescription periods, for example
Data concerning your use of Cosmo Connected services is kept in an active database for as long as you are active and then for a maximum of three years after the last time you use Cosmo Connected services. Cosmo Connected may contact you again to see if you want your account to remain active. If you do not respond positively and explicitly, your data will be deleted.
Your geolocation data will be deleted from our databases 18 months after their registration associated with your user ID, as they will no longer be necessary for the consultation of your journey history. These geolocation data can be kept by Cosmo Connected after this period only after having been anonymized, i.e. there will be no more risk of re-identification concerning you.
The data concerning your orders on the Cosmo Connected website, including your profiles and preferences, are kept in an active database for commercial prospecting purposes for three years after the expiry of the legal or contractual guarantee of your last purchase. The data concerning you as a non-customer prospect are kept for a period of three years after the last contact from you. Cosmo Connected may contact you again to find out if you wish to continue receiving commercial solicitations. If you do not respond positively and explicitly, your data will be deleted.
After the deletion of your data from our active databases within the above-mentioned time limits, certain relevant data may be placed in a secure archive for a period of time strictly necessary to comply with legal requirements or to enable Cosmo Connected to defend its interests in a legal or judicial context.
III. Use of the collected data
The collected Data are used to :
provide you with the services you have requested; for example we can collect if you wish the names, email and phone numbers of your 3 emergency contacts who will be notified by sms and email in case of incident;
collect your payments; when you place an order, we do not display or store your payment card information. The only information provided to us is to process your order, fulfil the contract and prevent fraud against you and us;
allow you to personalise our services, correct and improve them so that we can always offer you the best service; for example, your purchase history may allow us to better inform you when you visit our Site;
geolocation features; we collect location data only if you authorise us to do so and only for the purpose of providing you with the location-based Services you request (Service Alert, the free accident detection and journey sharing feature). Thus, to access these Services, the User must have initiated a journey in the Application and agreed to the use of the location of their device. You always have the possibility to withdraw this access free of charge by using the settings of your mobile phone. If geolocation is deactivated, the Application's Accident Detection Services and Emergency Assistance Alert will be inaccessible.
The history of your journeys is only kept for the purpose of improving the quality of our Services. You may request the deletion of your Data at any time.
Allow you to create an account that may give you access to certain services that require registration, for example, when you create an Account we ask for your email address and name to ensure the security of your Account;
Allow you to log in to your Account using the credentials used on a social network; if you choose to do so, when you first log in, you will be asked to give your consent to the social network provider to provide certain information to Cosmo Connected, including your name, email address, profile picture, posts, comments and other information associated with your account on that social network. All this information will be transmitted to Cosmo Connected by the social network provider because of the way the connection via a social network works. However, we only store and process your e-mail address. If you do not wish to do so, you can simply log in to your Account using your login information, without using the credentials associated with your social network account;
Provide you with product and customer support and monitor the quality and nature of that service; when you contact a customer support representative by email or telephone, we collect Personal Information such as your name, postal address, telephone number, email address and contact preferences, as well as information about the Products you own, such as their serial numbers and date of purchase. We may also create event logs that we use to diagnose product or application performance problems and to collect information about a support or service issue. Subject to applicable law, we may also record and listen to your conversations with our customer support representatives and analyse any feedback voluntarily provided via a customer survey, all for the purpose of improving our customer service. With your consent, which you may withdraw at any time, our customer support representatives may log into your Account if required to resolve problems.
IV. Communication of collected data
In order to provide you with the best possible service, we may share information about you, including your Personal Data, with third party companies who process it on our behalf, according to our instructions and in compliance with the applicable legislation and these terms and conditions. Your Data will only be shared with partners who present sufficient guarantees as to the implementation of appropriate technical and organisational measures so as to guarantee the protection of your rights and your Data.
In particular, in the course of using our Application, we may share your location data and certain Personal Data with the emergency services.
We may also share certain data, including your Personal Data, pursuant to a legal obligation to do so or if we believe in good faith that it is necessary to (i) respond to any claim made against Cosmo Connected, (ii) comply with any legally enforceable demand, (iii) enforce any contract entered into with our users, (iv) in the event of an emergency involving public health or the physical integrity of a person, (v) in connection with investigations and enquiries, or (vi) in order to protect the rights, property and safety of Cosmo Connected, its users and more generally any third party.
More generally, we may disclose to third parties all information that you have authorized us to disclose to them.
We also reserve the right to disclose some or all of the Data collected in connection with the transfer of ownership or restructuring of our business or its assets provided that the entity to which we transfer the Personal Data will only process your Personal Data in accordance with this Data Protection Policy and in compliance with applicable law.
V. Location of Data
We store your Personal Data on our secure servers located within the European Union. However, it is possible in the course of using the Services that the data we collect when you use our services may be transferred to other countries, including when you use the Application outside your home country.
In such cases, we will ensure that the processing is carried out securely and in accordance with this Policy and that it is governed by the European Commission's standard contractual clauses, with additional measures as appropriate, which ensure an adequate level of protection.
VI. Data security
We implement appropriate and customary security measures to protect your data from unauthorised access, modification, disclosure or destruction.
VII. Your rights
Cosmo Connected has put in place appropriate Personal Data protection measures to ensure that your Personal Data is used in accordance with the above-mentioned purposes and to ensure that it is accurate and up to date and that you can exercise your rights.
Right of access: You have the right to access the Personal Data we hold through your account (accessible through the Website or via the Application).
Right of rectification: You have the right to request the rectification and immediate update of your Data.
Right to erasure ("right to be forgotten"): Unless otherwise provided by law, we will delete your Data in order to comply with our legal obligations, including when your Data is no longer required or when you request us to do so.
Right to limit processing: You also have a right to limit the processing of your Personal Data if you consider that your Data is not accurate or you object to its use
Right to portability of your Data: You may ask us for a copy, in a structured, commonly used and machine-readable format, of the Data you have provided to us where processing is carried out using automated processes. Where technically possible, you may request that the Data be transferred directly to another controller.
Right to object: In certain circumstances and for reasons relating to your particular situation, you may object to our processing of your Personal Data. Where you make such a request and it is in accordance with applicable law, we will no longer process your Data unless we demonstrate the legitimacy and necessity of the processing of personal data and that the processing overrides your rights, interests and freedoms. We may also process your Data if this 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 be disclosed.
Please note that we may retain certain information where we are required to do so by law or where we have a legitimate reason to do so notwithstanding your deletion of the information.
Right to lodge a complaint with a supervisory authority: If you feel that you have not received your rights from Cosmo Connected, you can lodge a complaint with the Comission Nationale de l'Informatique et des Libertés (CNIL): 3 place de Fontenoy - TSA 80715 - 75334 Paris cedex 07 - tel: 01 53 73 22 22 - website: http://www.cnil.fr.
Finally, we will take all reasonable steps to notify each user to whom personal data has been communicated of any rectification or deletion of personal data or any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts.
VIII. Cookies and similar technologies
Cookies" are data stored in the terminal equipment of an Internet user that may be used by the Website to send information to the User's or Member's browser, enabling that browser to send information back to the originating site (e.g. a session identifier, choice of language or date, etc.). Cookies" also allow to keep status information when a browser accesses different pages of a website or when the browser returns to that website at a later time and thus optimise the navigation.
Cosmo Connected provides you with a preference centre that allows you to :
- inform you about the nature of the cookies deposited and read when you visit the site;
- configure their use either globally for the whole site and the purposes described, or for each purpose.
Please note, however, that if you refuse certain types of cookies, your browsing experience and the services we are able to offer you may be impacted.
When browsing the Website, you may encounter different types of cookies:
The Editor's "cookies
The main purposes of the Publisher's "cookies" are
the storage of variable and personalised data on a visitor to the Website;
the memorization of the various entries made in order to optimize the services that will interest the User or the Member and to facilitate the entry of the various forms.
Third party "cookies
tracking cookies ;
audience cookies ;
technical and operating cookies.
The main purposes of third party cookies are
distinguishing Users, sessions and new visits;
the establishment of statistics for the analysis of traffic and anonymous navigation;
recording the source of traffic or a campaign;
the memorization of the login and password in order to facilitate the connection of a Member already registered;
the personalisation of potential commercial offers;
securing the connection of a User/Member to the Website, memorising his/her user preferences and optimising navigation;
the collection of the display parameters of a site to facilitate navigation.
It is specified that this list is not exhaustive and may change with the Website.
You can find the list of cookies on the dedicated page.
The User may refuse the installation of "cookies" on his computer terminal by configuring his browser following the procedure indicated on the latter.
In this case, the use of the Website and access to the Services may be altered.
IX. Modification of the data collection and processing policy
We may change this Data Protection Policy from time to time. In the event of a substantial change, we will inform you and/or seek your consent as soon as possible and using reasonable means. You are advised to check our current Policy regularly for any changes or updates.
X. Contact and data controller
For any request or question related to this Policy and to the way we use your Personal Data, we invite you to contact the Data Protection Officer of Cosmo Connected directly at the following address: email@example.com.
You can also contact him/her by mail at the following address
Data Protection Officer
For the attention of the Data Controller
5 rue Saint Joseph
75002 PARIS - FRANCE