Data Protection Policy

Cosmo Connected collects, uses, and shares various information provided by users of our Products through our website (the “Website”) accessible from the website https://www.cosmoconnected.com/ or our mobile application (the “Application”).

Committed to preserving the confidentiality of your Personal Data and in the interest of transparency, we have developed this document to help you understand the data processing that we undertake with the information you provide to us.

Cosmo Connected is committed to ensuring the highest level of protection and security for your personal data in compliance with applicable European and French regulations.

Thus, this Data Protection Policy aims to describe:

  • The data we collect and the reasons for this collection;
  • How we use this data;
  • Your rights regarding the use of your personal data.

Please note that this Policy illustrates our contractual commitments, particularly the general terms of use of the Website and the Application.

This Data Protection Policy does not apply to third-party mobile applications and websites, whether or not they are partners of our company, to which our Website or Application may redirect you.

For more information on personal data protection, we invite you to visit the CNIL website: https://www.cnil.fr/

I. Data Collected

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: By using our Website or our Application, you may provide us with information that identifies you (“Personal Data”). For example, you provide us with Personal Data when you purchase one of our Products, fill out registration forms for our services, participate in our games, contests, promotional offers, studies, or surveys, or contact us by any means.

This information includes the following data:

  • Your name, first name, address, date and place of birth, gender, phone number, email address;
  • Information about your vehicle;
  • Phone numbers of your relatives provided voluntarily;
  • Banking and financial information, including your credit card number;
  • Location data when you have agreed to allow us to collect and process this data; In this regard, please note that medical data (weight, age, and height) that you may provide through the Application is neither collected nor processed by us and is only stored on the device where the Application is installed;

(ii) Data collected automatically: In the course of using our products and services, we systematically and automatically collect various information. This information mainly falls into the following categories:

  • Data related to the device used during the connection or the methods of consultation and usage of our services: we may collect information about the devices you use to access 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, as well as navigation data;
  • Local storage: we may collect and store data, including Personal Data, on the device you use. In any case, we collect and process only the data strictly necessary to achieve the purpose for which they were collected.

Finally, when we request information from you, we inform you whether providing this information is optional or mandatory and the consequences of not providing a response. Thus, only the completion of data fields identified with an asterisk is mandatory for us to offer you a service, such as placing an order.

Children

Our Website, Products, and Application are not intended for children under 16 years old, and we ask minors not to provide Personal Data to Cosmo Connected. If we discover that we have collected Personal Data from a minor under 16 years old, we will take all necessary measures to delete this information as soon as possible.

The data controller is Cosmo Connected – 5 rue Saint Joseph, 75002 Paris - France - support@cosmoconnected.com.

II. Data Retention Period

To comply with legal obligations or for evidentiary purposes, certain personal data may be retained in accordance with applicable statutory limitation periods, for example:

  • Data concerning your use of Cosmo Connected services is kept in the active database as long as you are active and for up to three years after the last time you used Cosmo Connected services. Cosmo Connected may contact you to find out if you wish to keep your account 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 being recorded associated with your user ID as it will no longer be necessary for the service of consulting your trip history. This geolocation data may be retained by Cosmo Connected beyond this period only after being anonymized, meaning there will be no risk of re-identification.
  • Data regarding your orders on the Cosmo Connected e-commerce site, including your profiles and preferences, are retained in the active database for commercial prospecting purposes for three years after the expiration of the legal or contractual warranty of your last purchase. Data concerning you as a non-client prospect are kept for three years from the last contact from you. Cosmo Connected may contact you to see if you wish to continue receiving commercial solicitations. If you do not respond positively and explicitly, your data will be deleted.
  • After your data is deleted from our active databases within the mentioned periods, certain relevant data may be placed in a secure archive for a duration strictly necessary to comply with legal prescriptions or to allow Cosmo Connected to protect its interests legally or judicially.

III. Use of Collected Data

The collected data is used to:

1. Provide you with the services you requested; for example, if you wish, we can collect the names, emails, and phone numbers of your 3 emergency contacts who will be notified by SMS and email in case of an incident;

2. Send you information about our services by any means of communication, such as important security warnings or significant changes to this Data Protection Policy, and provide you with quality customer support;

3. Collect your payments; when you place an order, we do not display or store your payment card information. The only information provided is used to process your order, fulfill the contract, and prevent any fraud attempts against you and us;

4. Personalize our services, correct and improve them to offer you the best possible service; thus, your purchase history can help us better inform you when you visit our Website;

5. Geolocation functions: we collect location data if you allow us and exclusively to provide you with location-based services that you request (Assistance Service Alert, the free accident detection and trip-sharing feature). To access these services, the User must have started a trip in the Application and accepted the use of their device's location. You can always withdraw this access for free using your mobile phone settings. If geolocation is disabled, the Application's services related to accident detection and Emergency Assistance Alert will be inaccessible. During the use of the Application, we may also collect geolocation data about you. In particular, we collect your geolocation data in the background during real-time GPS navigation on a route or activity detection. This data is only collected with your express consent when you download the Application. You can withdraw your consent at any time by writing to dpo@cosmoconnected.com.

Your trip history is only kept to improve the quality of our Services. You can request the deletion of your Data at any time.

6. Allow you to create an account that may give you access to certain services requiring prior registration, for example, when you create an Account, we ask for your email address and name to ensure the security of your Account;

7. Allow you to log in to your Account using credentials used on a social network; if you choose to do so, during your first login, you will be asked to agree to the social network provider providing certain information to Cosmo Connected, including your name, email address, profile photo, posts, comments, and other information associated with your social network account. All this information will be transmitted to Cosmo Connected by the social network provider due to the way social network login works. However, we only keep and process your email address. If you do not wish this, you can simply log in to your Account using your login information without using the credentials associated with your social network account;

8. Provide you with product and customer support and monitor the quality and nature of this service; when you communicate with a customer support advisor by email or phone, we collect Personal Data such as your name, postal address, phone number, email address, and contact preferences, as well as information about the Products you own, such as their serial number and purchase date. We may also create event logs to diagnose product or application performance issues and gather information about a support or service issue. In compliance with applicable law, we may also record and listen to your conversations with our customer support advisors and analyze any feedback provided voluntarily through a customer survey, all to improve our customer service. With your consent – which you can withdraw at any time – customer support advisors may access your Account if needed to resolve issues.

    IV. Disclosure of Collected Data

    To provide you with the best service, we may share information about you, including your Personal Data, with third-party companies that process it on our behalf, following our instructions and in compliance with applicable law and this Policy. Your Data will only be shared with partners who provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures to ensure the protection of your rights and Data.

    More specifically, when using our Application, we may share your location data and certain Personal Data with emergency services.

    We may also share certain data, including your Personal Data, in response to a legal obligation or if we believe in good faith that it is necessary to (i) respond to any claim against Cosmo Connected, (ii) comply with any enforceable legal request, (iii) enforce any contract concluded with our users, (iv) in case of an emergency involving public health or the physical integrity of a person, (v) in the context of investigations and inquiries, or (vi) to ensure the rights, property, and safety of Cosmo Connected, its users, and more generally any third party.

    More generally, we may communicate to third parties all the information you have authorized us to share.

    We also reserve the right to disclose all or part of the collected Data as part of a transfer of ownership or restructuring of our company or its assets, provided that the entity to which we transfer the Personal Data processes your Personal Data only in accordance with this Data Protection Policy and applicable law.

    V. Data Location

    We store your Personal Data on our secure servers located within the European Union. However, it is possible that in the course of using the Services, the data we collect when you use our services may be transferred to other countries, particularly when using the Application outside your home country.

    In such cases, we 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 if necessary, to ensure an adequate level of protection.

    VI. Data Security

    We implement appropriate and industry-standard security measures to protect your data from unauthorized access, alteration, disclosure, or destruction.

    VII. Your Rights

    Cosmo Connected has implemented appropriate Personal Data protection measures to ensure that they are used in accordance with the above purposes and to ensure their accuracy and update as well as the exercise of your rights.

    • Right of access: You have the right to access the Personal Data we hold through your account (accessible via the Website or the Application).
    • Right to rectification: You have the right to request the immediate rectification and update of your Data.
    • Right to erasure (“right to be forgotten”): Unless otherwise required by law, we will delete your Data to comply with our legal obligations, particularly when your Data is no longer necessary or when you request it.
    • Right to restrict processing: You also have the right to restrict the processing of your Personal Data if you believe that your Data is not accurate or if you object to its use.
    • Right to data portability: You can request a copy, in a structured, commonly used, and machine-readable format, of the Data you have provided to us, provided that their processing is carried out using automated means. Where technically possible, you can request that these Data be directly transmitted to another data controller.
    • Right to object: In certain circumstances and for reasons related to your particular situation, you can object to the processing of your Personal Data. If your request is compliant with applicable law, we will no longer process your Data unless we demonstrate the legitimacy and imperative nature of the processing, which overrides your rights, interests, and freedoms. We may also process your Data if necessary to establish, exercise, or defend legal claims.

    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 access.

    Please note that we may retain certain information when required by law or when we have a legitimate reason to do so notwithstanding your request to delete it.

    • Right to lodge a complaint with a supervisory authority: If you believe that Cosmo Connected has not respected your rights, you can lodge a complaint with the National Commission for Computing and Liberties (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 whose personal data has been communicated of any rectification or deletion of personal data or any restriction of processing unless such communication proves impossible or involves disproportionate effort.

    VIII. Cookies and Similar Technologies

    “Cookies” are data stored on an internet user's terminal and can be used by the Website to send information to the User or Member's browser, allowing the browser to send information back to the original website (e.g., session identifier, language choice, or date, etc.). “Cookies” also allow for the retention of state information when a browser accesses different pages of a website or when the browser later returns to the website, thus optimizing navigation.

    Cosmo Connected provides you with a preference center that allows you to:

    • Learn about the nature of cookies placed and read when you visit the site;
    • Set their use either globally for the entire site and purposes, or purpose by purpose.

    Please note that if you refuse certain types of cookies, your browsing experience and the services we can offer you may be affected.

    When browsing the Website, you may encounter different types of “cookies”:

    Publisher’s “cookies”

    Publisher’s “cookies” mainly aim to:

    • Store variable and personalized data on a visitor to the Website;
    • Retain various inputs made to optimize the services that will interest the User or Member and facilitate the input of various forms.

    Third-party “cookies”

    • Tracker cookies;
    • Audience cookies;
    • Technical and functional cookies. Third-party “cookies” mainly aim to:
    • Distinguish Users, sessions, and new visits;
    • Establish anonymous traffic and navigation analysis statistics;
    • Record the traffic source or a campaign;
    • Retain the login and password to facilitate the connection of a Member already registered;
    • Personalize potential commercial offers;
    • Secure a User/Member's connection to the Website, retain their usage preferences, and optimize navigation;
    • Collect display settings of a site to facilitate navigation.

    This list is not exhaustive and may evolve with the Website.

    Find the list of cookies on the dedicated page.

    The User can refuse the implantation of “cookies” on their computer terminal by configuring their browser according to the procedure indicated on it.

    In such cases, the use of the Website and access to Services may be affected.

    IX. Modification of the Data Collection and Processing Policy

    We may occasionally modify this Data Protection Policy. In case of substantial changes, we will inform you and/or seek your consent as soon as possible using reasonable means. We advise you to regularly consult our current Policy to be aware of any changes or updates.

    X. Contact and Data Controller

    For any request or question regarding this Policy and how we use your Personal Data, we invite you to contact Cosmo Connected’s data protection officer directly at the following address: dpo@cosmoconnected.com.

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

    COSMO CONNECTED

    Data Protection Officer Attention: Data Processing Manager 5 rue Saint Joseph 75002 PARIS - FRANCE