Privacy Policy

Effective as of February 01, 2023

This Privacy Policy describes the privacy practices of Cosmonic Corp and our subsidiaries and affiliates ("Cosmonic", "we", "us" or "our") and how we handle your personal information when you visit our website, cosmonic.com (the "Website") and any related sites and their subdomains, pages, applications, services and goods or any other website operated by Cosmonic that links to this Privacy Policy (the "Services"). The purpose of this Privacy Policy is to provide you with a clear explanation of what personal information we collect, when, why and how we collect, use and share your personal information and it explains your statutory rights.

We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal information before you use our Services.

If you are located in the European Economic Area or the United Kingdom, please consult the EEA/UK GDPR supplemental notice below.

Personal information we collect

Information you provide to us

Personal information is data that can be used to contact or identify you, such as your name, email address, phone number, etc.

Personal information you may provide to us through our Services, or otherwise, includes:

• Contact data, such as your first and last name, email address, mailing addresses, and phone number.
• Profile data, such as the username and password that you may set to establish an online account with us, and any other information that you add to or is associated with your account profile.
• Communications data, such as data that we exchange with you, including when you contact us with questions or feedback, through our Services, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Job application data, such as professional credentials and skills, educational and work history, LinkedIn profile page, GitHub ID, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from third party vendors and/or other commercially available sources with the personal information we collected. The third party sources from which we may receive personal information are:

• Public sources, such as social media platforms and other publicly available sources.
• Data providers, such as information services and data licensors that provide demographic and other information.
• Third party vendors, such as service providers providing fraud warnings or enrichment service providers to enhance and personalize your user experience.
• Marketing partners, such as joint marketing partners and event co-sponsors.

If you choose to connect your account on a third-party platform or network, such as GitHub/Facebook/LinkedIn/Twitter/YouTube, to your account through our Services, we may collect data from that platform or network, the data we collect may include your profile name, etc

Automatic data collection

We may automatically collect data about you, your computer or mobile device while you access, browse, view or otherwise interact with our Services, the data we collect may include:

• Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies

We use cookies and similar technologies (such as web beacons, pixels, tags and scripts) to improve and personalize your experience, provide our Services, analyze website performance and for marketing purposes. To learn more about how we use cookies and your control over these cookies, please see our Cookie Policy

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to

• provide, operate and improve the Service and our business;
• personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user profile on the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business

Marketing and advertising

We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes

• Direct marketing. We may send you direct marketing communications about our products, services or promotions that may be of interest to you. Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to legal@cosmonic.com.
• Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services

To manage our recruiting and process job applications

We may use personal information, such as data submitted to us in a job application, to facilitate our recruitment activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment statistics.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• maintain appropriate business records;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How we share your personal information

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

We may share your personal information with third parties as detailed below and as otherwise described in this Privacy Policy.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We share personal information with those third parties who provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).

Payment processors and fraud detection service providers. We share personal information with payment processors and fraud detection service providers for the purposes of facilitating payments done via the Services and securing the Services and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.

Advertising partners. We may share your personal information with third-party advertising companies for the interest-based advertising purposes purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles, and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Government agencies and regulators. We may share personal information with law enforcement agencies, public authorities or other parties: (i) in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; (ii) when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; (iii) to respond to claims against us; and (iv) to protect the rights, property, or personal safety of Cosmonic, our customers or the public.

In the context of a corporate transaction. Personal information may be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Cosmonic's assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If all, or substantially all, of our assets are acquired by a third party, data held by us about our users will be one of the transferred assets.

Other users and the public. Your profile and other user-generated content data (except for messages) may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

You have the following choices with respect to your personal information. Users who are located in the European Economic Area ("EEA") or United Kingdom ("UK") can find additional information about their rights below.

Access or update your information.

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us through the contact details set out in the "How to contact us" section below. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Advertising choices.

You can limit use of your information for interest-based advertising by:

• Browser settings. Blocking third-party cookies in your browser settings.
• Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative: https://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance: https://optout.aboutads.info/
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

You will need to apply these opt-out settings on each device from which you wish to opt-out.

Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked to above.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit, allowing users to opt out of tracking by websites and only services. We do not currently respond to "Do Not Track" signals. We do recognize the Global Privacy Control (GPC) signal where we display a cookie consent banner, which at present is for visitors from the European Economic Area, the United Kingdom and Switzerland: if your browser sends a GPC signal, consent for all non-essential cookies is automatically declined. We do not currently act on GPC signals from visitors elsewhere. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com, or consult our Cookie Policy to understand how you can opt out of receiving cookies

Declining to provide information

We need to collect personal information to provide certain services. If you do not provide that data we identify as required or mandatory, we may not be able to provide those services

Third-party platforms

If you choose to connect to our Services through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party

Other sites and services

Our Services may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into websites or other online services that are not associated with Cosmonic. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of each of the other third party websites, mobile applications and online services you visit.

How long do we keep your personal information

We apply a general rule of keeping personal information only for so long as is required to fulfill the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Security

We implement a number of technical and organizational safeguards designed to maintain the security of our Services in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. However, security risk is inherent in all internet and information technologies and the transmission of personal information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service. Users who have registered for our Services agree to keep their password in strict confidence and not to disclose such password to any third party.

International data transfer

We are headquartered in the United States. Some of the personal information you provide to us will be stored or processed on our behalf by third parties and may be located in other jurisdictions, such as the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in the UK and the EEA should read the important information provided in the EEA/UK supplemental notice below about transfer of personal information outside of the EEA and UK, as applicable.

Children

Our Services are offered and available to users who are at least 13 years of age or older. Minors under 13 are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission. Minors under 13 are not permitted to use the Website or our Services. Cosmonic does not knowingly collect personal information from children under 13. Parents or guardians should at all times supervise their children's activities. If we learn that we have collected or received personal information from a child under 13, we will delete that personal information. If you believe we might have information from or about a child under 13, please contact us at legal@cosmonic.com.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Website. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

How to contact us

To exercise any of your rights in connection with your personal information, please contact us at legal@cosmonic.com.

If you have any questions (or comments) concerning this Privacy Policy, please contact us at legal@cosmonic.com or 4105 18th St N, Arlington, VA 22207.

EEA/UK GDPR Supplemental notice

If you are located in the European Economic Area or the United Kingdom, and access our Services, this EEA/UK GDPR supplemental notice applies to you.

Personal information

References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by the applicable European data protection legislation.

Who is the Controller?

Cosmonic Corp., 4105 18th St N, Arlington, VA 22207, United States of America, is the controller of your personal information.

UK and EU Representative

1. Cosmonic has appointed Prighter Ltd as its UK representative, which can be contacted at 20 Mortlake Mortlake High Street, London, SW14 8JN, UNITED KINGDOM.
2. Cosmonic has appointed Maetzler Rechtsanwalts GmbH & Co KG as its EU representative, which can be contacted at Schellinggasse 3/10, 1010 Vienna, AUSTRIA.

Our legal basis for using your personal information

Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing as set out in the table below.

Your rights

Under applicable EU and UK data protection laws, you have the following rights in respect of your personal information:

• to obtain information about how and on what basis your personal information is processed and to obtain a copy;
• to rectify inaccurate personal information;
• to erase your personal information in limited circumstances where (i) you believe that it is no longer necessary for us to hold your personal information; (ii) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (ii) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (iv) where you believe the personal information we hold about you is being unlawfully processed by us;
• to restrict processing of your personal information where: (i) the accuracy of the personal information is contested; (ii) the processing is unlawful but you object to the erasure of the personal information; (iii) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim; or (iv) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
• to object to decisions which are based solely on automated processing or profiling;
• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us and we may be required to no longer process your personal information. Moreover, if your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.

When you request us to provide the personal information we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal information, however, we invite you to contact us first. Should you wish to lodge a complaint you should contact: (i) your relevant supervisory authority if you are located in the EEA; or (ii) if you are located in the UK, the Information Commissioner's Office. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

Cross-border data transfer

Your personal information may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the EEA, you should be aware that your personal information may be shared with, and transferred to, Cosmonic affiliates and third-party service providers who are located outside the EEA. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

• we will ensure that transfers within Cosmonic and its affiliates will be covered by an agreement entered into by members of Cosmonic (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Cosmonic group;
• where we transfer your personal information outside Cosmonic or to third parties who help provide our Services, we will obtain contractual commitments from them to protect your personal information; and
• where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal information is disclosed.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.