Privacy Policy

Welcome to COSEDE Privacy Policy!
COSEDE cares deeply about the privacy of its users and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our users regarding such information.

We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.

1. Please read carefully!
This COSEDE Privacy Policy ("Privacy Policy") describes how we (COSEDE, "we" or "us") collect and use information pertaining to each of our registered users ("User" ,"You", "App Users in connection with their access to and use of COSEDE's mobile app.

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights. This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.

Read this policy and make sure you fully understand our practices in relation to your Personal Information, before you access or use any of our Services. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately avoid or discontinue the use of our app. If you have any questions or concerns regarding this policy, please contact us.

By accessing or using any of our services, you acknowledge that you have read this Privacy Policy.

2. What information do we collect?
We collect Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual or may be of private or sensitive nature ("Personal Information"). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number) and billing details (name, physical billing address, payment method, and transaction details). Only required Users' information is collected for the purpose of connection, identification, and payment.

For the avoidance of doubt, any Non-Personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

3. How do we collect such information?
There are two main methods we use:

  1. We collect information through the use of the app. When a User registers and uses the App, we are aware of it and will usually gather, collect and record such uses, sessions and related information.
  2. We collect information which Users provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our app.

4. Why do we collect such information?
We collect Information for the following purposes:

  1. To provide and operate the app;
  2. To further develop, customize and improve our Services, based on Users' common or personal preferences, experiences and difficulties;
  3. To provide our Users with ongoing customer assistance and technical support;
  4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 7 below);
  5. To enhance our data security and fraud prevention capabilities;
  6. To comply with any applicable laws and regulations.

We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:

  1. Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with our Services, to provide you with our customer assistance and technical support), or
  2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
  3. Our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of marketing campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.

No one under age 18 should provide any Personal Information to us through any of our Services. We do not knowingly collect Personal Information from children under 18. Parents and guardians should supervise their children's activities at all times.

We also collect and use information in order to contact our users, and in order to comply with the laws applicable to us.

5. Where do we store your information?
COSEDE's Users' Personal Information may be maintained, processed and stored by COSEDE and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).

COSEDE's service providers that store or process your Personal Information on COSEDE's behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

Upon request, COSEDEwill provide you with information about whether we hold any of your Personal Information. You may access, correct or update your personal information at all times by yourself.

We will respond to your request via returned email within a timeframe imposed by local laws or a reasonable timeframe. Only once you receive a written confirmation from COSEDEregarding your request, you can regard your data as deleted.

After completing this process, you can no longer use any of your COSEDEServices, your User Account and all its data will be removed permanently, and COSEDEwill not be able to restore your account or retrieve your data in the future. If you contact COSEDEin the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.

COSEDE's data storage providers are contractually committed to protect and secure your data.

Among other things, COSEDEadheres to the EU - US & to the Swiss-US Privacy Shield Principles, for further protecting and enhancing our user's privacy.

Data Localization Obligations: If you reside in a jurisdiction that imposes "data localization" or "data residency" obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.

You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.

6. Sharing personal information with third parties
COSEDEwill not share your Personal Information with third parties (or otherwise allow them access to it) except for and only in the following manners and instances:

6.1 Law Enforcement, Legal Requests, and Duties:
Where permitted by local data protection laws, COSEDEmay disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.

6.2 Service Providers
The following third parties may have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

  1. To facilitate our Service;
  2. To provide the Service on our behalf;
  3. To perform Service-related services; or
  4. To assist us in analyzing how our Service is used.

To clarify, COSEDEmay share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, COSEDEmay transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.

7. Communications from COSEDE

7.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from COSEDEthrough such means.

If you do not wish to receive such promotional messages or calls, you may notify COSEDEat any time or turn off the notifications privileges on your device.

We take steps to limit the promotional content we send you to a reasonable and proportionate level and to send you information which we believe may be of interest or relevance to you, based on your information.

7.2. Service and Billing Messages:
COSEDE may also contact you with important information regarding our Services, or your use thereof.

For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions, or notify you of material changes in our Services.

It is important that you are always able to receive such messages. For this reason, you will not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a COSEDE User (which can only be done by deleting your account - see section 5 in this document).

8. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That's why COSEDE has taken the steps to enable you to access, receive a copy of, update, amend, or limit the use of your Personal Information.

Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes.

You can delete your information only by sending a written request to COSEDE and receiving a written confirmation. Only once you receive a written confirmation from COSEDE regarding your request, you can regard your data as deleted.

After completing this process, you can no longer use any of your COSEDE Services, your User Account and all its data will be removed permanently, and COSEDE will not be able to restore your account or retrieve your data in the future. COSEDE

9. Data Retention
We may retain your Personal Information for as long as your User Account is not permanently deleted, as indicated in this Privacy Policy.

We may continue to retain such Personal Information as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

We maintain a data retention policy which we apply to information in our care. Upon a personal written request will ensure it is securely deleted.

10. Security
COSEDE has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our User's privacy.

Regardless of the measures and efforts that are being taken by COSEDE, we cannot and do not guarantee the absolute protection and security of your Personal Information.

Since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information via any of these methods.

If you have any questions regarding the security of our Services, you are welcome to contact us.

11. Updates and interpretation
We may update this Privacy Policy as required by applicable law, and to reflect changes to our information collection, usage, and storage practices. If we make any changes that we deem as "material" (in our sole good faith discretion), we will notify you prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Unless stated otherwise, our most current Privacy Policy applies to all information that we have about Users, with respect to COSEDE and other Services.

Any heading, caption or section title contained herein, and any explanation is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.