LAST UPDATED: November 04, 2016
COSMO SYSTEM PRIVACY STATEMENT
Cosmo System Pte Ltd (collectively “Cosmo,” “our,” “we” or “us”) respect your privacy and are committed to maintaining the privacy and confidentiality of the personal information they collect.
Our personal information handling practices are described below, in any applicable privacy supplements, and in notices at the point of data collection.
We urge you to read this Privacy Statement so that you understand our commitment to you and your privacy, and how you can participate in that commitment. If you have any questions, please contact us at email@example.com.
SCOPE and YOUR CONSENT TO OUR USE OF YOUR INFORMATION
This Privacy Statement applies to personal information and other information collected by Cosmo or its service providers from or about: (i) visitors to, or users of, its websites (“Cosmo Websites”); (ii) prospective and current customers using Cosmo hosting and information technology services (the “Services”); (iii) users of any mobile-device applications that it offers (such as its iOS and Android applications); (iv) service providers and business partners; (v) job applicants; and (vi) other third-parties that it interacts with.
If you do not agree to our practices, please do not register, subscribe, create an account, or otherwise interact with our Services, Cosmo Websites, or mobile-device applications.
1.WHAT INFORMATION DOES COSMO SYSTEM COLLECT AND FOR WHAT PURPOSE IS IT USED?
When we refer to “Personal Information”, we mean any information that can identify you. It includes information or an opinion from which you are reasonably identifiable. In some jurisdictions, Personal Information includes information that identifies a legal entity, such as company name. We describe the Personal Information that we collect in more detail below.
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.
WHEN WE COLLECT INFORMATION ABOUT YOU
Information you give us or our service providers. You may provide Personal Information when you: (i) access Cosmo Websites, (ii) request, purchase and use the Services, (iii) use Cosmo mobile-device applications, (iv) communicate with Cosmo via phone calls, chat, email, web forms, social media and other methods of communication, (v) subscribe to Cosmo marketing material, (vi) apply for a job, or (vi) provide services to Cosmo.
Information we collect about you and your device via automated means. Each time you visit a Cosmo Website, use any of our mobile-device applications, view a Cosmo advertisement on a third party-owned website or read a Cosmo marketing email, we may automatically collect information about you via cookies, web beacons and other similar technologies.
Email communication. We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a Cosmo Website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
Mobile. When you download or use our mobile-device applications, or access one of our mobile-optimized Cosmo Websites, we may receive information about your mobile device, including a unique identifier for your device.
Information we receive from other sources. We work closely with third parties (for example, business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, credit reference agencies, fraud protection services, channel partners and resellers) and may receive information about you from them.
Social Media Platforms. We may receive certain information that’s stored or processed by third parties, such as the social media sites Facebook®, Twitter® and LinkedIn® when you interact with us through these social media platforms. Cosmo Websites may include social media features – such as the Facebook “Like” button – and widgets – such as the “share this” button. These features may collect your IP address as well as details of the pages you are visiting on Cosmo Websites. Social media features and widgets are either hosted by a third party or hosted by Cosmo Websites.
Public Forums, Blogs and the Customer Reference Program. Cosmo Websites may feature bulletin boards, blogs or forums. Any Personal Information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Cosmo posts a list of customers and testimonials on Cosmo Websites. These lists and testimonials usually contain Personal Information such as customer names and job titles. Cosmo obtains the consent of each customer prior to posting any information on such a list or posting testimonials.
Co-branding. Some Cosmo Websites or Services may be co-branded and offered in conjunction with another company. If you use such website or Services, both Cosmo and the other company may receive the Personal Information that’s collected via that co-branded website or Service. The company whose privacy statement is displayed on a co-branded website will be responsible for Personal Information collected on such a website.
Third-party vendors. In order to provide the Services and improve Cosmo Websites, Cosmo may engage the services of third-party vendors. In the process of supplying services to Cosmo, these third-party vendors may need to collect Personal Information about you.
THE TYPES OF INFORMATION WE COLLECT
Contact Information includes your name, company name, job title, telephone numbers, fax numbers, postal addresses, email addresses, or other addresses at which you receive communications from or on behalf of Cosmo (“Contact Information”). When you are expressing an interest in obtaining additional information about the Services or signing up to use the Services, Cosmo requires that you provide contact information (“Required Contact Information”).
Transactional Information includes information about the Services you use, and how you interact with us and the Services (for example through email, customer portal, or phone).
Billing Information includes financial qualification and billing information, such as billing name and address, and a credit card number, including card security number and credit card date of expiration.
Optional Information includes your company’s annual revenues, number of employees, industry or similar information that helps us tailor our Services to you. Please note, that Optional Information is information that you do not have to provide unless otherwise agreed between us.
Information Collected by Automated Means includes information that Cosmo collects through commonly used information-gathering tools, such as cookies and web beacons. Such information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and your activities on Cosmo Websites (such as the web pages viewed and the links clicked, number of visits, access time, device ID or other unique identifier, domain name, screen views, language information, device name and model, and operating system type), the URL of the site from which you came and the site to which you are going when you leave Cosmo Websites, your computer operating system, and mobile device operating system (if you are accessing Cosmo Websites using a mobile device).
Information Collected by Automated Means also includes information that we may collect about: your use of certain Service features; the functionality of the Services; when you click on ads; your participation in research initiatives like surveys about our Services.
While Cosmo does not monitor or view the specific data stored by its customers who are using the Services, it is necessary for Cosmo to track various parameters of transferred data (file size, etc.) to support features including, but not limited to, bandwidth monitoring and storage usage. Cosmo treats such information as Non-personal Information and in accordance with its agreements it has in place with its customers.
Sensitive Information: We will not intentionally collect or maintain, and do not want you to provide, any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive information.
HOW WE USE YOUR INFORMATION
Unless otherwise stated herein, we use your information for providing you the Services that you have requested from us, as referred below:
To contact you. We use your Contact Information to get in touch with you. Here are some examples of reasons why we might contact you to: communicate with you about your orders or the Services you use; conduct surveys; send you announcements about the Services; notify you about our upcoming events; administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners;
For marketing purposes. We use your Contact Information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers or to notify you about our upcoming events. To provide you with marketing communications is not essential for the maintenance or existence of the legal relationship we may have with you at a certain point; thus, you may opt-out from receiving such communications as described in section 3 below. Your decision to opt-out from our marketing communications will not affect your ability to continue receiving the Services from us.
To provide the Services to you. We need the Required Contact Information, Transactional Information, and Billing Information to: process orders (including payments) for our Services; provide the Services to you; provide access to secure areas of our websites; create and maintain your account, and control access to it.
To measure interest in Cosmo System Websites and advertisements. We need Information Collected via Automated Means to: measure interest in our websites and advertisements; develop our web pages and marketing plans; customize and improve the content you view when you visit Cosmo Websites; suggest products and services that you may be interested in purchasing; personalize the online ads we present to you based on your prior web visits or ads viewed; and enable us to review develop and continually improve the Services and offers we provide. Collecting this information is not essential for the maintenance or existence of the legal relationship we may have with you at a certain point. If you wish to opt-out of interest-based advertising or other forms of “tracking” please refer to our Cookie Notice.
To enable third parties to provide services to us. We may need to provide your Required Contact Information to third parties so that they may carry out technical, logistical or other functions on our behalf.
Please see more section 2 below. We also engage third-parties to provide us with reports about the usage and browsing patterns of Cosmo Websites. Such third parties track and analyze such information with respect to visitors to Cosmo Websites. Please see our Cookie Notice for additional details.
We may also use your Personal Information in other ways as more particularly described in our terms of service or other agreements between us / your company. Any Personal Information you provide when you sign up for the Services may be used by us as we describe in the applicable terms of service or agreements between us and as described in this Privacy Statement. To assist us with the uses described in this paragraph, the information that we or our service providers have collected from or about you (for example, through Cosmo Websites, mobile-device applications, or Cosmo e-mail communications with you) may be combined with or enhanced by other information about you that we have obtained from you or from other sources, including from our service providers or business partners.
To protect our business. We use information we collect to prevent or detect fraud or abuses of the Cosmo Websites and the Services, and to identify and protect our business from fraudulent transactions.
To manage our everyday business needs, such as to: administer and manage our business; train our employees; help promote compliance with our terms of service or any other agreements between us; allow you to apply for a job; carry out research and development; carry out other purposes that are disclosed to you and to which you consent; or to comply with the law.
Other. If you purchase our Services via one of our online tools, we will use the information that you provide during the online signup process to establish your account. Information you submit through on-line chat, email, and web form is archived and may be tied to information that we collect about your web visits. Your telephone call or a web conference may be recorded for training purposes and we may enter information you provide via telephone, or other means of communication, into our systems and use it for the purposes described in this section.
In an effort to avoid sending unnecessary messages to our customers and to comply with applicable email marketing laws and regulations, we compare our list of prospects and customers to those email lists that we receive from other companies.
2. DISCLOSURE OF PERSONAL INFORMATION
Except for the limited circumstances described in this Privacy Statement or your applicable agreement / terms of service, the Personal Information we gather is for internal use only and we will not authorize the release of this information to anyone outside of Cosmo unless you have consented to such disclosure. When we need to provide your Personal Information to third parties, we will only share it to the extent reasonably necessary. We may also share your Personal Information as required or permitted by law and as described below.
Please note that the parties to whom we send your Personal Information may be located in another country. Some of the countries in which these parties are located may not have the same or substantially similar privacy laws as those applicable to your own jurisdiction. We promise that your Personal Information will only be transferred to the Cosmo Group companies and other third parties as permitted by applicable law in a country where Cosmo operates and as described in this section.
Disclosure to our Service Providers and third-party business partners: We may disclose, to the extent necessary for the provision of services, Personal Information to third party service providers and channel partners. Please be aware that our third party service providers and channel partners may be located in a different country to you, so your Personal Information may be transferred outside of your country.
We require that our third party service providers and channel partners agree to keep confidential all information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third party service providers and channel partners are expected to maintain privacy and security protections that are consistent with Cosmo’s privacy and information security policies.
While we provide these third parties with no more information than is necessary to perform the function for which we engaged them, any information that you provide to these third parties independently is subject to their respective privacy policies and practices.
Disclosure to Others: Should you breach any of our terms and conditions (for example, our terms of service or the Cosmo Website term) or if we are under a duty to disclose or share your Personal Information in order to comply with any legal or compliance obligation, we may disclose your information to a relevant authority. We may need to release the information we collect to third parties when we believe it is appropriate to comply with the law, to enforce our legal rights, to protect the rights, safety or property of our business and others, or to assist with industry efforts to control fraud, spam or other undesirable conduct and as needed to support auditing, compliance, and corporate governance functions.
Additionally, we will provide information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Disclosure when we have your consent: We may also disclose your Personal Information and other information, for any other purpose disclosed by us when you provide the information, as otherwise required or permitted by law, and/or with your consent. Any such purposes may involve the transfer of your Personal Information across country borders.
We may disclose information that does not identify any individual or company (e.g., anonymous, aggregated data) without restriction. For example, we may provide our advertisers or other third parties with reports that contain aggregated and statistical data about our users.
3. HOW YOU CAN MANAGE YOUR PERSONAL INFORMATION
Communication Preferences and Opt-outs. If you wish to stop receiving email marketing communications from us, please click on the “unsubscribe” link at the bottom of the relevant email
marketing communication or by following the instructions detailed in the communication. Please note that this may not unsubscribe you from all other communications. If you wish to opt-out completely then please contact us using the details provided below. Please note that you cannot unsubscribe from service-related messages.
In accordance with industry standards and applicable laws, we reserve the right to retain your Personal Information for a reasonable amount of time so we can ensure that we do not contact you in the future.
Advertising and Tracking Technologies. If you wish to opt-out of interest-based advertising or other forms of “tracking” please refer to our Cookies Notice. Be aware that opting out of interest-based advertising will not prevent advertisements from being displayed to you but they will no longer be tailored to your interests.
Access and Correction.
Deleting your information. If you would like us to delete your Personal Information from our records then please contact us by using the details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law and/or for own legitimate business purposes.
To protect your privacy, we will require you to prove your identity before granting access to, or agreeing to update, correct or delete your Personal Information and we will only implement requests with respect to Personal Information about you (not anyone else).
Choosing not to provide us with certain information. You can choose not to provide certain information when using Cosmo Websites, Services or mobile-device applications, but this may prevent you from being able to take full advantage of the functions available online and it may prevent us from being able to provide you with Services.
4. SECURITY OF YOUR INFORMATION
The measures we take. We are committed to industry best practice when it comes to preventing loss, misuse, alteration, unauthorised access, or unlawful or unnecessary processing of the information we collect as described in section 1 of this Privacy Statement (“Cosmo Collected Information”). For example, we:
Make use of encryption technology as appropriate;
Use appropriate network access control technology to limit access to the systems on which Cosmo Collected Information is stored; and
Monitor for possible vulnerabilities and attacks.
Unfortunately we cannot guarantee that the technical, physical and organisational measures we take will prevent every security threat nor can we guarantee that your Cosmo Collected Information will not be improperly accessed, used, altered or destroyed. We will notify you if we discover there has been a material breach of security, which resulted in an unauthorized disclosure of your Personal Information.
5. DATA INTEGRITY and RIGHT TO ACCESS YOUR PERSONAL INFORMATION
Personal Information we collect is relevant for the purposes for which it is to be used. Cosmo takes reasonable steps to help ensure that data is reliable for its intended use, accurate, complete, and current.
We will retain your information for as long as needed to provide you the Services or as long as needed to fulfil the purpose for which Personal Information was originally collected.
As noted in section 3 above, you have the rights to access, correct and request the deletion of your own Personal Information in accordance with applicable law. You are also entitled to oppose to certain data processing practices or to revoke consent previously granted, to the extent permitted by the law. In order to exercise such rights please log in to the applicable Cosmo control panel to submit a customer support ticket or contact us to the contact data set forth below. When we receive such request, we may inform you of: (i) the information that you or your legal representative will be asked to provide (if any) and documents that you may need to enclose with your request; (ii) timeframes to receive a response from us regarding any request; (iii) forms and templates available for submitting the request (if any) and; (iv) how we will deliver the information to you (which usually would be copies of documents or data messages). Please note that some requests may be subject to a reasonable fee.
If you wish to cancel your account or request that we no longer provide you the Services, please log in to the applicable Cosmo control panel to submit a ticket. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you do not have an account with Cosmo, you can send a request by email to firstname.lastname@example.org or write to us at the address listed in section 10 of this Privacy Statement.
Our websites and the Services are not designed for or directed at individuals under the age of thirteen (13) or minors otherwise defined in local law or regulation. We will not intentionally collect or maintain information about these individuals. If you believe that we may have collected Personal Information from someone under the age of 13 or from a minor as may be otherwise defined in your country, please let us know using the methods described in the “Inquiries and Complaints” section of this Privacy Statement. We will then take appropriate measures to investigate and, if appropriate, delete that information.
Cosmo utilizes the self-assessment approach to assure its compliance with its Privacy Statement. Cosmo regularly verifies that the Privacy Statement is accurate, comprehensive, prominently displayed, completely implemented and conducts its self-assessment on an annual basis to ensure that all relevant privacy practices are being followed.
8. CUSTOMER DATA – PERSONAL INFORMATION OF OUR CUSTOMERS’ CLIENTS
If you believe you have provided data to somebody who hosts your Personal Information with us, then this section applies to you!
Our customers use the Service to host, transmit or process data on our hosted systems, which may include your Personal Information (“Customer Data”). In these situations, it is our customers rather than us who decide the reasons for which the Customer Data is collected and otherwise processed.
Cosmo will not review, share, distribute, nor reference any such Customer Data except as provided in the agreement that we have in place with the customer, or as may be required by law. Nothing contained in this Privacy Statement shall be construed to alter specific terms and conditions applicable to the Services. Our customers remain responsible for Personal Information that they collect and process and for compliance with applicable data protection laws.
Our customers are responsible for maintaining the security and confidentiality of their accounts and access to the hosted systems, and encrypting any Personal Information they store on or transmit to/from our hosted system.
For details of how the Customer Data will be used and protected, and details of how to access or correct it, please refer to the privacy statement of the relevant Cosmo customer to which you submitted your Personal Information.
9. PRIVACY PRACTICES OF THIRD PARTIES
This Privacy Statement only addresses the use and disclosure of Personal Information that’s collected via Cosmo Websites, the Services, and our mobile-device applications.
In the course of our interactions with you, we may provide you with links to third-party websites for your convenience and information. The privacy practices of those sites may differ from our own practices and are not controlled by us nor covered by this Privacy Statement. We do not make any representations about third-party websites. We encourage you to review their privacy policies before submitting your personal data.
10. INQUIRIES OR COMPLAINTS
If you have a question or complaint about this Privacy Statement or our information collection practices, please contact us at email@example.com
We will investigate the matter and are committed to resolve any privacy concerns that you may have.
Our business changes constantly and our Privacy Statement may also change from time to time. The “Last Updated” section at the top of this page states when this Privacy Statement was last revised. You should check the Cosmo Websites frequently to see recent changes. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Cosmo Websites. Your continued use of the Cosmo Websites and the Services following these changes means that you accept the revised Privacy Statement.
We encourage you to periodically review this Privacy Statement to stay informed about how we collect, use and share Personal Information. For any enquiry, please contact our Data Protection Officer (DPO) via email, firstname.lastname@example.org
Cosmo System Pte Ltd
7 Temasek Boulevard,
Suntec Tower 1 #08-10