Last Update: Sept 7, 2021
The terms “COSOO”, “we”, “us” and “our” refer to CS Software Solutions Ltd, a company registered in the United Kingdom (company number 11422172) whose registered office is at Kemp House, 160 City Road, London, EC1V 2NX, UK, and UAB “Cards and Payments EU”, a company registered in Lithuania (company number 305756168) whose registered office is at Upės g. 19-1, LT-08128 Vilnius, LITHUANIA. When we ask for your personal information, it is because we are required by applicable laws or regulations to collect such information or it is relevant for our specified purposes.
this web-site/portal features and services provided to you when you visit our website or portal;
when you apply to use any of our services;
your use of software including mobile and desktop applications provided by COSOO;
email, other electronic messages including SMS, telephone, website, portal and other communication between you and us.
What data do we collect?
How do we collect your data?
How will we use your data?
Transfer of your personal data
How do we store and protect your data?
What are your data protection rights?
What are cookies?
What types of cookies do we use?
How to manage your cookies
Privacy policies of other websites
How to contact us
How to contact the appropriate authorities
We the following dаta:
Personal identification information (name, home address, passport details, date of birth, email address, phone number, username, signature). This information helps us to identify you.
Information required by regulatory authorities (e.g. AML/CTF & KYC requirements) (identity documents, personal photo, incorporation documents for legal entities, information about the ultimate beneficiaries, proof of address, utility bills or bank statements, source of fund declaration, purposes of fund documents and source of wealth).
Information related to usage of our Services (web requests, IP address, browser type, language, time zone settings, browser plug-in types and versions, operating system and hardware setting, phone number, information derived from network operator, GPS, base station and WLAN). This information helps our systems to ensure that our Services are accessible for Users across all platforms and can aid during criminal investigations. Your location information (determined through GPS and IP address) helps us to prevent fraud when your location and device type are different from what you would normally use.
Information related to Transactions (account numbers, account balances, Transactions history, transaction activity, distribution history). We collect this information to monitor suspicious trading activity for fraud protection, legal case resolution and other purposes disclosed in this Policy.
Communication information (communication that you send to us or generated through your use of our Services, including all messages, requests or other information you send in the course of your contract with us, all communications and file attachments in connection with your usage of our Services).
We do not seek to collect any information in relation to User’s race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic or biometric data.
You directly provide us with most of the data we collect. We collect data and process data when you:
Register for, log in or visit our Website, Platform, or use any Service of COSOO;
Voluntarily complete any User survey or provide feedback to us via email or other channels;
Use or view our Website or Platform via your browser’s or software’s cookies.
We may also receive your data indirectly from the following sources:
public databases, credit bureaus and ID verification or AML/KYC verification partners and transaction monitoring tools;
third parties that provide services to you or us;
marketing partners and resellers;
advertising partners and analytics providers.
We collect your data so that we can:
provide and maintain our Services. We use the collected information to deliver, maintain and improve our Services and verify our Users’ identities.
protect our Users. We use the collected information to protect our Website, Platform, Users’s Accounts and archives. We use IP addresses and cookies to protect against automated abuse such as spam, phishing and other hacker attacks.
communicate with you. We use your personal information like your phone number or email address to interact with you directly when providing customer service or to keep you informed on logins, transactions, account security and other aspects. All direct communications are properly kept with us or the service provider designated by us, to be reviewed for accuracy, to be kept as evidence, or to be used to perform other statutory or contractual obligations.
marketing and advertising. We may use your personal information for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising.
establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Please do not supply any other person’s personal data to us, unless we prompt you to do so and/or we have agreed in writing prior to receiving the data from you. Any information that we receive that is not identified shall be notified to you and destroyed immediately.
Transfer of your personal data
You understand that we have the right to have all or some of the collected personal information transferred to or stored in other countries or regions than your country of nationality, your country of residence, or the country where the server is, without your specific consent, under the following circumstances:
if it is necessary to protect, process, analyze, reasonably use the personal information;
if it is necessary for the public interest;
if it is necessary to establish, exercise or defend the rights of us, our partners, or other Users;
other circumstances required by law or government orders.
Some of our Services or activities may be outsourced to third parties which will process your personal data (e.g. third party organisations that provide applications/functionality, data processing or IT services to us). We will share your personal data only to the extent necessary for the purposes defined in the relevant agreements. We use standard contract clauses, rely on the European Commission’s adequacy decision about certain countries, and when applicable, conduct data protection impact assessment prior to processing which may potentially result in a high risk to your rights and freedoms. By using our Services you give us your consent to process your personal data in third countries, including outside the EEA or the UK. You have the right to revoke your consent at any time by sending us an email to firstname.lastname@example.org.
We like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on the unsubscribe link in the bottom of the marketing email and submit your request to unsubscribe.
We would like to make sure you are fully aware of all of your data protection rights. Every client is entitled to the following:
The right to access – You have the right to request us for copies of your personal data. We may charge you a reasonable fee for providing this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete within a reasonable limit.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions. However, you should understand that such restriction of the processing may prevent us from providing you with some of our Services.
The right to object to processing – You have the right to object that we process your personal data, under certain conditions. However, you should understand that such restriction of the processing may prevent us from providing you with some of our Services.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. We may charge a reasonable fee for providing this service.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: email@example.com.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our Website or Platform, we may collect information from you automatically through cookies or similar technology
For further information, visit allaboutcookies.org.
Keeping you signed in;
Understanding your habits and preferences when browsing COSOO;
Analyzing our performance and verifying the effectiveness of online advertising.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless you delete it before the expiry date; a session cookie, on the other hand, will expire at the end of your navigation session, when the web browser is closed.
Most browsers are preset to accept cookies. You can adjust your browser setting to prevent cookies or to notify you as soon as cookies are loaded. However, stopping all cookies might mean that you cannot access or use some features of COSOO. Should you have any further questions, or if you wish to exercise any of your rights under the British Data Protection Act 2018 (DPA), the General Data Protection Regulation (GDPR) or the European Union Directive ePrivacy 2009/136/EC (ePR), please contact us at firstname.lastname@example.org.
Email us at: email@example.com
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact your National Data Protection Authority if you are a resident of the EEA, or the Information Commissioner’s Office in the UK. Residents of other jurisdictions may contact their national data protection authority.