Coslay Privacy Policy

Effective April 4, 2020.
We want you to understand how and why Coslay, LLC. (“Coslay,” “we” or “us”) collects, uses, and shares information about you when you use our websites, mobile apps, widgets, and other online products and services (collectively, the "Services") or when you otherwise interact with us or receive a communication from us. This Privacy Policy applies to all of our Platforms, Services, or Applications.

1. Cookies

We use cookies and other similar technologies (e.g. pixels etc.) (“Cookies”) to enhance your experience using the Platform. Cookies are used to collect information, including personal data, from you. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

2. How we use your personal data

We will use the information we collect about you in the following ways: In accordance with, and to perform our contract with you, we will use your information to: notify you about changes to our service; provide you with user support; enforce our terms, conditions and policies; administer the Platform including troubleshooting; personalise the content you receive and provide you with tailored content that will be of interest to you; enable you to share User Content and interact with other users; enable our messenger service to function if you choose to use this function; enable you to participate in the virtual items program; and communicate with you. In order to comply with our legal obligations, we use your data to help us detect abuse, fraud and illegal activity on the Platform; In accordance with our legitimate interests to provide an effective and dynamic Platform, we will use your information to: ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content; ensure content is presented in the most effective manner for you and your device; improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform; carry out data analysis and test the Platform to ensure its stability and security; allow you to participate in interactive features of the Platform; to enable you to socialise on the Platform, for example, by allowing other users to identify you via the "Find other friends" function or through their phone contacts; to ensure that you are old enough to use our Platform (as required by law). With your consent, we will use your information to: provide you with personalised advertising. and provide you with location-based services (where those services are available in your jurisdiction and you choose to share your precise location with us).

Buy CosCreds.

If you buy CosCreds via in-app purchases, please note the provisions of our Virtual Items Policy. Your purchase will be made via your Apple iTunes or Google Play account. We do not collect any financial or billing information from you in relation to such a transaction. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in coins, we keep a record of the purchases you make, the time at which you make those purchases and the amount spent.

3. The types of personal data we use

We collect and use the following information about you:

Your Profile Information.

You give us information when you register on the Platform, including your username, date of birth, email address and/or telephone number, information you disclose in your user profile and your photograph or profile video.

User Content and Behavioural Information.

We process the content you generate on the Platform, including preferences you set (such as choice of language), photographs and videos you upload and comments you make (“User Content”). In order to help build our neural network for costume recoginition and to improve the upload speed of User Content before clicking Submit" to confirm the upload, we will provide a preload service to upload audio files, video files, and photos in advance. These files may remain on our servers even in the event the initial upload attempt fails or is cancelled. We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, videos you watch and problems encountered, the content you like, the content you save to ‘My Favorites’ and the users you follow. We also infer your preferences, including your interests, gender and age for the purpose of personalising content. We process information about your followers, the likes you receive and responses to content you upload, for the purposes of promoting your content to other users and exploring whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.

Information from Third Parties.

You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:
Business Partners If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with your social network such as your app ID, access token and the referring URL. For further information on sharing your Facebook contact list with us, please see Find other users and invite your friends.
Advertisers and Advertising Networks We use the information collected from you, and your interaction with the Platform and other third party sites, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our App and from similar information received from third parties who advertise on our Platform and whose sites you visit.

Technical Information we collect about you

We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes your IP address, browsing history (i.e. the content you have viewed on the Platform), mobile carrier, time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location.

We use the 'Region' you select in Settings to customise your Coslay experience. When you use the Platform on a mobile device, we will collect information about your location. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location information. If you do not wish to share your precise location with us, you can switch off location services via the settings on your mobile device.

Find other users and invite your friends.

You can choose whether to find other users of the Platform using our 'Find Friends' function. This functionality allows you to see which of your friends from either your telephone's contact list or Facebook friends list is using the Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Platform. We will use the contact information you have for that person, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third party message (such as Whatsapp, Facebook (including Facebook Messenger) or Twitter) inviting them to view your Coslay

4. How we share your personal data

We share your data with the following selected third parties:


Business Partners If you choose to register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Payment Providers If you choose to Buy Coins, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account with the correct value in coins once you have made the payment.

Service Providers We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Analytics providers We use analytics providers to help us in the optimisation and improvement of the Platform. Our third party analytics providers also help us serve targeted adverts (if you have chosen to receive personalized advertising from us and/ or our partners). For more information about how our analytics providers collect data from the Platform, please see our Cookies Policy.

Advertisers and Advertising Networks We share information with advertisers and third party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.

Our Corporate Group We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or based on our legitimate business interests if such use is reasonably necessary to: comply with legal obligation, process or request; enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Public Profiles Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings to 'Private Account' in 'Manage my account' settings.

Sale or Merger We will also disclose your information to third parties:
in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Your Rights

You may submit a request to access or delete the information we have collected about you by sending your request to us at the email or physical address provided in the Contact section at the bottom of this policy. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have.

6. Children

Children under the age of 13 are not allowed to create an account or otherwise use the Services. Additionally, if you are in the EEA, you must be over the age required by the laws of your country to create an account or otherwise use the Services, or we need to have obtained verifiable consent from your parent or legal guardian.

7. Additional Information for EEA Users

Users in the European Economic Area have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. These rights can be exercised using the information provided under “Your Choices” above or using the contact information provided at the end of this document. EEA users also have the right to lodge a complaint with their local supervisory authority.
As required by applicable law, we collect and process information about individuals in the EEA only where we have legal bases for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:

You have consented for us to do so for a specific purpose;
We need to process the information to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; It satisfies a legitimate interest (which is not overridden by your data protection interests), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, and marketing and promoting the Services; We need to process your information to comply with our legal obligations.

8. Children

Children under the age of 13 are not allowed to create an account or otherwise use the Services. Additionally, if you are in the EEA, you must be over the age required by the laws of your country to create an account or otherwise use the Services, or we need to have obtained verifiable consent from your parent or legal guardian.

9. Changes to This Policy

We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date at the top of the policy. If we make a change to this policy that, in our sole discretion, is material, we will provide you with additional notice (such as adding a statement to r/announcements, the front page of the Services or sending you a notification). We encourage you to review the Privacy Policy whenever you access or use our Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. By continuing to use our Services after Privacy Policy changes go into effect, you agree to be bound by the revised policy.

10. Contact Us

If you have any questions about this Privacy Policy, please contact us at info@coslay.co.