COSMULA

PRIVACY POLICY

LAST UPDATED: NOVEMBER 19, 2019

We are delighted that you have shown interest in the services and products of Cosmula, an online platform which allows users to create their personal profile, buy diet plans and fitness related eBooks, operated by BUB Business Ltd. based in Bulgaria, Sofia 1000, 99 G.S (hereinafter referred to as “Cosmula” or “We” or “Us” etc.), such services are provided via https://cosmula.com (the “Website”). Data protection is a particularly high priority for the management of Cosmula. The use of the Website is possible without any indication of personal data; however, if a data subject wants to use Services via our Website, processing of personal data may become necessary. If the processing of personal data is necessary, and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or phone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and in accordance with the country-specific data protection regulations applicable to Cosmula. Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed through this data protection declaration, of the rights to which they are entitled.

As the controller, Cosmula has implemented numerous technical and organisational measures to ensure the complete protection of personal data processed through the Website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.

Definitions

The data protection declaration of Cosmula is based on the terms used for the adoption of General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and country-specific data protection regulations applicable to Cosmula. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, among other things, the following terms:

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the controller or the specific criteria for its nomination may be provided for by law.

Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and Address of the controller

Controller related to data is Bun Business Ltd. based in Bulgaria, Sofia 1000, 99 G.S

Name and Address of the Data Protection Officer:

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection:

Email: [email protected]

Cookies

The Website use cookies. Cookies are text files that are stored in a computer system via an Internet browser or directly in a mobile device.

Through the use of cookies, Cosmula can provide the users of the Website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our Website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our Website users. The purpose of this recognition is to make it easier for users to utilise our Website. The Website user that uses cookies, e.g. does not have to enter access data each time the Website is accessed, because this is taken over by the Website, and the cookie is thus stored on the user’s computer system or mobile device. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

Collection of general data and information

The Website collects a series of general data and information when a data subject or automated system calls up the Website. This general data and information are stored in the server log files. Collected may be (1) the device types and versions used, (2) the operating system used by the accessing system, (3) the location of the accessing system, (4) the date and time of access to the Website, (5) an Internet protocol address (IP address), (6) the Internet service provider of the accessing system, and (7) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Cosmula does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Website correctly, (2) optimize the content of our Website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and Website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Cosmula analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to achieve an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Contact possibility via the Website

The Website contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by law or regulations to which the controller is subject.

Data protection provisions about the application and use of Facebook

On the Website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the device of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/.  During the course of this technical procedure, Facebook is made aware of what specific section of our Website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our Website by the data subject—and for the entire duration of their stay on our Website—which specific section of our Website was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our Website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our Website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our Website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our Website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject.

Data protection provisions about the application and use of Google Analytics (with anonymisation function)

On the Website, the controller has integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to Website. A web analysis service collects, inter alia, data about the Website from which a person has come (the so-called referrer), which sections were visited, or how often and for what duration a section was viewed. Web analytics are mainly used for the optimisation of a Website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of the Google Analytics component is to analyse the traffic on our Website. Google uses the collected data and information, among other things, to evaluate the use of our Website and to provide online reports, which show the activities on our Platforms, and to provide other services concerning the use of our Website for us.

Data Protection Provisions about the use of other third-party service providers

The Controller may allow other third-party service providers to collect data of Data Subjects which may include but are not limited to the Facebook Pixel, Google ads pixel, PayPal, Native ads pixel, Google analytics pixel, CRM, email marketing, WordPress, payment clearing company, etc. The sole purpose of allowing such third-party providers to integrate into the Website is to provide efficient and reliable services and/or to monetize the services.

Protection for Children

The use of the Website is intended for and directed to adults. Website Services are not directed to minors and Cosmula does not knowingly collect personal information from minors. If at any time in the future we plan to collect personal data from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the Children's Online Privacy Protection Act ("COPPA") and appropriate consent from the child's parent or guardian will be sought where required by COPPA. When we become aware that personal data from a child under 13 has been collected without such child's parent or guardian's consent, we will use all reasonable efforts to delete such information from our database.

Changes to this Privacy Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personal data in a way that materially differs from this Privacy Policy, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the Service and our services following the posting of any changes to this Privacy Policy means you accept such changes.

Contact:

Please contact us with any questions or comments about this Privacy Policy by email at: [email protected]