We want Cosmos to be a safe and trustworthy space for discussion about artificial intelligence and we consider your privacy as a fundamental key for establishing such a space. This Privacy Policy is intended to describe our practices regarding the information we may collect from you when you use or access our Services, the ways in which we may use such information, and the choices and rights available to you.

This Privacy Policy supplements and shall be read in conjunction with our Terms of Service, and may be supplemented by additional privacy statements, terms or notices provided to you. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Service.

1. YOUR CONSENT

PLEASE READ THIS PRIVACY POLICY BEFORE ACCESSING AND USING THE SERVICES. BY ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES.

2. WHAT TYPES OF INFORMATION DO YOU COLLECT?

• Non-Personal Information: “Non-Personal Information” is un-identified and non-identifiable information pertaining to a user, which may be made available to us, or collected automatically via your use of the Services which does not enable us to identify the person from whom it was collected. This which is being gathered consists of behavioral information mainly of technical and aggregated non-identifiable usage information, such as system data related to your operating system and browser version, screen size, duration of usage of the Services, etc.
• Personal Information: “Personal Information” is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such an individual with a persistent identifier such as a name, an identification number, a persistent cookie identifier, etc. Personal Information does not include information that has been anonymized or aggregated and can no longer be used to identify a specific natural person. Personal Information that is collected by us consists of the following types of information:
  • Registration Information. We collect login credentials such as full name, username, and email address in connection with your request to register for an account, together with bio, job title, company, profile picture, pronouns, location, and other information you may elect to share within the Services. In addition, we may collect Personal Information associated with your social media accounts on other platforms if you opt to allow us to do so, such as your picture, bio, or email address.
  • Usage Information. Your engagement metrics (whether or not you create an account), the User Generated Content (“UGC” as defined under our Terms and Conditions), and other content made available to you, and/or consumed, viewed, or accessed by you through the Services.
  • Verification Information. When you request to verify your account, we may require you to provide information necessary to verify your identity such as your email address.
  • Content. The content including UGC, may include or imply Personal Information about you. We collect the content you upload through the Services including UGC, plus data about bookmarks, likes, and links you follow in order to share that data with others, through the forums. If the forum is public, we publish your activity. If the forum is access-restricted, or access restrictions apply to the specific post, we make your activity available only to users permitted to see it. We also collect data about private messages that you send through the forums. We make private messages available to senders and their recipients, and also service administrators. When you edit posts, we will keep all versions of your posts.
  • Sign up for mailing lists and announcements. When you fill out and submit a web form to sign up for mailing lists or announcements, we collect the information you put in the form, such as your e-mail address.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of this Privacy Policy.

3. HOW DO YOU COLLECT INFORMATION FROM ME?

• We collect information through your use of the Service. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage, including by using “cookies” and other tracking technologies, as further detailed in Section ‎9 below.
• We collect information which you provide us voluntarily. For example, we collect Personal information that you voluntarily provide when you request to register as a User and provide us with your login credentials on Cosmos.

4. WHY DO YOU COLLECT AND PROCESS MY INFORMATION?

• To provide and to personalize our Services by, among other things, offering you specific content or forums that we think would interest you, and customizing the content and the pages we display.
• To provide, develop and operate our Services and other Vast Data products and services, enhancing our services, and user experience, research and explore Artificial Intelligence related trends and materials, and being able to contact Users to provide them with technical assistance, and support, handling requests and complaints, and collect feedback in connection with the performance of the Website;
• To send you updates, notices, notifications, content, and additional information related to the Services, including activity on the forums, and related offers.
• To create cumulative statistical data and other cumulative information that is non-personal, with which we and/or our business partners might make use to operate and improve our Services and internal research and development of Vast Data products and related services.
• To monitor against, prevent, and handle fraud, illegal behavior on the Services, or other misuse of our Services, including inter-alia detecting, preventing, or otherwise addressing fraud or abuse.
• To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our Affiliates.
• To contact you about legal requests, including DMCA takedown requests.
• To inform you about new products and features that we offer, for marketing purposes including information regarding Vast Data product roadmap.

5. WHAT ARE YOUR LEGAL GROUNDS FOR COLLECTING MY PERSONAL INFORMATION?

• Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes like detecting, preventing or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Service; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfill our obligations under applicable laws, legal process, subpoena or governmental request.
• With your consent: We ask for your agreement to process your information for the specific purposes stated in this Privacy Policy and you have the right to withdraw your consent at any time.

6. WHO DO YOU SHARE MY INFORMATION WITH AND WHY?

We may share information with third parties (or otherwise allow them access to it) only in the following manners and instances:

• Internally – We may share information with our Group, as well as our employees, for the purposes described in this Privacy Policy and in accordance with Section 5 above. In addition, should Vast Data Ltd. or any of its Affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, through prominent notice on our Services.
• Public – When you submit and publish content through our Services, the content may be shared with the general public. Please note that the content, including information concerning your account such as name and profile pictures, is available for viewing by other Users and the general public. Such content and information may also be collected by external sources outside of Company’s control, such as search results on internet search engines.
• Protecting Our Rights and Safety – We may share your information to enforce this Privacy Policy and/or the Terms of Service, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.
• Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section 4 above. These third parties serve in facilitating and enhancing our Services and related services, including such third-party services required to allow synchronous communication services (e.g. Discord), platform analytics (e.g. Discourse), online technical labs (e.g. CloudShare), authentication processing (e.g. Auth0), and data analytics of the functionality and usability of our Services (e.g. Plausible.io). Our third-party services providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof).
• Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

For avoidance of doubt, we will NOT sell (as “sell” is traditionally defined) your personal data. That is, we will not provide your name and email or other personally identifiable information to third parties in exchange for money. We may share anonymized or de-identified information with any other third party, at our sole discretion. However, under California law, certain cases of sharing information, such as for advertising purposes, may be considered a “sale” of personal information. However, to the extent applicable, including if a supervisory authority determines that our practices include the selling and/or sharing of your personal information (as such terms are defined under applicable US State Privacy Laws including the CCPA), and you would like to opt out of the “sale” or “sharing” of your personal information, please contact us at cosmos-support@vastdata.com.

7. WHERE DO YOU TRANSFER OR STORE MY INFORMATION?

Your information may be transferred to, maintained, processed and stored by us and our authorized Affiliates and service providers in the United States and EU. Please note that the data protection laws in the above jurisdictions may not be as comprehensive as those in your country of residence. Residents of certain countries may be subject to additional protections, as set forth below. GDPR (EEA Users): This section applies only to natural persons residing in the European Union, EFTA States, or the United Kingdom (for the purpose of this section only, "you" or "your'' shall be limited accordingly). It is the Company's policy to comply with the EEA's General Data Protection Regulation (“GDPR”) and the UK GDPR. In accordance with the GDPR, we may transfer your Personal Information from your home country to the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:

• The country to which Personal Information has been transferred, has been determined by the EU Commission. to be a country providing adequate protection to the privacy rights of EU residents.
• Application of Standard Contractual Clauses where appropriate.

8. WHAT ARE MY RIGHTS?

Under certain laws, including the EU or UK General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), individuals have rights regarding their personal data. These rights include – each to the extent applicable to you. You can exercise your rights at any time independently or by contacting us. Those rights may include, but are not limited to, the following:

• Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
• Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can. The setting for a particular forum may also allow you to close your account, on the setting page for your account. Depending on the settings for your particular forum, you may also be able to edit, anonymize, or erase your posts.
• Data deletion. In some circumstances you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
• Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer it to another party.
• Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.

9. DO YOU USE OF COOKIES OR SIMILAR TRACKING TECHNOLOGIES?

We use certain monitoring and tracking technologies, including ones offered by third party service providers. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our users. For example, these technologies enable us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, and (iv) create and monitor analytics.
We may use cookies in connection with our Services. A “Cookie” is a small data file that is downloaded and stored on your computer or mobile device when you visit our Services. We use the following third-party Cookies:

• Discourse for platform analytics.
• Plausible.io for anonymous, aggregate website analytics
• Auth0 for the performance of the authentication process.
• Discord for communication tools.

Learn more about your choices and how to opt-out of tracking technologies:

Please note though that if you do block or restrict tracking technologies on your device, you will still be able to use the Services, but various features and functionality of the Services may be impaired. Certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates. However, due to differences in how web browsers interpret this feature and send those signals, and lack of standardization, we do not change our practices in response to such “Do Not Track” signals. However, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether. In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or you may also opt out of third party tracking technologies by following the instructions provided by each third party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu orwww.aboutads.info/choices. Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

10. HOW DO YOU KEEP MY INFORMATION SECURE?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. We limit access of your information only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us. Despite these measures, Company cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If there are any questions about security, please contact us at cosmos-support@vastdata.com.

11. HOW LONG WILL YOU RETAIN MY INFORMATION?

We will retain your Personal Information for as long as you are a registered User. If you are using the Services without having a registered User account we will retain your information for such period of time as necessary to provide the Services. If you withdraw your consent to our processing your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our Affiliates).

12. HOW DO YOU PROTECT THE PRIVACY OF CHILDREN?

To use our Services, users must be over the age of thirteen (13). Therefore, we do not knowingly collect Personal Information from individuals under the age of thirteen and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of thirteen are not using the Services. If you believe that we might have any information from or about an individual under the age of thirteen, please contact us at cosmos-support@vastdata.com.

13. UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Services (as reflected in the “Last Revised” heading). You are advised to check for updates regularly. By continuing to access and use our Services after any updates become effective, you accept and agree to be bound by the updated Privacy Policy.

14. DIRECT MARKETING

You hereby agree that we may use your contact details provided during registration, for the purpose of informing you regarding our services, and Website which may interest you, and to send to you other marketing material. You may withdraw your consent via sending a written notice to the Company by email to the following address: cosmos-support@vastdata.com or by pressing the “Unsubscribe” button in the mail.

15. GENERAL INFORMATION

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of New York, without respect to its conflict of law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in New York, NY.

16. HOW CAN I CONTACT YOU?

If you wish to exercise any of the aforementioned rights or receive more information, please contact us using the details provided below:
Vast Data Ltd. Email: cosmos-support@vastdata.com
The Company may notify you under these Cosmos Privacy Policy using the e-mail address you provide for your account on the Services.