Política de Privacidad

1. Who We Are

Cosmo is a fintech platform headquartered in the European Union, focused on enabling access to sustainable and green finance for banks, investors, and companies.

• Controller: Cosmo (TransCircular UG)
• Address: Schumannstr. 27 60325 Frankfurt am Main
• Contact email: contact@simplycosmo.com

2. What Data We Collect

We collect the following types of data, depending on your use of our Services:

• Identification Data:Name, email address, position, company name, phone number
• Login and Account Data:Username, password, login history, access logs
• Financial and Business Information:Institution profiles, investment interests, ESG metrics, uploaded documentation
• Technical Data: IP address, device ID, browser type, cookies, usage analytics
• Communications: Messages, support inquiries, comments

3. Legal Basis for Processing

We process your personal data on the following legal bases:

4. How We Use Your Data

We use personal data to:

• Provide and maintain our platform and Services
• Match users with relevant green finance opportunities
• Perform compliance checks (e.g., ESG, KYC/AML)
• Send service updates and newsletters (only with consent)
• Detect fraud and enforce Terms of Service

5. How We Share Your Data

We may share your data with:

• Service Providers: Cloud hosting, email services, analytics tools
• Financial Counterparties: If authorized by you, for green finance matching
• Regulators and Law Enforcement: When legally required
• Third-party Integrations: Only if you activate them (e.g., ESG data providers)

All processors are subject to Data Processing Agreements compliant with Art. 28 GDPR.

6. International Transfers

If your data is transferred outside the European Economic Area (EEA), we ensure it is protected by:

• Adequacy Decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules (BCRs) (where applicable)

You may request a copy of the relevant safeguards by contacting us.

7. Data Retention

We retain your data only for the time necessary for the purposes established in this Policy:

8. Your Rights under GDPR

You have the following rights under GDPR:

• Access – Obtain a copy of your data
• Rectification – Correct inaccurate or incomplete data
• Erasure ("Right to be Forgotten") – Request deletion of data
• Restriction – Limit how your data is processed
• Portability – Receive data in a structured, machine-readable format
• Objection – Object to processing on legitimate interest grounds
• Withdraw Consent – At any time, where applicable

To exercise your rights, contact: contact@simplycosmo.com

You also have the right to lodge a complaint with your local Data Protection Authority (DPA).

9. Cookies and Tracking Technologies

We use cookies to:

• Analyze usage
• Improve platform performance
• Remember user preferences

You can manage cookie preferences through our Cookie Settings Panel. For more details, see our Cookie Policy.

10. Data Security

We implement technical and organizational measures (TOMs) to protect your personal data, including:

• Data encryption (in transit and at rest)
• Multi-factor authentication (MFA)
• Access control and audit logging
• Regular security assessments and penetration testing

11. Changes to This Policy

We may update this Privacy Policy to reflect legal or operational changes. You will be notified of material changes when required under GDPR.

12. Contact Us

For any privacy-related questions or to exercise your rights, please contact:

• Data Protection Officer (DPO)
• Email: contact@simplycosmo.com
• Address: Schumannstr. 27 60325 Frankfurt am Main