Thank you for trusting and using Cosy. In accordance with the latest laws, regulations, and regulatory policy requirements, we have updated the "Cosy Privacy Policy." Please read the following terms carefully and fully understand them.
This Privacy Policy applies to Cosy services. When you use Cosy, we collect and use your relevant information. We deeply understand the importance of personal information. To better present and explain our privacy rules and your user rights, as well as to explain how Cosy collects, uses, and stores your personal information and the rights you enjoy, we will outline in this Privacy Policy the types of personal information we collect from you and their corresponding purposes. This will help you understand the specific categories of personal information we collect for a particular function, the reasons for use, and the methods of collection. Before using Cosy, please be sure to read and thoroughly understand this Privacy Policy. Use the related products or services only after you have fully understood and agreed to it.
The following sections will help you understand in detail how we collect, use, and protect your personal information; how you can inquire, access, delete, correct, or withdraw authorization for your personal information. Important terms regarding your personal information rights are highlighted in bold, so please pay special attention.
Personal Information: Refers to various types of information recorded electronically or otherwise that can independently or in combination with other information identify the identity of a specific natural person or reflect the activities of a specific natural person. The specific types of personal information we actually collect are described below.
Sensitive Personal Information: Refers to personal information that, if leaked, illegally provided, or misused, can harm personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. The specific types of sensitive personal information we actually collect are described below. Compared to other personal information, sensitive personal information has a greater impact on your personal rights. We kindly remind you to provide your sensitive personal information to us only after careful consideration.
Authorized Consent: Refers to your explicit authorization for specific processing of your personal information, including authorization through positive actions (i.e., explicit consent) and through passive inaction. Please be aware that "authorized consent" in this policy is sometimes also referred to as "authorization" or "consent."
User Profile: The process of collecting, aggregating, and analyzing personal information to analyze or predict your personal characteristics, such as occupation, economy, education, personal preferences, credit, and behavior, thereby forming a personal characteristic model.
Anonymization: Refers to the technical processing of personal information so that the subjects of the personal information cannot be identified or linked, and the processed information cannot be restored.
De-identification: Refers to the technical processing of personal information so that it cannot be identified or linked to the subject of the personal information without additional information.
Deletion: Refers to the removal of personal information from systems involved in daily business functions, making it non-retrievable and inaccessible.
We will adhere to the principles of legality, fairness, and necessity, and collect, use, and store the personal information you voluntarily provide or that is generated during your use of Cosy in accordance with the purposes described in this policy. If we intend to use your personal information for purposes not stated in this policy, or use information collected for specific purposes for other purposes, we will inform you and obtain your consent before use.
To ensure the normal use of the platform's basic functions and services, improve and optimize our service experience, and ensure the security of your account, when you use our platform's services or visit the platform's web pages, we will automatically receive and record information from your computer or mobile device, including your IP address, language used, access date, and time. If you download or use our or our affiliated companies' client software, or use our platform's services via mobile web pages, we will read information related to your mobile device (including your hardware model, operating system version, device configuration, unique device identifier, International Mobile Equipment Identity (IMEI), network device hardware address (MAC), advertising identifier (IDFA)), device connection information (browser type, telecom operator, language used), and device status information (including device sensor data, list of installed applications). We will correlate the information collected from your various devices to provide consistent services across these devices.
To enhance your entertainment experience on Cosy, the following features will collect and use your personal information. If you do not provide this personal information, you can still use some of Cosy's features:
To provide you with better services, you agree that we may obtain your personal information from third parties, including but not limited to our affiliated companies and partners. We obtain authorized shared account information from third parties (including but not limited to avatars, nicknames, and account information), and after you agree to this Privacy Policy, we will bind your third-party account with your Cosy account. We will use your personal information in accordance with this policy and under the premise of complying with relevant laws and regulations.
As our business develops, adjustments to Cosy may occur. When new features or services are related to registration, public squares, ad pushing, publishing graphics and text, interactive communication, search, queries, authentication, or virtual property scenarios, the personal information collected and used is directly related to the original purpose. In scenarios not directly related to the original purpose, we will obtain your consent again before collecting and using your personal information. Please note: Many of our services allow you to share information not only with your own social network but also publicly with all users using that feature. For example, information you upload or publish on our platform, your responses to others' uploads or publications, as well as related location data and audio information. Other users of our services may also share information related to you, including your location data and audio information. Specifically, our social media services are designed to allow you to share information widely and in real-time with users around the world. As long as you do not delete the shared information, the information will remain in the public domain. Even if you delete the shared information, it may still be independently cached, copied, or stored by other users or uncontrolled third parties, or saved in the public domain by other users or third parties. Therefore, please carefully consider the content of the information you upload, publish, and communicate through our services. In some cases, you can control the range of users authorized to view your shared information through the privacy settings of certain services.
To provide you with better services, you agree that we may obtain your personal information from third parties, including but not limited to our affiliated companies and partners. We obtain authorized shared account information from third parties (including but not limited to avatars, nicknames, and account information), and after you agree to this Privacy Policy, we will bind your third-party account with your Cosy account. We will use your personal information in accordance with this policy and under the premise of complying with relevant laws and regulations.
According to relevant laws and regulations, in the following circumstances, we may collect and use some necessary personal information without obtaining your authorized consent:
1. Directly related to national security or defense security;
2. Directly related to public safety, public health, or significant public interests;
3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
4. Necessary for the protection of your or others' life, property, or significant legitimate rights and interests, but it is difficult to obtain the individual's consent;
5. The personal information collected is publicly disclosed by you to the public;
6. Personal information collected from legally publicly disclosed information, such as legitimate news reports and government information disclosure channels;
7. Necessary for signing and fulfilling contracts based on your request;
8. Necessary for maintaining the security and stable operation of Cosy's products and/or services, such as discovering and addressing product or service failures;
9. Other circumstances as prescribed by laws and regulations.
Cookies and device information identifiers are commonly used technologies on the internet. When you use Cosy, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information about your access and use of this product. We commit not to use cookies for any purposes other than those stated in this Privacy Policy. We primarily use cookies and similar technologies to achieve the following functions or services:
1. Ensure the Security and Efficient Operation of Products and Services:
We may set authentication and security-related cookies or anonymous identifiers to confirm whether you are securely logged into the service or if you are experiencing unauthorized use, fraud, or other illegal activities. These technologies also help us improve service efficiency and enhance login and response speeds.
2. Help You Have a Smoother Access Experience:
Using such technologies can help you avoid the steps and processes of repeatedly filling in personal information or entering search content.
3. Clearing Cookies:
Most browsers provide users with the ability to clear browser cache data. You can perform corresponding data clearing operations in the browser settings. You can also manage and clear all cookies saved by the CosyApp on your mobile device. If you clear them, you may not be able to use the corresponding functions provided by us.
Certain specific modules or functions provided on the platform are supplied by external vendors. For example, we may hire service providers to assist us in completing real-name authentication for users. For companies, organizations, and individuals entrusted with processing personal information on our behalf, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.
Certain specific modules or functions provided on the platform are supplied by external vendors. For example, we may hire service providers to assist us in completing real-name authentication for users. For companies, organizations, and individuals entrusted with processing personal information on our behalf, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.
1. In Compliance with Laws and Regulations or Government/State Agency Requirements:
- According to laws and regulations or requirements from relevant government/state agency departments.
2. Necessary for Maintaining Our and Our Affiliates’ or Users’ Legitimate Rights, Public Interests, Property, or Safety:
- As required by relevant government/state agency departments.
3. Sharing Your Personal Information with Our Affiliates:
- You agree that we can share your personal information with affiliated companies and their products.
4. Providing Your Personal Information to Partners:
- Only to achieve the purposes stated in this policy, certain services are provided by authorized partners. We will share some of your personal information with partners to provide better customer service and user experience. We will only share personal information for legitimate, proper, necessary, specific, and explicit purposes and only the personal information necessary for providing the service. Our partners are not authorized to use the shared personal information for any other purposes. Our authorized partners include the following types:
1. Authorized Partners for Analytical Services: Unless you permit, we will not share your personally identifiable information with partners providing analytical services.
2. Vendors, Service Providers, and Other Partners: We send information to vendors, service providers, and other partners globally who jointly provide services to you. These collaborations include providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of ads and services, providing customer service or prizes, marketing activities, payment facilitation, or conducting academic research and surveys. For example, when you need to use location functions, to achieve this function, we will collect your location information and related device information (e.g., hardware model, operating system version), de-identify them, and provide them to the aforementioned providers. You can refuse to provide such information, but this will not affect your use of other services. For companies, organizations, and individuals with whom we share personal information, we will agree on strict confidentiality terms and evaluate their data security capabilities and environments, requiring third parties to handle such information with confidentiality and security measures no lower than those required by this policy. They must handle personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures. If a third party needs to use personal information beyond the aforementioned authorized scope due to business needs, the third party must obtain your consent again.
To ensure the stable operation of Cosy or to achieve related functions, we may integrate third-party Software Development Kits (SDKs) to achieve the aforementioned purposes. The third-party SDKs integrated into Cosy are listed in this directory.
5. Necessary for Resolving Disputes or Conflicts Between You and Others;
6. If You Violate Relevant Laws, Regulations, or Our Platform’s Relevant Agreements and Rules, We Need to Disclose to Third Parties.
Unless you explicitly consent, we will not transfer your personal information to any company, organization, or individual. In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy.
You fully understand that in the following circumstances, we can share, transfer, or publicly disclose your personal information without obtaining your authorized consent:
1. Related to National Security and Public Interests;
2. Related to Criminal Investigation, Prosecution, Trial, and Execution of Judgments;
3. Necessary for Protecting the Life, Property, or Significant Legitimate Rights and Interests of the Personal Information Subject or Others, but It Is Difficult to Obtain Consent;
4. The Personal Information Collected Is Publicly Disclosed by the Personal Information Subject to the Public;
5. Personal Information Collected from Legally Publicly Disclosed Information, Such as Legitimate News Reports and Government Information Disclosure Channels;
6. Violations of Laws or Platform Rules Leading Us to Take Necessary Measures Against You;
7. Necessary for Signing and Fulfilling Contracts Based on Your Request;
8. Necessary for Maintaining the Security and Stable Operation of Provided Products or Services, Such as Discovering and Addressing Product or Service Failures;
9. Necessary for Legitimate News Reporting;
10. Necessary for Statistical or Academic Research Conducted by Academic Research Institutions Based on Public Interest or Non-Profit Purposes, and the Personal Information Included in the Results Provided Externally Is De-identified;
11. Other Circumstances as Prescribed by Laws and Regulations.
According to legal provisions, sharing or transferring de-identified personal information, ensuring that the data recipient cannot restore and re-identify the personal information subject, does not constitute sharing, transferring, or publicly disclosing personal information. The storage and processing of such data do not require separate notification to you or obtaining your consent.
We attach great importance to the security of your personal information. To ensure your information's security, we strive to adopt various reasonable physical, electronic, and managerial measures that meet industry standards to ensure that our personal information processing activities comply with legal, administrative regulations, or other applicable system requirements, and to prevent unauthorized access as well as leakage, alteration, or loss of personal information. These measures include but are not limited to deploying host intrusion detection systems, encrypting the storage of important sensitive information, access control to data centers, and security audits of log records.
Certain specific modules or functions provided on the platform are supplied by external vendors. For example, we may hire service providers to assist us in completing real-name authentication for users. For companies, organizations, and individuals entrusted with processing personal information on our behalf, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.
1. Security Technical Measures:
We will use encryption, de-identification technologies, anonymization processing, and other reasonable and feasible means that meet industry standards to protect your personal information. We will also use security protection mechanisms to prevent your personal information from being maliciously attacked.
2. Management Systems:
We will establish specialized security departments, security management systems, and data security processes to ensure the security of your personal information. We implement strict data usage and access systems to ensure that only authorized personnel can access your personal information. We will regularly conduct security education and training for personnel and perform security audits of data and technology as appropriate. We also strictly manage employees who have access to your information, including but not limited to implementing different permission controls based on job roles, signing confidentiality agreements with them, and monitoring their operations.
3. Emergency Response Plans for Personal Information Security Incidents:
We will develop and implement emergency response plans for personal information security incidents and activate these plans immediately upon occurrence of such incidents to control their impact and prevent adverse consequences from escalating. In the event of or potential personal information security incidents (leakage, alteration, loss), we will inform you promptly in accordance with legal and regulatory requirements about the types of personal information affected, the reasons, and potential harms caused; the remedial measures we have taken; measures you can take to mitigate the harm; and how to contact us. We will notify you of the incident details through push notifications, emails, letters, SMS, and other relevant forms. If it is difficult to notify each individual, we will use reasonable and effective methods to release announcements. Additionally, we will report the handling of personal information security incidents to relevant regulatory authorities as required.
4. Security Tips:
Although we have taken the above reasonable and effective measures and complied with relevant legal and regulatory standards, please understand that due to technical limitations and potential malicious methods, it is impossible to guarantee 100% information security in the internet industry, even with the strongest security measures. We will do our best to ensure the security of the personal information you provide to us. You acknowledge and understand that the systems and communication networks you use to access our services may encounter issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to not disclosing your mobile phone verification codes, account information, and related personal information to others.
1. Methods and Duration of Information Storage:
We will store your information securely, including local storage (e.g., using the app for data caching), databases, and server logs. Generally, we will only store your personal information for the time necessary to achieve the service purposes or under conditions prescribed by laws and regulations, such as:
a) Mobile Number: After you register and log in using your mobile number, we need to retain your mobile number continuously to provide you with normal services, respond to your possible inquiries and customer complaints, and ensure the security of your account and system.
b) Content You Publish and Related Information: We will retain them until you withdraw, delete, or deactivate your account to provide you with continuous business functions.
c) Account Deactivation, Personal Information Deletion, or Information Exceeding Necessary Retention Periods: We will delete or anonymize your personal information, except in the following cases:
- Complying with legal and regulatory requirements regarding information retention.
- Reasonably extending the retention period for purposes such as finance, auditing, and dispute resolution.
We promise that the storage duration of your personal information will always be within a reasonable and necessary period. For personal information exceeding the period, we will immediately delete or anonymize it.
2. Notification When Products or Services Cease Operation:
When our products or services cease operation, we will notify you through push notifications or announcements and delete your personal information or anonymize it within a reasonable period, unless otherwise required by laws and regulations.
We highly value your attention to personal information and make every effort to protect your rights to access, correct, delete, and withdraw consent for your personal information, ensuring that you have full capacity to safeguard your privacy and security. Your rights include:
1. Inquiring and Correcting Your Personal Information:
You can inquire and correct the personal information you provided when using our products and services through your personal profile page. If you need to inquire about other personal information generated during your use of Cosy, we will provide it upon reasonable request.
2. Destroying Your Personal Information:
You can delete the personal information you provided through your personal profile page. If you believe we have violated laws, administrative regulations, or failed to collect and use your personal information in accordance with our agreements, please contact us using the contact information at the end of this document to have it corrected or destroyed.
3. Withdrawing Authorized Consent:
You can operate within your personal device system to grant or withdraw authorization for notifications, location information, camera, photo album, file storage and access, microphone, etc. On different devices, the way permissions are displayed and how to close them may vary. Please refer to the instructions or guidelines provided by the device and system developers. You can also close or withdraw relevant consents or authorizations in the Cosy app under "My – Settings – Privacy Settings – System Permissions Settings." After you withdraw consent, we will no longer process the corresponding personal information. However, please understand that after you withdraw consent or authorization, we cannot continue to provide the specific functions and/or services corresponding to the withdrawn consent or authorization. Your decision to withdraw consent does not affect the personal information processing we conducted based on your prior authorization.
4. Obtaining a Copy of Personal Information:
You have the right to obtain a copy of your personal information. You can contact us, and we will process your request within fifteen days after verifying your user identity.
Users under the age of 18 are subject to the "Cosy Minor Privacy Protection Statement."
1. Reading the Privacy Policy with Guardians:
Minors under eighteen years old should read this Privacy Policy in the presence of their parents or guardians. Using our products and services requires the consent of a guardian. We value the protection of minors' personal information. Minor users must have their guardians carefully read this Privacy Policy and ensure that they have obtained their guardian's consent before using our services and providing us with their information. If your guardian does not agree to you using our services or providing us with information in accordance with this policy, please immediately stop using our services and promptly notify us.
2. Registration and Use by Minors:
If you are a minor registering or using Cosy, according to relevant laws and regulations, you must obtain the consent of your parents or legal guardians before using Cosy, and have your parents or legal guardians help you complete the Cosy registration process to use the products or services we provide.
3. Guardians Helping Minors:
If you are a guardian of a minor, when helping the minor complete the registration and use of products or services, you should carefully read this policy and the "Cosy Minor Privacy Protection Statement," decide whether to agree to this policy and the statement, and help the minor register and use the services so that the minor can use the products or services we provide.
4. Collection of Minors' Personal Information:
We will not collect personal information of minors without knowing it. Unless your guardian consents, minors should not register accounts or send personal information such as their name, address, phone number, or email address to us. We will protect the confidentiality and security of minor users' information in accordance with national relevant laws, regulations, and this policy.
5. Displaying Minors' Personal Information:
We will not display search results of minors' personal information without the consent of their guardians. If a guardian requests us to delete or block a minor's personal information related to Cosy, please contact us.
6. Protection of Minors' Privacy Rights:
Specifically, to better protect the privacy rights of minors, we remind you to be cautious when posting content that includes images of minors. Once posted, it is deemed that you have obtained your guardian's consent to display the minor's portrait and voice and allow us to use and manage the content related to minors in accordance with the user service agreement and this Privacy Policy. If the rights holder notifies us that the content you posted infringes the rights of a minor, considering the protection of the rights holder and the minor's rights, we have the right to handle the content you posted.
7. Responsibility for Minors' Use of Services:
All behaviors and consequences arising from minors' use of this service are borne by the minors and their guardians. We do not assume any responsibility.
We revise the Privacy Policy in a timely manner, and such revisions constitute part of this Privacy Policy. Without your explicit consent, we will not reduce the rights you are entitled to under this policy. For significant changes to the Privacy Policy, we will publish the relevant terms in a prominent position on the website or notify users in the form of push notifications. If you do not agree with the revised Privacy Policy, you have the right to and should immediately stop using Cosy. If you continue to use Cosy, it means you agree to be bound by the revised Privacy Policy.
1. Final Interpretation Rights:
Cosy holds the final interpretation rights to this Privacy Policy.
2. Dispute Resolution:
If any disputes or conflicts arise between you and us, both parties should negotiate amicably.
3. Severability:
If any provision of this Privacy Policy is found to be invalid for any reason, the remaining provisions will remain valid and binding on both parties. Waiver of any provision of this Privacy Policy shall not be deemed a waiver of that provision or any other provision, and any rights or provisions not asserted by us under this Privacy Policy shall not constitute a waiver of those rights or provisions.