Additional Privacy Disclosures under Non-US Law for Individuals Located Outside the United States
Last Updated: September 30, 2023
These privacy disclosures (these “Disclosures”) provide information on collection and use of data about individuals located in a Relevant Country (as defined below).
In these Disclosures,
“Personal Data” means information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, by use of any identifier or characteristic specific to that individual.
“Relevant Law” means any non-U.S. jurisdiction’s personal data protection law that applies to the processing of Personal Data by a Kosmos Society Entity.
“Relevant Country” means a country which has enacted a Relevant Law.
“In-scope Processing” means the collection, use, handling, processing or sharing of Personal Data by a Kosmos Society Entity when those activities are within the scope of any Relevant Law.
“Kosmos Society Entity” means a Kosmos Society project, software, or other Kosmos Society controlled entity.
These Disclosures apply only to In-scope Processing. Please note that, depending on the situation, some of the Kosmos Society activities described below may in the given case not constitute In-scope Processing as that term is used in these Disclosures.
Further, these Disclosures apply only to the Kosmos Society Entities that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we,” “us” or “our” refer to any such Kosmos Society Entities. In some cases, a Kosmos Society Entity or other Kosmos Society unit may provide other information about its In-scope Processing in its own supplemental or separate disclosures.
These Disclosures concern In-scope Processing by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
A. How We Collect and Use Personal Data
We use the Personal Data that we collect to carry on various institutional and educational activities as described in more detail below. The ways in which we collect and use your data vary depending on the relationship between you and us. The following sections of these Disclosures describe in more detail how and why we collect and use Personal Data in various circumstances that may involve In-scope Processing.
1. Personal Data We Collect
Websites and Mobile Applications
As is true of most digital platforms, we obtain certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example when you enter data into form fields. If we also process data through our websites or mobile applications for one of the activities described further below, those descriptions will provide additional information about how those data are collected and used. We and our third-party vendors use this Personal Data for the primary purposes of conducting analytics, improving our websites, responding to your requests and providing you with relevant information including program offerings that we believe may be of interest.
What Personal Data Do We Collect?
We and our third-party vendors collect Personal Data through websites and mobile applications, often as a result of users volunteering their data. We and our third-party vendors may collect:
Contact Information: for example, your name, home address, email address, phone number and social media usernames;
Log Files: Information collected automatically when you are interacting with websites or mobile applications, for example, IP address, browser type, internet service provider, pages visited (including referring/exit pages), operating system, date/time stamp and/or clickstream data;
Location Information: We may use your IP address to identify the general geographic area from which you are accessing our website. Our mobile applications may collect more precise location information about you to provide functions identified in the application, such as a map feature; and
Mobile Device Sensor Information: Some of our mobile applications may use various sensors and components of your mobile device (for example, your camera or microphone) to collect information for the purposes of providing you with additional functions and features.
What is the Purpose of Processing?
We process your Personal Data collected on our websites and mobile applications:
To facilitate our online interactions with you, for example, by responding to your requests;
To operate, maintain and improve our websites and mobile applications, for example, by conducting analytics to improve and manage our websites and mobile applications, analyze user trends, and create custom audience lists;
To collect data about you and your activities online over time and across different websites and social media channels for marketing purposes, including delivering relevant marketing communications to you; or
To engage in other activities described under “Additional Uses of Personal Data” below.
What is Our Legal Basis of Processing?
We process your Personal Data for the purposes described above consistent with the legal bases recognized by the Relevant Law in each Relevant Country, which may include, for instance: to facilitate transactions requested by you and meet our contractual obligations (for example, registering you for events); to pursue our legitimate interests (for example, website analytics); as necessary for compliance with a legal obligation; or on the basis of your consent, where applicable.
2. Additional Uses of Personal Data
In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Data We Obtain from Third Party Sources,” we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to pursue our legitimate interest in the following activities:
Conducting our operations and administering and developing our educational offerings;
Processing and responding to your requests or inquiries of any other kind;
Providing you with newsletters, articles, service alerts or announcements, event invitations, volunteer opportunities, and other information that we believe may be of interest to you;
Ensuring the rights, safety and security of our students, faculty, fellows, employees and others;
Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
Responding to subpoenas, court orders, or other legal process; fulfilling and enforcing our agreements and legal rights; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.
3. Data Retention
We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures, in accordance with Relevant Law and the legal bases for acquiring the data.
For example, we may generally retain Personal Data as follows:
For as long as may be required under applicable law;
As needed to resolve disputes or protect our legal rights;
Where processing is based on your consent, for the period of time necessary to carry out the processing activities to which you consented;
Where processing is based on contract, for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship;
Where processing is based on the public interest, for the period of time that continues to serve that underlying interest.
Where processing is based on our legitimate interests, for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects. In some cases, where Personal Data was primarily processed and retained on the basis of consent, contract, the public interest, or other bases described in these Disclosures, we may continue thereafter to retain the data based on a legitimate interest.
Consistent with the foregoing guidance, some data may be retained indefinitely.
B. How We Share and Disclose Personal Data
We share your Personal Data with third parties in the ways described in these Disclosures, including the “How We Collect and Use Personal Data” section above. Additionally, we may share information as described below:
We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:
Event registration and coordination;
Providing course platforms or tools that enable or enhance our offerings;
System maintenance and security;
Third-Party Mobile App Providers
If you use certain of our mobile applications, your mobile device may gather and transfer your Personal Data, including location information, to other applications, functions and tools within your mobile device.
Social Media Platforms
We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms.
Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by law. We may also disclose your Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine that disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.
C. International Data Transfers
Much of our Personal Data processing takes place in the United States, though sometimes we or third parties with whom we share data may process data in other countries. The data protection laws in the United States and other countries may provide less protection than such laws in your Relevant Country. In the event we transfer your Personal Data outside your Relevant Country as part of our In-scope Processing, we rely where required on appropriate or suitable safeguards or specific legal provisions permitting such transfers under the Relevant Law.
When transferring Personal Data from a country in the European Economic Area (EEA) or from the United Kingdom (UK) to a country outside the EEA and the UK, we may base such transfers on contracts containing legally authorized data protection clauses referred to as Standard Contractual Clauses. You may request a copy of the Standard Contractual Clauses relevant to any such transfer of your Personal Data by contacting us as set forth in the “Contact Us” section below.
D. Cookies and Similar Technologies
Whenever you visit or use our websites or online services, we may deploy cookies and related technologies (“Cookies”) to collect certain personal information about you. We use the information in order to enhance and personalize the experience, to help provide our services, to analyze website and service usage, and to help improve the websites and our related services. To find out more about cookies, visit https://www.internetcookies.org/.
You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies, or you can opt out of the collection and use of some Cookies through tools like the Network Advertising Initiative opt-out page. If you disable or delete certain Cookies in your settings, you may not be able to use features of our websites.
We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information using Google Analytics, please see www.google.com/policies/privacy/partners/, and for how to opt out, please see https://tools.google.com/dlpage/gaoptout.
The opt-outs described above may not work for all browsers or devices.
E. Rights You May Have
To the extent required by Relevant Law, upon your reasonable and good faith request, we will inform you whether we hold any of your Personal Data as part of our In-scope Processing. With respect to your Personal Data collected and used in our In-scope Processing, under the Relevant Law you may also be able to:
obtain a copy of your Personal Data in an easily accessible format;
request that we correct or update any of your Personal Data that is inaccurate;
restrict or limit the ways in which we use your Personal Data;
object to the processing of your Personal Data;
request the deletion of your Personal Data; and
request that we transmit your Personal Data to another party.
Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we may need to ask you for information verifying your identity. We will respond to your request within a reasonable timeframe
If our In-scope Processing as to your Personal Data is solely based on your consent, in certain cases you may also have the right under a Relevant Law to withdraw your consent to our processing. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures, or otherwise limit our use of your Personal Data or request its deletion, we may no longer be able to provide you some or all of the related services.
Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent or requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may need to retain certain data to comply with an independent legal obligation, for achieving the lawful purposes for which we obtained the data, or for such reasons as keeping our services and operations safe and secure or safeguarding our rights or the rights or safety of others.
If you have any complaints regarding our privacy practices, you may be able to make a complaint to your national data protection authority, supervisory authority, or other legal authority.
F. User Generated Content
Some of our online activities, such as websites, forums, online meetings, and bulletin boards, enable users to submit their own content. Please remember that any Personal Data you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.
G. Updates to the Disclosures
We may update these Disclosures from time to time without prior notice by posting revised Disclosures. You can determine when these Disclosures were last revised by checking the Last Updated date at the beginning of these Disclosures.
H. Contact Us
If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following way:
Email kosmos.helpdesk (at ) gmail.com