COCOS Inc. and its affiliates ("COCOS, we/us/our") are committed to safeguarding the privacy of our customers and users ("you/your") and the User Data you have entrusted to us. It is important for you to understand what User Data we will collect, how we will use it, and who may access it.
User Data means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers including your Social Insurance Number and personal references, to the extent permitted by local laws.

This Privacy Policy governs your use as a visitor and/or user to www.cocoscard.com and/or other websites managed by COCOS that reference the Privacy Policy (the "COCOS WebSites"). Please read the Privacy Policy carefully. By using, accessing, and/or visiting the COCOS WebSites, you accept and agree to the Privacy Policy. If you do not accept and agree to the Privacy Policy, you should immediately stop using, accessing, and/or visiting the COCOS WebSites.

Children’s Privacy. COCOS’s services are intended for general audiences and not for children under the age of 13. We do not knowingly collect personal information from children under the age of 13, and if we become aware of such collection, we will take reasonable steps to delete any such information as soon as practicable.

If you are an existing customer of ours, further details about how we use your User Data are set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your User Data together with the ability to opt in or out of selected uses may also be provided when we collect User Data from you.

Our websites may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your User Data. Please check these policies before you submit any User Data to such third-party websites.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

(a) What User Data about you we may collect.
(b) How we may use your User Data.
(c) Who we may share your User Data with.
(d) How we protect your User Data.
(e) Contacting us & your rights to prevent marketing and to access and update your User Data.
(f) Our Cookies Policy.
(g) How changes to this Privacy Policy and the Cookies Policy will be made.

2. Information We May Collect About You
We will collect and process all or some of the following User Data about you:

(a) Information you provide to us. User Data that you provide to us, such as when using the contact form on our website, including your name, email address, and other contact details;
(b) Our correspondence. If you contact us, we will typically keep a record of that correspondence;
(c) User Data about how you use our products and services, such as information about the amount of time you use our products/services, the pages you visit, and other information about your activities while using our hardware or software or while logged into your COCOS ID account. We collect this to develop our products and services and to understand your usage patterns and preferences so that our marketing is relevant to you;
(d) Survey information. We may also ask you to complete surveys that we use for research purposes. In such circumstances, we shall collect the information provided in the completed survey;
(e) Promotions. We may request User Data to administer your participation in contests, sweepstakes, or other promotions that we organize;
(f) Device Information. Information such as details about your operating system, browser, software applications, IP address, geolocation, security status, and other device information to improve your experience, protect against fraud, and manage risk;
(g) Marketing preference information. Details of your marketing preferences (e.g., communication preferences) and information relevant to selecting appropriate products and services to offer you;
(h) Website and communication usage. Details of your visits to the websites and information collected through cookies and other tracking technologies, including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, posts on the COCOS Insider forum, other communication data, and the resources that you access;
(i) Activities on Social Networking Sites (SNS). If you choose to participate (for example, by "liking" COCOS's profile on Facebook or Twitter, posting a message, or answering a poll), we will have access to the information you divulge, which may include User Data, depending on your SNS privacy settings.
(j) Tokens from Third-Party Websites. If you install COCOS Nexus on your device and choose to link COCOS Nexus to your YouTube account, COCOS Nexus will access your Google account to obtain a token generated by Google dynamically. This token is a unique identifier we use for the purpose of validating and retrieving the streaming endpoint so that COCOS Nexus can match and transmit your stream to the correct YouTube channel. No personally identifiable data is obtained or stored by COCOS in this process, nor is any transferred to any third party. Your video stream will be passed through to YouTube.

3. Uses Made of Your User Data:
In this section, we outline the purposes for which we use User Data collected through our website and, in compliance with our obligations under local laws and European law, identify the legal grounds on which we rely to process the information.
These legal grounds enable companies to process personal data only when the processing is permitted by the specific legal grounds set out in local laws or European law, as applicable.
Consent: where you have consented to our use of your information.
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest, and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute, or make a claim against you, us, or a third party.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g., your employer) have a legitimate interest to do so, you have the right to object to that use; though, in some cases, this may mean no longer using the Services.

Please note that in addition to the disclosures we have identified below, we may disclose User Data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g., legal, financial, business, or other advisors), and affiliates of COCOS that perform activities on our behalf, as well as other members of the COCOS group.

(a) To provide and manage products and services you have requested: To administer our services, including carrying out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products.
Use justifications: contract performance; consent, legitimate interests (to enable us to perform our obligations and provide our services to you or to notify you about changes to our service).
(b) To sponsor you and/or your e-sports team: To carry out our obligations arising from any sponsorship agreements entered into between you and us, to notify you about changes to the terms of our sponsorship, or to advertise the fact that you and/or your e-sports team are sponsored by us.
Use justifications: contract performance; consent.
(c) To communicate with you regarding products and services: To provide you with updates and offers, where you have chosen to receive these. We may also use your information to market our own and our selected business partners' products and services to you by way of in-app alerts, post, email, phone, SMS, or online or social media advertisement. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option on the appropriate platform to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.
Use justifications: legitimate interests (to keep you updated with news in relation to our products and services); consent.
(d) To understand our customers and to develop and tailor our products and services: We may analyze the User Data we hold to better understand your usage patterns, preferences, and marketing requirements, as well as to better understand our business and develop our products and services.
Use justifications: legitimate interests (to ensure the quality and legality of our services and to allow us to improve our services).
(e) To monitor certain activities: To monitor queries and transactions to ensure service quality, compliance with procedures, terms of use, and policies (including our COCOS Insider House Rules), and to combat fraud (including running anti-fraud checks against your payment method when processing your orders on our website)
Use justifications: contract performance, legal obligations, legal claims, legitimate interests (to ensure the quality and legality of our services).
(f) To inform you of changes: To notify you about changes to our services and products.
Use justifications: legitimate interests (to notify you about changes to our service).
(g) To ensure website content is relevant: To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers, and/or service providers
Use justifications: legitimate interests (to allow us to provide you with the content and services on the websites).
(h) To reorganize or make changes to our business: In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your User Data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your User Data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.
Use justifications: legitimate interests (in order to allow us to change our business).
(i) In connection with legal or regulatory obligations: We may process your User Data to comply with our regulatory requirements or dialogue with regulators as applicable, which may include disclosing your User Data to third parties, the court service, and/or regulators or law enforcement agencies in connection with inquiries, proceedings, or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).

4. Profiling and Automated Decision Making:
The advertisements and recommendations (including online, while you are logged into your COCOS PAY account, and while you are using our mobile app) that we show you are chosen by analyzing the User Data you provide to us, as described in section
This includes information about your past purchases from us, the way in which you use our products and/or services, and previous advertisements that you have interacted with. To select advertisements that are tailored and most likely to be of interest to you, we compile and analyze information received from all our users to gain a better understanding of your preferences based on users similar to you. We use similar predictive techniques to combat payment fraud, as described below.

5. Identity Verification:
When creating an account or initiating a transaction on our site, we may process your User Data, including personal information such as name, mobile number, identification details, and related documents. This is done for identity verification and to comply with know-your-customer obligations under applicable laws. If the submitted User Data is deemed insufficient, inaccurate, or fails identity verification, we reserve the right to disable your account and/or decline transaction processing. If you opt for biometric verification, COCOS PAY will collect and process a public key generated by your device for identity recognition, login verification, and transaction instruction verification. This public key is created by your device using public key cryptography and is associated with your COCOS PAY account for device recognition. Importantly, COCOS PAY does not access or process any biometric information stored on your device, such as fingerprints or faceprints, ensuring privacy and security.6. Sharing your Personal Information (and transfers outside of the EEA):
We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy. Sharing outside the COCOS group: Personal Information may be provided to third parties, including anti-fraud organizations, legal, regulatory, or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities, or other self-regulatory organizations, or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts).

Sharing within the COCOS group: We may share your Personal Information within the COCOS group, including locations outside of the European Economic Area where we do business, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up-to-date information about you (such as your current address or date of birth), and to better manage your relationship with us.

Business sale or reorganization: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with any accounts, products, or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganization or other change in corporate control.

Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics, and marketing. Such companies will be given only the Personal Information needed to perform those services, and we do not authorize them to use or disclose Personal Information for their marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed.

7. EEA Rights to Personal Information
COCOS individuals in the EEA have the right, under certain circumstances, to:
Access their personal information.
Correct inaccurate personal information.
Request erasure of their personal information without undue delay.
Request the restricted processing of their personal information.
Receive the personal information that they have provided us with, in a structured, commonly used, and machine-readable format, and have the right to transmit that information to another controller without hindrance or ask us to do so.
Object to the processing of their personal information.
Users in the EEA may request access to their personal information, modify, or remove most information associated with their COCOS account at any time by logging into their COCOS account and accessing features such as Edit Profile and Account Info. Users may also email to exercise any of the above rights by emailing us at privacy@cocoscard.com

EU users also have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of their habitual residence, place of work, or place of the alleged infringement if they consider that our processing of their personal information infringes the applicable data protection laws. Please contact us at privacy@cocoscard.com, and we will provide you with detailed information regarding the contact details of the respective competent supervisory authority.

Learn more about COCOS GDPR.

8. Transfers Outside of the EEA:
Your COCOS Personal Information may be accessed by staff, suppliers, or other persons in, transferred to, and/or stored at a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.
Where we transfer Personal Information from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws, and therefore no additional safeguards are required to export Personal Information to these jurisdictions. In countries which have not had these approvals (see the full list here: EU Commission-approved model contractual clauses), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses or other legal grounds permitted by applicable legal requirements.
If you live outside the EEA or California, COCOS will undertake best efforts to give you a similar degree of control over your privacy.

9. Security of your COCOS Personal Information:
We utilize physical, electronic, and procedural measures to prevent unauthorized use, access, alteration, destruction, disclosure, loss, or theft of your COCOS Personal Information within our custody or control. Furthermore, we have implemented agreements and controls with third-party service providers, ensuring that any information shared with them is protected and used exclusively for the specified purpose of delivering the services requested from the company.

10. Security over the Internet for COCOS:
While no data transmission on the Internet or websites can guarantee absolute security against intrusion, we employ commercially reasonable physical, electronic, and procedural safeguards to protect your COCOS Personal Information in line with the requirements of data protection legislation. All information you furnish to us is stored on our secure servers or those of our subcontractors, accessed, and used in adherence to our security policies and standards. If we provide you with a password for accessing specific sections of our websites, it is your responsibility to maintain confidentiality and adhere to any additional security procedures we communicate. We advise against sharing your password with others.

11. Retention of your COCOS Personal Information:
Our retention periods for personal data are based on business needs and legal requirements. We retain your COCOS Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired or to comply with regulatory requirements regarding the retention of such data. When COCOS Personal Information is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.

12. Marketing for COCOS:
Most of our processing relies on "legal grounds" other than consent (refer to section 2 above). For Direct Marketing purposes, we will seek your consent before using your COCOS Personal Information if required. If you wish to opt out of receiving our Direct Marketing communications or having your COCOS Personal Information shared within the COCOS group for marketing, you can request the removal of your name from our Direct Marketing and/or shared information lists.

Direct Marketing refers to our communication via mail, telemarketing, or email, using your contact details to share information about products and services we believe may interest you. This excludes communications about your existing products or services, including enhancements, additional features, and transactional information.
13. Updating information for COCOS:
We will use reasonable endeavors to ensure that your COCOS Personal Information is accurate. To assist us with this, please notify us of any changes to the COCOS Personal Information you have provided by contacting us as set out in the "Contacting Us" section below.

14. Your rights for COCOS:
If you have any questions regarding our use of your COCOS Personal Information, you should first contact us as per the "Contacting Us" section below. Under certain conditions, you may have the right to require us to:

You can request details, corrections, or deletion of your COCOS Personal Information, withdraw consent, object to processing based on legitimate interests, and limit information use during a complaint investigation, subject to specific exemptions. We aim to respond within a month to your exercised rights, balancing public and our interests.
15. Contacting us for COCOS:
If you have any questions or concerns about our privacy practices, the privacy of your COCOS Personal Information, or you want to change your privacy preferences, please contact us through this form. You can also directly contact our Data Protection Officer at dpo@cocoscard.com

16. Cookies use and change policy for COCOS:
The Cookies policy for COCOS is outlined on our websites. For more details on our use of cookies, please refer to our Cookies Policy at http://www.cocoscard.com/legal.

Changes to our Privacy Policy and/or Cookies Policy for COCOS may occur as we modify website content and cookie usage. Consequently, our Privacy Policy and Cookie Policy may be subject to periodic updates in the future. In the event of any changes, we will update the modification date below. Material changes will be clearly indicated on our website.