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Cosmopix Privacy Policy

Updated 23/06/2025

COSMOPIX ('we', 'our', or 'the company') values the security and privacy of personal data from users who visit our website and play our games (“websites”, “games', 'our Services'). To ensure transparency about the rules governing this relationship, we present our Privacy Policy ('this policy'), which applies to all interactions with the official COSMOPIX website, other company websites, our platform and our games.

1. General Rules

  • This Privacy Policy provides important information about Data Privacy, including your choices as a user regarding the collection, use, and disclosure of certain information, such as your personal data, by COSMOPIX.
  • Our privacy rules have been created in compliance with Brazilian legislation, specifically the General Data Protection Law – Law 13.709/2018, as well as applicable U.S. data protection regulations. While the U.S. does not have a single federal data protection law, we adhere to general privacy principles and state-specific laws where applicable. If a U.S. state law imposes requirements not addressed in this policy, such provisions shall take precedence for users in that jurisdiction.
  • COSMOPIX GAMES LIMITADA is registered as a limited liability company headquartered in Curitiba, Paraná, at Bom Jesus Street, nº 212, Building AR 3000 - Cabral Corporate & Offices, Room nº 1904, Juvevê neighborhood, ZIP Code 80.035-010. The company is registered with the Paraná Board of Trade under CNPJ/MF 43.792.351/0001-95.

2. DPO Information and Privacy Rights

2.1. General Information

  • In accordance with applicable legislation, our Data Protection Officer (DPO) responsible for addressing any matters related to this policy is Andrei Lemisz Silverio dos Santos, who can be reached at andreilemisz@cosmopix.games.

2.2. Contacting Us

  • If you contact our DPO for assistance, for your safety and that of COSMOPIX, we may need to verify your identity before processing your request. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

2.3. Appeals

  • In accordance with certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us again at andreilemisz@cosmopix.games. The appeal requires the company to include a written explanation of the reason for the decision to take or not take action regarding your request. If your appeal is denied, you may submit a complaint to your state attorney general.

2.4. Your Privacy Rights

  • You can request confirmation from our Data Protection Officer at any time to verify the existence of your data in our database. You may also request the modification or deletion of your information. Additionally, the law grants other rights, such as data anonymization, withdrawal of consent, opting out of marketing and promotional communication, or being informed if the company has shared your data with other public or private entities.
  • On the other hand, COSMOPIX may deny requests that are unreasonable or not required by law, such as those that are excessively impractical, demand disproportionate technical effort, or could expose us to operational risks. The company may retain information as required or permitted by applicable laws and regulations, including to honor your choices, maintain records, or fulfill the purposes described in this Privacy Policy. COSMOPIX takes reasonable measures to securely destroy or anonymize personal information when it is no longer needed.

3. Information we Collect

  • The information we collect depends on how you interact with us. We can collect information you provide for us, information automatically collected when you use our services and information from third-party services and organizations, as described below.

3.1. Website

  • Our website collects personal information from users who choose to voluntarily share this data.
  • We also automatically collect certain information when you visit our site. This information does not reveal your specific identity but may include usage information, such as your IP address, browser, language preference, referring URLs, country, information about how and when you use our services, and other technical information.

3.2. Games

  • In our games, we may collect personal and non-personal information, such as, but not limited to:
    • Personal Information: name, email, phone number, address, date of birth, mobile number, credit card details;
    • Non-Personal Information: technical details about the mobile device, including IP address, device ID, username, user ID, game feature usage, game statistics, scores, and achievements

4. Use of Information

  • In general, we use the gathered information for a number of operations necessary to provide the best service for our users. Such operations are, but not limited to, the following:
    • To provide our services, managing your information and accounts, providing access to certain features and functionalities, answering requests for technical support, communicating with you about your account, activities and policy changes, processing your financial information and other payment methods;
    • For administrative purposes, such as pursuing legitimate interests such as direct marketing, research and development, network and information security and fraud prevention, detecting security incidents, protection against malicious, deceptive, fraudulent or illegal activity, measuring interest and engagement in our services, developing new products and services, ensuring internal quality control and safety, authenticating and verifying individual identities, including requests to exercise your rights under this Policy, debugging and error repair, sharing personal information with third parties as needed to provide our services, enforcing our agreements and policies, and carrying out activities that are required to comply with our legal obligations;
    • For marketing and to advertise our products and services, using the information for email campaigns, text messages, custom audiences advertising, personalized advertising and cross-device tracking;
    • For analytical purposes, to help us better understand the performance of our services, with the aim to improve our sites and games.

4.1. Website

  • On our website, the email provided by users will be used to send marketing and promotional emails, keeping them informed about company updates and games in development. The legal basis for email marketing is the user's consent, given when they choose to provide their email on our website. The user can opt out of our newsletter at any moment, using the link at the end of our emails.

4.2. Games

  • The collection of data within our games aims to offer the best user experience and deliver ads tailored to the player's profile, based on the type of information collected.
  • It is also essential for our payment and advertising systems, as well as for saving user progress and offering technical support when needed.

5. Disclosure of Information

  • We can disclose your information to third parties for a variety of business purposes, only when aimed to improve or provide functions inside our services, or to protect us or others. More detailed cases are as follow:
    • Service Providers: we may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with app marketplace (such as Apple’s App Store or Google Play Store), IT support, hosting, payment processing, customer service, and related services.
    • Other Users: we may share your information with other Users in connection with our Services, regarding multiplayer features in our games.
    • Business Partners: we may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
    • Advertising Partners: we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”
    • Good faith: we may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

6. International Transfers of Information

  • All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, Brazil, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

7. Retention of Personal Information

  • We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
  • To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. Security

8.1. General Security Terms

  • We take your privacy seriously and implement all reasonable measures and precautions to protect your personal data. We work diligently to safeguard it against unauthorized access, accidental or unlawful alterations, disclosures, or destruction. Our systems have multiple layers of security in place.
  • However, we emphasize that transmitting information over the internet involves various parties and potential risks, including those originating from your own computer. As such, we cannot guarantee the absolute security of all data you transmit online—only the information under our control.
  • Additionally, you are responsible for keeping your password confidential when accessing our systems and services. This measure helps prevent unauthorized access to your account. We will never request your password via email, SMS, or any other contact method outside the login form on our website and/or applications.

8.2. Third-Party Websites and Applications

  • Our websites and games may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

8.3. Company’s Liability

  • The Company shall not be held liable for any damages, losses, or consequences resulting from the User's misuse, improper use, or unauthorized use of the services provided. Users assume full responsibility for their actions while engaging with our site, platform and games.

9. Data of Children Under 18

  • Our website and games are not intended for individuals under 18 years old, and we do not knowingly collect personal information from children below this age without verifiable parental or guardian consent.
  • If a minor wishes to access our games, a parent or legal guardian must explicitly approve this access through our platforms. This consent will be obtained via a mandatory checkbox during account creation or gameplay, with the following declaration:
    • 'I am the parent or legal guardian of this minor and I grant permission for them to access and use this game’s content.'
  • If we discover that we have received or collected personal information from a child without such consent, we will promptly delete the information. Parents or guardians who believe their child has accessed our services without authorization may contact our Data Protection Officer to request data removal.

10. Policy Changes

  • This Privacy Policy may be updated to enhance transparency or include relevant information about the handling of users’ personal data on our websites and mobile applications.
  • If updates involve the collection of new categories of personal data or material changes to how we use your data, we will require your renewed consent before implementing such changes. If such changes occur and we have your contact information, you will receive an email detailing the updates made to the policy. Continued use of our services after being notified of changes will constitute acceptance of the updated policy, except where renewed consent is required as described above.

11. Deletion of Personal Data

  • You have the right to request the permanent deletion of your personal data stored by CosmoPix Games, in accordance with applicable data protection laws. If you wish to exercise this right, please complete our request form available on our privacy portal at: Delete Data.