Privacy Policy

1. Data Controller

The data controller is Cosmico S.r.l. (“Cosmico” or the “Controller”), with registered office in Milan, Piazza Armando Diaz, 1, VAT No. 11186440969.

The Controller has appointed a Data Protection Officer (DPO) who can be contacted at any time regarding this privacy policy or for any questions about data processing at: privacy@wearecosmico.com.

2. Scope of This Policy

This privacy policy is provided pursuant to Article 13 of EU Regulation 2016/679 (the “Regulation”) and applies to visitors of wearecosmico.com, experience.wearecosmico.com, or any landing page redirecting to our websites (the “Site”), and to individuals joining the Cosmico community to access services and explore professional opportunities (“Talent”).

This notice does not cover processing performed by:

  • companies you may collaborate with as a Talent,

  • owners of external websites or platforms linked on the Site,

  • service providers acting on their own behalf,

  • or social networks where you share information.

Please refer to the respective privacy policies of such third parties.

3. Processed Personal Data

3.1 Browsing Data

When you visit the Site, we collect browsing data such as:

  • IP address,

  • device domain name,

  • URI (Uniform Resource Identifier) of requested resources,

  • request time and method,

  • file size returned,

  • server response status code,

  • operating system details.

The Site also uses cookies and tracking technologies. For details, please see our Cookie Policy.

3.2 Registration and Community Data

When you register, we process:

  • login details, first and last name,

  • email address,

  • professional skills, experience, and CV data.

As a community member, we may also process:

  • your preferences, opinions, reviews,

  • your image if you attend events,

  • any additional data you voluntarily share.

You may also access a reserved area of the Site to interact with other community members. Data shared there will also be processed.

3.3 Talent Engagement Data

If you work as a Talent, we process your billing and administrative data.

3.4 Sensitive Data

Unless strictly necessary, please do not provide special categories of personal data (Article 9 GDPR), such as information on racial or ethnic origin, political or religious beliefs, health, or sexual orientation.

4. Purposes and Legal Basis of Processing

Your personal data will be processed, with consent where required, for the following purposes:

  1. Website and account security – to ensure safe browsing, registration, and account management.
    Legal basis: legitimate interest.

  2. Service delivery – to connect you with professional opportunities, allow participation in events, training, or other services, and perform administrative tasks.
    Legal basis: contract performance (Articles 6(1)(b), 22(2)(a) GDPR).

  3. Legal compliance – to fulfill obligations under laws or respond to authorities.
    Legal basis: legal obligation.

  4. Newsletter – if you subscribe, to send invitations, offers, promotions, and updates.
    Legal basis: Art. 130(4) Italian Privacy Code. Unsubscribe anytime.

  5. Marketing communications – with your consent, to send promotional content via email, SMS, MMS, automated or operator calls, app messages, or post.
    Legal basis: consent (revocable anytime).

  6. Profiling – with your consent, to analyze preferences, skills, needs, and results to suggest tailored opportunities.
    Legal basis: consent (revocable anytime).

  7. Testimonials & Reviews – with your consent, to publish your reviews, photo, name, expertise, and past companies on the Site or social media.
    Legal basis: consent (revocable anytime).

  8. Statistics – to process anonymous data for statistical purposes.

Providing data is optional, but necessary to access Cosmico’s services.

5. Data Sharing and International Transfers

We do not sell personal data for commercial purposes. Data may be disclosed only to:

  • Companies and organizations seeking profiles like yours or providing requested services (training, travel, co-working, co-living).

  • Data processors (Art. 28 GDPR): consultants in accounting, administration, legal, tax, finance; IT maintenance providers; service providers (hosting, mailing, communication systems).

  • Authorities when required by law.

  • Authorized staff of Cosmico (Art. 29 GDPR).

Some data may be transferred outside the European Economic Area under safeguards required by Articles 44–49 GDPR.

6. Data Retention

  • Account data (Art. 4.1): max 12 months after account closure request.

  • Service data (Art. 4.2): retained only as long as necessary, and for periods allowed under Italian law (Art. 2946 Civil Code).

  • Legal data (Art. 4.3): retained as required by law.

  • Newsletter & reviews (Art. 4.4 and 4.7): until you unsubscribe or request deletion.

  • Marketing & profiling (Art. 4.5 and 4.6): until consent withdrawal, and in any case max 24 months after last interaction.

Cosmico may retain data longer when permitted by Italian law (Art. 2947(1)(3) Civil Code).

7. Data Subject Rights

Under Articles 15–22 GDPR, you have the right to:

  • Withdraw consent at any time (without affecting prior lawful processing).

  • Access, verify, update, or rectify your personal data.

  • Request deletion (Art. 17 GDPR) or restriction of processing (Art. 18 GDPR).

  • Receive your data in a structured, machine-readable format (Art. 20 GDPR).

  • Object to processing (Arts. 21–22 GDPR).

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) pursuant to Article 77 GDPR.

8. Changes

Cosmico reserves the right to amend or update this privacy policy at any time. Please refer to the latest version published on the Site for details on how your data is processed.