Cookie Policy

1. Who we are

This Cookie Policy explains how the website cosmy.ai uses cookies and similar technologies. The data controller is:

Laizy S.r.l.
Via Paolo da Cannobio 9, 20122, Milan, Italy
VAT number: IT04138990926
privacy@cosmy.ai

This policy covers the public website. How we process personal data in general, including within the Cosmy application, is described in our Privacy Policy, which you should read together with this page.

2. What are cookies

Cookies are small text files that a website stores on your device when you visit it. Similar technologies, such as local storage, pixels and scripts that read information from your device, work in a comparable way and are covered by this policy. In this policy, "cookies" refers to all of them.

Cookies set by the website you are visiting are first-party cookies. Cookies set by another company's domain (for example PostHog's) are third-party cookies.

3. Legal basis and your consent

We use two categories of cookies:

• Strictly necessary cookies are needed for the website to work and to remember your cookie choices. Under Art. 122 of the Italian Privacy Code (Legislative Decree 196/2003), which implements the EU ePrivacy Directive, they do not require your consent. The legal basis is our legitimate interest in running the website (Art. 6(1)(f) GDPR).
• Analytics cookies help us understand how visitors use the website so we can improve it. We set them only if you consent (Art. 122 Italian Privacy Code and Art. 6(1)(a) GDPR). We do not set advertising cookies ourselves. With your consent, Google Analytics uses Google signals, described in section 4.

How consent works on our website, in line with the Italian Data Protection Authority's (Garante) cookie guidelines of 10 June 2021:

• No analytics cookies are set and no analytics scripts are loaded before you make a choice;
• Our cookie banner lets you accept all, reject all or choose by category. Rejecting is as easy as accepting;
• Closing the banner (with the "X") counts as rejecting. Scrolling or continuing to browse does not count as consent;
• We remember your choice for 6 months and do not ask again before then, unless something in this policy changes significantly;
• You can change your mind or withdraw your consent at any time, as easily as you gave it, through the "Cookie settings" link at the bottom of every page. Withdrawing consent does not affect processing that took place before.

Refusing analytics cookies has no effect on your ability to use the website.

4. Cookies we use

Strictly necessary

Analytics (only with your consent)

Google Analytics 4 (Google Ireland Limited) measures traffic and page views. Google Analytics 4 does not log or store IP addresses. We have turned on Google signals: for visitors who are signed in to a Google account and have allowed ad personalization in their Google settings, Google can associate this website's analytics data with that account, so we get aggregated cross-device reports and audience insights (for example age range and interests). To do this, Google Analytics also contacts Google's advertising domains (such as doubleclick.net and google.com), where Google may use its own cookies under the Google partner sites policy. We only see aggregated reports, never individual Google accounts, and you can turn ad personalization off in your Google Ad Settings. Analytics data is kept for 14 months at most.

PostHog (PostHog Inc., EU Cloud) is product analytics for the website. It records page views, clicks and other usage events to help us understand how the site is used. It also makes session recordings: a replay of how you move through the pages (scrolling, clicks, page changes). Everything you type into form fields is masked before it leaves your browser, and recordings are deleted after 30 days. We do not create identified person profiles on the website. The PostHog identifier is shared with the Cosmy app at app.cosmy.ai: if you later sign in to the app, your earlier website visits, including how you first found us (for example the referring site or campaign), are linked to your Cosmy account.

Google Tag Manager (Google Ireland Limited) is the tool we use to load Google Analytics 4 and PostHog, only after you consent. It does not set cookies itself.

5. Third parties and transfers

Google and PostHog process analytics data on our behalf, under data processing terms we have agreed with them. PostHog is configured on its EU Cloud. Where data is transferred to the United States, it is covered by the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR), and where applicable by the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023).

For more on how these providers handle data, see the Google Privacy Policy and the PostHog Privacy Policy.

6. Managing your preferences

• On our website: use the "Cookie settings" link at the bottom of any page to see and change your choices;
• In your browser: you can block or delete cookies in your browser settings. Blocking strictly necessary cookies means we cannot remember your choices, so the banner will appear again;
• Google Analytics: you can also install the Google Analytics opt-out browser add-on.

7. Your rights

Under the GDPR you have the right to access, correct and delete your personal data, to restrict or object to its processing, to data portability, and to withdraw your consent at any time. To exercise these rights, write to privacy@cosmy.ai. Details are in our Privacy Policy.

If you believe we have not handled your data correctly, you can lodge a complaint with the supervisory authority:

Garante per la protezione dei dati personali
Piazza Venezia 11, 00187, Rome, Italy
www.garanteprivacy.it

8. Changes to this Cookie Policy

We may update this Cookie Policy when the technologies we use or the law change. The date at the top of this page shows the latest version. If we add cookies for a new purpose, we will ask for your consent again before setting them.

9. Contact

For any questions about this Cookie Policy or how we use cookies:

Laizy S.r.l.
Via Paolo da Cannobio 9, 20122, Milan, Italy
privacy@cosmy.ai