1. Purpose
At 1Kosmos, data privacy is important to us. This Privacy Policy explains how One Kosmos Inc. and its affiliates (collectively “1Kosmos”, “One Kosmos”, “us” or “we”) collects, uses, discloses, stores, safeguards and retains your Personal Information. Please take the time to read this Privacy Policy carefully in order to understand how we collect, share, and otherwise process information relating to individuals (“Personal Data”). This Privacy Policy describes our practices with respect to the personal information we collect from professionals and other individuals who interact with us directly, such as visitors to https://www.1kosmos.com.
2. Personal Information
“Personal Information” means information, other than business contact information, about an identified or identifiable individual. This includes but shall not be limited to name, location data, identification number and such other information.
If any of your Personal Information collected or stored by us or our service providers is not accurate, complete or up-to-date, please contact our Chief Privacy Officer so that we can correct the information or direct you to the third party responsible for correcting the information.
This Privacy Policy applies to Personal Information that we collect when you use our website or services, and to public Personal Information that we may collect from third party websites. This Privacy Policy does not apply to the practices of companies or other entities that we do not own or control, or to people that we do not employ or manage. Any Personal Information that you supply, or authorize us to supply to any third parties is governed by the privacy policies of those third parties.
3. Collection
1Kosmos collects personal information from individuals who interact with us directly through our website, mobile app or at trade shows, or business meetings. We only collect personal information when we have a legal basis for doing so.
We collect information from and about you in connection with your use of the Services. Some examples of the types of information that we may collect include:
contact information, such as your name, address, telephone number, email address;
usage information and history, such as your usernames, internet protocol (IP) addresses, support ticket history, and website usage information;
meaningless but unique numbers (MBUN); and
persistent anonymous identifiers (PAI).
4. Usage
1Kosmos will not sell, rent, or trade your Personal Data. We will only transfer your Personal Data at your request, and with your consent, for use by third parties to verify your identity or community eligibility, or as required for the prevention of fraud or otherwise permitted by law. We will collect and use your Personal Information in connection with the provision of products and services from our website including:
i. delivery of our services, such as our authentication service(s) or our identity service(s)
ii. carrying out transactions that you have requested,
iii. to fulfill our contractual obligations towards you,
iv. for billing purposes,
v. in order to communicate with you about new products and services, and promotional offers, and such other marketing purposes
vi. to prevent fraud and other prohibited or illegal activities, and
vii. managing recruitment and employment relationships;
viii. to resolve disputes, enforce our agreements, and as otherwise permitted or required by law.
We may use your Personal Information, in conjunction with information available from third parties, to provide the complete functionality of our services.
5. Disclosure
We may share your Personal Information with our corporate affiliates to carry out transactions that you request or to make our business, or that of our corporate affiliates, more responsive to your needs. We will not sell, trade, or disclose to third parties any Personal Information — including customer names and addresses — without the consent of the customer.
We may share your Personal Information with third parties that we engage to provide products and services on our behalf, or to third parties on whose behalf we collect your Personal Information. We will also not disclose your Personal Information to third parties for the purposes of the third-party marketing products to you.
We may disclose your Personal Information:
to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule or regulation (including privacy laws, rules and regulations);
in response to a court order, subpoena, discovery request or other lawful judicial or administrative proceeding;
in order to comply with an applicable law, rule or regulation; and
in good faith, to protect or defend our rights or property, or the rights or property of other customers or users.
during negotiations or completion of any business transaction—such as a merger, acquisition, divestiture, sale, or financing of all or part of 1Kosmos.
your request and explicit consent, we will share your personal data with third parties to verify your identity or community eligibility, or otherwise as directed by you.
6. Accuracy
If any of your Personal Information collected or stored by us or our service providers is not accurate, complete or up-to-date, please contact our Chief Privacy Officer so that we can correct the information or direct you to the third party responsible for correcting the information.
7. TrueDepth API
Our app makes use of automatically collected information using the device camera and the TrueDepth API provided by Apple. This information is used to track the user’s head and face so that we can detect any kind of image or video spoofing thus making LiveID scan feature more robust. None of the information collected by the TrueDepth API ever leaves the user’s device nor is it persistently stored on the device.
8. Data retention
Your Personal Information will be retained only as long as necessary for the purposes for which it was collected, or until you request that we delete it, in which case it will be deleted in accordance with (and subject to) our data retention policy and our legal obligations.
You should exercise discretion when disclosing your Personal Information to us, and should not disclose sensitive or confidential information that you wish to remain private. Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.
9. Security posture & measures taken
Security is a critical priority for 1Kosmos. We maintain a comprehensive, written information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent unauthorized access to Personal Data.
We have implemented reasonable technology and security features appropriate to the sensitivity of the information to safeguard the privacy of your Personal Data from unauthorized access or improper use. These measures include, but are not limited to:
Encryption of data in transit and at rest.
Access controls and authentication mechanisms to limit data access to authorized personnel only.
Regular security assessments and vulnerability testing.
Comprehensive written information security program designed to maintain confidentiality, integrity, and availability of Personal Data.
However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your credential(s) and maintaining the security of your devices.
If you use the 1Kosmos online service via a subscription purchased for you by a 1Kosmos customer, then that customer is responsible for configuring your instance appropriately. Additional information about security settings and configurations can be found in the documentation related to our online service, including the Trust & Compliance documentation.
10. Privacy Rights
10.1. Your European Privacy Rights
Under the General Data Protection Regulation, if you are a European Union data subject, you have rights to understand and request how we collect, use, and disclose Personal Data in our capacity as a data controller to the extent permitted by applicable law.
Right to Access. You have the right to access your Personal Data held by us.
Please note that we do not have access to, or the ability to share, information about you. For information about fraudulent activities, you may contact the relevant fraud prevention agency for further information.
Right to Rectification. You have the right to rectify inaccurate Personal Data and, taking into account the purpose of processing, to ensure it is complete.
Right to Erasure (or “Right to be Forgotten”). You have the right to have your Personal Data erased or deleted, and that is under your complete control.
Right to Restrict Processing. You have the right to restrict our processing of your Personal Data where applicable.
You can ask us to do this if:
you dispute the accuracy of your personal information;
our processing is unlawful but you prefer restriction to deletion;
we no longer need the information but you need it for legal reasons; or
you have objected to our processing and we are still dealing with this objection.
If you would like to contact us about your restriction rights, please complete our online form.
Right to Data Portability. You have the right to transfer your digital Personal Data when requested, when possible, through the digital wallet.
Right to Object. You have the right to object to the processing of your Personal Data that is carried out on the basis of legitimate interests, such as direct marketing.
There are unlikely to be any circumstances when this right applies to 1Kosmos Identity Verification service personal information. If you want to contact us about your objection rights, please complete our online form.
Right Not to be Subject to Automated Decision-Making. You have the right not to be subject to automated decision-making, including profiling, which produces legal effects. 1Kosmos does not currently engage in the foregoing on our websites or in our products and services.
Right to Withdraw Consent: You may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.
Legal Basis Transparency: We process Personal Data based on consent, contractual necessity, legitimate interests, or other lawful grounds as described in this policy.
If you would like to make a request and exercise your rights described above, please complete our online form.
10.2. Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), effective January 1, 2020, if you are a California resident, you have rights to understand and request that we disclose how we collect, use, disclose, and sell your Personal Data to the extent permitted by applicable law. If you would like to learn about our verification process, including the details that you must provide to us to verify your request, click here.
Right to Know About Personal Data Collected, Disclosed, or Sold. You have the right to request that we disclose what Personal Data we collect, use, disclose, and sell.
Right to Request Deletion of Personal Data. You have the right to request the deletion of your Personal Data collected or maintained by us as a business.
Right to Opt-Out of the Sale of Personal Data. You have the right to opt-out of the sale of your Personal Data by us as a business, in the event we sell Personal Data.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right, at any time, to direct us to limit the use of your sensitive personal information to what is necessary to perform the services or provide the goods you would reasonably expect when you request those goods or services, in line with applicable law.
Right to Data Portability. You have the right to receive the specific pieces of personal information we have obtained from you in a format that is easily understandable to the average person and transmit it to another entity.
Where technically feasible, this information shall be provided in a structured, commonly used, machine-readable format.
Additionally, you have the right to request that this information be transmitted to another entity without hindrance if you so choose.
10.3. Your Indian Privacy Rights
Under Digital Personal Data Protection Act, 2023, if you have any questions or wish to know which personal data we hold about you, please contact us. If it does not conflict with any applicable laws, you are entitled to the following:
Knowledge of why your personal data is needed, what will happen to it, and the duration of its retention.
Copies of your personal data upon request, subject to certain conditions and a possible small fee for this service.
Correction of any information you believe is inaccurate, as well as completion of information you consider incomplete.
Erasure of your personal data under certain conditions.
Objection to our processing of your personal data under certain conditions.
Nomination of any other individual who, in the event of your death or incapacity, be able to exercise these rights.
Grievance redressal against your request.
Notification in the event of a personal data breach, subject to certain conditions.
Please make sure to clearly identify yourself when making a request to ensure that we do not modify or delete the data of the wrong person.
11. International Transfers of Personal Information
1Kosmos is Delaware Corporation with operations across the globe. If you reside outside the USA, your Personal Data may be processed or stored in the USA or other countries of operation which may not have equivalent privacy or data protection laws. However, regardless of where your personal information is transferred, we will protect it in accordance with this Privacy Policy and applicable laws. Please reach out to us if you require more information about our cross-border transfers.
12. Authorized Agent
You may designate an authorized agent to make a request under the CCPA on your behalf by us with a copy of your power-of-attorney document granting that right.
13. Financial Incentives.
We do not provide any financial incentives tied to the collection, sale, or deletion of your Personal Data.
If you would like to make a request and exercise your rights described above, please complete our online form, or contact us via the telephone number listed in the contact us page. If you would like to opt-out of Personal Data sharing with marketing and advertising third parties through the use of cookies, please see the section above on Your Privacy Choices. Since there is no reasonable way for us to verify information for which we are a service provider to our customers, we will not respond to any requests in relation to data we hold on behalf of our customers.
14. Third-Party Websites
Our website and services may include links to third-party websites for your convenience. Accessing and using such linked websites will result in your departure from our site. These third-party websites are subject to their own privacy policies. We advise you to review the privacy notices of each third-party website you visit before submitting any personal data. We do not exercise control over these third-party websites and are not responsible for their content or privacy practices. Should you choose to access any of the third-party websites linked from our site, you do so at your own risk.
15. Children
Our website is not designed to attract children, and it is not our intent to collect personal data from children under the age of consent in their country of residence. We therefore request that children under the age of consent do not submit any personal data to us.
16. Withdrawal of consent
You may withdraw your consent to the collection, use and disclosure of your Personal Information at any time. To do this, please contact our Chief Privacy Officer. Withdrawal of your consent to the collection, use and disclosure of your Personal Information will result in you being unable to continue to use our website or services.
17. Submitting a Complaint
If you are not satisfied with the way in which we handle a complaint about the processing of your personal data, you have the right to submit a complaint to the Data Protection Board of India.
18. Amendments to this Privacy Statement
We reserve the right to make amendments to this privacy statement. We recommend that you regularly consult this privacy statement to stay informed of any changes. Additionally, we will endeavour to actively inform you of any amendments, wherever possible.
19. Contact Details
If you have any questions, our privacy team is here to help – please reach out to us at:
Privacy Officer: Huzefa Olia
1Kosmos, Inc.
Address: 1st Floor, 399 Thornall Street, Edison, NJ 08837
Website: https://www.1kosmos.com/
Email: privacy@1kosmos.com
Phone number: +1 (833) 850-5464
