GLOBAL PRIVACY POLICY
Cosmos Language School – International Student and Parent Privacy Charter
Welcome to Cosmos Language School! We respect your privacy and are committed to protecting your personal data. This Global Privacy Policy explains how we collect, use, share, and protect your information when you visit our website, purchase our online 1:1 language instructional services, or interact with our platform.
This policy is designed to comply with the highest international data protection frameworks, including the EU General Data Protection Regulation (GDPR), the United States Children’s Online Privacy Protection Act (COPPA), California Consumer Privacy Act (CCPA/CPRA), the Australian Privacy Act 1988, and the New Zealand Privacy Act 2020.
1. Data Controller & Contact Information
Until the formal transition to a United States LLC framework, the Data Controller for your personal data is:
Katarzyna Pietrzyk, conducting individual business activities under the registered trade name Katarzyna Pietrzyk, with its registered seat at ul. Grzybowska 39/1218, 00-855 Warsaw, Poland. Tax Identification Number (NIP): 5060103172, REGON: 527015120. Email for all privacy matters: languagecosmos@gmail.com.
2. Personal Data We Collect
We collect several categories of information to provide our premium 1:1 live instructional services:
- Account & Contact Identifiers: Name, email address, phone number, billing address, and account login credentials.
- Commercial & Educational Data: Records of services purchased, language proficiency level, study preferences, and scheduling history.
- Technical & Network Activity: IP address, browser type, operating system, device parameters, and usage patterns via essential cookies and analytics tools.
- Payment Transaction Data: We process financial data through encrypted, third-party global gateways (e.g., Stripe, PayPal). Cosmos Language School never captures or stores raw credit card credentials on its servers.
3. Children’s Privacy (Strict COPPA & GDPR Compliance)
Because Cosmos Language School specializes in educational services that may be utilized by minors, we implement rigid child privacy standards:
- Adult-Only Purchases: Our public website, marketing, and purchase mechanisms are strictly directed to adults (parents or legal guardians). We do not knowingly collect personal data directly from children under the age of 13 (USA) or under 16 (EU) without verifiable parental consent.
- Minimal Child Data: When a parent registers a minor for 1:1 online sessions, we collect the minimal amount of data necessary to customize the live instruction (e.g., student first name and age). This data is isolated and protected with high-level access security protocols.
- Parental Control Oversight: Parents maintain the unconditional right to review their child’s collected parameters, halt further data collection, or demand absolute erasure of all child data records at any point by contacting languagecosmos@gmail.com.
4. Legal Bases & Purposes of Data Processing
We process your personal information under the following international legal doctrines:
- Performance of a Contract: To create accounts, manage live 1:1 lesson schedules, process global payments, and deliver live audio/video educational content.
- Legitimate Business Interests: To answer student/parent inquiries, audit structural platform performance, prevent digital fraud, and optimize our high-end educational digital assets.
- Legal Obligations: To comply with mandatory tax laws, corporate accounting mandates, or valid judicial child protection inquiries.
5. Global Data Sharing & International Transfers
Language Cosmos does not sell, rent, or lease your personal information to third-party data brokers. To deliver global cloud services, your information may be processed by trusted technical subprocessors:
- Authorized Subprocessors: Cloud video services (Google Meet), transaction gateways (Stripe), email distribution systems, and essential analytics providers.
- International Transfers (Standard Contractual Clauses): Because our operations are hosted within the European Economic Area (EEA) while serving students in the USA, Australia, and New Zealand, your data may be transferred across international borders. To ensure complete alignment with EU GDPR requirements, all data transfers outside the EEA are governed by the European Commission’s Standard Contractual Clauses (SCCs) embedded within our service partner frameworks.
6. Regional Privacy Mandates & Legal Rights
A. European Union (GDPR) Rights
If you are a resident of the EEA or UK, you possess the right to access, rectify, or erase your data, the right to restrict or object to processing, data portability, and the right to lodge a formal complaint with a European Supervisory Authority.
B. United States & California (CCPA/CPRA) Privacy Provisions
- No Sale of Personal Data: Cosmos Language School does not exchange user personal data for monetary compensation. However, under California law, utilizing analytics or ad-delivery technologies may fall under 'sharing’ or 'selling’ data. You possess the absolute right to opt-out of such exchanges via your browser settings or by sending a direct 'Do Not Sell or Share My Info’ request to our support email.
- Non-Discrimination Guarantee: We do not selectively discriminate or change our premium pricing metrics based on your decision to enforce your privacy rights.
C. Australia (Privacy Act 1988)
In accordance with Australian Privacy Principles, we explicitly disclose that your personal data may be stored or transferred to secure cloud datacenters located in the United States and the European Union via our premium service partners (Google, Stripe).
7. Retention & Data Erasure
We retain personal information only as long as necessary to fulfill active educational accounts, complete operational tax obligations, or satisfy necessary international legal requirements. Upon expiration of the retention timeline, data is securely overwritten or permanently anonymized.
8. Policy Modifications & Effective Date
We update this policy periodically to reflect shifting global digital privacy mandates. If significant structural updates occur, we will notify registered parents via email.
Global Privacy Policy Effective Date: May 26, 2026