Privacy Policy

1.Information We Collect

We collect personal information when you voluntarily provide it by registering, purchasing, subscribing, completing forms, interacting with our platforms or contacting us. This information may include:

• Identification data: full name, email address, phone number.
• Payment data: information securely processed by our authorized payment providers. The Company does not store credit or debit card data directly.
• Demographic data: country, language, content preferences.
• Browsing data: IP address, browser type, pages visited, time on page, traffic source, device used.
• Interaction data: messages sent through forms, chatbots, WhatsApp or email.
• Content consumption data: course progress, membership sessions, attendance at webinars and virtual events.
• Consent records: date, time, time zone, IP address and the exact text of the consent checkboxes you check on our forms.
• Source data: program or service of interest, profile assigned by our questionnaires, referring page and campaign parameters (UTM).
• Recordings and transcripts: of classes, mentoring, live sessions and calls with artificial intelligence agents, when you are informed in advance.
• NEU app data: content usage, device type, operating system and notification preferences.
• Business client data (Cosmos AI): business contact details and data of the people who interact with the AI agents we implement for that client.

2.Use of Information

The information collected is used exclusively for the following purposes:

• Processing purchases, payments and access to digital products and services.
• Sending transactional communications related to your purchase or registration.
• Sending promotional, educational and marketing communications with your prior consent.
• Personalizing your experience on the Platforms.
• Improving the design, content and operation of our products and services.
• Complying with legal obligations and resolving disputes.
• Protecting the security of the Platforms and preventing fraud.
• Managing interactions with artificial intelligence agents and automations.

Important: The Company does not sell, rent or transfer your personal information to third parties for their own commercial purposes. We only share it with authorized service providers under confidentiality agreements, or when required by a court order.

3.Cookies and Tracking Technologies

The Platforms use cookies and similar third-party analytics, advertising and tracking technologies to improve the user experience, analyze traffic and optimize our marketing communications. Non-essential cookies are only activated after you give your consent through the cookie banner, where you can accept, reject or configure them by category. We use, among others, Google Analytics and Google Tag Manager and, on pages that receive advertising traffic, advertising pixels such as Meta's.

Types of cookies we use:

• Necessary cookies: essential for the basic operation of the Platforms. They cannot be disabled.
• Functional cookies: enable additional features, such as videos, content sharing or remembering your preferences.
• Analytics cookies: help us understand how users interact with the Platforms through web traffic measurement and analysis tools.
• Performance cookies: measure the speed and performance of the Platforms.
• Advertising cookies: used to show relevant content and advertising based on your browsing behavior, for retargeting, and to measure our campaigns.

You can control or delete cookies from your browser settings. Please note that disabling certain cookies may affect the functionality of the Platforms. The tracking tools used on the Platforms may change over time as the Company adopts new analytics and advertising technologies.

For the full list of cookies, their purpose and duration, see our Cookie Policy. You can change your choice at any time using the "Cookie Preferences" button in our Cookie Policy or the "Do Not Sell or Share My Personal Information" link in the footer.

4.Sharing Information with Third Parties

The Company may share your personal information only in the following cases:

• Authorized service providers: companies acting on behalf of the Company to operate the Platforms, including payment processors (such as Stripe), digital content delivery platforms, CRM and automation (such as GoHighLevel), email marketing and analytics tools, artificial intelligence providers, and marketing, sales and advertising agencies hired by the Company, under confidentiality and data processing agreements that prohibit them from using such data for their own purposes or for other clients.
• Partners, collaborators and affiliates: authorized people or companies that work with the Company to promote or deliver services (for example, facilitators, support or affiliates promoting our programs). They only receive the minimum information needed to deliver the service or settle commissions (for example, referral metrics), under confidentiality agreements, and never receive your contact data for their own marketing.
• Legal requirement: when required by law, regulation, legal process or a valid government order.
• Protection of rights: when necessary to protect the rights, property or safety of the Company, its users or the public.
• Corporate transactions: in the event of a merger, acquisition or asset sale, your information may be transferred as part of that transaction, with prior notice.
• Third-party sales platforms: when you purchase through Hotmart or another sales platform, that platform collects and processes your data as an independent controller, under its own privacy policy, and shares with the Company the data needed to deliver the product.

Any use of your data by third parties for their own commercial purposes will require your prior and express consent.

5.Communications and Consent

• Email: when you register or purchase, you will receive transactional emails (access, receipts, service notices) and, unless you indicate otherwise, educational, promotional and news emails from the Company and its brands.
• SMS, WhatsApp and calls: promotional text messages, WhatsApp messages and calls, including those made by artificial intelligence agents with an artificial voice, are only sent if you have given your express written consent through the corresponding checkbox on our forms. That consent is optional and is not a condition of purchase.
• Conversations you start: when you message or call us through any channel (WhatsApp, SMS, phone, chat or form), we may reply through that same channel, by people or artificial intelligence agents, to handle your request.
• Channels and communities: joining our broadcast channels, groups or social media does not constitute consent to receive communications outside that platform.

You may unsubscribe at any time by clicking the unsubscribe link included in any email, replying "STOP" to any SMS or WhatsApp message, or emailing [email protected].

Unsubscribing from promotional communications does not affect strictly necessary transactional communications related to your purchase or active membership.

6.Use of Artificial Intelligence and Automations

The Platforms may include artificial intelligence agents, chatbots and automation systems designed to improve the user experience, answer questions, manage sales processes and provide support. By interacting with these systems, you acknowledge and accept that:

• AI agents may collect and process information you provide during the interaction, including name, email, phone and questions asked.
• Information collected by these systems is used to improve service quality and personalize your experience. It is not shared with third parties except in the cases described in Section 4.
• Responses generated by artificial intelligence are informational and do not constitute legal, financial, medical, psychological or any other professional advice.
• The Company implements reasonable security measures to protect the information processed by these systems.
• Voice agents identify themselves as artificial intelligence at the start of each call. Calls and conversations may be recorded and transcribed, with prior notice, for quality, security and service improvement purposes.
• Information may be processed through artificial intelligence providers hired by the Company, under agreements that prohibit them from using your data to train publicly available models.

The use of any artificial intelligence or automation tool on the Platforms implies automatic acceptance of the terms described in this section.

7.Information Security

The Company implements reasonable technical, administrative and physical measures to protect your personal information against unauthorized access, alteration, disclosure or destruction. However, no security system is completely infallible. Transmitting information over the internet carries inherent risks that the Company cannot guarantee to eliminate entirely.

In the event of a security breach affecting your personal data, the Company will notify you in accordance with applicable law.

8.User Rights

Under applicable laws, including the EU General Data Protection Regulation (GDPR) and the UK GDPR for users in the European Union and the United Kingdom, and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), for California residents, you have the following rights:

• Access: request a copy of the personal data we hold about you.
• Rectification: request the correction of inaccurate or incomplete data.
• Erasure: request the deletion of your personal data, subject to legal retention obligations.
• Portability: request the transfer of your data to another provider in a structured format.
• Objection: object to the processing of your data for direct marketing purposes.
• Non-discrimination: you will not be discriminated against for exercising any of these rights.
• Withdraw consent: withdraw at any time the consent you have given, without affecting the lawfulness of prior processing.
• No sale or sharing: the Company does not sell your personal information for money. However, certain advertising cookies and pixels may be considered a "sale" or "sharing" of personal information for cross-context behavioral advertising under certain U.S. state privacy laws. You can opt out using the "Do Not Sell or Share My Personal Information" link in the footer. We also honor Global Privacy Control (GPC) signals sent by your browser.

To exercise any of these rights, contact us at [email protected]. We will respond within the time limits established by applicable law.

These rights are also recognized for residents of other U.S. states with privacy laws and of Latin American countries with personal data protection laws (habeas data), under the terms of their local legislation.

9.Minors

The Platforms are intended for adults. Minors may only access them under the supervision and responsibility of their parents or legal guardians, who assume full responsibility for such access, including the use of content related to artificial intelligence, automations and business development. The Company cannot verify the age of its users and disclaims all liability arising from unsupervised access by minors.

The Company does not knowingly collect personal information from children under 13. If we become aware that we have received it, we will delete it immediately. If you are a parent or guardian and believe a minor has provided us with data, email us at [email protected].

10.Data Retention

The Company retains your personal information for as long as necessary to fulfill the purposes described in this Policy, unless the law requires or permits a longer retention period. The criteria used to determine retention periods include the length of the business relationship, applicable legal and tax obligations, and dispute resolution.

11.International Data Transfers

The personal information you provide may be transferred, stored and processed in the United States of America or other countries where we operate or where our service providers are located, regardless of the country from which you access the Platforms or make a purchase. This includes, without limitation, countries in Latin America, Europe, Asia and any other region of the world.

By using the Platforms, you expressly consent to this international data transfer. The Company will adopt appropriate contractual and security measures to ensure that your data is treated with the same level of protection described in this Policy, regardless of its geographic location.

For transfers of data of people in the European Union, the United Kingdom or other jurisdictions that require it, the Company uses recognized mechanisms, such as standard contractual clauses, or relies on equivalent safeguards offered by its providers.

11A.Recordings and Use of Image

Classes, mentoring sessions, membership sessions and live events may be recorded and made available to the participants of that program. By participating, your image, voice, name and contributions may be included in those recordings. We will not use your image for advertising purposes without your express authorization. You may keep your camera off and participate in writing if you do not wish to appear.

11B.NEU App

The NEU app collects the data it needs to work: account, content usage, device type, operating system and notification preferences. The subscription is purchased and paid only through the Company's website, not inside the app. We use usage analytics (for example, Google Analytics for Firebase) to improve the app. You can turn off notifications and request the deletion of your account at any time.

11C.Cosmos AI Business Clients

When Cosmos AI implements artificial intelligence agents, automations or systems for a business client, the Company processes the data of that client's contacts on behalf of and under the instructions of the client, in accordance with the service contract and, where applicable, a data processing agreement. In those cases, the business client is responsible for informing its own contacts and obtaining the necessary consents.

11D.Communities and Third-Party Platforms

Our private groups and broadcast channels on third-party platforms (WhatsApp, YouTube, Spotify, Instagram, TikTok, Facebook, LinkedIn, Zoom, among others) are also governed by each platform's privacy policy. Information you post in those communities may be visible to other members. Neither the Company nor its brands are associated with those platforms.

11E.Data Controller

The controller of your personal data is Cosmos Digital Group LLC, 155 Willowbrook Blvd, Suite 110, #7840, Wayne, New Jersey 07470, USA. For any privacy question or to exercise your rights, email [email protected].

12.Changes to this Policy

The Company reserves the right to modify this Privacy Policy at any time. Any change is effective upon publication on the Platforms. The "Last updated" date at the top of the document reflects the current version. We recommend reviewing this Policy periodically. Continued use of the Platforms after changes are published constitutes your acceptance of them.