Please read these terms and conditions (the “Terms”) before using the Cosmos Finance Website (the “Website”). The Website is operated by Brit FX Limited, trading as Cosmos Finance, Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY and Sreda Money Ltd, trading as Cosmos Finance, 422 Richards Street, Suite 170 Vancouver, BC, Canada
V6B2Z4 (the “Website Operator.”) By using the Website, you signify your acceptance of the Terms in consideration of which, the Website Operator provides you with access. The Website Operator may occasionally modify the Terms. Accordingly, please continue to review the Terms whenever accessing or using the Website. If at any time you do not wish to accept the Terms, you may not use the Website. The Website Operator may occasionally run competitions and promotions via the Website. Separate terms and conditions will be posted where applicable governing such competitions and promotions.
Website Copyright © Cosmos Finance 2024. All rights reserved.
This website, including but not limited to its design, graphics, text and dynamic content, is protected in accordance with The Copyright, Designs and Patents Act 1988. It may not be reproduced in part or whole without the express written permission of The Website Operator.
The Website Operator owns all the Intellectual Property Rights relating to the Website, including but not limited to its design, imagery, graphics, programming & structure.
You may not copy anything on the site without the express written permission of The Website Operator. You are granted the right only to view the site and print material from it.
For more information, please contact:
Brit FX Limited
Ground Floor Offices
The Belmont,
Middleton Road,
Manchester,
England, M8 4JY.
Sreda Money Ltd,
422 Richards Street, Suite 170 Vancouver, BC, Canada
V6B2Z4
The Website Operator has endeavoured to ensure the accuracy of the information accessed via the Website, The Website Operator does not guarantee or give any warranty as to the accuracy, timeliness or completeness of any information or material on the Website.
Websites or pages to which the Website is linked are for information only and have not been reviewed by The Website Operator. The Website Operator has no responsibility for the content of the Websites or pages linked or linking to this Website, The Website Operator accepts no responsibility or liability for any losses or penalties whatsoever that may be incurred as a result of any linking to any location on any linked Websites.
The Website, including (but not limited to) text, content, software, video, music, sound, graphics, photographs, illustrations, artwork, photographs, names, logos, trademarks, service marks and other material (“Content”) is protected by copyrights, trademarks and/or other proprietary rights. The Content includes both content owned or controlled The Website Operator and content owned or controlled by third parties and licensed to The Website Operator. All individual articles, reports, and other elements making up the Website may be copyright works. You agree to abide by all applicable copyright laws and by all additional copyright notices or restrictions contained in the Website.
You may not use any of The Website Operator’s trademarks or trade names without The Website Operator’s prior express written consent and you acknowledge that you have no ownership rights in and to any of those names and marks.
You agree to notify The Website Operator in writing promptly upon becoming aware of any unauthorised access to or use of the Website by any party or of any claim that the Website or any of the contents of the Website infringes any copyright, trade mark, or other contractual, statutory or common law rights of any party.
You acquire no rights or licences in or to the Website and/or the Content other than the limited right to use the Website in accordance with these Terms and to download on the terms set out in this section. Other than as set out in this section you may not copy, reproduce, recompile, decompile, disassemble, reverse engineer, distribute, publish, display, perform, modify, upload to create derivative works from, transmit, or in any other way exploit any part of the Website.
Download is permitted by The Website Operator provided only that:
(i) you make no more than one printed copy of such download and no further copies of such printed copy are made;
(ii) you make only personal, non-commercial use of such download and/or printed copy; and
(iii) you retain on such download and/or printed copy all copyright notices and shall remain bound by the terms of such wording and notices.
Additionally, you may not offer for sale or sell or distribute over any other medium (including distribution by over-the-air television or radio broadcast or distribution on a computer network) the Content or any part thereof. You may not make any part of the Website available as part of another Website, whether by hyperlink framing on the internet or otherwise. The Website and the information contained therein may not be used to construct a database of any kind, nor may the Website be stored (in its entirety or in any part) in databases for access by you or any third party or to distribute any database Websites containing all or part of the Website.
If you would like information about obtaining The Website Operator’s permission to use any of the Content, write to:
Cosmos Finance,Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY,
Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, Canada
V6B2Z4
marking it ‘Website’.
The Website and the Content are provided “as is” excluding any warranties of any kind, either express or implied, to the fullest extent permissible pursuant to applicable law including (but not limited to) the exclusion of warranties of title, merchantability, satisfactory quality, fitness for a particular purpose and non-infringement of proprietary or third party rights. The Website Operator further accepts no responsibility or liability for functions contained on the Website and makes no warranties that the Website will operate uninterrupted or error-free or that defects will be corrected. Please note that some jurisdictions do not allow the exclusion of implied warranties, so some or all of the above exclusions may not apply to you.
The Website Operator does not warrant that the Website is compatible with your computer equipment or that the Website or its server is free of errors or viruses, worms or “Trojan horses” and The Website Operator is not liable for any damage you may suffer as a result of such destructive features.
The Website Operator shall not be held responsible for Content provided by third parties. The Website Operator is also not responsible for the reliability or continued availability of the telephone lines and equipment you use to access the Website.
These Terms do not affect your statutory rights or your legal rights as a consumer.
You acknowledge that your use of the Website, including the Content is at your own risk. If you are dissatisfied with the Website, the Terms or any or the Content your sole remedy is to discontinue use of the Website.
Save in respect of fraud and of personal injury or death to the extent it results from The Website Operator’s negligence, in no event will The Website Operator be liable to you or any third party for any direct, special, indirect, consequential or incidental damages, exemplary or lost profits, or any other damages of any kind whether based on warranty, contract, tort (including negligence) or otherwise, even if The Website Operator has been advised of the possibility thereof. Applicable law may not allow the limitation or exclusion of liability for consequential or incidental damages, so this limitation or exclusion may not apply to you.
The Website is not directed at any person in any jurisdiction where for any reason the publication or availability of the Website is prohibited. Those in respect of whom such prohibitions apply must not access the Website.
The Website Operator does not represent that either the Website or the Content are appropriate for use or permitted by local laws in all jurisdictions. Those who access the Website do so on their own initiative and are responsible for compliance with applicable local laws or regulations; legal advice should be sought in cases of doubt.
You agree to indemnify, defend, and hold harmless each of The Website Operator, its employees, representatives and agents, from and against any claims, actions, demands or other proceedings brought against any of The Website Operator, its employees, representatives or agents, by a third party, to the extent that such claim, suit, action or other proceeding brought against The Website Operator, its employees, representatives, suppliers, or agents is based on or arises in connection with:
(i) your use of the Website;
(ii) any breach by you of the Terms;
(iii) a claim that any use of the Website by you
(iv) infringes any intellectual property rights of any third party, or any right of personality or publicity, or
(v) is libellous or defamatory, or otherwise results in injury or damage to any third party;
(vi) any deletions, additions, insertions, or alterations to, or any unauthorised use of, the Website by you; or
(vii) any misrepresentation or breach of representation or warranty made by you contained herein.
References in this section of the Terms to your use of the Website shall be deemed to include any use by a third party where such a third party accesses the Website using your computer.
You agree to pay The Website Operator, its employees, representatives, and agents any and all costs, damages, and expenses (including reasonable legal fees) awarded against any of them or otherwise incurred by any of them in connection with or arising from any such third party claim, suit, action or proceeding attributable to any such third party claim.
Either you or The Website Operator may terminate these terms with or without cause at any time. If the Website Operator terminates these terms, The Website Operator will email you at the address you provide on registration, and you will be deemed to have received it within one hour of transmission. Termination will be effective at that time. You will be responsible for notifying us of any changes to your email address. You may terminate by writing to: Brit FX Ltd ,Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY, for UK and Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, Canada V6B2Z4, for Canada.
marking it ‘Website’. . On termination you shall destroy all Content, and copies thereof, obtained from the Website.
You accept that The Website Operator has the right to change the content or technical specifications of any aspect of the Website at any time at The Website Operator’s sole discretion. You further accept that such changes may result in your being unable to access the Website.
No waiver by The Website Operator of any breach of any obligation arising under these Terms shall constitute a waiver of any other breach and no failure to exercise or partial exercise The Website Operator of any remedy shall constitute a waiver of the right subsequently to exercise that or any other remedy.
The Terms are governed by the laws of England and Wales and the parties submit to the exclusive jurisdiction of the English courts.
This Privacy Policy depicts your privacy rights in terms of gathering, use, storing, sharing, and protecting your personal data (hereinafter – Personal data), as well as the scope of processed Personal Data, the purposes, sources, recipients and other important aspects of data processing by registering, accessing, or using Cosmos Finance (Brit FX Limited), Suite 12, Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY and Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, CanadaV6B2Z4 (hereinafter – the Company or we) products, services, solutions, features, and technologies. If you do not agree, you should stop accessing our website https://www.cosmosfinance.com (hereinafter – Website), or our services immediately and refrain from further access and use of them. We respect the privacy of every individual who visits our Website.
We use and process your personal data in accordance with this Privacy Policy and in compliance with the applicable legal acts such as:
When writing “you”, we refer to you as a potential, existing, former client of the Company, our client’s employee or other related party such as beneficial owner, authorized representatives, business partners, other associated parties or a user of our Website.
We process your personal data with the following principles:
If you are a potential client, or register with us as a client, we will ask you for information about yourself. The categories of personal data that we may collect about you are as follows:
| Type of information | Personal data |
| Basic Personal Data | Name, surname, job title etc. |
| Identification information and other background verification data (your or your representative’s, ultimate beneficiary owner’s of legal entities) | (your or your representative’s, ultimate beneficiary owner’s of legal entities) name, surname, personal identity code, date of birth, address, nationality, gender, passport or ID card copy, evidence of beneficial ownership or the source of funds, number of shares held, voting rights or share capital part, title, visually scanned or photographed image of your face or image that you provide through a mobile application or camera, video and audio recordings for identification, telephone conversations to comply with client due diligence/”know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures. |
| Financial data | Transactional data (e.g. beneficiary details, date, time, amount and currency which was used, name/IP address of sender and receiver), accounts, amount of transactions, income, location, etc. |
| Information related to legal requirements | Data resulting from enquiries made by the authorities, data that enables us to perform anti-money laundering requirements and ensure the compliance with international sanctions, including the purpose of the business relationship and whether you are a politically exposed person and other data that is required to be processed by us in order to comply with the legal obligation to “know your client”. |
| Contact data | Registered/actual place of residence, phone number, email address etc. |
| Special category data | Biometrical data, i.e. physical, or behavioral characteristics resulting from specific technical processing used during remote identification which confirms the unique identification of a person, e.g. facial images. We do not process special category data related to your health, ethnicity, or religious or political beliefs unless required by law or in specific circumstances where, for example, you reveal such data while using services (e.g. in payments details). |
| Any other Personal Data related to you that you may provide |
Your personal data is processed in accordance with the purposes and legal basis indicated in the table below.
The definitions from the table above are understood as follows:
Legitimate Interest: The interest of ours as a business in conducting and managing our services to enable us to provide to you and offer the most secure experience.
Contract performance: Processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legal Obligation: Processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: Your consent shall mean any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify your agreement to the processing of personal data relating to you. We can request from you a consent for processing when we do not have another legal basis for processing of your data.
| Purpose | Legal basis | Categories of Personal Data |
| Conclusion of the contract or for performance of measures at your request prior to the conclusion of the contract (to get to know, identify and verify our clients) | Contract performance | Basic Personal Data; Identification and other background verification data; Contact Data; Other Personal Data needed (in order to identify the possibility of providing services). |
| For the fulfilment of a contract concluded with you, including but not limited to provision of services of issuance, distribution and redemption of electronic money and provision of payment services | Contract performance | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| Verification of your identity, prevention of money laundering and fraud, control and reporting obligations, for example: Know Your Customer requirements, Preventing, detecting, and investigating money laundering, terrorist financing, and fraud, sanctions screening; risk management obligations Reporting to tax authorities, police authorities, enforcements authorities, supervisory authorities Bookkeeping regulations, Other obligations related to service or product specific legislations | Complying with legal obligations applicable to us | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing our services. |
| For remote identification of your personal identity (matching the photo image or video records of your face point that you provide through a mobile app or camera with your ID document) | Your consent | Special category data, i.e. biometrical data |
| To prevent, limit and investigate any misuse or unlawful use or disturbance of the services or to establish, exercising and defend legal claims | Legitimate interests | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| To ensure adequate provisions of the services, the safety of information within the Services, as well as to improve, develop and maintain applications, technical systems and IT-infrastructure or our legitimate business interests , such as enabling us to improve and deliver a better and more personalized service. | Legitimate interests | Basic Personal Data; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| To provide an answer when you contact us through our website or other communication measures | Contract performance | Basic Personal Data; Contact Data; Other Personal Data provided to us by you. |
| Direct marketing | Your consent | Basic Personal Data; Contact Data; Other Personal Data provided to us by you. |
We collect information you provide directly to us. For example, when becoming a new client (if you have entered into or seek to enter into an agreement with us). The Company also collects information which you provide to us, such as messages that you have sent to us, by access and use of our website or mobile application, by setting up an account with us, when you subscribe to our electronic publications (e.g. newsletters).
Personal Data that we may collect from third parties:
In order to make your identity verification, we are using several tools/solutions provided by our partners.
We are using the “Jumio”. The solution matches the photo image or video records of your face point that you provide through a mobile app or camera with your ID document. For more information on “Jumio” please read its privacy policy:
https://www.jumio.com/privacy-center/privacy-notices/online-services-notice/
“Jumio” solution is used for comparing live photographic data or video record of yourself and your ID card/passport, to comply with legal obligations.
The result of the face similarity (match or mismatch) will be retained for as long as it is necessary to carry out verification and for the period required by anti-money laundering laws.
We ensure that the checks disclosed above are a process of comparing data acquired at the time of the verification, i.e. this is a one-time user authorization.
Your provided data is not created, recorded and stored. It is not possible to regenerate the raw data from retained information. These processes shall allow us to verify you more precisely and will make the process quicker and easier to execute.
Using “Jumio” services, personal data is used for your identification since “Jumio” verifies the identity of the person in the identity document and the person captured in the photo.
If you do not feel comfortable with these identification methods disclosed above, you may contact us by email at cco@cosmosfinance.com for an alternative way to identify yourself.
You as a data subject shall have the rights in respect of Personal Data that we hold on you. You have the following rights for your Personal Data that we have about you:
For Complaints regarding the services of Cosmos Finance:
You can contact us via email complaints@cosmosfinance.com or by personally appearing at our registered office address at Suite 12, Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY or by ordinary mail sent to our registered address.
For Canda , Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, Canada
V6B2Z4
We ask you to clearly disclose your name, surname, contact details and the relevant information, which you should indicate why you reasonably feel that we may process your personal data by violating GDPR or other applicable legal acts.
Your requests addressed to “Cosmos Finance”, shall be fulfilled or fulfilment of your requests shall be refused by specifying the reasons for such refusal within 30 (thirty) calendar days from the date of submission of the request meeting our internal rules and GDPR. The afore-mentioned time frame may be extended for 30 (thirty) calendar days by giving a prior notice to you if the request is related to a great scope of Personal Data or other simultaneously examined requests. A response to you will be provided in a form of your choosing as the requester. We, after examining the complaint, report the results and actions taken to satisfy your complaint, or provide relevant information on what further actions you may take if your complaint was not satisfied.
However, please be informed that if you believe that the Personal Data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation You may lodge a complaint to relevant authorities.
For complaints regarding Cosmos Finance Payments Europe services: you may address the State Data Protection Inspectorate with a claim regarding the processing of your Personal Data if you believe that the Personal Data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation. You may apply in accordance with the procedures for handling complaints that are established by State Authorities,For complaints regarding “Cosmos Finance” you may address the UK data protection regulator, the Information Commissioner’s Office (ICO) which may be found by this link: https://ico.org.uk/make-a-complaint/
We will retain your data for a statutory period, following the principle of limitation of the length of the storage.
We may use your data for as long as reasonably necessary for the limited purpose of providing our services to you.
The terms of retention of the personal data for the purposes of the processing of the personal data as defined in this Privacy Policy are following:
In the cases when the terms of data keeping are indicated in the legislative regulations, the legislative regulations are applied.
Your Personal Data might be stored longer if:
In some cases, we may use automated decision-making which refers to a decision taken solely on the basis of automated processing of your Personal Data.
Automated decision-making refers to the processing using, for example, a software code or an algorithm, which does not require human intervention.
We may use forms of automated decision making on processing your Personal Data for some services and products. You can request a manual review of the accuracy of an automated decision in case you are not satisfied with it.
We may transfer your Personal Data in accordance with the principles of confidentiality to the following categories of recipients:
– between the companies belonging to Cosmos Finance;
– our business partners, agents or intermediaries who are a necessary part of the provision of our products and services, as well as, card organizations (such as VISA or MasterCard) – in connection with our payment services;
– governmental bodies and/or supervisory authorities (in accordance with the requirements and obligations under the provisions of legal acts concerning anti-money laundering, fraud prevention, counter terrorist financing), credit, financial, payment and/or other electronic money institutions;
– pre-trial investigation institutions, the State Tax Inspectorate, ICO;
– lawyers, bailiffs, auditors etc.;
– service providers, who make your identity verification by using their IT solutions;
– companies providing services for money laundering, politically exposed persons and terrorist financing check-up and other fraud and crime prevention purposes and/ or companies providing similar services;
– external service providers (that provide such services as, for example, system development and/or improvement, audit services);
– beneficiaries of transaction funds receiving the information in payment statements together with the funds of the transaction;
– other entities that have a legitimate interest or the Personal Data may be shared with them under the contract which is concluded between you and us;
– other entities under an agreement with us.
For the purpose to provide you our services we can engage third-party service providers outside the European Economic Area (hereinafter – EEA). The transfer of Personal Data may be considered as needed in such situations as, e.g.:
– in order to conclude the contract between you and us and/or to fulfill the obligations under such contract;
– in cases indicated in laws and regulations for protection of our lawful interests, e.g. in order to bring proceedings in court/other governmental bodies;
– in order to fulfill legal requirements or in order to realize public interest.
As well, in other case your Personal Data is transferred outside the EEA, we will take all steps to ensure that your data is treated securely and in accordance with this Privacy Policy and we will ensure that it is protected and transferred in a manner consistent with the legal requirements applicable to the Personal Data. This can be done in a number of different ways, for example:
– the country to which we send the Personal Data, a territory or one or more specified sectors within that third country, or the international organization is approved by the European Commission as having an adequate level of protection;
– the recipient has signed standard data protection clauses which are approved by the European Commission;
– special permission has been obtained from a supervisory authority.
We may transfer Personal Data to a third country by taking other measures if it ensures appropriate safeguards as indicated in the GDPR.
From time to time we may offer to distribute news and other marketing content to individuals who have asked us to do so. We will do this via mailing lists.
You always have the chance to withdraw your consent once you give your consent for us, even before receiving your first email with our news or other marketing content. In cases when you do not object to the use of your e-mail for the marketing of our similar goods and services you are granted with clear, free of charge and easily realizable unsubscribe link in all emails from our mailing lists, so that you can remove your contact information at any time. We shall state in each notification sent by email that you are entitled to object to the processing of the personal data or refuse to receive notifications from us.
We will only contact you via your email address in the way which you have given your consent and we will only send you emails on topics as described during the mailing list signup, for instance, news about our products.
We will not share our mailing list subscribers with any other third party, other than as required for us to send emails to the mailing list.
We will only store email addresses in our mailing list.
In case you do not agree to receive these marketing emails offered by us, our business partners or third parties, this will not have any impact on the provision of services to you as the client.
We use cookies and other similar technologies to ensure the stable operations of our website, in order to adapt its content to your needs, to improve the features of our website and to manage advertising campaign based on the interests of our website audience.
For more information regarding cookies, please read our COOKIE POLICY.
The Company will take reasonable precautions to prevent the loss, misuse, accidental or unlawful destruction, modification, disclosure, unauthorized access alteration or any other unlawful handling of information you give us. Agents or contractors of us who have access to information which you give us in the course of providing services to Cosmos Finance are required to keep that information confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for Cosmos Finance.
The Company and any third-party service providers that may engage in the processing of Personal Data on our behalf (for the purposes indicated above) are also contractually obligated to respect the confidentiality of the Personal Data.
Cosmos Finance will maintain all applicable PCI DSS requirements to the extent proportionate to the cardholder data processed or transmitted on behalf of you, or to the extent that Cosmos Finance could impact the security of your cardholder data environment.
We regularly review this Privacy Policy and reserve the right to modify it at any time in accordance with applicable laws and regulations. Any changes and clarifications will take effect immediately upon their publication on our Website.
Please review this Privacy Policy from time to time to stay updated on any changes.
You may contact us by writing to us at cco@cosmosfinance.com or post us at our relevant registered office address.
Our data protection officer (hereinafter – DPO) continuously monitors our privacy compliance and communicates with us on data protection matters relevant to the provision of our services. You may contact our DPO regarding all issues relating to our company’s processing of your personal data and the exercise of your data protection rights by sending an e-mail to the address: cco@cosmosfinance.com
Privacy policy last modified on: 22nd April 2024
