1. Introduction

This Privacy Policy describes how COSMANX PTE. LTD. (“Company”, “CosmanX”, “we”, “us”, or “our”) handles information collected in connection with the CosmanX Platform and related services.

By accessing or using the Platform, you acknowledge the data practices described in this Privacy Policy.

2. Legal Basis and Compliance

CosmanX processes personal data in accordance with applicable privacy and data-protection requirements, including:

• the Personal Data Protection Act 2012 (PDPA) of Singapore;
• applicable international data-protection standards where relevant; and
• additional compliance or data safeguards required by partner issuers or service providers.

3. Information We Collect

3.1 Personal Information

• full name;
• date of birth;
• nationality;
• identity documents such as passport, national ID, or driving licence;
• residential address and contact details; and
• business registration information where applicable.

3.2 Platform and Account Information

• account credentials;
• login records and device information;
• IP address and location-related information; and
• communications between the User and CosmanX.

3.3 KYC / AML Information

• proof of address;
• proof of income or source-of-funds information where required;
• business verification documents; and
• supporting business or advertising documentation when required for verification or compliance purposes.

3.4 Transaction and Card Usage Information

• Virtual Card creation and usage history;
• merchant category codes (MCCs);
• transaction values and timestamps; and
• funding and conversion information involving fiat or digital assets where applicable.

CosmanX does not collect biometric information unless such data is specifically required by a partner issuer or another applicable service provider.

4. How We Use Information

Information may be processed for purposes including:

• creating and managing user accounts;
• conducting KYC/AML checks and preventing fraud;
• enabling access to and management of Virtual Cards;
• risk assessment, security monitoring, and dispute prevention;
• meeting legal, regulatory, and compliance obligations;
• providing customer support and account recovery assistance;
• improving services and developing new functionality; and
• sending policy notices, service communications, and security alerts.

5. Data Sharing and Disclosure

CosmanX may disclose User information where reasonably necessary to operate the Services, including to:

• licensed partner issuers that provide Virtual Cards;
• KYC, identity-verification, and compliance service providers;
• digital-asset or payment conversion providers where applicable;
• payment networks and acquiring partners, including networks such as Visa or Mastercard; and
• regulators, courts, law-enforcement authorities, or government bodies where disclosure is legally required.

CosmanX does not sell, rent, or trade Users’ personal data to third parties.

Where personal data is transferred outside Singapore, CosmanX will take reasonable steps to ensure that the transfer is handled in accordance with applicable PDPA cross-border requirements.

6. Data Retention

CosmanX keeps User information only for as long as reasonably necessary to operate the Services, meet legal or regulatory requirements, manage risk, and address disputes, investigations, or compliance matters.

Retention periods may be extended when required by partner issuers, service providers, regulators, or applicable law. Once information is no longer required, it may be securely deleted or anonymised.

7. Data Security

CosmanX uses administrative, technical, and organisational safeguards designed to protect User information from unauthorised access, alteration, disclosure, misuse, or loss.

These measures may include encryption, access restrictions, multi-factor authentication, network-security controls, and risk-monitoring systems.

No information system can be guaranteed to be completely secure, and absolute protection against every security risk cannot be guaranteed.

8. User Rights

Subject to applicable law, Users may request to:

• access personal information maintained by CosmanX;
• correct inaccurate or incomplete information;
• request deletion where legally permitted;
• request information about how their personal data is processed.

Requests may be submitted to contact@cosmanx.us. CosmanX may request reasonable identity or account verification before processing a privacy-related request.

9. Cookies and Tracking Technologies

The Platform may use cookies and similar technologies to maintain User sessions, understand Platform usage, improve navigation, and support access to Platform functionality.

Users may disable cookies through their browser settings. However, doing so may affect the availability or normal operation of certain Platform features.

10. Third-Party Services

The Platform may connect with third-party providers, including compliance partners, payment or digital-asset processors, and partner issuers.

Information shared with these parties will be limited, where reasonably practicable, to information required to provide or support the relevant service.

CosmanX does not control the independent privacy practices of third-party systems. Users should review the privacy notices of those providers where applicable.

11. International Data Transfers

Where User information is transferred outside Singapore for operational, service, verification, or compliance purposes, CosmanX will apply safeguards intended to meet applicable PDPA requirements.

Such safeguards may include contractual protections or equivalent cross-border data-transfer mechanisms where required.

12. Children’s Privacy

The CosmanX Platform is intended for business use and is not designed for individuals under 18 years of age.

CosmanX does not knowingly collect personal information from minors.

13. Changes to This Privacy Policy

CosmanX may revise this Privacy Policy from time to time to reflect operational, legal, regulatory, or service changes.

Updated versions will become effective when published on the Platform unless otherwise stated.

14. Contact

For questions, privacy requests, or concerns relating to this Privacy Policy, please contact: