Global Data Protection Addendum (2026)

1. International Data Transfers

Cosnap LLC is headquartered in the United States. By using our Services, you acknowledge that your personal and biometric data will be transferred to, stored, and processed in the United States on Amazon Web Services (AWS) servers.

• Standard Contractual Clauses (SCCs): For residents of the EEA and UK, we utilize the European Commission’s Standard Contractual Clauses to ensure that your data receives a level of protection equivalent to that guaranteed within the EU.

• Adequacy & Security: We implement rigorous technical security measures, including AES-256 encryption for data at rest and TLS/SSL for data in transit, to satisfy the "Adequacy" requirements of South Africa’s POPIA and Australia’s Privacy Act.

2. Regional Compliance

• 2.1 European Union & UK (GDPR & EU AI Act) — Legal Basis for Processing: We process biometric data (facial embeddings) only with your explicit consent. All other account data is processed based on contractual necessity or our legitimate interest in securing our Services. EU AI Act Transparency: Our facial recognition system is classified as a "High-Risk AI System." We maintain internal Data Protection Impact Assessments (DPIAs) and ensure that human oversight is available to contest automated matching results.

• 2.2 South Africa (POPIA) — Special Personal Information: We treat biometric identifiers as "Special Personal Information" under the Protection of Personal Information Act (POPIA). Information Officer: Requests regarding POPIA compliance can be directed to our Data Privacy Officer at info@cosnap.ai.

• 2.3 Australia (Privacy Act 1988) — Automated Decision-Making: We disclose that we use AI-driven automated tools to match photos to identities. Sensitive Information: Facial embeddings are handled as "sensitive information" and are subject to the highest level of protection under the Australian Privacy Principles (APPs).

3. Enhanced Data Subject Rights

Regardless of your location, Cosnap LLC provides the following "Golden Standard" rights to all international users:

• Right to Access & Portability: You may request a copy of your data in a structured, machine-readable format.

• Right to Erasure (Right to be Forgotten): You may request the permanent deletion of your biometric identifiers and account data at any time.

• Right to Human Intervention: You have the right to request that a human staff member review any automated biometric identification match you believe is inaccurate.

• Right to Withdraw Consent: You can disable facial recognition in your settings at any time, which results in the immediate cessation of biometric processing for your profile.

4. Contact & Complaints

If you believe we have not complied with your local privacy laws, please contact us first at info@cosnap.ai