1. Data Controller
This Privacy Policy describes how personal data is collected and processed in connection with the Celedrity mobile application (the “App”).
The data controller is:
Cosmic Brokkoli UAB
J. Savickio g. 4-7, LT-01108 Vilnius
Lithuania
Email: info@cosmicbrokkoli.com
(“Cosmic Brokkoli”, “we”, “us”, or “our”).
2. Scope of this Policy
This Privacy Policy applies to all users of the Celedrity App and explains:
what personal data we collect
how and why we process it
the legal basis for processing
how long we retain it
when content may become publicly visible
your rights under the GDPR
The App enables users to upload content that may be displayed on public LED walls in physical locations.
Because of this functionality, some user-submitted content may become publicly visible.
3. Categories of Personal Data Collected
We may collect and process the following categories of personal data.
3.1 Data Provided by the User
Account information:
name
username
email address
Profile information:
profile image
optional biography
preferences
User-generated content:
images
videos
overlay text
captions
scheduling requests
metadata associated with uploaded media
This content may be displayed publicly depending on user actions.
3.2 Content Display Metadata
When users request publication of content on a LED wall, we process:
selected LED wall location
scheduling time window
moderation status
operator approval metadata (where applicable)
execution status logs
These data are necessary to provide the service.
3.3 Usage Data
We may automatically collect:
feature usage activity
session interaction events
crash diagnostics
device type
operating system version
app version
IP address
timestamps
3.4 Push Notification Data
If enabled by the user:
push notification token
delivery status metadata
notification interaction events
Push notifications may be used to inform users about:
content moderation status
scheduling updates
content playback execution
system notifications
3.5 Payment Data (if applicable)
If paid features are available, we process transaction metadata such as:
purchase confirmation status
subscription status
transaction identifiers
Payment credentials are processed exclusively by third-party providers and never stored by Cosmic Brokkoli.
4. Public Display of User Content
The App allows users to request the display of uploaded content on physical LED walls located in public or semi-public spaces.
As a result, content submitted through the App may become:
publicly visible
photographed by third parties
recorded on video
shared on social networks
further processed by unknown recipients
Users remain solely responsible for ensuring they have the legal right to upload and request publication of such content.
This processing is based on:
Art. 6(1)(b) GDPR – contract performance
and
Art. 6(1)(a) GDPR – explicit user action requesting display
5. Purposes of Processing and Legal Basis
We process personal data for the following purposes:
| Purpose | Legal Basis |
|---|
| Account creation and management | Art. 6(1)(b) |
| Providing App functionality | Art. 6(1)(b) |
| Scheduling media publication | Art. 6(1)(b) |
| Moderation workflows | Art. 6(1)(f) |
| Customer support | Art. 6(1)(f) |
| Security and fraud prevention | Art. 6(1)(f) |
| Service improvement and diagnostics | Art. 6(1)(f) |
| Push notifications | Art. 6(1)(a) |
| Legal compliance | Art. 6(1)(c) |
6. Moderation and Operator Access
Content submitted for display may be reviewed by:
automated moderation systems
authorized moderators
LED wall operators
Moderators and operators may access only the data necessary to perform their role.
This processing is necessary to:
ensure compliance with applicable laws
protect public safety
prevent misuse of infrastructure
enforce acceptable content policies
Legal basis:
Art. 6(1)(f) GDPR – legitimate interest
7. Data Sharing
We may share personal data with:
Infrastructure providers:
cloud hosting
storage providers
content delivery networks
Technical service providers:
analytics tools
notification services
crash reporting services
Payment providers:
subscription processors
in-app purchase platforms
Public authorities:
where required by law
All processors operate under GDPR-compliant data processing agreements (DPAs).
8. International Data Transfers
Where personal data is transferred outside the European Economic Area, we rely on:
European Commission adequacy decisions
Standard Contractual Clauses (SCCs)
equivalent safeguards required by GDPR
9. Data Retention
We retain personal data only as long as necessary:
| Data type | Retention |
|---|
| Account data | Until account deletion |
| Uploaded media | Until deletion by user or expiration of service purpose |
| Moderation logs | Security retention period |
| Technical logs | Limited retention |
| Financial records | Legal retention obligations |
Some execution logs may be retained for audit and dispute-resolution purposes.
10. Account Deletion and Data Erasure
Users may request deletion:
inside the App
or via: info@cosmicbrokkoli.com
Upon deletion request:
all personal data will be erased without undue delay except where retention is legally required.
Residual retained data will:
remain restricted
not be reused
remain securely stored
exist only for legal compliance
11. Data Security
We implement appropriate technical and organizational safeguards including:
encrypted transport (TLS)
encrypted storage where applicable
role-based access control
authentication mechanisms
audit logging
infrastructure monitoring
12. User Rights under GDPR
Users have the right to:
access their data (Art. 15)
rectify inaccurate data (Art. 16)
erase data (Art. 17)
restrict processing (Art. 18)
data portability (Art. 20)
object to processing (Art. 21)
withdraw consent (Art. 7)
Requests may be sent to: info@cosmicbrokkoli.com
13. Supervisory Authority
Users may lodge complaints with a supervisory authority, particularly:
their country of residence
their workplace location
the location of the alleged infringement
For Lithuania:
State Data Protection Inspectorate (VDAI)
14. Children's Privacy
The App is not intended for individuals under 16 years of age.
We do not knowingly collect personal data from children without parental authorization.
15. Changes to this Policy
We may update this Privacy Policy periodically.
Users will be informed via:
in-app notice
App Store updates
website publication
where required.
16. Contact
Cosmic Brokkoli UAB
J. Savickio g. 4-7, LT-01108 Vilnius
Lithuania
info@cosmicbrokkoli.com