Privacy Policy – Celedrity

Last updated: April 2026

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:

PurposeLegal Basis
Account creation and managementArt. 6(1)(b)
Providing App functionalityArt. 6(1)(b)
Scheduling media publicationArt. 6(1)(b)
Moderation workflowsArt. 6(1)(f)
Customer supportArt. 6(1)(f)
Security and fraud preventionArt. 6(1)(f)
Service improvement and diagnosticsArt. 6(1)(f)
Push notificationsArt. 6(1)(a)
Legal complianceArt. 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 typeRetention
Account dataUntil account deletion
Uploaded mediaUntil deletion by user or expiration of service purpose
Moderation logsSecurity retention period
Technical logsLimited retention
Financial recordsLegal 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

Privacy Policy – Celedrity - Cosmic Brokkoli