COOKIE POLICY

and Notice on Cookies and Similar Technologies

Tryneth Platform and Website

Effective date: 10.07.2026

Techneth EOOD • ul. “Perla” 26, Zapad, Mladost, 9000 Varna, Bulgaria • UIC 208663227
Contact: support@tryneth.com

1. Introduction, Scope, and How to Use This Policy

1.1 About this Policy

This Cookie Policy (the “Policy”) explains how Techneth EOOD (“Techneth”, “we”, “us”, “our”) uses cookies and similar technologies on the Tryneth platform, its websites, web applications, client portals, and related online services (together, the “Service”), and describes the choices and controls available to you. It is intended to be read together with our Privacy Policy, which explains how we handle personal data more broadly, and our Terms and Conditions. Where a term used in this Policy is defined in the Privacy Policy or the Terms and Conditions, it has the same meaning here, and a glossary of cookie-specific terms is set out in Appendix A.

We have written this Policy to be comprehensive and transparent. Because the specific cookies in use on a modern platform change over time as features and providers change, the authoritative and continuously updated list of cookies actually in use is maintained in our cookie preference centre, which you can open at any time from the Service. This Policy explains the categories, purposes, durations, legal bases, and your controls, and Appendix B provides an illustrative inventory.

1.2 Scope of this Policy

This Policy applies to cookies and similar technologies that we set and control on our own Service and websites. It also explains, where relevant, how third-party technologies operate when they are present on our Service. This Policy does not apply to the websites, applications, or services of third parties, or to the properties of our business customers who deploy the Service under their own brand, each of which is governed by its own cookie and privacy notices.

1.3 Who this Policy is for

This Policy is relevant to: visitors to our public websites; authorised users who access the Service under a customer account; prospective customers who interact with our online properties; and, where applicable, individuals who interact with pages or portals that a customer has configured using the Service. Where we act only as a provider of technology to a business customer, and the customer determines how cookies are used on the customer’s own properties, the customer is the controller for those cookies and is responsible for its own cookie notice and consent.

1.4 Business-oriented service

The Service is a business-to-business platform intended for organisations that operate a website, such as marketing agencies and businesses. It is not directed at consumers acting outside their trade, business, or profession, and it is not directed at children. We provide jurisdiction-specific and consumer-facing information in this Policy only where applicable law requires it, as set out in Section 26.

1.5 How to use this Policy

If you want a quick overview, read the At a Glance summary above. If you want to understand the categories of cookies and your choices, read Sections 5, 6, 10, 11, and 12. If you want the technical detail, read Sections 2, 7, and Appendices A and B. If you want to know your rights and the rules that apply where you live, read Sections 25 and 26 and Appendix F. To manage your choices immediately, open the cookie preference centre from the Service or follow the browser instructions in Appendix C.

1.6 Changes to this Policy

We may update this Policy from time to time to reflect changes in the technologies we use, our practices, or applicable law. Where changes are material, we will take appropriate steps to inform you, for example through the Service or by re-presenting the cookie banner, to the extent required by law. The “Effective date” on the cover indicates when this version took effect. Section 28 explains how we handle changes in more detail.

2. What Are Cookies and Similar Technologies

2.1 Cookies

A cookie is a small text file that a website or online service asks your browser to store on your device. When you return to the same service, or visit another service that recognises the cookie, your browser sends the cookie back, which allows the service to recognise your device, remember information about your visit, and function correctly. Cookies are a long-established and widely used technology, and most browsers are set to accept them by default, although you can change this.

2.2 First-party and third-party cookies

A first-party cookie is set by the service you are visiting, in our case the Tryneth platform or website. A third-party cookie is set by a different domain, typically a provider whose functionality is embedded in or used by the service, such as an analytics, security, or infrastructure provider. Section 8 explains how we use first-party and third-party cookies, and our overall approach to third-party providers, whom we describe by function rather than by name in this Policy.

2.3 Session and persistent cookies

A session cookie exists only for the duration of your browsing session and is deleted when you close your browser. A persistent cookie remains on your device for a defined period, or until you delete it, and allows the service to recognise you across sessions, for example to remember your preferences. The typical durations of the cookies we use are indicated by category in Section 7 and Appendix B.

2.4 Similar technologies

In addition to cookies, we and our providers may use other technologies that perform similar functions. These include:

• Pixels and web beacons: tiny, typically invisible, image files or snippets of code that can record that a page was viewed, an email was opened, or an action was taken, and that can work together with cookies.
• Tags and tag managers: small pieces of code that help manage and deploy other technologies on a page in a controlled way.
• Software development kits (SDKs): blocks of code included in mobile or embedded applications that can collect information about the device and use of the application, performing functions similar to cookies in an app context.
• Local storage and session storage: mechanisms that allow a service to store information in your browser or app beyond a single request, which can be used to remember settings and improve performance, as explained in Section 17.
• Other client-side storage: technologies such as indexed databases and cache mechanisms that can store data on your device to support functionality and performance.
• Device and browser characteristics: information about your device and browser configuration that, in combination, can be used to recognise a device. We do not use such techniques for cross-site tracking or advertising.

In this Policy, unless we say otherwise, we use the word “cookies” to refer to cookies and all of these similar technologies together, because they raise similar considerations and are subject to similar rules.

2.5 What information cookies may hold

A cookie or similar technology may store an identifier and limited information such as the name of the service that set it, how long it lasts, and a value that lets the service recognise your device or remember a setting. Some cookies are linked to information that can identify you, such as your account, in which case the related processing of personal data is described in our Privacy Policy. Other cookies hold only technical values that do not identify you directly. Whether a cookie involves personal data depends on the cookie and the context.

3. Why We Use Cookies and Similar Technologies

We use cookies and similar technologies for a limited set of purposes, which we describe in detail in Section 6. In summary, we use them to:

• operate the Service and enable core functionality, such as signing you in, keeping you signed in, routing your requests, and keeping your session secure;
• remember your choices and preferences, such as language, region, and interface settings, so that the Service works the way you expect;
• keep the Service and your account secure, detect and prevent fraud and abuse, and protect the integrity of the Service;
• understand how the Service is used, on an aggregated basis where possible, so that we can measure and improve performance, reliability, and user experience;
• support the delivery of the Service across our infrastructure, for example by balancing load and maintaining stability; and
• comply with our legal obligations and record your cookie choices so that we can honour them.

We do not use cookies to build advertising profiles about you, to serve you targeted third-party advertising, or to track you across unrelated websites for advertising purposes. Section 19 explains our position on advertising, sale, and sharing in detail.

4. The Legal Framework That Applies to Cookies

The use of cookies and similar technologies is regulated by a combination of laws, which differ by jurisdiction. This Section summarises the main frameworks that inform this Policy, and Appendix F provides a fuller summary. Section 26 sets out jurisdiction-specific provisions.

4.1 The EU ePrivacy rules

In the European Economic Area, the storing of information, or the gaining of access to information already stored, on a user’s device is regulated by the ePrivacy Directive (Directive 2002/58/EC) as implemented in national law. As a general rule, this requires the user’s consent before non-essential cookies are placed or read, with a limited exemption for cookies that are strictly necessary to provide a service that the user has requested, or that are used for the sole purpose of carrying out the transmission of a communication.

4.2 The EU General Data Protection Regulation

Where cookies involve the processing of personal data, the EU General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) also applies. This means that, in addition to obtaining consent for non-essential cookies under the ePrivacy rules, we must have a legal basis for the related processing of personal data, must provide transparent information, and must respect data-subject rights. Section 5 explains how consent and legal basis fit together, and our Privacy Policy explains the related processing.

4.3 United Kingdom rules

In the United Kingdom, the Privacy and Electronic Communications Regulations (“PECR”) govern the use of cookies and similar technologies, alongside the UK GDPR. The approach is materially similar to the EU approach: consent is generally required for non-essential cookies, with an exemption for strictly necessary cookies.

4.4 Swiss rules

In Switzerland, the use of cookies is addressed under the Federal Act on Data Protection (“FADP”) and related telecommunications rules. We provide appropriate information and choices consistent with those rules.

4.5 United States rules

In the United States, several state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), regulate certain uses of cookies and similar technologies, particularly where they involve the “sale” or “sharing” of personal information or targeted advertising, and require that businesses honour recognised opt-out preference signals. As explained in Sections 13 and 19, we do not sell or share personal information collected through cookies for cross-context behavioural advertising, and we honour recognised opt-out signals where required.

4.6 Other jurisdictions

Other jurisdictions have their own rules on cookies and online tracking. Where such rules apply to our use of cookies, we take appropriate steps to comply with their mandatory requirements, as noted in Section 26.

5. Consent and the Legal Basis for Each Category

This Section explains how consent and legal basis work together for the cookies we use. It is central to how we comply with the law, and it explains why some cookies are set automatically while others are set only if you agree.

5.1 Strictly necessary cookies do not require consent

Cookies that are strictly necessary to provide the Service you have requested are exempt from the consent requirement under the ePrivacy rules. We set these cookies on the basis that they are essential, and, where they involve personal data, we rely on our legitimate interest in operating a secure and functional Service, and on the necessity of the processing to perform our contract with the customer. You cannot switch these off through our preference centre, because the Service would not work without them, but you can block them through your browser, in which case parts of the Service may not function.

5.2 Non-essential cookies require consent

For all cookies that are not strictly necessary, including functional and analytics cookies, we obtain your consent before they are set, where consent is required by law. We do this through our cookie banner and preference centre, described in Section 10. Consent must be freely given, specific, informed, and unambiguous, and given by a clear affirmative action. We do not treat continued browsing, scrolling, or the mere closing of a banner as consent, and we do not use pre-ticked boxes.

5.3 Withdrawing consent

You can withdraw your consent at any time, as easily as you gave it, through our preference centre. Withdrawing consent does not affect the lawfulness of any processing carried out before you withdrew it. After withdrawal, we stop setting the relevant cookies and, where applicable, take steps to limit further use of information previously collected through them, subject to technical constraints.

5.4 Records of consent

We keep records of the consents given through our preference centre, including what you were told and what you agreed to, so that we can demonstrate compliance and honour your choices. These records are retained for the period described in Section 21.

5.5 Re-obtaining consent

We may ask you to review your choices again from time to time, for example if our use of cookies changes materially, if a significant period has passed, or if you use the Service from a new device or browser or after clearing your cookies.

5.6 Summary table of categories and bases

6. Categories of Cookies and Similar Technologies We Use

We organise the cookies and similar technologies we use into the categories described below. The categorisation follows the approach commonly used by mature software-as-a-service providers, and it maps to the controls in our preference centre. The authoritative, itemised list is maintained in the preference centre, and Appendix B provides an illustrative inventory.

6.1 Strictly necessary cookies

These cookies are essential for the Service to function and cannot be switched off in our systems through the preference centre. They are generally set only in response to actions you take that amount to a request for a

service, such as signing in, setting your privacy preferences, maintaining the security of your session, submitting information, or completing a purchase. Examples of their functions include:

• maintaining your authenticated session so that you do not have to sign in on every page;
• protecting against cross-site request forgery and other security threats;
• remembering information you enter as you move through a multi-step process;
• routing your requests efficiently across our infrastructure and balancing load;
• recording your cookie preferences so that we can honour them.

Because these cookies are essential, we do not seek consent for them, but we describe them here in the interest of transparency, and you can block them through your browser if you accept that the Service may not work properly.

6.2 Functional and preference cookies

These cookies enable enhanced functionality and personalisation but are not strictly necessary. They allow the Service to remember choices you make and to provide improved, more personal features. Examples of their functions include remembering your language, region, and locale; remembering interface preferences and layout choices; and retaining settings that make the Service more convenient. If you do not allow these cookies, some or all of these features may not function properly. We use these cookies only with your consent.

6.3 Analytics and performance cookies

These cookies help us understand how visitors and users interact with the Service by collecting and reporting information, generally on an aggregated basis. They allow us to count visits and traffic sources, to measure and improve the performance and reliability of the Service, to understand which features are used and how, and to identify and fix problems. Where possible, the information these cookies collect is aggregated or de-identified. If you do not allow these cookies, we will not know when you have used the Service, and we will be less able to monitor and improve its performance. We use these cookies only with your consent.

6.4 Security and fraud-prevention cookies

These cookies support authentication, help detect and prevent fraudulent or abusive activity, and help keep the Service and your account secure. Where these cookies are essential to providing the secure Service you have requested, we treat them as strictly necessary and do not seek separate consent for them. Where any such technology is not essential, we use it only with your consent.

6.5 Load-balancing and infrastructure cookies

These cookies and similar technologies support the reliable delivery of the Service across our hosting and content-delivery infrastructure, for example by directing your requests to an appropriate server and maintaining stability and continuity. They are essential to delivering the Service reliably and are treated as strictly necessary.

6.6 Categories we do not use

For the avoidance of doubt, we do not use advertising or targeting cookies that build profiles of you for third-party advertising, we do not use cookies to sell or share your personal information for cross-context behavioural advertising, and we do not knowingly permit third parties to use cookies on our Service to track you across unrelated websites for their own advertising purposes. If this position changes in the future, we will update this Policy, update our preference centre, and, where required, obtain your consent before any such cookies are used.

7. Illustrative Inventory of Cookies and Similar Technologies

The tables in this Section are illustrative and are provided to help you understand the types of cookies we use, their general purposes, whether they are first-party or third-party, and their typical durations. They are not a complete or definitive list. The authoritative, up-to-date inventory, including the specific cookies actually in use at any time, is maintained in our cookie preference centre. Appendix B expands on this inventory. We describe third-party cookies by function rather than by naming the provider.

7.1 Strictly necessary cookies (illustrative)

7.2 Functional and preference cookies (illustrative)

7.3 Analytics and performance cookies (illustrative)

7.4 Security and fraud-prevention cookies (illustrative)

8. First-Party and Third-Party Cookies

8.1 First-party cookies

Most of the cookies we use are first-party cookies that we set and control directly to operate the Service, remember your preferences, keep the Service secure, and understand and improve performance. We are responsible for these cookies, and you can manage them through our preference centre and your browser.

8.2 Third-party cookies

Some cookies on our Service are set by third-party providers who deliver functions on our behalf, such as analytics, security, and infrastructure providers. Consistent with the rest of our documentation, we describe these providers by function rather than by name in this Policy. Where these providers act as our processors, they are bound by data-protection terms and may not use information collected through cookies on our Service for their own independent purposes. A current list of providers that process personal data, identified by name, is maintained in our Sub-Processor Register, available on request via support@tryneth.com or as published in-product.

8.3 Our approach to third-party cookies

We seek to minimise the number of third-party cookies on our Service, to ensure that non-essential third-party cookies are set only after consent, and to prevent third parties from using cookies on our Service to track you across unrelated websites for their own advertising. We keep the specific third-party technologies in use recorded in our preference centre.

9. Cookies Set Through the White-Label and Client-Portal Features

The Service allows business customers to deploy functionality under their own brand and to operate client-facing portals and pages. Where a customer uses these features on the customer’s own properties, the customer determines how cookies and similar technologies are used on those properties and is the controller for that use. In that case, the customer is responsible for providing its own cookie notice, for obtaining any required consents from its own end-clients and visitors, and for complying with applicable cookie and data-protection law. We provide the underlying technology and act as a processor for the customer in respect of that use. This Policy describes our own use of cookies on our own Service, and it does not replace the cookie notice that a customer must provide on the customer’s properties.

10. Consent Management: Our Cookie Banner and Preference Centre

10.1 The cookie banner

When you first visit our Service, and at appropriate times afterwards, we present a cookie banner that informs you about our use of cookies and lets you accept or reject non-essential cookies, or make granular choices. Non-essential cookies are not set before you make a choice, where consent is required. The banner gives equal prominence to accepting and rejecting non-essential cookies, so that rejecting is as easy as accepting.

10.2 The preference centre

Our preference centre lets you review the categories of cookies we use, see information about their purposes and durations, and turn non-essential categories on or off. Strictly necessary cookies are shown for transparency but cannot be switched off through the preference centre. You can open the preference centre at any time from the Service, for example through a clearly labelled link, to review or change your choices.

10.3 Granularity of choices

We allow you to consent to some categories of non-essential cookies while rejecting others, rather than requiring an all-or-nothing choice. Your granular choices are recorded and honoured.

10.4 What happens if you do not choose

If you do not make a choice, we do not set non-essential cookies, and we may continue to present the banner until you make a choice, subject to setting only the strictly necessary cookies needed to operate the Service and to remember that the banner has been shown.

11. How to Manage, Change, or Withdraw Your Consent

You are in control of the non-essential cookies we use, and you have several ways to manage them:

• Through our preference centre: open it at any time from the Service to turn non-essential categories on or off, or to withdraw consent you previously gave.
• Through your browser: most browsers let you view, delete, and block cookies, and you can set your browser to warn you before accepting cookies. Appendix C provides step-by-step guidance for major browsers.
• Through device controls: mobile and other devices offer controls relevant to app-based technologies and device identifiers, as described in Section 15.
• Through opt-out preference signals: we honour recognised signals such as Global Privacy Control where legally required, as described in Section 13.

If you delete cookies or use a different browser or device, your previous choices may no longer apply, and we may ask you to choose again. If you block or delete strictly necessary cookies, parts of the Service may not work properly.

12. Browser Controls and Device-Level Controls

Independently of our preference centre, you can use your browser and device settings to manage cookies. These controls are provided by the makers of your browser and device, not by us, and their exact operation may change. In general, browser settings allow you to block all cookies, block third-party cookies, delete cookies when you close the browser, and delete existing cookies. Browsers also offer private or incognito modes that limit the persistence of cookies. Appendix C provides detailed, step-by-step instructions for managing cookies in widely used browsers, including on desktop and mobile devices. Please note that if you use browser controls to block cookies, including strictly necessary cookies, some features of the Service may not function as intended, and you may need to set your preferences again each time you visit.

13. Global Privacy Control and Opt-Out Preference Signals

Some browsers and extensions can send an opt-out preference signal, such as Global Privacy Control, that communicates your choice to opt out of the sale or sharing of your personal information, or of certain targeted advertising. Where required by applicable law, we treat a recognised opt-out preference signal as a valid request to opt out for the browser or device from which it is sent. Because we do not sell or share personal information collected through cookies for cross-context behavioural advertising, as explained in Section 19, the practical effect of such a signal on our Service is limited, but we honour recognised signals where the law requires and we will apply them to the relevant browser or device. Appendix D provides more information about opt-out preference signals and industry opt-out programmes.

14. Do Not Track Signals

Some browsers offer a “Do Not Track” setting that sends a signal to services you visit indicating that you do not wish to be tracked. There is currently no common, agreed industry standard for how services should interpret and respond to Do Not Track signals. As a result, our Service does not currently respond to Do Not Track signals. We instead give you meaningful control through our preference centre, our honouring of recognised opt-out preference signals as described in Section 13, and the browser and device controls described in Sections 11 and 12.

15. Mobile Applications, Software Development Kits, and Device Identifiers

15.1 Technologies used in apps

Where the Service is provided through a mobile or embedded application, we and our providers may use technologies that perform functions similar to cookies, including software development kits and locally stored identifiers, to enable core functionality, remember preferences, keep the application secure, and understand and improve performance. The same category and consent principles described in this Policy apply to these technologies.

15.2 Device identifiers and controls

Mobile operating systems provide device-level identifiers and controls that let you limit certain uses of those identifiers, reset them, or opt out of certain tracking. You can use the privacy settings on your device to manage these controls. The exact options depend on your device and operating system, and they are provided by the maker of your device.

15.3 Consent in the app context

Where consent is required for non-essential technologies used in an application, we seek it through appropriate in-app mechanisms, and, where the operating system requires a permission prompt for certain tracking, we respect your response to that prompt.

16. Pixels, Web Beacons, and Email Tracking Technologies

16.1 Pixels and web beacons on the Service

We and our providers may use pixels and web beacons on the Service, often in combination with cookies, to understand how the Service and our content are used, to measure performance, and to support security. These technologies are subject to the same category and consent principles as cookies, and non-essential uses are subject to consent.

16.2 Email tracking

Our emails may contain pixels or similar technologies that tell us whether an email was opened and whether links were clicked, so that we can understand the effectiveness of our communications and improve them. Where you have chosen to receive marketing emails, this measurement supports those communications. You can limit email tracking by configuring your email client to block remote images, and you can opt out of marketing emails at any time using the unsubscribe mechanism in the email or by contacting support@tryneth.com. Service and transactional emails necessary to administer your account or the Service may still be sent.

17. Local Storage, Session Storage, and Similar Client-Side Storage

In addition to cookies, the Service may use client-side storage technologies provided by your browser, such as local storage and session storage, and similar mechanisms. These technologies allow the Service to store information on your device to support functionality and performance, for example by remembering settings, caching data to make the Service faster, and maintaining state within the application. Client-side storage is subject to the same principles as cookies under this Policy: storage that is strictly necessary to provide the Service is treated as essential, and non-essential uses are subject to consent where required. You can clear client-side storage through your browser settings, although doing so may affect the functionality and performance of the Service and may reset your preferences.

18. Data We Collect Through Cookies and How We Use It

Cookies and similar technologies may collect or store limited information, which can include an identifier for your device or session, information about how you use the Service, technical information about your device and browser, and your preferences. Depending on the cookie and the context, this information may or may not identify you directly, and it may be linked to other information we hold, such as your account.

We use the information collected through cookies for the purposes described in Sections 3 and 6, namely to operate the Service, remember your preferences, keep the Service secure, understand and improve performance, deliver the Service reliably, and honour your choices. Where this information is personal data, our Privacy Policy explains the categories of personal data, the purposes and legal bases, how we share it, how long we keep it, and your rights. This Cookie Policy and our Privacy Policy are intended to be read together.

18.1 Use for analytics and improvement

Where you consent to analytics cookies, we use the information they collect to understand and improve the Service. Wherever practicable, we use this information in aggregated or de-identified form. Our approach to aggregation, de-identification, and the improvement of the Service, including the training of artificial-intelligence features, is described in our Privacy Policy, including our commitment not to use our customers’ end-client personal data to train our models unless the customer opts in and confirms it has the necessary consents.

18.2 No use for third-party advertising

We do not use the information collected through cookies to build advertising profiles or to serve you targeted third-party advertising, and we do not sell or share it for cross-context behavioural advertising, as explained in Section 19.

19. Advertising, Cross-Context Behavioural Advertising, and Sale or Sharing

We want to be clear and unambiguous about advertising, because it is the area of greatest sensitivity and legal risk in relation to cookies.

• No advertising cookies. We do not use cookies or similar technologies on our Service to serve third-party targeted or behavioural advertising to you.
• No sale of personal information. We do not sell personal information collected through cookies, as “sale” is defined under applicable US state privacy laws or as otherwise understood under applicable law.
• No sharing for cross-context behavioural advertising. We do not share personal information collected through cookies for cross-context behavioural advertising, as “share” is defined under the CCPA/CPRA.
• No third-party tracking for their own advertising. We do not knowingly permit third parties to use cookies on our Service to track you across unrelated websites for their own advertising purposes.

Because of these positions, opt-out-of-sale and opt-out-of-sharing rights have limited practical application to our Service, but we nonetheless honour recognised opt-out preference signals where the law requires, as described in Section 13, and we describe the relevant industry opt-out programmes in Appendix D for completeness. If we ever change these positions, we will update this Policy, update our preference centre, and obtain any consent required before any such technologies are used.

20. International Transfers of Data Collected Through Cookies

Some of the providers whose technologies operate on our Service, and some of our own systems, may process information collected through cookies in countries outside the country where you are located, including outside the European Economic Area, the United Kingdom, and Switzerland. Where such transfers involve personal data, we implement an appropriate transfer safeguard recognised under applicable law, such as an adequacy decision, the European Commission’s Standard Contractual Clauses, the United Kingdom International Data Transfer Agreement or Addendum, or the Swiss adaptation, together with supplementary measures where needed. Our Privacy Policy describes international transfers and the safeguards we rely on in more detail, and you can request further information via support@tryneth.com.

21. Retention of Cookie Data and Cookie Lifespans

Cookies remain on your device for the period described by category in Section 7 and Appendix B, or until you delete them. Session cookies are deleted when you close your browser. Persistent cookies remain for a defined period, which we seek to limit to what is necessary for the purpose.

Information collected through cookies is retained only for as long as necessary for the purposes for which it was collected, after which it is deleted or irreversibly de-identified, subject to any legal requirement to retain it. Records of your cookie consent are retained for a period appropriate to demonstrate compliance and to honour your choices, typically for a defined number of months or years consistent with regulatory expectations. Our Privacy Policy describes our general retention approach, and specific periods may vary based on legal requirements and legitimate business needs.

22. Security of Data Collected Through Cookies

We apply appropriate technical and organisational measures to protect information collected through cookies against unauthorised access, alteration, disclosure, or destruction, consistent with the measures described in our Privacy Policy. These include, as appropriate, transport-layer encryption, access controls, the use of secure and, where appropriate, restricted cookie attributes, and monitoring. Where cookies carry session or authentication information, we take particular care to protect them, for example by using appropriate security flags and short lifespans. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, so you should also take care to protect your devices and credentials.

23. Children and Cookies

The Service is a business tool and is not directed at children, and we do not knowingly use cookies to collect personal data from children below the age at which they can provide valid consent under applicable law. If you believe that a child has provided personal data to us through the Service, please contact us at support@tryneth.com and we will take appropriate steps to delete it and to remove any related cookie-based information where required.

24. Automated Decision-Making and Profiling Through Cookies

We do not use cookies or similar technologies to carry out automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, without human involvement. We use analytics information, where you consent, to understand and improve the Service on an aggregated basis, not to make decisions about you individually that have such effects. Where a business customer configures its own use of the Service, the customer is responsible for the lawfulness of any profiling it carries out as controller.

25. Your Rights in Relation to Data Collected Through Cookies

Where the information collected through cookies is personal data, you have rights in relation to it under applicable data-protection law. Depending on where you are located, these may include the right to access, rectify, erase, restrict, or object to processing, the right to data portability, the right to withdraw consent, and rights to opt out of sale or sharing. The specific rights available to you, and how to exercise them, are described in our Privacy Policy, including the jurisdiction-specific provisions there. You can exercise your rights, or ask questions about them, by contacting us at support@tryneth.com. You also have the right to lodge a complaint with a supervisory authority, as described in Section 26 and Appendix E.

26. Jurisdiction-Specific Provisions

This Section provides additional information for individuals in specific jurisdictions. Where a provision in this Section conflicts with the general provisions above, this Section prevails for individuals in the relevant jurisdiction. Appendix F summarises the applicable legal frameworks, and Appendix E lists the relevant authorities.

26.1 European Economic Area

If you are in the European Economic Area, our use of cookies is governed by the ePrivacy rules as implemented in your country, together with the GDPR where personal data is involved. We obtain consent for non-essential cookies, rely on the strictly-necessary exemption only where it applies, and provide the transparency and choices described in this Policy. You may exercise your rights as described in our Privacy Policy and may lodge a complaint with your national supervisory authority or with the Bulgarian Commission for Personal Data Protection.

26.2 United Kingdom

If you are in the United Kingdom, our use of cookies is governed by the Privacy and Electronic Communications Regulations and the UK GDPR. Our approach is materially the same as in the European Economic Area: we obtain consent for non-essential cookies and rely on the strictly-necessary exemption only where it applies. You may lodge a complaint with the United Kingdom Information Commissioner’s Office.

26.3 Switzerland

If you are in Switzerland, our use of cookies is addressed under the Federal Act on Data Protection and related rules. We provide appropriate information and choices, and you may contact the Swiss Federal Data Protection and Information Commissioner with concerns.

26.4 United States

If you are a resident of California or another US state with comparable privacy laws, the following applies in addition to the rest of this Policy. We use cookies as described above, and, as explained in Section 19, we do not sell personal information and do not share it for cross-context behavioural advertising. Where required, we honour recognised opt-out preference signals, such as Global Privacy Control, for the browser or device from which they are sent. Depending on your state, you may have the right to know about, access, delete, or correct personal information, to opt out of sale or sharing, and to limit the use of sensitive personal information, and you have the right not to receive discriminatory treatment for exercising your rights. We do not use sensitive personal information collected through cookies for purposes that would require a right to limit under the CCPA/CPRA. You may exercise your rights as described in our Privacy Policy or by contacting support@tryneth.com, including through an authorised agent where permitted.

26.5 Other jurisdictions

If you are in another jurisdiction with rules on cookies or online tracking, we take appropriate steps to comply with the mandatory requirements of that jurisdiction. You may contact us at support@tryneth.com for information relevant to your location.

27. Third-Party Links and Embedded Content

The Service and our websites may contain links to third-party websites and services, and may include embedded content such as videos, maps, or documents hosted by third parties. When you follow a link to a third-party site, or interact with embedded third-party content, that third party may set its own cookies, over which we have no control. This Policy does not apply to third-party sites or services, and we encourage you to review the cookie and privacy notices of any third party before interacting with it.

28. Changes to This Cookie Policy

We may update this Policy from time to time to reflect changes in the technologies we use, our practices, our providers, or applicable law, or for other operational, legal, or regulatory reasons. When we make changes, we will update the “Effective date” on the cover and, where the changes are material, we will take additional steps to inform you, which may include presenting the cookie banner again, displaying a notice in the Service, or notifying you by other appropriate means, to the extent required by law. Where a change requires your consent, we will obtain it before the relevant cookies are used. We encourage you to review this Policy periodically. Your continued use of the Service after an update takes effect, together with your choices in the preference centre, reflects your awareness of the updated Policy, to the extent permitted by law.

29. How to Contact Us

If you have any questions, requests, or concerns about this Cookie Policy or our use of cookies and similar technologies, you can contact us as follows:

Techneth EOOD, Privacy Team
ul. “Perla” 26, Zapad, Mladost, 9000 Varna, Bulgaria
UIC 208663227
Email: support@tryneth.com

We will respond to your enquiry within a reasonable time and in accordance with applicable law. If you are not satisfied with our response, you have the right to contact the relevant supervisory authority identified in Appendix E.

30. Detailed United States State-by-State Provisions

This Section provides additional, state-specific information for residents of United States states that have enacted comprehensive privacy laws relevant to cookies and online tracking. It supplements Section 26.4. Across all of these states, our core positions are the same: we use cookies as described in this Policy, we do not sell personal information, we do not share personal information for cross-context behavioural or targeted advertising, we do not use sensitive personal information collected through cookies for purposes that would trigger a right to limit, and we honour recognised opt-out preference signals where required. You may exercise your rights, or ask questions, by contacting support@tryneth.com, and our Privacy Policy contains the full description of rights and procedures.

30.1 California

Under the California Consumer Privacy Act as amended by the California Privacy Rights Act, California residents have the right to know and access the personal information collected about them, to delete it, to correct inaccurate information, to opt out of the sale or sharing of personal information, and to limit the use of sensitive personal information. Because we do not sell or share personal information collected through cookies, and do not use sensitive personal information for purposes requiring a right to limit, these opt-out and limitation rights have limited application to our Service, but we honour recognised opt-out preference signals such as Global Privacy

Control for the browser or device from which they are sent. California residents are not subject to discriminatory treatment for exercising their rights, and may use an authorised agent to submit requests.

30.2 Virginia

Under the Virginia Consumer Data Protection Act, Virginia residents have the right to confirm and access their personal data, to correct it, to delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of personal data, and certain profiling. Because we do not use cookies for targeted advertising or sell personal data, these opt-out rights have limited application to our Service, and we provide the access, correction, deletion, and portability rights as described in our Privacy Policy.

30.3 Colorado

Under the Colorado Privacy Act, Colorado residents have rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and certain profiling, including through a recognised universal opt-out mechanism. We honour recognised universal opt-out mechanisms where required, and, because we do not use cookies for targeted advertising or sell personal data, the practical effect on our Service is limited.

30.4 Connecticut

Under the Connecticut Data Privacy Act, Connecticut residents have rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and certain profiling, including through an opt-out preference signal. We honour recognised opt-out preference signals where required, subject to the same limited practical effect described above.

30.5 Utah

Under the Utah Consumer Privacy Act, Utah residents have rights of access, deletion, and portability, and the right to opt out of targeted advertising and the sale of personal data. Because we do not use cookies for targeted advertising or sell personal data, these opt-out rights have limited application to our Service, and we provide the other rights as described in our Privacy Policy.

30.6 Texas

Under the Texas Data Privacy and Security Act, Texas residents have rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and certain profiling, including through a recognised opt-out preference signal. We honour recognised signals where required, subject to the same limited practical effect.

30.7 Other states

Additional states have enacted or are enacting comprehensive privacy laws with broadly similar rights, including rights to access, correct, delete, and port personal data, and to opt out of targeted advertising, sale, and certain profiling. Where such a law applies to you, we will honour the mandatory rights it provides, consistent with the positions described in this Policy. Please contact support@tryneth.com for information relevant to your state.

31. How Consent Is Technically Enforced

This Section explains, in plain terms, how we give effect to your cookie choices in practice, so that you can understand what happens behind the scenes when you use our banner and preference centre.

31.1 Blocking before consent

Our aim is that non-essential cookies are not set, and non-essential technologies do not run, until you have given consent, where consent is required. Strictly necessary cookies, and the minimal storage needed to present the banner and remember that it has been shown, may operate before you choose, because they are essential.

31.2 Applying your choices

When you accept or reject categories, or make granular choices, we record your decision and configure the Service to load only the technologies consistent with your choices. If you reject a category, the technologies in that category are not loaded, and any that were conditionally present are prevented from operating for non-essential purposes, subject to technical constraints.

31.3 Storing and honouring your choices

Your choices are stored, typically in a consent record on your device and, where applicable, in our systems, so that we can apply them on future visits and demonstrate compliance. If you clear your cookies, use a different browser or device, or a significant period passes, we may ask you to choose again.

31.4 Opt-out preference signals

Where your browser or device sends a recognised opt-out preference signal, and applicable law requires us to honour it, we treat it as a valid opt-out for that browser or device, as described in Sections 13 and 30.

31.5 Limits and good faith

We make reasonable and good-faith efforts to enforce your choices, but the operation of cookies depends on your browser, your device, and third-party technologies that we do not fully control. Some enforcement is subject to technical limitations, and there may be a short delay before a change takes full effect. If you believe your choices are not being honoured, please contact support@tryneth.com.

32. Legitimate-Interests and Necessity Assessment for Essential Cookies

For cookies that we treat as strictly necessary or that we set on the basis of legitimate interests, we have considered whether that treatment is appropriate. This Section summarises that assessment for transparency; a fuller assessment is available on request via support@tryneth.com.

32.1 Purpose and necessity

We use essential cookies only where they are genuinely necessary to provide the Service you have requested, to keep it secure, or to deliver it reliably. We do not classify cookies as essential in order to avoid seeking consent where consent is properly required.

32.2 Balancing

For cookies set on the basis of legitimate interests, we have balanced our interests, such as security, fraud prevention, and reliable delivery, against your interests, rights, and reasonable expectations. We consider that these cookies are consistent with your expectations when you use a secure online service, that they are limited to what is necessary, and that they do not involve intrusive tracking. We apply safeguards such as limited durations, restricted access, and, where possible, aggregation or de-identification.

32.3 Your controls

Even for essential cookies, you retain control through your browser and device settings, as described in Sections 11 and 12 and Appendix C, on the understanding that blocking essential cookies may prevent the Service from working.

33. Frequently Asked Questions

33.1 Do I have to accept cookies to use the Service?

You do not have to accept non-essential cookies. The Service will work with only strictly necessary cookies, although some convenience and personalisation features may be unavailable if you reject functional cookies, and we will not be able to measure and improve performance as effectively if you reject analytics cookies.

33.2 Will you track me for advertising?

No. We do not use cookies to build advertising profiles or to serve you targeted third-party advertising, and we do not sell or share your personal information for cross-context behavioural advertising.

33.3 How do I change my mind after I have chosen?

You can reopen our preference centre from the Service at any time to change or withdraw your choices, or you can use your browser or device settings, as described in Section 11 and Appendix C.

33.4 What happens if I clear my cookies?

If you clear your cookies, your saved preferences, including your consent record, may be deleted, so you may be asked to choose again, and you may be signed out of the Service.

33.5 Do you use cookies in your mobile or embedded apps?

Where the Service is provided through an application, we may use technologies that perform functions similar to cookies, such as software development kits and locally stored identifiers, subject to the same principles and, where required, your consent, as described in Section 15.

33.6 Who do I contact with questions?

You can contact our Privacy Team at support@tryneth.com, and you can also contact the relevant supervisory authority listed in Appendix E.

Appendices

Appendix A: Glossary of Cookie and Tracking Terms

This glossary explains terms commonly used in relation to cookies and online tracking. It is provided to help you understand this Policy and does not narrow any right or obligation under applicable law.

• Adequacy decision: a decision by a competent authority that a country outside its territory provides an adequate level of data protection, allowing personal data to be transferred there without additional safeguards.
• Analytics: the measurement and analysis of how a service is used, typically to understand and improve performance and user experience, often on an aggregated basis.
• Anonymous or anonymised data: data that has been processed so that it can no longer be attributed to an identifiable individual, and that is therefore outside the scope of data-protection law.
• Behavioural advertising: advertising that is targeted to individuals based on a profile built from their activity over time, often across multiple websites or services.
• Client-side storage: storage mechanisms provided by a browser or application that keep information on your device, such as local storage, session storage, and indexed databases.
• Consent: a freely given, specific, informed, and unambiguous indication of a person’s wishes, given by a clear affirmative action, that signifies agreement to processing.
• Consent management platform: a tool that presents cookie choices to users, records their consent, and helps a service honour those choices; also called a preference centre.
• Cookie: a small text file that a service asks your browser to store on your device and that can be read back later to recognise the device or remember information.
• Cross-context behavioural advertising: the targeting of advertising to a consumer based on personal information obtained from the consumer’s activity across businesses, websites, or services that are not the business with which the consumer intentionally interacts; a defined term under the CCPA/CPRA.
• Device fingerprinting: a technique that combines information about a device and its configuration to recognise the device, potentially without using cookies.
• Do Not Track: a browser setting that signals a user’s preference not to be tracked, for which there is no common industry standard of response.
• First-party cookie: a cookie set by the service you are visiting, under its own domain.
• Global Privacy Control: an opt-out preference signal that a browser or extension can send to communicate a user’s choice to opt out of the sale or sharing of personal information.
• Local storage: a client-side storage mechanism that allows a service to store information in your browser that persists across sessions until cleared.
• Persistent cookie: a cookie that remains on your device for a defined period or until deleted, allowing recognition across sessions.
• Personal data or personal information: information relating to an identified or identifiable individual, as defined under applicable law.
• Pixel or web beacon: a small, often invisible, file or piece of code that can record that a page was viewed or an action taken, often working with cookies.
• Preference centre: the interface through which you can review and change your cookie choices; see consent management platform.
• Processor or service provider: an entity that processes personal data on behalf of, and under the instructions of, a controller or business.
• Sale (of personal information): as defined under applicable US state privacy laws, the disclosure of personal information for monetary or other valuable consideration; we do not sell personal information collected through cookies.
• Session cookie: a cookie that exists only for the duration of a browsing session and is deleted when the browser is closed.

• Sharing (for cross-context behavioural advertising): as defined under the CCPA/CPRA, the disclosure of personal information for cross-context behavioural advertising; we do not share personal information collected through cookies for this purpose.
• Software development kit (SDK): a set of code included in an application that can provide functionality and collect information, performing functions similar to cookies in an app context.
• Standard Contractual Clauses: standard data-protection clauses approved by a competent authority that provide a safeguard for international transfers of personal data.
• Strictly necessary cookie: a cookie that is essential to provide a service that the user has requested, and that is therefore exempt from the consent requirement under the ePrivacy rules.
• Supervisory authority: an independent public authority responsible for monitoring the application of data-protection law.
• Tag or tag manager: code used to deploy and manage other technologies on a page in a controlled way.
• Third-party cookie: a cookie set by a domain other than the service you are visiting, such as a provider embedded in the service.

Appendix B: Detailed Illustrative Cookie Inventory

This appendix provides a more detailed illustrative inventory of the cookies and similar technologies we may use, organised by category. It is illustrative and not definitive. The authoritative, up-to-date inventory, including the specific cookies actually in use and any third-party technologies, is maintained in our cookie preference centre. Third-party technologies are described by function rather than by name, consistent with the rest of our documentation. Durations are typical and may vary.

B.1 Strictly necessary cookies

B.2 Functional and preference cookies

B.3 Analytics and performance cookies

B.4 Security and fraud-prevention cookies

Appendix C: How to Manage Cookies in Major Browsers

You can manage cookies through your browser settings, in addition to using our preference centre. The following instructions are provided as general guidance for widely used browsers. Browser makers update their software regularly, so the exact steps and menu names may change. If the steps below do not match your version, consult your browser’s help resources. These browsers are named only to help you find the relevant settings; they are not our service providers.

C.1 Google Chrome (desktop)

Open the menu in the top-right corner, choose Settings, then Privacy and security, then Cookies and other site data (or Third-party cookies, depending on your version). From there you can choose to block or allow cookies, block third-party cookies, clear cookies when you close all windows, and see and delete existing cookies. You can also clear browsing data, including cookies, from the Privacy and security section.

C.2 Mozilla Firefox (desktop)

Open the menu in the top-right corner, choose Settings, then Privacy & Security. Under Enhanced Tracking Protection you can select a protection level, and under Cookies and Site Data you can clear data, manage exceptions, and choose to delete cookies when Firefox is closed. Firefox also lets you manage data for individual sites.

C.3 Apple Safari (macOS)

Open Safari, choose Safari in the menu bar, then Settings (or Preferences), then Privacy. There you can choose to block all cookies, prevent cross-site tracking, and manage or remove stored website data. You can also clear history and website data from the Safari menu.

C.4 Microsoft Edge (desktop)

Open the menu in the top-right corner, choose Settings, then Cookies and site permissions, then Manage and delete cookies and site data. From there you can allow or block cookies, block third-party cookies, and see and delete existing cookies. You can also clear browsing data, including cookies, from the Privacy, search, and services section.

C.5 Opera (desktop)

Open Settings, then go to Privacy & security. Under Cookies and other site data you can choose how cookies are handled, block third-party cookies, and clear cookies on exit, and you can view and delete existing cookies.

C.6 Safari on iPhone and iPad

Open the Settings app, scroll to Safari, then under Privacy & Security you can enable Prevent Cross-Site Tracking and Block All Cookies, and you can clear history and website data. You can also manage tracking permissions for apps under Settings, then Privacy & Security, then Tracking.

C.7 Google Chrome on Android

Open Chrome, tap the menu, choose Settings, then Site settings, then Cookies. From there you can allow or block cookies and block third-party cookies. You can clear cookies through Settings, then Privacy and security, then Clear browsing data.

C.8 A note on blocking cookies

If you block or delete cookies through your browser, including strictly necessary cookies, some features of the Service may not work properly, you may be signed out, and you may need to set your preferences again each time

you visit. Private or incognito browsing modes limit the persistence of cookies but do not by themselves prevent all cookies during your session.

Appendix D: Opt-Out Preference Signals and Industry Opt-Out Programmes

This appendix explains opt-out preference signals and industry opt-out programmes. Because we do not use cookies for third-party behavioural advertising, and do not sell or share personal information for cross-context behavioural advertising, these mechanisms have limited practical effect on our Service, but we provide the information for completeness and transparency.

D.1 Opt-out preference signals

Opt-out preference signals, such as Global Privacy Control, are signals that a browser or extension can send to a service to communicate your choice to opt out of the sale or sharing of your personal information. Where required by applicable law, we treat a recognised opt-out preference signal as a valid opt-out request for the browser or device from which it is sent. You can enable such a signal by using a browser or extension that supports it; the availability and configuration of these signals are determined by the maker of the browser or extension.

D.2 Industry opt-out programmes

Various self-regulatory programmes allow you to opt out of interest-based advertising from participating companies. These include, in Europe, the Your Online Choices programme operated under the European Interactive Digital Advertising Alliance, and, in the United States, the programmes operated by the Digital Advertising Alliance and the Network Advertising Initiative. These programmes are operated by industry bodies, not by us, and opting out through them typically sets its own cookies to record your preference. Because we do not use third-party advertising cookies on our Service, opting out through these programmes is not necessary to prevent advertising by us, but you may use them to manage advertising by participating companies more generally.

D.3 Analytics opt-out

You can prevent analytics cookies on our Service by declining them in our preference centre or by using your browser controls. Where analytics are provided through a third-party technology that offers its own opt-out mechanism, that mechanism is described in our preference centre where applicable.

Appendix E: Supervisory Authorities and Regulators

If you have concerns about our use of cookies or our handling of personal data, we encourage you to contact us first at support@tryneth.com. You also have the right to contact the relevant supervisory authority. The following are the principal authorities relevant to this Policy. You may also contact the authority in your own country of residence or work.

Contact details for these authorities are available on their official websites. We will cooperate with supervisory authorities in the exercise of their functions.

Appendix F: Summary of Applicable Legal Frameworks

This appendix summarises the principal legal frameworks that inform this Policy. It is provided for transparency and is not legal advice. The frameworks that apply to you depend on where you are located and how you use the Service.