ALLROUNDER BABY - COOKIES POLICY

1. Introduction to Cookies and Tracking Technologies

This Cookies Policy explains how Sarvashine Allrounder Baby Solutions Private Limited ("Allrounder Baby", "Company", "we", "us", or "our") uses cookies and similar tracking technologies on our website, mobile applications, and digital platforms (collectively, the "Platform").

Tracking technologies may include:

• cookies,
• pixels,
• tags,
• web beacons,
• SDKs (Software Development Kits),
• local storage,
• device identifiers,
• messaging and communication tracking technologies, and
• similar technologies used to collect or store information about your interaction with our Platform.

These technologies may collect information that is:

• personal data (i.e., information that directly or indirectly identifies you), or
• non-personal data (i.e., information that does not directly identify any individual).

Depending on your interaction with our Platform, this information may include:

• device and browser details,
• IP address and approximate location,
• pages visited and interaction patterns,
• session data and authentication status,
• referral sources and campaign interactions,
• video interaction and engagement data,
• advertising and remarketing signals,
• communication interaction data (such as message delivery, opens, clicks, or engagement where applicable).

1.1 Scope of this Cookies Policy

This Cookies Policy applies to:

• our website (including public and logged-in areas),
• our mobile applications (Android and iOS),
• embedded services, video players, and third-party integrations,
• marketing pages, landing pages, and campaign flows,
• communication channels integrated with our services (such as WhatsApp, Telegram, or similar platforms),
• tracking technologies used across devices, sessions, and environments.

This Policy should be read together with:

• our Privacy Policy, and
• our Terms of Use.

1.2 Purpose of Cookies and Tracking Technologies

We use cookies and similar technologies to:

• ensure the Platform functions securely and correctly,
• enable login, authentication, and session management,
• deliver and protect video-based content (including DRM systems),
• measure usage, performance, and engagement,
• improve user experience and platform functionality,
• support analytics and business insights,
• enable marketing, remarketing, and campaign performance tracking,
• personalize content and communication where applicable,
• facilitate and analyze communication through messaging platforms (such as WhatsApp, Telegram, or similar services), including delivery status, interaction, and engagement where applicable.

1.3 Strictly Necessary vs Non-Essential Technologies

Some tracking technologies are strictly necessary for the operation of the Platform. These include technologies used for:

• authentication and login systems,
• session management,
• security controls and fraud prevention,
• content delivery and DRM enforcement,
• infrastructure stability and load balancing,
• essential communication delivery (such as OTPs, transactional messages, or account-related notifications through messaging platforms).

These technologies are used without requiring consent, where permitted by applicable law.

Only those cookies and similar technologies that are strictly necessary to provide a service explicitly requested by the user, or to ensure the security, integrity, and core technical functioning of the Platform, are used without consent where permitted by applicable law. This category does not include analytics, audience measurement, advertising, remarketing, personalization, or marketing/engagement tracking merely because they are useful to our business.

1.4 Consent and Preference Management

We operate a strict opt-in consent model for non-essential tracking technologies.

Before such technologies are activated:

• you will be presented with a cookie banner,
• you may choose to:
  • accept all cookies,
  • reject non-essential cookies, or
  • customize your preferences.

You can manage your preferences through a dedicated Cookie Preference Center, which allows you to:

• enable or disable specific categories of cookies and tracking technologies,
• withdraw your consent at any time,
• update your preferences for future interactions.

Your consent choices may be stored using a combination of:

• cookies on your device, and
• secure backend records (including timestamp, consent status, and policy version),

to support compliance, auditability, and consistent user experience.

We may request renewed consent:

• if there are material changes to our use of cookies or tracking technologies, and
• periodically, where required for compliance or best practices.

Our consent interface is designed so that rejecting non-essential cookies is as easy as accepting them, and users are not required to go through unnecessary steps to refuse non-essential tracking.

No non-essential cookies or tracking technologies are placed or activated on your device before you provide valid consent, except where strictly necessary.

The option to reject non-essential cookies and tracking technologies shall be presented with substantially the same visibility and ease as the option to accept them, and access to the Platform shall not be made conditional on acceptance of non-essential technologies.

Where technically feasible, we may provide more granular controls, including preferences at the level of specific technologies or individual service providers.

We do not use dark patterns or misleading design practices when obtaining user consent.

We do not design consent interfaces in a manner intended to manipulate, coerce, or unfairly influence user decisions.

Where technically feasible, consent preferences are enforced through both client-side and server-side mechanisms to prevent unauthorized activation of non-essential technologies.

1.5 Relationship with Personal Data

Where cookies and tracking technologies collect or process personal data, such data is handled in accordance with our Privacy Policy.

This includes information relating to:

• how we collect and use personal data,
• the legal bases for processing,
• data retention practices,
• data sharing and third-party involvement, and
• your rights and choices.

For more details, please refer to our Privacy Policy.

User-submitted content such as images, audio, or videos is governed under the Privacy Policy. Where such content is submitted through workflows that clearly disclose intended use, the authorization framework described in the Privacy Policy will apply to internal and, where disclosed, public marketing use.

1.6 Legal Basis for Use of Cookies and Tracking Technologies

We rely on the following legal bases under applicable data protection laws:

• Strictly Necessary Technologies -> Necessary for providing a service explicitly requested by the user and/or for ensuring security and core functionality (as permitted under applicable ePrivacy laws).
• Where such technologies involve the processing of personal data, we may rely on legitimate interests (such as security, fraud prevention, and system integrity) where permitted under applicable data protection laws.
• Functional Technologies -> Consent (where required)
• Analytics Technologies -> Consent
• Advertising and Marketing Technologies -> Explicit consent
• Communication Tracking (marketing-related) -> Consent

Where cookies involve personal data processing, the legal basis aligns with Article 6 of the GDPR or equivalent applicable laws.

Where applicable (including users in the European Economic Area), we comply with the requirements of the ePrivacy Directive and related national laws governing the use of cookies and similar technologies.

Where we rely on legitimate interests, we ensure that such interests are balanced against your rights and freedoms, and that appropriate safeguards are implemented to minimize any impact.

Where legitimate interests are relied upon for strictly necessary technologies, such processing is limited to what is strictly required for security, fraud prevention, or core service delivery, and does not override consent requirements for non-essential tracking technologies.

1.7 Consent Logging and Audit Records

We maintain secure records of user consent, including:

• timestamp of consent
• consent preferences selected
• policy version at time of consent
• device or session identifiers (where necessary)

These records are maintained for compliance, audit, and dispute resolution purposes.

Consent records are protected through appropriate technical and organizational measures to prevent unauthorized access, alteration, or loss.

Access to consent records is restricted to authorized personnel on a need-to-know basis and subject to appropriate access controls.

Consent records may include the version of the notice shown, the categories accepted or rejected, the date and time of the user’s choice, and related compliance metadata reasonably necessary to demonstrate lawful consent management.

2. Cookies and Tracking Technologies We Use

We use a combination of first-party and third-party cookies and similar technologies across our Platform, including our website, mobile applications, and integrated services.

These technologies may operate:

• on your browser,
• within mobile applications through SDKs,
• through embedded services (such as video players),
• via communication platforms (such as WhatsApp or similar messaging systems),
• or through third-party integrations supporting analytics, payments, payouts, and infrastructure.

2.1 Types of Tracking Technologies

We use the following categories of tracking technologies:

(a) Cookies

Cookies are small text files stored on your device when you visit a website.

They are used to:

• maintain session continuity (e.g., login state),
• remember preferences and settings,
• enable secure navigation and functionality,
• support analytics and performance measurement,
• enable advertising and remarketing activities.

Cookies may be:

• Session cookies – deleted when you close your browser, or
• Persistent cookies – stored for a defined period.

(b) Software Development Kits (SDKs)

In our mobile applications, we use SDKs provided by third-party services.

SDKs may collect and process data such as:

• app usage and interaction data,
• device identifiers or app instance identifiers,
• session activity and navigation events,
• crash reports and performance data.

SDKs may be used by services including:

• analytics providers,
• messaging and communication systems,
• payment and payout integrations,
• video delivery and DRM systems.

Unlike browser cookies, SDKs operate within mobile applications and may collect similar types of information.

(c) Pixels, Tags, and Tracking Scripts

Pixels and tags are small pieces of code embedded in our Platform that allow us to:

• track user behavior and interactions,
• measure campaign performance,
• attribute conversions,
• understand engagement across pages or sessions.

These technologies may be associated with advertising platforms such as:

• Meta (Facebook/Instagram),
• Google Ads and related services,
• LinkedIn Ads,
• and similar providers.

(d) Web Beacons

Web beacons (also known as clear GIFs or tracking beacons) are small invisible elements used to:

• measure interaction with content (such as emails or web pages),
• track whether a user has viewed or engaged with specific content,
• support analytics and campaign measurement.

(e) Device Signals and Limited Device Recognition Signals (Non-Tracking)

We use limited device-related signals strictly for security, authentication, and fraud prevention purposes.

We do not use device fingerprinting techniques for cross-service tracking or advertising profiling.

These signals are not used to track users across unrelated services or for advertising profiling without consent.

These signals may include:

• device type and configuration
• operating system and app version
• session identifiers and login patterns
• device-level usage characteristics

(f) Video and Content Interaction Technologies (DRM & Playback Tracking)

We use specialized video delivery and content protection systems (such as DRM-enabled platforms) to:

• deliver secure video content,
• enforce playback restrictions,
• prevent unauthorized access or distribution,
• monitor video interaction and engagement.

These systems may collect:

• playback duration and interaction events,
• session-level activity,
• device and access-related signals,
• content access patterns.

Such technologies are essential for content protection, platform security, and service delivery.

(g) Communication and Messaging Tracking Technologies

We may use communication platforms (such as WhatsApp, Telegram, or similar services) integrated through third-party providers to send:

• authentication messages (e.g., OTPs),
• transactional updates (e.g., account or payout status),
• marketing or engagement messages (where permitted).

Where applicable, these systems may collect or process:

• message delivery status,
• interaction signals (such as message opens or clicks),
• engagement or response data.

Tracking associated with:

• transactional communications is treated as necessary for service delivery, while
• marketing or engagement tracking is treated as non-essential and subject to consent where required.

2.2 First-Party vs Third-Party Technologies

We use both:

First-party technologies

Set directly by us to:

• enable platform functionality,
• manage sessions and authentication,
• store preferences and consent settings,
• support internal analytics and operations.

Third-party technologies

Set by external service providers integrated into our Platform, including providers supporting:

• analytics and performance measurement,
• advertising and remarketing,
• payment processing,
• payout processing,
• communication and messaging,
• video delivery and DRM,
• infrastructure and hosting.

These third parties may process data in accordance with their own policies, subject to applicable contractual and legal safeguards.

2.3 Categories of Cookies and Tracking Technologies

We classify cookies and similar technologies into the following categories:

(a) Strictly Necessary Technologies

These technologies are essential for the Platform to function and cannot be disabled.

They are used for:

• login and authentication,
• session management,
• security and fraud prevention,
• DRM and content protection,
• platform stability and infrastructure,
• essential communication delivery (e.g., OTP, account notifications).

(b) Functional Technologies

These technologies enhance usability and user experience by:

• remembering preferences and settings,
• enabling language or interface customization,
• supporting certain interactive features.

(c) Analytics and Performance Technologies

These technologies help us:

• understand how users interact with the Platform,
• measure engagement and performance,
• improve functionality and user experience,
• conduct internal analysis and reporting.

Where feasible, data may be aggregated or anonymized.

(d) Advertising and Marketing Technologies

These technologies are used to:

• measure campaign effectiveness,
• enable remarketing and retargeting,
• deliver relevant advertisements,
• optimize advertising performance.

We do not upload customer contact lists (such as email or phone numbers) to advertising platforms for custom audience targeting without a valid legal basis.

(e) Communication and Engagement Technologies

These technologies are used to:

• deliver messages via communication platforms (e.g., WhatsApp, Telegram),
• track delivery and engagement where applicable,
• improve communication effectiveness.

Marketing-related communication tracking is enabled only after consent where required.

(f) Security and Integrity Technologies

These technologies are used to:

• detect and prevent fraud or misuse,
• enforce access controls and device limits,
• monitor suspicious activity,
• protect user accounts and platform integrity.

For clarity, analytics, performance measurement, advertising, remarketing, attribution, and similar tracking technologies are not treated as “strictly necessary” solely because they are useful for business operations, reporting, or growth.

2.4 Use Across Website and Mobile Applications

Tracking technologies may operate differently across:

Website:

• browser-based cookies,
• pixels and tags,
• session storage and local storage.

Mobile Applications:

• SDK-based tracking,
• device identifiers,
• in-app event tracking,
• DRM and video interaction tracking.

In our mobile applications, consent choices may be recorded and enforced through in-app consent states, SDK configurations, and device-level settings rather than browser cookies alone. Depending on the technology used, withdrawing consent in the app may require disabling specific SDK-based processing for future interactions while allowing strictly necessary app functions to continue.

Where mobile applications use SDKs, device identifiers, or similar application-level tracking technologies for analytics, attribution, advertising, or performance monitoring, such technologies shall be subject to consent requirements equivalent to those applied to non-essential website cookies where required by applicable law and platform rules.

2.5 Third-Party Service Integration (Illustrative)

We may use or integrate services from third-party providers supporting:

• payment processing (e.g., Razorpay, Cashfree, PayPal),
• payout processing (e.g., Tremendous),
• messaging and communication (e.g., MSG91 or similar providers),
• video delivery and DRM (e.g., VdoCipher),
• analytics and performance tools (e.g., Google Analytics, Firebase),
• advertising platforms (Meta, Google, LinkedIn)
• mobile platform providers (Google Play Store, Apple App Store)
• infrastructure and hosting services.

Such providers may use cookies or similar technologies as part of their services.

A more detailed and current list of cookies, SDKs, pixels, and similar technologies in active use, including provider names, purposes, categories, and retention periods where available, may be provided through our Cookie Preference Center or an associated cookie details layer.

For certain advertising and analytics providers (such as Meta or Google), we and such providers may act as independent controllers or joint controllers depending on the context of processing. Where applicable, such arrangements are governed by the provider’s terms and data processing agreements.

Where required, joint controller arrangements or equivalent legal frameworks are implemented in accordance with applicable data protection laws.

The Company shall take reasonable steps to configure third-party tools so that non-essential tracking is not activated before the required user consent is obtained, except where a particular technology is strictly necessary for the core service expressly requested by the user.

Where joint controllership applies (for example, in relation to certain analytics or advertising integrations), we provide relevant information regarding the essence of such arrangements through our privacy notices or by reference to the respective provider’s disclosures, as required under applicable law.

3. Categories of Cookies and Tracking Technologies We Use

We use different categories of cookies and similar tracking technologies across our Platform. These technologies serve different purposes and are subject to different consent requirements depending on their nature and function.

We classify these technologies into the following categories:

3.1 Strictly Necessary Technologies

These technologies are essential for the operation, security, and core functionality of the Platform. They cannot be disabled through our cookie preference settings.

These technologies are used for purposes such as:

• enabling login and authentication,
• maintaining secure user sessions,
• enforcing access controls and device restrictions,
• protecting content through DRM and playback controls,
• ensuring platform stability and infrastructure performance,
• enabling essential communication such as OTP delivery and account-related notifications,
• preventing fraud, abuse, or unauthorized access.

Without these technologies, the Platform may not function correctly or securely.

Examples of use:

• session identifiers and authentication tokens,
• login state management,
• device/session control systems,
• video access control and playback enforcement mechanisms,
• essential backend communication processes.

Duration:

• Session-based or up to 12 months, depending on function.

Legal basis:

Necessary for providing a service explicitly requested by the user under applicable ePrivacy laws, and, where personal data is processed, legitimate interests (Article 6(1)(f) GDPR) for security, fraud prevention, and system integrity.

Consent requirement:

Where consent is required under applicable law, processing will not be carried out on the basis of legitimate interests alone.

3.2 Functional Technologies

These technologies enhance the usability and experience of the Platform but are not strictly required for core functionality.

They may be used to:

• remember user preferences and settings,
• store language or interface preferences,
• improve user experience across sessions,
• support optional features or convenience functions.

Examples of use:

• preference storage,
• UI customization settings,
• non-essential feature enablement.

Duration:

• Typically up to 12 months

Legal basis:

Consent (Article 6(1)(a) GDPR, where applicable)

Consent requirement:

Required prior to activation

3.3 Analytics and Performance Technologies

These technologies help us understand how users interact with the Platform and improve performance and functionality.

They may be used to:

• measure user engagement and navigation patterns,
• analyze feature usage and performance,
• identify technical issues or errors,
• improve content, structure, and user experience,
• generate aggregated insights for internal analysis and reporting.

These technologies may operate across:

• website environments (via cookies and tags), and
• mobile applications (via SDKs such as analytics and crash reporting tools).

Where possible, we aim to use aggregated or non-identifiable data for long-term analysis.

Our mobile applications are distributed through platforms including the Google Play Store and the Apple App Store. Use of our applications may also be subject to the terms, policies, and privacy frameworks of these platform providers.

On iOS devices, certain data collection, tracking, or attribution activities may be governed by Apple platform requirements, including user permissions and device-level privacy settings. Users may control such permissions through their device settings.

Examples of use:

• page views, session duration, and navigation flows,
• app usage events and performance metrics,
• crash reporting and diagnostics,
• internal reporting tools (such as business intelligence systems).

Duration:

• Typically 30 days to 24 months

Legal basis:

Consent (Article 6(1)(a) GDPR, where applicable)

Consent requirement:

Required prior to activation

3.4 Advertising and Marketing Technologies

These technologies are used to support advertising, campaign measurement, and marketing optimization.

They may be used to:

• measure effectiveness of advertising campaigns,
• track interactions with ads or promotional content,
• enable remarketing and retargeting,
• attribute conversions and user journeys,
• optimize marketing strategies and communication relevance.

These technologies may be provided by third-party platforms such as advertising networks and social media platforms.

We do not upload customer contact lists (such as email addresses or phone numbers) to advertising platforms for custom audience targeting without a valid legal basis.

Examples of use:

• campaign performance tracking,
• ad interaction measurement,
• conversion attribution,
• remarketing signals.

Duration:

• Typically 90 days to 24 months

Legal basis:

Consent (Article 6(1)(a) GDPR, where applicable)

Consent requirement:

Required prior to activation

These technologies are not used to make solely automated decisions that produce legal or similarly significant effects on users.

Advertising and marketing technologies, including remarketing, audience building, conversion measurement, and similar tracking, shall operate only on the basis of valid consent where such consent is required under applicable law.

3.5 Communication and Engagement Technologies

Technologies used solely to deliver or confirm user-requested or service-critical communications, such as OTPs, login notices, or essential account/payout status updates, may be treated as necessary where permitted by law. Technologies used to measure opens, clicks, engagement, profiling, optimization, or effectiveness of marketing or promotional communications are treated as non-essential and require consent where applicable.

This may include integration with platforms such as:

• WhatsApp (via service providers such as MSG91),
• Telegram or similar messaging platforms,
• email and notification systems.

Tracking associated with:

• transactional communications is treated as necessary, while
• marketing or engagement tracking is treated as non-essential and subject to consent.

Examples of use:

• message delivery confirmation,
• interaction tracking (such as clicks or engagement),
• communication performance measurement.

Duration:

• Typically session-based to 12 months

Legal basis:

Consent (Article 6(1)(a) GDPR, where applicable)

Consent requirement:

Required prior to activation

3.6 Security, Integrity, and Device-Control Technologies

These technologies are used to protect the Platform, enforce usage policies, and maintain system integrity.

They may be used to:

• detect and prevent fraud, abuse, or unauthorized access,
• enforce account-level restrictions (such as device limits),
• monitor login attempts and unusual activity patterns,
• maintain audit trails and system logs,
• support risk assessment and platform security controls.

These technologies may involve the use of limited device-related signals and session-level data.

Such processing is designed to support security and operational integrity and is not intended for invasive tracking across unrelated services.

Examples of use:

• login attempt monitoring,
• device/session validation,
• fraud detection systems,
• access control enforcement.

Duration:

• Session-based to extended retention (as required for security and compliance)

Legal basis:

Legitimate interests (security, fraud prevention, platform integrity)

Consent requirement:

Not required (where permitted by applicable law)

3.7 Dynamic Nature of Cookies and Technologies

The specific cookies, tracking technologies, and service providers we use may change over time due to:

• updates to our Platform,
• introduction of new features or services,
• changes in third-party providers,
• improvements in analytics, security, or marketing tools.

As a result:

• the categories described above remain applicable, even if specific technologies change,
• we may update this Cookies Policy periodically to reflect such changes,
• where required, we will update consent mechanisms accordingly.

4. Third-Party Cookies, Technologies and Service Providers

We use and integrate services provided by third-party vendors to support the operation, security, functionality, analytics, communication, and growth of our Platform.

These third parties may use cookies, SDKs, pixels, or similar technologies as part of their services.

4.1 Categories of Third-Party Providers

We may engage third-party providers across the following categories:

(a) Payment Processing Providers

Used to securely process payments and transactions:

• Razorpay
• Cashfree
• PayPal

These providers may collect and process payment-related information, transaction data, and technical identifiers necessary to complete and validate transactions.

(b) Payout and Reward Processing Providers

Used to distribute referral rewards, incentives, or payouts:

• Tremendous

Tremendous may operate as an independent service provider and/or data controller for certain aspects of payout processing, including redemption options and financial transfers.

Users interacting with such services may also be subject to the provider’s own terms and privacy policies.

(c) Messaging and Communication Providers

Used to deliver transactional and engagement-related communications:

• MSG91 (for WhatsApp communication) 
• Telegram (where applicable)
• similar communication platforms

These providers may process:

• message delivery data,
• interaction signals (such as clicks or engagement),
• communication metadata.

(d) Video Delivery and DRM Providers

Used to securely deliver and protect video content:

• VdoCipher

Such providers may process:

• playback activity,
• session-level data,
• device-related signals,
• content access information

in accordance with their own policies and for purposes of content protection and service delivery.

(e) Analytics and Performance Providers

Used to analyze usage and improve Platform performance:

• Google Analytics (GA4)
• Firebase (analytics, crash reporting, notifications)
• internal analytics systems (such as Power BI)

These tools help us understand user behavior, measure performance, and improve user experience.

(f) Advertising and Marketing Platforms

Used to measure and optimize advertising campaigns:

• Meta (Facebook/Instagram)
• Google Ads and related services
• LinkedIn Ads
• and similar advertising partners

These providers may use tracking technologies to measure campaign performance, attribute conversions, and enable remarketing where permitted.

(g) Infrastructure, Hosting and Support Services

Used to ensure the Platform operates securely and efficiently:

• hosting providers,
• cloud infrastructure services,
• content delivery systems,
• security and monitoring tools.

4.2 Nature of Data Sharing

We may share limited data with third-party providers strictly as required to deliver their services.

Such sharing may include:

• technical identifiers (such as device or session information),
• usage and interaction data,
• transaction-related data (for payment or payout processing),
• communication-related data (for message delivery and engagement),
• analytics and performance data.

We follow a data minimization approach, meaning we share only the data that is necessary for the specific purpose.

4.3 Processor vs Independent Controller Roles

Depending on the service and context, third-party providers may process information either on our behalf under contractual restrictions or for their own independent purposes. Their role may vary by product, integration, and applicable law. Where third parties act independently, their processing is governed by their own privacy notices, terms, and compliance obligations.

Where third-party providers act as independent controllers for their own advertising, analytics, or measurement purposes, their processing shall remain subject to applicable consent requirements, transparency obligations, and their own privacy notices, in addition to this Policy.

4.4 Cross-Border Data Transfers

Due to the global nature of our operations and service providers, your data may be processed or transferred to countries outside your jurisdiction, including jurisdictions that may have different data protection standards.

Where such transfers occur, we implement appropriate technical and organizational measures to ensure that:

• appropriate safeguards are in place,
• contractual protections are implemented where required,
• data is handled in accordance with applicable data protection laws.

Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Data Processing Agreements 
• Adequacy decisions (where applicable)

or other legally recognized mechanisms under applicable data protection laws.

Where required, users may request additional information regarding applicable transfer safeguards.

4.5 Vendor Security and Compliance

We require third-party service providers to:

• implement appropriate security measures,
• process data in accordance with applicable data protection laws,
• adhere to contractual obligations relating to confidentiality and data protection.

However, where providers act independently, their obligations are governed by their own policies and applicable laws.

4.6 Advertising and Data Use Clarification

We do not upload customer contact lists (such as email addresses or phone numbers) to advertising platforms for custom audience targeting without a valid legal basis.

Advertising technologies are used primarily for:

• performance measurement,
• campaign optimization,
• aggregated insights and attribution.

4.7 Child-Related Data Safeguards

Where information relates to children (provided by parents or guardians):

• such data is handled with additional sensitivity,
• it is not used for independent advertising profiling of children,
• it is not shared with third-party advertising platforms for child-targeted marketing.

We do not knowingly use non-essential cookies, SDKs, or similar technologies to create advertising profiles of children or to target children with behavioral advertising.

We do not use cookies or tracking technologies for behavioral advertising targeting children.

4.8 Payment and Third-Party Responsibility

While we facilitate integrations with payment, payout, and communication providers, such providers operate independently.

We are not responsible for:

• errors, delays, or failures caused by third-party systems,
• fees or charges applied by third-party providers,
• policies or actions of such providers outside our control,

except to the extent required by applicable law.

4.9 Updates to Third-Party Providers

We may update, add, or remove third-party providers from time to time due to:

• changes in business operations,
• introduction of new services or features,
• improvements in technology or security,
• regulatory or compliance requirements.

This Cookies Policy will be updated where necessary to reflect material changes.

5. Managing Cookie Preferences and Your Choices

You have control over how cookies and similar tracking technologies are used on our Platform. This section explains how you can manage your preferences and exercise your choices.

5.1 Cookie Banner and Initial Choices

When you first visit the Platform, you may be presented with a cookie banner or similar consent interface. Except for strictly necessary technologies, cookies and comparable tracking technologies are not activated unless and until you provide the required consent.

The banner or consent interface is designed to provide clear choices, including the ability to accept all, reject non-essential technologies, or manage preferences by category. The reject option shall be presented with substantially the same visibility and ease as the accept option.

5.2 Cookie Preference Center

You can manage your cookie preferences at any time through our Cookie Preference Center, which allows you to:

• review the categories of cookies and tracking technologies in use,
• enable or disable specific categories (except strictly necessary technologies),
• update your preferences for future interactions,
• withdraw previously given consent.

The Cookie Preference Center is accessible through:

• a persistent interface element (such as a floating icon on the Platform), and/or
• links provided in the footer or settings area of the Platform.

Changes to your preferences will apply going forward and may not affect prior processing already carried out based on earlier consent.

Where available, the preference center shall permit category-level choices, such as strictly necessary, functional, analytics, and advertising or marketing technologies.

5.3 Withdrawal of Consent

Where you have provided consent for non-essential cookies or tracking technologies, you have the right to withdraw that consent at any time.

Upon withdrawal:

• non-essential tracking technologies will be disabled going forward,
• previously stored cookies may remain on your device until they expire or are manually deleted,
• certain features or functionalities of the Platform may be affected.

Withdrawal of consent is designed to be as easy as giving consent, without unnecessary friction or additional steps.

Withdrawal or modification of consent shall be as easy to perform as the giving of consent, subject only to technical steps reasonably necessary to authenticate and apply the updated choice.

5.4 Browser and Device Controls

In addition to our Cookie Preference Center, most web browsers and devices allow you to control cookies through their settings.

You may be able to:

• block or restrict cookies,
• delete existing cookies,
• receive alerts when cookies are being set.

Please note:

• disabling certain cookies may impact the functionality, performance, or user experience of the Platform,
• browser-level controls may not fully manage all types of tracking technologies (such as SDK-based tracking in mobile applications).

5.5 Mobile Application Controls

For our mobile applications:

• tracking technologies may operate through SDKs rather than browser cookies,
• you may control certain permissions through your device settings (such as app permissions, notifications, or tracking preferences),
• disabling certain permissions may affect app functionality, performance, or personalized features.

In mobile application environments, consent choices may also be implemented through in-app settings, consent prompts, device permissions, or platform-level privacy controls, depending on the nature of the technology used and the requirements of applicable law.

5.6 Do Not Track and Similar Signals

Some browsers or devices provide “Do Not Track” or similar privacy signals.

At present:

• there is no universally accepted standard for interpreting such signals,
• our Platform may not respond to all such signals in a consistent manner.

However, you can manage your preferences directly through our Cookie Preference Center as described above.

Where you make choices through our Cookie Preference Center or equivalent in-app consent controls, we will apply those choices to the non-essential technologies we control, subject to technical limitations and the architecture of third-party services.

5.7 Impact of Disabling Cookies

If you choose to restrict or disable certain cookies or tracking technologies:

• some parts of the Platform may not function correctly,
• login sessions may not be maintained,
• personalization and certain features may be limited,
• video playback or content access controls may be affected,
• communication or notification features may not work as expected.

Strictly necessary technologies will remain active as required for core functionality and security.

5.8 Updates to Preferences and Policy

We may update:

• our use of cookies and tracking technologies, and/or
• this Cookies Policy

from time to time.

Where required:

• you may be asked to review and update your preferences,
• your consent may be refreshed (for example, after significant changes or periodically in line with best practices).

Retention Clarification

Retention periods described in this Policy may refer to:

• the lifespan of cookies stored on your device; and/or
• backend records such as consent logs, analytics data, or security logs

These periods may differ depending on the purpose and legal requirements.

Consent records are retained for a period consistent with legal, audit, and compliance requirements.

6. Detailed Cookie and Tracking Technology List

A detailed and regularly updated list of cookies and similar technologies used on our Platform is made available through our Cookie Preference Center or equivalent disclosure layer where implemented.

This list includes:

• Cookie / technology name
• Provider (first-party / third-party)
• Purpose
• Category (necessary, analytics, etc.)
• Duration / retention
• Whether personal data is processed
• Third-party links (where applicable)

We ensure that this information is accessible prior to obtaining consent and remains available for review at any time.

This information is made available prior to obtaining user consent and is accessible directly from the cookie banner and preference interface.