Cookie Policy

Cognitiva Systems Inc.
Effective Date: 15 April 2026
Last Updated: 29 September 2026

1. INTRODUCTION

This Cookie Policy explains how Cognitiva Systems Inc. ("Cognitiva," "we," "us," or "our") uses cookies and similar technologies on cognitivasystems.com and related domains ("Website").

Relationship to Privacy Policy:
This Cookie Policy supplements our Privacy Policy. Terms not defined here have the meanings in the Privacy Policy.

Consent:
Strictly necessary cookies are set because the Website needs them. Every other cookie is set only after you choose to allow it in the cookie banner, and you can change that choice at any time through "Cookie settings" in the site footer. Until you choose, no analytics or marketing script is loaded.

2. WHAT ARE COOKIES

2.1 Definition

Cookies are small text files placed on your device (computer, smartphone, tablet) when you visit a website. Cookies allow the website to recognize your device and remember information about your visit.

2.2 Similar Technologies

We also use similar technologies:

• Local Storage: Browser-based storage (HTML5)
• Session Storage: Temporary browser storage
• Pixels/Beacons: Invisible images that track page views
• Scripts: JavaScript code that collects information

For simplicity, this policy uses "cookies" to refer to all these technologies.

3. WHY WE USE COOKIES

We use cookies to:

✓ Enable essential website functionality
✓ Remember your preferences and settings
✓ Analyze how visitors use our Website
✓ Improve website performance
✓ Provide secure authentication
✓ Prevent fraud and abuse
✓ Measure marketing effectiveness

4. TYPES OF COOKIES WE USE

4.1 Strictly Necessary Cookies

Purpose: Essential for website operation. Cannot be disabled without breaking functionality.

Examples:

• Session cookies (keep you logged in)
• Security cookies (prevent fraud)
• Load balancer cookies (distribute traffic)
• Cookie consent cookies (remember your preferences)

Duration: Session (deleted when browser closed) or up to 1 year

Legal Basis: Legitimate interest (necessary for service provision)

Can You Decline? NO - these are required for the Website to function.

Specific Cookies:

4.2 Performance & Analytics Cookies

Purpose: Understand how visitors use our Website to improve it.

Examples:

• Google Analytics 4 (GA4)

Duration: Up to 2 years

Legal Basis: Consent (you can opt-out)

Can You Decline? YES - declining limits our ability to improve the Website but doesn't affect core functionality.

Specific Cookies:

The Google Analytics script itself is loaded only after you allow analytics or marketing cookies.

Data Collected:

• Pages visited
• Time spent on pages
• Browser and device type
• Geographic region (city-level)
• Referral source

Data Sharing:

• Google Analytics: Aggregated data only, IP anonymization enabled
• No personal data shared with advertisers

4.3 Functional Cookies

Purpose: Remember your preferences to enhance experience.

Examples:

• Region preference
• Dismissed notices

Duration: Up to 1 year

Legal Basis: Consent (you can opt-out)

Can You Decline? YES - declining means we won't remember your preferences across sessions.

Specific Cookies:

4.4 Marketing & Targeting Cookies

Purpose: Measure ad campaign effectiveness and show relevant ads.

Current use: We do not set any marketing or advertising cookies today. If we add them, they will be listed here and set only with your consent.

Duration: Up to 1 year

Legal Basis: Consent (you can opt-out)

Can You Decline? YES - you won't see personalized ads, but may see generic ads.

Specific Cookies:

None at present.

5. FIRST-PARTY VS. THIRD-PARTY COOKIES

5.1 First-Party Cookies

Set by: Cognitiva (cognitivasystems.com domain)

Purpose: Core functionality, your preferences, analytics

Control: Managed by us directly

Examples: cookie choices, region, login sessions

5.2 Third-Party Cookies

Set by: Google (Analytics), only after consent

Purpose: Analytics

Control: Managed by third parties per their privacy policies

Examples: Google Analytics 4

Third-Party Privacy Policies:

• Google: https://policies.google.com/privacy

6. HOW TO MANAGE COOKIES

6.1 Cookie Consent Banner

First Visit:
When you first visit our Website, you'll see a cookie consent banner with options:

• Accept All: Allow all cookie categories
• Reject All: Only strictly necessary cookies
• Customize: Choose specific categories

Update Preferences:
Click "Cookie Settings" in the footer anytime to change preferences.

6.2 Browser Settings

Most browsers allow you to:

• Block all cookies
• Delete existing cookies
• Accept/reject cookies per-site
• Receive alerts before cookies are set

How to Access:

• Chrome: Settings > Privacy and Security > Cookies
• Firefox: Preferences > Privacy & Security > Cookies
• Safari: Preferences > Privacy > Cookies
• Edge: Settings > Cookies and Site Permissions

Warning:
Blocking all cookies may prevent you from using certain features of our Website, including login.

6.3 Do Not Track (DNT)

Browser Signal:
Some browsers support "Do Not Track" signals.

Our Response:
We do not currently change our behaviour in response to DNT signals. Analytics and marketing cookies are off unless you turn them on in the cookie banner, whatever your browser sends.

How to Enable DNT:
Check your browser's privacy settings.

6.4 Opt-Out Tools

Google Analytics Opt-Out:
https://tools.google.com/dlpage/gaoptout

7. COOKIES AND MOBILE APPS

Native Apps:
Our mobile apps (if applicable) do NOT use browser cookies.

Alternative Technologies:

• Device identifiers (anonymized)
• App-specific local storage
• SDK analytics

Consent:
Managed through in-app privacy settings.

8. COOKIES FOR LOGGED-IN USERS

8.1 Platform Cookies

When you log into CognitivaOS, we use additional cookies:

Authentication:

• auth_token: Encrypted authentication token (7 days or "remember me")
• refresh_token: Token refresh mechanism (30 days)

Session Management:

• workspace_id: Current workspace context
• user_prefs: User-specific settings

Security:

• device_fingerprint: Detect unusual login locations
• mfa_verified: Multi-factor authentication status

Duration: Varies (session to 30 days depending on "remember me" setting)

Required: YES - these are necessary for platform functionality

8.2 API Session Cookies

For API Users:
API authentication uses bearer tokens in headers, NOT cookies.

OAuth Flow:
Temporary session cookies during OAuth authorization flow only.

9. GEOGRAPHIC CONSIDERATIONS

9.1 EU/EEA Visitors

ePrivacy Directive Compliance:

• Explicit consent required for non-essential cookies
• Granular consent options provided
• Consent recorded and auditable
• Easy withdrawal mechanism

Cookie Wall:
We do NOT use cookie walls (blocking access until consent given).

Legitimate Interest:
We do NOT rely on legitimate interest for marketing cookies.

9.2 UK Visitors

PECR Compliance:
Same as EU/EEA (UK PECR regulations).

9.3 California Visitors

CCPA "Sale" Disclosure:

While cookies themselves don't constitute "sale," sharing data with marketing platforms might.

Your Rights:

• Opt-out of marketing cookies
• Request disclosure of data shared
• "Do Not Sell My Personal Information" link in footer

10. CHILDREN'S PRIVACY

Age Restriction:
Our Website is not intended for children under 18.

No Targeted Cookies:
We do not knowingly set cookies on devices of children under 18.

Parental Control:
Parents can use browser parental controls to block cookies.

11. CHANGES TO THIS POLICY

11.1 Updates

We may update this Cookie Policy:

• When we add/remove cookie categories
• When third-party services change
• To comply with new regulations
• To improve clarity

11.2 Notification

Material Changes:
We will notify you via:

• Email (for registered users)
• Banner on Website (for visitors)
• Updated "Last Updated" date

Notice Period: 30 days before effective date for material changes

11.3 Re-Consent

If we add new cookie categories, we may ask you to re-consent.

12. CONTACT US

12.1 Cookie Questions

Email: privacy@cognitiva.systems
Subject: "Cookie Policy Inquiry"

12.2 Supervisory Authority

EU/UK Residents:
You may file complaints with your local Data Protection Authority regarding our cookie practices.

Find Your DPA:
https://edpb.europa.eu/about-edpb/about-edpb/members_en

13. DEFINITIONS

Cookie: Small text file stored on your device by a website.

First-Party Cookie: Set by the website you're visiting.

Third-Party Cookie: Set by external services embedded on the website.

Session Cookie: Deleted when browser closes.

Persistent Cookie: Remains until expiry date or manual deletion.

Strictly Necessary: Cookies essential for website functionality.

Analytics Cookie: Cookies that measure website usage.

Marketing Cookie: Cookies for advertising and conversion tracking.

14. COOKIE AUDIT LOG

Last Audit: 15 April 2026

Next Audit: January 2027, before launch

Audit Process:

1. Scan Website for all cookies
2. Categorize cookies (necessary, analytics, marketing)
3. Verify third-party privacy policies
4. Update this policy
5. Update consent banner

Changes Since Last Audit:

• Initial publication — no prior audit to compare against

QUICK REFERENCE

Accept/Reject Cookies:
Click "Cookie Settings" in footer

Delete Cookies:
Browser Settings > Privacy > Clear Browsing Data

Opt-Out of Analytics:
https://tools.google.com/dlpage/gaoptout

Contact Us:
privacy@cognitiva.systems

END OF COOKIE POLICY

Version: 2.1
Last Updated: 29 September 2026
Next Review: April 2027