COOKIE POLICY

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

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1. INTRODUCTION

This Cookie Policy explains how Cognitiva Systems Inc. ("Cognitiva," "we," "us," or "our") uses cookies and similar technologies on cognitiva.systems 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:
By using our Website, you consent to our use of cookies as described in this policy, subject to your cookie preferences.

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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.

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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

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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 (with IP anonymization)
• Error tracking (Sentry)
• Page load time measurement
• Feature usage statistics

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:

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:

• Language preference
• Interface theme (light/dark mode)
• Dashboard layout customization
• Dismissed notifications

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.

Examples:

• Conversion tracking pixels
• Retargeting cookies
• Social media plugins

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:

Important:
We do NOT use cookies for behavioral advertising across third-party websites. Marketing cookies are limited to conversion tracking for our own campaigns.

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5. FIRST-PARTY VS. THIRD-PARTY COOKIES

5.1 First-Party Cookies

Set by: Cognitiva (cognitiva.systems domain)

Purpose: Core functionality, your preferences, analytics

Control: Managed by us directly

Examples: Session, CSRF, language, theme

5.2 Third-Party Cookies

Set by: External services (Google, Facebook, LinkedIn)

Purpose: Analytics, conversion tracking

Control: Managed by third parties per their privacy policies

Examples: Google Analytics, Facebook Pixel

Third-Party Privacy Policies:

• Google: https://policies.google.com/privacy
• Facebook: https://www.facebook.com/privacy/policy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy

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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 respect DNT signals and will not set analytics or marketing cookies if DNT is enabled.

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

Facebook Opt-Out:
https://www.facebook.com/ads/preferences

LinkedIn Opt-Out:
https://www.linkedin.com/psettings/guest-controls

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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.

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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.

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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

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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.

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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.

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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

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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.

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14. COOKIE AUDIT LOG

Last Audit: 15 April 2026

Next Audit: October 2026

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

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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

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END OF COOKIE POLICY

Version: 2.0
Last Updated: 15 April 2026
Next Review: April 2027