COOKIE POLICY

TEMPTERA LIMITED
Romanou 2, Tlais Tower, Office 601, 1070 Nicosia, Cyprus
VAT: CY60154949E

Version: 1.2
Effective Date: 01.05.2025
Last Updated: 08.08.2026

1. About this Policy

This Cookie Policy explains how TEMPTERA LIMITED ("Temptera", "we", "us", "our") uses cookies and similar technologies on the websites, customer portals, dashboards, APIs, and other online interfaces that we operate (the "Platform").

This Policy is issued in accordance with:

• Article 5(3) of Directive 2002/58/EC of the European Parliament and of the Council (the "ePrivacy Directive"), as amended;
• Article 99 of the Cyprus Law on the Regulation of Electronic Communications and Postal Services 112(I)/2004, as amended, transposing the ePrivacy Directive;
• Regulation (EU) 2016/679 (the "GDPR"), in respect of any personal data collected via cookies;
• The Cyprus Law on the Protection of Natural Persons against the Processing of Personal Data 125(I)/2018;
• The Guidelines 2/2023 on the technical scope of Article 5(3) of the ePrivacy Directive of the European Data Protection Board ("EDPB"); and
• The Guidelines 05/2020 on consent under Regulation 2016/679 of the EDPB.

This Policy supplements, and should be read alongside, our Privacy Policy and our Terms of Service.

2. What are Cookies and Similar Technologies

A cookie is a small text file that is placed on your device (computer, tablet, mobile phone) when you visit a website. Cookies allow the website to recognise your device and remember information about your visit (such as preferences, login state, and language). Most modern browsers allow you to view, manage, and delete cookies.

In addition to HTTP cookies, this Policy applies to all other technologies that store or access information on your device, including but not limited to:

• Local storage and session storage (HTML5 Web Storage)
• IndexedDB and other browser databases
• Pixels, web beacons, clear GIFs, and tracking scripts
• Software development kits (SDKs) embedded in our mobile and desktop applications
• Device fingerprinting techniques
• Server-side tracking technologies that rely on identifiers created on, or read from, your device.

Throughout this Policy, the word "cookies" includes all such similar technologies.

3. Legal Basis for Using Cookies

3.1 Strictly necessary cookies are placed on your device on the basis of the exemption in Article 5(3) of the ePrivacy Directive: their storage is strictly necessary to provide the service that you have requested. No prior consent is required for these cookies.

3.2 All other cookies (functional, analytics, marketing/advertising, social) are placed only after you have given your prior, freely given, specific, informed, and unambiguous consent through our cookie banner, in accordance with Article 5(3) of the ePrivacy Directive and Article 4(11) GDPR. Where the cookie also processes personal data, the lawful basis for that processing under Article 6(1)(a) GDPR is your consent.

3.3 You may withdraw your consent at any time through our Cookie Settings panel, accessible from the footer of every page on the Platform, or as described in Section 7 below. Withdrawal is as easy as giving consent and does not affect the lawfulness of processing carried out before withdrawal.

3.4 We do not deploy any "cookie wall". You can access the Platform without consenting to non-essential cookies. Refusing non-essential cookies will not deprive you of access to the Services.

4. Categories of Cookies We Use

We classify cookies into the following categories. The specific cookies in each category are listed in Section 5.

4.1 Strictly Necessary

These cookies are essential for the Platform to function. They enable core security, authentication, session management, load balancing, fraud prevention, accessibility, and the recording of your cookie-consent choices. They cannot be disabled without breaking the Platform. Examples: session identifier; CSRF token; cookie-consent state.

4.2 Functional / Preferences

These cookies remember choices you make (such as language, currency, region, dashboard layout, or display preferences) to deliver a more personalised experience. They are placed only with your consent.

4.3 Analytics / Performance

These cookies allow us, or our analytics providers, to count visits, measure traffic sources, understand how visitors interact with the Platform, and improve the Platform. They are placed only with your consent. Where technically feasible, we configure analytics tools to use IP-anonymisation, server-side processing, and aggregation.

4.4 Marketing / Advertising

These cookies are set by us or by our advertising and marketing partners. They build a profile of your interests and may be used to display relevant advertising on third-party websites, to measure the effectiveness of campaigns, and to manage retargeting. They are placed only with your consent.

4.5 Social Media

Some pages may include features from social-media platforms (such as embedded videos or "share" buttons). These features may set cookies and read existing cookies on your device. They are placed only with your consent.

5. Cookies We Use — Detailed List

The tables below list the cookies and similar technologies used across our Platform, grouped by category. Strictly necessary items are always active; all others are set only after you consent through our cookie banner. Third-party cookies are set by the named provider under its own policy.

Strictly Necessary

Functional

Analytics

Marketing / Advertising

Social / Embedded

6. Third-Party Recipients and International Transfers

6.1 Where cookies are set by, or transmit data to, third parties (for example, our analytics, advertising, CRM, or video providers), those third parties are independent controllers or, where applicable, processors of the data they collect through the cookie. Their processing is governed by their own privacy policies, to which links are provided in our cookie banner.

6.2 Some of these third parties are established outside the European Economic Area, including in the United States. Where personal data is transferred outside the EEA, we rely on:

(a) adequacy decisions of the European Commission under Article 45 GDPR (including, where applicable, the EU–US Data Privacy Framework where the recipient is certified);

(b) the European Commission's Standard Contractual Clauses approved by Implementing Decision (EU) 2021/914, supplemented by additional technical, organisational, and contractual measures where required following the Schrems II judgment of the Court of Justice of the European Union (Case C-311/18); or

(c) other safeguards under Articles 46–49 GDPR.

A list of the third-party recipients in respect of cookies, the country of processing, and the transfer mechanism is maintained in our cookie banner and is available on request.

7. Your Choices — How to Manage Cookies

7.1 Cookie Settings panel

You can review, modify, or withdraw your cookie choices at any time by clicking "Cookie Settings" in the footer of any page on the Platform. The panel displays each non-essential category, allows granular acceptance or rejection per category, and applies your changes immediately. Withdrawal is as easy as giving consent.

7.2 Browser controls

You can also control cookies directly through your browser settings. Most browsers allow you to:

• view the cookies that have been set;
• block all cookies, or block third-party cookies only;
• delete cookies when you close the browser;
• delete specific cookies on demand;
• enable or disable "Do Not Track" or "Global Privacy Control" signals.

Instructions:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Apple Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge
• Mobile devices: consult the documentation of your operating system and browser.

Blocking strictly necessary cookies will impair the functioning of the Platform. We are unable to remedy any consequence of doing so.

7.3 Industry opt-out tools

For online behavioural advertising, you may also use industry-wide opt-out tools, including:

• European Interactive Digital Advertising Alliance (EDAA): https://www.youronlinechoices.eu
• Network Advertising Initiative (NAI): https://optout.networkadvertising.org
• Digital Advertising Alliance (DAA): https://optout.aboutads.info
• Global Privacy Control (GPC): browsers and extensions that broadcast a GPC signal — we honour this signal where required by law.

7.4 Provider-specific opt-outs

• Google Analytics: https://tools.google.com/dlpage/gaoptout
• Meta (Facebook): through your Meta account ad-preferences page
• LinkedIn: through your LinkedIn account settings
• Microsoft Advertising: through your Microsoft account preferences

8. Re-prompting for Consent

Where you have refused or withdrawn consent for a category of cookies, we will not re-prompt you for at least six (6) months, in accordance with the prevailing guidance of EU data protection authorities (including the position of the French CNIL and the Italian Garante, and the practice of the Cyprus Office of the Commissioner for Personal Data Protection). You may, of course, change your choices at any time through the Cookie Settings panel.

9. Personal Data Collected via Cookies

Where cookies process personal data, the controller, lawful basis, retention, recipients, transfers, and your rights are described in our Privacy Policy. Briefly:

• We are the controller of personal data collected through first-party cookies that we set;
• Third parties are independent controllers of data they collect through their own cookies, except where they act as our processor under a written agreement;
• You have the rights of access, rectification, erasure, restriction, portability, and objection (as detailed in the Privacy Policy);
• You may at any time lodge a complaint with the Cyprus Office of the Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus; tel +357 22 818 456; email commissioner@dataprotection.gov.cy; web https://www.dataprotection.gov.cy, or with the supervisory authority of your habitual residence.

10. Children

The Platform is not directed to persons under 18 years of age. We do not knowingly use cookies to process personal data of children. Where a child has interacted with the Platform, contact us and we will delete any associated data, save where retention is required by law.

11. Changes to This Policy

We may update this Policy from time to time, in particular when we add, remove, or change cookies, when applicable law changes, or when EDPB or Cyprus regulator guidance changes. The current version is identified by the version number and effective date at the top. Material changes will be notified through the cookie banner and, where appropriate, by email. The "Last Updated" date is your signal to review.

12. Contact

For any question regarding this Cookie Policy:

TEMPTERA LIMITED
Romanou 2, Tlais Tower, Office 601, 1070 Nicosia, Cyprus
Email (privacy): privacy@temptera.com
Email (general): privacy@temptera.com

© 2026 TEMPTERA LIMITED. All rights reserved.