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Cookies Policy

Cookies Policy

Effective date: The date displayed when this Cookies Policy is published or last updated on Univerax.

1. Purpose and Scope

1.1. This Cookies Policy explains how Zenlyai OÜ, trading as Univerax (“Univerax,” “we,” “us,” or “our”), uses cookies and similar technologies on Univerax, its websites, applications, interfaces, and related services (collectively, the “Platform”).

1.2. This Policy explains:

a. what cookies and similar technologies are;

b. why they may be used;

c. the categories of technologies used on the Platform;

d. when consent is requested;

e. how third parties may use these technologies;

f. how long relevant information may remain on a device; and

g. how users can manage or withdraw their choices.

1.3. This Policy should be read together with the Privacy Policy, which explains how Univerax processes personal data and how users may exercise their data protection rights.

1.4. This Policy applies to visitors, Customers, Creators, account holders, and other individuals who use the Platform.

2. Who Is Responsible?

Unless another entity is expressly identified for a particular technology or processing activity, the entity responsible for the Platform’s use of cookies and similar technologies is:

Legal entity: Zenlyai OÜ
Trade name: Univerax
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138 https://ariregister.rik.ee/eng/company/17160305, Estonia
Registration number: 17160305
Privacy email: author@univerax.com
Legal email: info@univerax.com
Phone: +90 850 532 23 02

Questions about this Policy or the use of cookies may be sent to author@univerax.com.

3. What Are Cookies?

3.1. Cookies are small text files or data records stored on or accessed from a browser, device, application, or similar equipment when a user visits or interacts with an online service.

3.2. Cookies may allow the Platform to recognise a browser or device, maintain a session, remember preferences, secure an account, measure performance, understand interactions, or support other functions described in this Policy.

3.3. Cookies may store or generate identifiers and technical information. Depending on their purpose and the information associated with them, this information may constitute personal data.

3.4. Cookies may be:

a. session cookies, which normally expire when the browser or application session ends; or

b. persistent cookies, which remain until their stated expiration date or until deleted.

4. Similar Technologies

4.1. This Policy also applies to technologies that perform functions similar to cookies, including:

a. local storage;

b. session storage;

c. pixels and web beacons;

d. tags and scripts;

e. software development kits;

f. device or application identifiers;

g. embedded content technologies;

h. link and campaign identifiers; and

i. other technologies that store information on, or access information from, a user’s device.

4.2. References to “cookies” in this Policy include these similar technologies unless the context requires otherwise.

4.3. The legal rules applicable to a technology may depend on what it does, whether it accesses a user’s device, whether it processes personal data, and the jurisdiction in which it is used.

5. First-Party and Third-Party Cookies

5.1. First-party cookies are placed or accessed by Univerax or through a domain controlled by Univerax.

5.2. Third-party cookies are placed or accessed by another organisation whose technology or service is integrated into the Platform.

5.3. Third parties may include providers supporting functions such as:

a. hosting and content delivery;

b. security and fraud prevention;

c. authentication;

d. payments;

e. customer support;

f. analytics and performance measurement;

g. embedded media or social functionality;

h. advertising and campaign measurement; and

i. other Platform integrations.

5.4. A third party may independently determine how it processes information collected through its technology. Where this occurs, that third party’s privacy and cookie information also applies.

5.5. The cookie preference tool or cookie declaration should identify relevant third parties and provide further information about their cookies where required.

6. Categories of Cookies

6.1. Strictly Necessary Cookies

Strictly necessary cookies support functions required to provide the Platform or a service expressly requested by the user.

They may be used to:

a. establish and maintain user sessions;

b. authenticate users and protect accounts;

c. remember privacy and cookie choices;

d. provide shopping cart, checkout, payment, and Booking functions;

e. distribute network traffic;

f. prevent fraud, abuse, and security attacks;

g. maintain technical stability; and

h. deliver communications over an electronic network.

Where permitted by applicable law, strictly necessary cookies may be used without consent because the relevant service cannot be securely or properly provided without them.

Strictly necessary cookies will not be used for unrelated advertising or optional analytics merely because they are classified as necessary.

Disabling these cookies through browser or device controls may prevent important Platform functions from operating correctly.

6.2. Preference and Functionality Cookies

Preference and functionality cookies may remember choices and provide enhanced or personalised functions.

They may remember:

a. language and regional preferences;

b. display and accessibility settings;

c. time zone;

d. saved interface choices;

e. selected account or Creator tools;

f. previously entered non-sensitive information; and

g. other optional settings.

Where required by applicable law, these cookies will be used only after the user provides consent.

Rejecting these cookies may cause some preferences to be reset or make optional functionality unavailable.

6.3. Analytics and Performance Cookies

Analytics and performance cookies may help us understand how the Platform is used and performs.

They may be used to:

a. measure visits, sessions, and feature use;

b. understand navigation and interaction patterns;

c. detect errors and performance problems;

d. compare the effectiveness of interface changes;

e. prepare aggregated statistics;

f. improve Platform reliability and usability; and

g. measure the performance of communications or campaigns.

Where required by applicable law, analytics and performance cookies will not be used until consent has been provided.

We will not classify optional audience measurement or behavioural analytics as strictly necessary where consent is legally required.

6.4. Personalisation and Recommendation Cookies

Personalisation cookies may support customised feeds, search results, Creator discovery, product or Service recommendations, and other tailored experiences.

They may use information about:

a. viewed Content and Offerings;

b. searches and selected categories;

c. previous Platform interactions;

d. language and approximate region;

e. saved preferences; and

f. engagement with recommendations.

Where required by law, these cookies will be used only with consent.

Users may also have separate account controls for recommendation systems and profiling. Further information is provided in the Privacy Policy and the AI Transparency and Automated Decision Policy.

6.5. Advertising and Marketing Cookies

Advertising and marketing cookies may be used, where enabled, to:

a. measure advertising or promotional campaigns;

b. limit how often an advertisement is displayed;

c. attribute visits or transactions to a campaign;

d. create or use audience segments;

e. support relevant advertising; and

f. understand interactions with marketing communications.

Advertising and marketing cookies are not strictly necessary. Where consent is required, they will remain disabled unless the user actively accepts them.

Sponsored Content or paid promotion displayed on the Platform should be clearly identified, regardless of whether advertising cookies are used.

Rejecting advertising cookies should not prevent access to ordinary Platform functions, except where a specific function genuinely depends on a separate requested service.

6.6. Social Media and Embedded Content Cookies

The Platform may include videos, maps, social media content, sharing controls, payment interfaces, support tools, or other embedded third-party features.

The relevant third party may place or access cookies when the embedded feature is loaded or used.

Where required, optional embedded content will not load, or its cookies will not operate, until the user provides consent or actively requests the relevant third-party content.

Interacting with an embedded service may allow that provider to associate the interaction with an existing account held with that provider.

7. Purposes of Cookie-Related Processing

Depending on the category selected, cookie-related information may be processed to:

7.1. operate, maintain, and secure the Platform;

7.2. authenticate accounts and prevent unauthorised access;

7.3. remember user choices and consent records;

7.4. enable transactions, payments, Digital Content access, Services, and Bookings;

7.5. detect fraud, abuse, manipulation, and technical attacks;

7.6. measure traffic, usage, and technical performance;

7.7. improve interfaces, features, and accessibility;

7.8. personalise Content, search, and recommendations;

7.9. provide embedded or connected services;

7.10. measure communications, referrals, and promotional campaigns; and

7.11. comply with applicable legal and regulatory obligations.

8. Information Processed Through Cookies

Depending on the technology and the user’s choices, cookie-related processing may involve:

8.1. cookie, browser, device, session, or advertising identifiers;

8.2. IP address and approximate location derived from it;

8.3. browser, device, operating system, application version, and language;

8.4. pages, screens, links, and features viewed or used;

8.5. searches, clicks, navigation paths, and interaction timestamps;

8.6. referring pages, referral links, and campaign information;

8.7. login, authentication, security, error, and diagnostic information;

8.8. selected settings and cookie preferences;

8.9. shopping cart, checkout, transaction, or Booking state;

8.10. Content, Creator, product, Digital Content, or Service interactions; and

8.11. inferred interests or audience categories where permitted.

Additional information about personal data processing appears in the Privacy Policy.

9. Consent and Legal Basis

9.1. Where applicable law requires consent before information may be stored on or accessed from a user’s device, we will request that consent before activating the relevant non-essential cookies.

9.2. Consent must be freely given, specific, informed, and indicated through a clear affirmative action.

9.3. We will not treat silence, inactivity, continued browsing by itself, or a pre-selected option as valid consent where an affirmative choice is required.

9.4. Users should be able to reject non-essential cookies as readily as they can accept them.

9.5. Consent choices may be divided by cookie category or, where required and technically supported, by individual provider or purpose.

9.6. Strictly necessary cookies may be used without consent where they are genuinely required to transmit a communication, provide a service expressly requested by the user, maintain security, record cookie choices, or satisfy another applicable legal exemption.

9.7. Where information obtained through cookies constitutes personal data, the subsequent processing must also have a valid legal basis under applicable data protection law. Depending on the activity, that basis may be consent, performance of a contract, compliance with a legal obligation, or a legitimate interest where legally permitted.

9.8. Consent to cookies does not automatically constitute consent for every subsequent use of personal data. Additional information or consent will be provided where required.

10. Cookie Preference Tool

10.1. Where a cookie preference tool is provided, users may use it to:

a. accept or reject optional categories;

b. review available cookie information;

c. update previous choices; and

d. withdraw consent.

10.2. A link to cookie settings should remain reasonably accessible through the Platform after the initial choice has been made.

10.3. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal.

10.4. After consent is withdrawn, relevant optional cookies will no longer be activated. Existing cookies may need to be deleted or expire before all associated identifiers disappear from the device.

10.5. A strictly necessary cookie or similar record may be retained to remember that optional cookies were rejected or that consent was withdrawn.

10.6. Cookie choices may need to be requested again if:

a. cookies or browser storage are deleted;

b. a different browser, application, profile, or device is used;

c. a material change is made to the technologies or purposes;

d. the existing consent record expires; or

e. a new choice is otherwise required by law.

11. Cookie Details and Duration

11.1. The cookie preference tool or cookie declaration should provide, as applicable:

a. the cookie or technology name;

b. the responsible provider;

c. whether it is first-party or third-party;

d. its purpose;

e. its category;

f. its duration or expiration period; and

g. relevant information about third-party processing.

11.2. Session cookies normally expire when the relevant browser or application session ends.

11.3. Persistent cookies remain until their specified expiration date or until deleted.

11.4. The duration of a cookie will be limited to what is reasonably necessary for its stated purpose and any applicable legal requirements.

11.5. We may refresh a cookie’s duration only where this is justified by the purpose, accurately disclosed, and legally permitted.

11.6. The retention of personal data obtained through a cookie may differ from the period during which the cookie remains on the device. Personal data retention is addressed in the Privacy Policy and Data Retention and Deletion Policy.

12. Browser and Device Controls

12.1. Most browsers and devices provide settings that allow users to:

a. view stored cookies;

b. delete some or all cookies;

c. block first-party or third-party cookies;

d. restrict tracking technologies;

e. clear local storage; or

f. receive alerts when cookies are used.

12.2. Browser and device controls operate separately from Univerax’s cookie preference tool. Changing one does not necessarily update the other.

12.3. Blocking all cookies may prevent login, security, payments, shopping cart, Booking, preference, or other important Platform functions from working.

12.4. Users should consult the help information supplied with their browser or device for current instructions.

12.5. Private browsing or similar modes do not necessarily prevent every form of local storage, device identification, or server-side processing.

13. Third-Party Choices

13.1. Some third parties provide their own privacy, advertising, or opt-out controls.

13.2. A choice submitted directly to a third party may apply only to that provider, browser, device, or account and may not update Univerax’s cookie preference tool.

13.3. Univerax does not control the design or continued availability of independent third-party preference mechanisms.

13.4. Third parties may process information as independent controllers under their own privacy notices. Where required, their identities and relevant purposes should be disclosed through the cookie preference tool or cookie declaration.

14. Global Privacy Signals

14.1. Browsers or devices may send automated privacy preference signals.

14.2. Where applicable law requires recognition of a supported signal, Univerax will treat the signal in accordance with that law and the technical meaning of the signal.

14.3. Because such signals may differ in scope and operation, users should also review the Platform’s cookie preference tool to confirm their choices.

15. Children and Minors

15.1. We do not knowingly use optional advertising or profiling cookies to target children in a manner prohibited by applicable law.

15.2. Where consent for cookies is requested from a minor, parental or guardian authorisation will be obtained where required by applicable law.

15.3. If you believe that cookies or similar technologies have been used inappropriately in connection with a child, contact author@univerax.com.

16. Security and Fraud Prevention

16.1. Cookies and similar technologies may be used to protect accounts, detect suspicious activity, prevent fraudulent transactions, manage sessions, and defend the Platform against technical attacks.

16.2. Security technologies will be configured and retained in a manner proportionate to the relevant risk and purpose.

16.3. Information collected for security should not be repurposed for unrelated advertising without an appropriate legal basis and any required consent.

17. International Processing

17.1. Cookie providers and other recipients may process information in countries other than the country where the user is located.

17.2. Where cookie-related personal data protected by the GDPR or comparable law is transferred internationally, appropriate transfer safeguards will be used where required.

17.3. Further information about international data transfers and available safeguards appears in the Privacy Policy.

18. Changes to This Cookies Policy

18.1. We may update this Policy to reflect changes in law, technology, providers, Platform functions, or cookie practices.

18.2. The updated Policy will identify its effective date.

18.3. If a change materially affects an existing consent, we will request a new choice where required by law.

18.4. The current cookie preference tool or cookie declaration should be consulted for the most recent operational list of cookies and similar technologies.

19. Contact Us

Questions, concerns, or requests concerning cookies and similar technologies may be directed to:

Legal entity: Zenlyai OÜ
Trade name: Univerax
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138 https://ariregister.rik.ee/eng/company/17160305, Estonia
Registration number: 17160305
Privacy email: author@univerax.com
Legal email: info@univerax.com
Support email: support@univerax.com
Phone: +90 850 532 23 02

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