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Cookie Policy
Effective Date: 16.10.2025
1. Introduction
This Cookie Policy (“Policy”) explains how Qubeletum OÜ (“we”, “us”, “our”), registry code 17309345, with registered office at Pille tn 11/1-32, Kesklinna linnaosa, Tallinn, 10138, Estonia, uses cookies and similar technologies on our website https://unlocksy.net. For details on how we process personal data collected via registration forms, payments, or forum activities, please see our Privacy Policy. Certain cookies are essential for secure payment processing and fraud prevention measures on our checkout pages.
2. Scope & Controller
This Policy applies to our website and subdomains where this Policy is referenced. Qubeletum OÜ acts as the data controller for cookie operations conducted on our domains.
3. Legal Framework & Principles
This Policy complies with the EU ePrivacy Directive (2002/58/EC as amended by 2009/136/EC) and the General Data Protection Regulation (Regulation (EU) 2016/679 — GDPR), and follows guidance from the European Data Protection Board (EDPB) on consent. Consent must be freely given, specific, informed, and unambiguous; pre-ticked boxes and implied consent are not permitted.
4. Strict Mode: Consent Rules
- Prior consent: Non-essential cookies (e.g., analytics, marketing) are not set before an affirmative user action granting consent.
- Equal prominence: The first-layer banner presents “Accept all” and “Reject all” options with equal prominence, alongside “Customize”.
- No dark patterns: We do not use nudging, deceptive design, or cookie walls that would undermine free consent.
- Refresh of consent: We refresh consent at least every 12 months or sooner if the cookie stack materially changes.
- Withdrawal: Consent can be changed or withdrawn at any time via the “Cookie Settings” link in the footer.
5. Types of Cookies
- Strictly Necessary Cookies – essential for login, navigation, secure payments, CSRF protection, and fraud prevention.
- Preference Cookies – remember settings such as language or region.
- Analytics Cookies – collect aggregated usage information to improve performance and user experience.
- Marketing Cookies – support personalized advertising and conversion tracking (used only with explicit consent).
6. Cookie Inventory
The table below lists typical cookies used on our website. The actual set may vary over time; our Consent Management Platform (CMP) performs regular scans and updates this inventory accordingly.
7. Consent Management Platform (CMP)
We use an EU-hosted CMP (e.g., CookieYes) to display the banner, capture consent signals, and enforce prior consent. Consent logs (consent ID, timestamp, choices, banner version) are stored securely for 12 months and are exportable for regulatory or banking audits. Certificates and attestations (e.g., ISO 27001 / SOC 2 of the hosting provider) can be provided to financial institutions upon request.
8. Consent Record & Audit Trail
We maintain an auditable consent record with the user’s preferences, timestamps, and consent ID. Records can be exported upon request for verification by auditors, banks, PSPs, or supervisory authorities. We also keep an internal change log of cookie stack and banner versions.
9. Payment & Fraud Prevention Cookies
Strictly necessary cookies support secure payment operations, session continuity, bot mitigation, and fraud prevention (e.g., device and risk signals). These cookies are always active, limited to what is necessary, and never used for marketing or profiling.
10. Third-Party Vendors, DPAs & IAB TCF 2.2
We integrate only third-party tools that comply with GDPR and have signed appropriate Data Processing Agreements (DPAs). Where advertising vendors are involved, we implement IAB Europe’s Transparency & Consent Framework v2.2 (TCF 2.2): consent (not legitimate interest) for personalization; vendor-level transparency; and easy withdrawal of consent.
11. International Transfers (SCC) & DPIA
Where analytics or marketing data are transferred outside the EEA (e.g., to Google LLC, USA), Standard Contractual Clauses (SCCs) apply. We perform Data Protection Impact Assessments (DPIA) when required and apply supplementary measures in line with Schrems II.
12. Security of Cookies
First-party cookies are configured with Secure, HttpOnly (where applicable), and SameSite attributes. We minimize retention periods and scope, and we do not store payment card data in cookies.
13. Data Minimization & Separation of Data Streams
Data collected via registration or forum forms (e.g., username, email, IP) are processed for authentication, communication, and safety. Such personal data are never merged with cookie-based tracking for marketing purposes.
14. Managing Cookies & Withdrawal
You can review or change your cookie preferences at any time via the “Cookie Settings” link. You may also use your browser settings to manage or delete cookies. Disabling certain cookies may impact website functionality.
15. Multilingual & Accessibility
This Policy is available in English and Estonian (additional EU languages may be provided). In case of discrepancies, the English version prevails. We aim to ensure the banner and settings are accessible (keyboard navigable, screen-reader compatible).
16. Updates
We review this Policy annually or upon material change to our cookie stack or regulatory guidance. Updates will be posted here with a revised Effective Date.
17. Contact & Data Protection Officer (DPO)
For questions regarding this Policy or your rights under GDPR, contact our Data Protection Officer (DPO):
Email: privacy@unlocksy.net
Address: Pille tn 11/1-32, Kesklinna linnaosa, Tallinn, 10138, Estonia.
Our DPO is authorized to handle inquiries from regulatory bodies, banks, and PSPs.
Email: privacy@unlocksy.net
Address: Pille tn 11/1-32, Kesklinna linnaosa, Tallinn, 10138, Estonia.
Our DPO is authorized to handle inquiries from regulatory bodies, banks, and PSPs.
18. Governing Law
This Policy is governed by the laws of Estonia. Disputes shall be handled exclusively by the courts of Estonia.