Effective Date: 15 January 2026

Last Updated: 15 January 2026

1. General Provisions

This Cookie Policy (hereinafter referred to as the "Policy") describes how Finity Pay (hereinafter referred to as the "Company," "we," or "our") uses cookies and similar technologies when users visit our website https://finity-pay.com (hereinafter referred to as the "Site").

We respect users' privacy and process personal data in accordance with the requirements of:

• Regulation (EU) 2016/679 (GDPR);
• Directive 2002/58/EC (ePrivacy Directive);
• applicable national legislation of the European Union.

2. What are Cookies

Cookies are small text files that are stored on your device (computer, smartphone, or tablet) when you visit the Site. They allow us to:

• ensure the proper functioning of the Website;
• remember user preferences;
• analyze Website usage;
• personalize content and advertising (subject to consent).

3. Types of Cookies Used

We use the following categories of cookies:

3.1. Essential Cookies

These cookies are necessary for the Website to function and cannot be disabled. They do not require user consent.

Legal basis: legitimate interest (Article 6(1)(f) of the GDPR)

Examples:

• ensuring security;
• session management;
• storing language or region preferences.

3.2. Functionality Cookies

These cookies improve the functionality and personalization of the Website.

Legal basis: user consent (Article 6(1)(a) of the GDPR)

Examples:

• remembering settings;
• storing user preferences.

3.3. Analytical (statistical) cookies

These are used to analyze how users interact with the Website in order to improve it.

Legal basis: User consent

Examples of data:

• Pages visited;
• Session duration;
• Device and browser type.

3.4. Marketing cookies

These are used to display relevant advertising and track the effectiveness of marketing campaigns.

Legal basis: User consent

May be set by third parties (advertising platforms).

4. Third-party cookies

The Website may use cookies set by third parties (e.g., analytics or advertising providers). These third parties process data in accordance with their own privacy policies.

We are not responsible for the data processing of such third parties, but we take reasonable steps to only work with partners who comply with the GDPR.

5. Managing Consent

When you first visit the Website, you will see a cookie banner that allows you to:

• accept all cookies;
• reject non-essential cookies;
• configure cookie categories.

You can change or revoke your consent at any time through the cookie settings on the Website or in your browser settings.

6. Managing Cookies via Browser

You can manage or delete cookies using your browser settings. Please note that disabling some cookies may affect the functionality of the Website.

Instructions are available on the websites of browser manufacturers:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

7. Data Storage

Cookies are stored:

• either during the session (session cookies);
• or for a set period (persistent cookies);
• but not longer than necessary to achieve the purposes of processing.

8. Data Transfers Outside the EU

If data processing involves transfers outside the European Economic Area, we provide appropriate safeguards, including:

• standard contractual clauses of the European Commission;
• adequacy decisions;
• other mechanisms provided for by the GDPR.

9. User Rights

Under the GDPR, you have the right to:

• access your data;
• rectify it;
• delete it ("right to be forgotten");
• restrict processing;
• data portability;
• object to processing;
• file a complaint with an EU supervisory authority.

10. Policy Changes

We reserve the right to amend this Policy. The current version is always available on the Website, with the date of its update indicated.