Cookie Policy

Section 1 - What Are Cookies?

1.1 Definition

Cookies are small text files that are placed on your device (computer, smartphone, tablet) by websites you visit. They are widely used to make websites work more efficiently and to provide information to website owners. Cookies contain information that is transferred to your device's hard drive or memory, allowing the website to recognize your device and remember information about your visit.

1.2 How Cookies Work

When you visit a website, the website sends a cookie to your browser. Your browser stores the cookie in a file on your device. The next time you visit the same website, the browser sends the cookie back, allowing the website to recognize your device and remember your preferences.

1.3 First-Party vs. Third-Party Cookies

(a) First-Party Cookies - Set directly by the website you are visiting (in this case, the Store operated by Profalgo). We control these cookies and determine how they are used.

(b) Third-Party Cookies - Set by domains other than the website you are visiting. These are typically set by third-party service providers integrated into the website (e.g., analytics providers, payment processors, advertising networks). Profalgo is responsible for all cookies set on the Store, whether first-party or third-party.

1.4 Session vs. Persistent Cookies

(a) Session Cookies - Temporary cookies that are deleted when you close your browser. They are used to maintain your session while you navigate the website.

(b) Persistent Cookies - Remain on your device for a specified period (days, months, or years) or until you manually delete them. They are used to remember your preferences on return visits.

Section 2 - Why We Use Cookies

2.1 Essential Website Functionality

To enable core features and functionality of the Store, including: user authentication and session management, shopping cart and checkout functionality, security features (preventing fraud, protecting against attacks), load balancing and performance optimization, and remembering your preferences during your session. You cannot disable these cookies without seriously affecting the functionality of the Store.

2.2 Performance and Analytics

To understand how visitors use the Store, identify technical issues, and improve performance, including: tracking page visits and time on page, identifying navigation paths, detecting errors and performance bottlenecks, generating anonymous aggregate statistics, and testing new features (A/B testing).

2.3 Functionality and Personalization

To remember your choices and provide enhanced, personalized features, including: language and currency preferences, user interface settings, "Remember Me" login functionality, recent searches, and opt-in/opt-out preferences.

2.4 Marketing and Advertising

We do NOT currently use cookies for marketing or advertising purposes. If we implement marketing cookies in the future, we will update this Cookie Policy, request your explicit consent (where required by law), and provide clear opt-out mechanisms.

Section 3 - Types of Cookies We Use

3.1 Essential Cookies (Strictly Necessary)

Purpose: Required for the Store to function properly and securely.

Examples: Session ID cookies, authentication cookies, shopping cart cookies, security cookies (CSRF protection), load balancing cookies.

Duration: Session cookies deleted when you close your browser; persistent cookies typically 24 hours to 30 days.

Legal Basis: Strictly necessary - do not require consent under ePrivacy Directive Article 5(3).

Can You Disable Them? No. Disabling these cookies will prevent the Store from functioning properly.

3.2 Performance and Analytics Cookies

Purpose: Collect information about how visitors use the Store to improve performance and user experience.

Examples: Google Analytics (if used), error tracking, performance monitoring, heatmaps and session recordings (if used).

Data Collected: IP address (often anonymized), browser type and version, operating system, device type, pages visited, referral source, geographic location.

Duration: Typically 30 days to 2 years.

Legal Basis: Legitimate interests (GDPR Article 6(1)(f)) and consent (where required by ePrivacy Directive).

Can You Disable Them? Yes, through our cookie consent banner or your browser settings. Disabling does not affect Store functionality.

3.3 Functional Cookies

Purpose: Remember your preferences and provide enhanced features.

Examples: Language preference, currency preference, UI customization, "Remember Me", marketing opt-in/opt-out preferences.

Duration: Typically 30 days to 1 year.

Can You Disable Them? Yes. The Store will still function but may not remember your preferences.

3.4 Third-Party Cookies

Purpose: Set by third-party service providers integrated into the Store.

Examples: Payment processors (Stripe, PayPal), CDNs (Cloudflare), analytics providers (Google Analytics), customer support tools.

Duration: Typically 30 days to 2 years, varies by provider.

Can You Disable Them? Yes, through our cookie consent banner or browser settings. Disabling payment processor cookies may prevent you from completing purchases.

Third-Party Privacy Policies:

• Stripe: stripe.com/privacy
• PayPal: paypal.com/privacy
• Google Analytics: policies.google.com/privacy
• Cloudflare: cloudflare.com/privacypolicy

Section 4 - Consent and Control

4.1 Cookie Consent Banner (EU/EEA Users)

When you first visit the Store from the EU or EEA, we display a cookie consent banner that allows you to: (a) Accept All Cookies; (b) Reject Non-Essential Cookies (accept only strictly necessary cookies); (c) Customize Cookie Preferences (select which categories to accept or reject). Your choice is stored so we remember your preferences on future visits.

You may withdraw consent at any time by clicking "Cookie Settings" in the Store footer, adjusting your browser settings, or contacting us at info@forexeasolutions.com.

4.2 Browser Settings

You can control cookies through your web browser settings. Most browsers allow you to: view stored cookies, delete cookies individually or all at once, block cookies from specific or all websites, block third-party cookies, receive notifications when a cookie is set, and set cookie expiration.

Warning: Disabling cookies may affect your ability to use the Store. Essential cookies are required for login, checkout, and security features.

4.3 Do Not Track (DNT) and Global Privacy Control (GPC)

We do NOT currently respond to DNT or GPC signals. There is no industry-wide standard for interpreting DNT signals, and implementing DNT could break essential Store functionality. If you wish to limit tracking, we recommend using our cookie consent banner to reject non-essential cookies, adjusting your browser settings, or using browser extensions that block trackers.

4.4 Mobile Devices

On mobile devices, cookies work similarly to desktop browsers. Use your mobile browser settings (Safari on iOS, Chrome on Android) to manage cookies. We do NOT currently use mobile advertising IDs, but if we do in the future, we will update this Cookie Policy.

Section 5 - Cookie Responsibility and Liability

5.1 Profalgo's Responsibility

Profalgo is responsible for: (a) Determining which cookies are used on the Store and for what purposes; (b) Ensuring compliance with applicable laws (ePrivacy Directive, GDPR, Maltese law); (c) Providing clear information about cookies; (d) Obtaining consent for non-essential cookies; (e) Providing mechanisms to manage cookie preferences; (f) Selecting compliant third-party service providers.

5.2 Implementation and Technical Operation

Cookies on the Store are implemented through website code and scripts, third-party integrations, and the Store's underlying technical infrastructure. All decisions regarding cookies - including selection, categorization, purposes, retention periods, consent mechanisms, and compliance - are made solely by Profalgo as the data controller. Technical service providers implement cookies only according to Profalgo's instructions and have no independent decision-making authority.

5.3 No Joint Controllers

No third party acts as a joint controller with Profalgo for the processing of personal data through cookies. All cookies are deployed and controlled solely by Profalgo as the data controller.

5.4 User Relationship

Your rights regarding cookies are exercisable solely against Profalgo. All inquiries, complaints, or requests regarding cookies must be directed to Profalgo at info@forexeasolutions.com.

5.5 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, PROFALGO IS NOT LIABLE FOR: TECHNICAL FAILURES IN COOKIE FUNCTIONALITY, COOKIES NOT WORKING DUE TO BROWSER SETTINGS, DATA LOSS FROM DELETING COOKIES, THIRD-PARTY COOKIES BEYOND PROFALGO'S CONTROL, INCOMPATIBILITY BETWEEN COOKIES AND SPECIFIC BROWSERS/DEVICES, OR PRIVACY RISKS RESULTING FROM COOKIES.

This does NOT exclude liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be excluded under applicable law. For EU/EEA data subjects, your statutory rights under GDPR and ePrivacy Directive are NOT affected.

Section 6 - Third-Party Cookies and Services

6.1 Third-Party Service Providers

The Store uses third-party service providers that may set cookies, including: payment processors, analytics providers, content delivery networks (CDNs), customer support tools, and marketing/email providers.

6.2 Third-Party Cookie Policies

Third-party providers have their own cookie and privacy policies. We recommend reviewing:

• Stripe: stripe.com/cookies-policy/legal
• PayPal: paypal.com/webapps/mpp/ua/cookie-full
• Google Analytics: developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
• Cloudflare: cloudflare.com/cookie-policy

6.3 Profalgo's Control Over Third-Party Cookies

Profalgo determines which third-party services are integrated, what categories of cookies are permitted, and general retention periods. Profalgo does NOT control the specific technical implementation by each provider, the exact data collected, or how providers use data for their own purposes. Profalgo retains full and exclusive control and responsibility for all cookies used on the Store.

6.4 Third Parties as Independent Controllers

Some third-party providers may act as independent data controllers for certain purposes. For example, Google Analytics may use data for improving Google services, and payment processors may use cookies for fraud detection. When third parties act as independent controllers, their own privacy and cookie policies apply, and you may have data subject rights against them directly.

6.5 No Liability for Third-Party Cookies

To the maximum extent permitted by law, Profalgo is not liable for: third-party cookie practices, malfunctions, security vulnerabilities, data breaches by third-party providers, or changes to their policies. If you have concerns about third-party cookies, review their policies, contact them directly, or use browser settings to block them.

Section 7 - Cookies and Personal Data

7.1 Personal Data Collected Through Cookies

Cookies may collect and process personal data including: (a) Online identifiers (IP address, cookie IDs, device identifiers, browser fingerprints); (b) Browsing data (pages visited, timestamps, referral URLs, click behavior); (c) Device and technical data (browser type, operating system, screen resolution, language); (d) Location data (approximate location based on IP address); (e) Account and purchase data (user ID, preferences, cart contents, purchase history).

7.2 Legal Bases for Processing

We process cookie data based on: (a) Consent (Article 6(1)(a)) for non-essential cookies; (b) Performance of Contract (Article 6(1)(b)) for essential cookies; (c) Legitimate Interests (Article 6(1)(f)) for analytics; (d) Legal Obligation (Article 6(1)(c)) for compliance cookies.

7.3 Data Processing and Privacy Policy

Personal data collected through cookies is processed in accordance with our Privacy Policy.

7.4 Cookie Data Retention

(a) Session cookies: deleted when you close your browser. (b) Persistent cookies: retained for 30 days to 2 years. (c) Server-side analytics data: retained for 2 years. (d) Third-party cookie data: retained per the third party's policies. You can delete cookies at any time through your browser settings. To request deletion of server-side data, exercise your Right to Erasure under the Privacy Policy.

Section 8 - Cookies and ePrivacy Directive

8.1 ePrivacy Directive Compliance

The use of cookies is regulated by the ePrivacy Directive 2002/58/EC (the "Cookie Law"). Article 5(3) requires websites to provide clear information about cookies, obtain informed consent before non-essential cookies are stored, and ensure consent is freely given, specific, informed, and unambiguous.

8.2 Strictly Necessary Cookies Exemption

Consent is NOT required for cookies that are "strictly necessary" to provide a service explicitly requested by the user (e.g., shopping cart, login) or to facilitate communication over an electronic network. Our essential cookies (Section 3.1) fall under this exemption.

8.3 Consent for Non-Essential Cookies

Consent IS required for analytics, functional (except strictly necessary), marketing, and third-party cookies (except those strictly necessary for payment or security). We obtain consent via a cookie consent banner with the ability to accept all, reject non-essential, or customize preferences. Pre-ticked boxes and implied consent are NOT valid under GDPR and ePrivacy Directive.

8.4 Proposed ePrivacy Regulation

The proposed ePrivacy Regulation (to replace the ePrivacy Directive) has not yet been adopted. If adopted, we will update this Cookie Policy accordingly.

8.5 Compliance Statement

This Cookie Policy complies with: ePrivacy Directive 2002/58/EC, GDPR (EU) 2016/679, and Maltese data protection laws. We do NOT commit to complying with regulations that are not yet in force.

Section 9 - Updates to This Cookie Policy

We reserve the right to update this Cookie Policy at any time to reflect changes in cookie usage, applicable laws, new features, or feedback from users or regulators.

We will notify you of material changes by posting the updated Cookie Policy with a new "Last Updated" date, displaying a notice on the Store or in the cookie consent banner, and sending an email notification for material changes if you have an account. Minor or non-material changes may be made without notice.

Changes become effective on the date specified or immediately upon posting. Continued use of the Store constitutes acceptance of the updated Cookie Policy. We encourage you to review this Cookie Policy periodically.

Section 10 - Contact Information

10.1 Cookie and Privacy Inquiries

10.2 Data Protection Authority

If you have concerns about our cookie practices, you may contact: Office of the Information and Data Protection Commissioner (IDPC), Level 2, Airways House, High Street, Sliema SLM 1549, Malta. Website: idpc.org.mt. You may also contact the data protection authority in your country of residence.

10.3 Exercising Your Rights

To exercise your data protection rights regarding cookie data, please refer to our Privacy Policy.

Section 11 - Governing Law and Jurisdiction

This Cookie Policy is governed by the laws of Malta, the ePrivacy Directive 2002/58/EC, and the GDPR (EU) 2016/679.

Any disputes arising from this Cookie Policy shall be subject to the exclusive jurisdiction of the courts of Malta. For EU/EEA residents, you may also bring proceedings in the courts of your country of residence.

Nothing in this Cookie Policy creates any contractual relationship between User and any third-party service provider. All claims regarding cookies must be directed exclusively to Profalgo as the data controller.

Section 12 - Cookie Glossary