Cookie Policy

4. Detailed Cookie Table

Below is a comprehensive list of cookies used on our Services:

5. Third-Party Cookies

We allow trusted third-party service providers to set cookies on our Services for:

Analytics Partners:

• Google Analytics – Usage analytics and behavior tracking
• Mixpanel – Advanced analytics and event tracking
• Hotjar – User session recording and heatmaps

Marketing & Advertising:

• Facebook – Conversion tracking and audience building
• Google Ads – Performance marketing and retargeting
• Pinterest Ads – Visual commerce and audience targeting
• LinkedIn Ads – B2B advertising and lead generation
• Criteo – Dynamic product retargeting

Affiliate & Partner Tracking:

• Impact.com — affiliate click + conversion attribution via first-party domain impact.upmos.com; consent gated; opt out via Cookie Preferences (Marketing category). See Affiliate Program Terms for the underlying program.

Payments & Security:

• Stripe – Payment processing and fraud detection
• Cloudflare – DDoS protection and security

These third parties are bound by Data Processing Agreements and must comply with GDPR, CCPA, and other privacy laws.

6. Other Tracking Technologies

Pixels & Web Beacons

These are transparent 1×1 pixel images embedded in emails and pages to track:

• Email open rates and click-through rates
• Page views and engagement
• Conversion tracking

Device Fingerprinting

We may use device fingerprinting (non-PII identifiers like browser type, OS, screen resolution) to:

• Detect and prevent fraud
• Recognize returning users without cookies
• Comply with security requirements

Local Storage & IndexedDB

We use browser storage to:

• Cache essential data for faster loading
• Store offline functionality data
• Remember user preferences

You can clear local storage via browser settings.

7. Your Rights & Control

Cookie Consent Management

When you first visit our website, we present a consent banner allowing you to:

• Accept All: Accept all non-essential cookies
• Reject All: Reject all non-essential cookies (only essential cookies used)
• Customize: Choose which categories to accept/reject
• Manage Later: Update preferences anytime at Cookie Preferences

Browser Cookie Management

Most browsers allow you to control cookies. See guides for:

• Google Chrome
• Firefox
• Safari
• Edge & Internet Explorer

Disabling Cookies

Opting Out of Targeted Advertising

Opt out of behavioral advertising via:

• Digital Advertising Alliance (DAA)
• Network Advertising Initiative (NAI)
• TrustArc (IAPP)
• YourAdChoices

8. Do Not Track & Global Privacy Control

Do Not Track (DNT)

Some browsers include a “Do Not Track” feature. We honor DNT signals where technically feasible, but DNT standards are not yet uniform across the industry. See EFF guidance on DNT.

Global Privacy Control (GPC)

We recognize the Global Privacy Control (GPC) signal in your browser, which functions as an opt-out request for:

• Sale of personal information
• Sharing of personal information
• Targeted advertising

When GPC is enabled, we disable marketing and advertising cookies.

9. Amendments & Updates

Changes to This Policy

We may update this Cookie Policy to reflect changes in our practices, technology, or regulations. Material changes will be communicated via:

• Email notification to registered users
• Website notice
• Updated “Last Updated” date

Your continued use of our Services after updates constitutes acceptance of the revised Cookie Policy.

Changelog

• December 31, 2025: Initial published Cookie Policy with comprehensive cookie list, consent management, GPC support.

10. Children & Minors

Our Services are not directed to children under the age of 16 (or 13, where applicable under local law). We do not knowingly collect personal information from children through cookies or other tracking technologies.

Age-Gated Content

If we discover that cookies have collected data from a child under the applicable minimum age without verified parental consent, we will:

• Delete all associated cookie data and tracking information promptly
• Disable any analytics or marketing cookies that may have been activated
• Notify the parent or guardian if contact information is available

Applicable Laws

• COPPA (US): Children under 13 require verifiable parental consent
• GDPR (EU/EEA): Children under 16 (or as low as 13 per member state) require parental consent
• UK Age Appropriate Design Code: Enhanced protections for users under 18

11. Legal Basis & Consent

We process cookie data under the following legal bases as required by GDPR Article 6 and the ePrivacy Directive:

Withdrawal of Consent

You have the right to withdraw your cookie consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. To withdraw consent:

• Click “Manage Cookies” in the cookie banner
• Visit Cookie Preferences
• Email privacy@upmos.com
• Clear cookies via your browser settings

Upon withdrawal, we will cease setting non-essential cookies and delete any previously stored non-essential cookie data within 30 days.

12. Jurisdiction-Specific Rights

Depending on your location, you may have additional rights regarding cookies and tracking technologies:

European Union / EEA (GDPR & ePrivacy)

• Right to access data collected through cookies
• Right to erasure of cookie-collected data
• Right to data portability for cookie-collected information
• Right to lodge a complaint with your local Data Protection Authority
• Prior consent required for all non-essential cookies (ePrivacy Directive Art. 5(3))

California (CCPA / CPRA)

• Right to know what personal information cookies collect
• Right to delete personal information from cookies
• Right to opt out of the “sale” or “sharing” of personal information via cookies
• Right to limit the use of sensitive personal information
• No discrimination for exercising your rights

United Kingdom (UK GDPR & PECR)

• Same rights as EU GDPR plus UK-specific protections under PECR
• ICO guidance on cookies applies
• Age Appropriate Design Code protections for minors

Brazil (LGPD)

• Right to confirmation and access to cookie data
• Right to correction and deletion of cookie data
• Right to object to processing based on cookies

Canada (PIPEDA)

• Right to know about cookie data collection practices
• Right to access and correct cookie-collected data
• Meaningful consent required for non-essential cookies

13. Cross-Border Data Transfers

Cookie data collected on our Services may be transferred to, stored in, and processed in countries outside your country of residence, including the United States.

Safeguards

When we transfer cookie data internationally, we ensure adequate protections through:

• Standard Contractual Clauses (SCCs): EU-approved contractual safeguards for data transfers
• Adequacy Decisions: Transfers to countries deemed adequate by the European Commission
• EU-US Data Privacy Framework: Where applicable, certified under the DPF
• Binding Corporate Rules: Internal rules for multinational data transfers
• Supplementary Measures: Technical and organizational measures including encryption, pseudonymization, and access controls

14. Data Protection Officer

Our Data Protection Officer (DPO) oversees cookie compliance and data protection matters:

You may also contact your local Data Protection Authority if you are not satisfied with our response.

15. Frequently Asked Questions

What are strictly necessary cookies?