Çerez Politikası

This Cookie Policy explains how Atbion OÜ uses cookies and similar storage technologies on Votinova (the "Platform"), a software service for interactive presentations and real-time audience voting, accessible at https://votinova.com and through its web and mobile applications.

This Policy supplements the Privacy Policy and forms part of the Platform's legal framework. It applies both to customers acting as businesses or professionals and to those acting as consumers, as well as to participants who join a session.

Controller: Atbion OÜ — Ahtri tn 12, Kesklinna linnaosa, Tallinn 15551, Estonia — registry code 16890390. Enquiries: privacy@votinova.com.

Cookies are small text files that a website stores in the user's browser. They make it possible, for example, to keep a user logged in or to remember preferences. Alongside cookies, the Platform uses equivalent browser storage technologies, such as local storage (local storage) and session storage (session storage).

Cookies may be:

• First-party or third-party: depending on whether they are set by Atbion OÜ or by an external provider (for example, the payment provider).
• Session or persistent: depending on whether they are deleted when the browser is closed or remain for a defined period.
• Essential or non-essential: depending on whether they are strictly necessary to provide the requested service, or not.

Votinova uses strictly necessary cookies and storage to operate the Platform and secure payments, plus advertising cookies that are only set if the user accepts them. Our own usage analytics is self-hosted and uses no cookies or persistent identifiers.

Authentication tokens are stored in httpOnly cookies, inaccessible to browser JavaScript, as a safeguard against cross-site scripting attacks.

Until the user accepts the advertising category, the Google tag is not loaded at all: no resource is requested from Google's servers by the user's browser, and therefore their IP address is not disclosed to Google.

The Platform integrates two external providers that may set cookies:

• Stripe (payment provider): sets the __stripe_mid and __stripe_sid cookies for the sole purpose of fraud prevention during payment. They are strictly necessary and require no consent. More information in Stripe's privacy policy.
• Google Ads (advertising measurement): sets the _gcl_au cookie to attribute sign-ups to our campaigns. It is only loaded with the user's prior consent and involves an international data transfer to Google LLC (United States) under the EU-U.S. Data Privacy Framework. More information in Google's privacy policy.

Platform usage analytics is performed with Umami, a tool self-hosted on Atbion OÜ infrastructure within the European Union that uses no cookies and creates no persistent user identifiers, and therefore requires no consent.

Other providers Atbion OÜ uses to deliver the service (for example Google or Apple sign-in, or error tracking with Sentry) set no tracking cookies on the Platform. These providers are detailed in the Privacy Policy.

The use of strictly necessary cookies and storage does not require the user's prior consent, under Article 5(3) of Directive 2002/58/EC (the ePrivacy Directive) and its transposition into Estonian law, which exempts storage strictly necessary to provide a service explicitly requested by the user.

Insofar as any of these cookies involves the processing of personal data, the legal basis is Atbion OÜ's legitimate interest in operating the Platform securely and the performance of the contract (Article 6(1)(b) and (f) GDPR).

Advertising cookies are not essential: they are set solely on the basis of the user's prior, freely given, specific, informed and unambiguous consent (Article 5(3) ePrivacy Directive and Article 6(1)(a) GDPR). Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

On the first visit a notice is shown allowing the user to accept all, reject all, or configure each category separately. Rejecting is as easy as accepting: both actions are available in a single click, with equal prominence and at the same layer of the notice. No non-essential category is enabled by default.

Until the user decides, no non-essential cookie is set and no third-party tag is loaded.

The user can change or withdraw their decision at any time through the "Cookie settings" link permanently available in the Platform footer. Withdrawal takes immediate effect on the setting of new cookies and on data being sent to the affected third parties.

The choice is kept in the browser's local storage (vz-consent) together with the date it was made, as proof of consent for the purposes of Article 7(1) GDPR. Should new categories or purposes be added in future, the previous record ceases to be valid and consent is requested again.

Users may manage, block or delete cookies through their browser settings. Please note that disabling essential cookies may prevent logging in or the proper functioning of the Platform, including the payment process.

Instructions for the most common browsers:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Mozilla Firefox: https://support.mozilla.org/es/kb/Borrar-cookies
• Apple Safari: https://support.apple.com/es-es/guide/safari/sfri11471/mac
• Microsoft Edge: https://support.microsoft.com/es-es/microsoft-edge

Users may also log out at any time from within the Platform itself, which invalidates the authentication tokens.

Participants who join a session (via code or QR code) do so, by default, anonymously and without the need for an account. For participants, only the storage strictly necessary for the operation of the voting is used (for example, remembering the session they have joined and their ephemeral participant identifier during the session). The processing of participants' data is governed by the Privacy Policy and, where the customer acts as the controller, by the Data Processing Agreement.

No advertising or third-party marketing tag is loaded on the participation surfaces, regardless of any consent given elsewhere on the Platform.

Atbion OÜ may update this Cookie Policy to reflect changes in the cookies used or in the applicable legislation. The effective date shown at the beginning of the document indicates the most recent update. Material changes will be communicated through the Platform.