Cookie Policy

1. Why We Have This Cookie Policy

This Cookie Policy complies with our obligations under applicable data protection and privacy laws, including but not limited to:

• Hong Kong's Personal Data (Privacy) Ordinance ("PDPO")
• EU's General Data Protection Regulation (GDPR) and Privacy and Electronic Communications Directive ("PECD")
• Other relevant local privacy laws applicable to our service regions

Pursuant to these laws, we are required to:

• Clearly inform you about the types of cookies we use
• Explain the purposes and retention periods of each cookie type
• Obtain your explicit consent before using non-essential cookies
• Provide you with options to manage and withdraw your consent

2. What Are Cookies?

A cookie is a small text file containing a unique identifier that is sent to your device (computer, smartphone, tablet, etc.) by a website server when you visit the site. Each time you return to the same website, your browser retrieves and sends the relevant cookies back to the website server.

Cookies can be categorized by their storage duration:

• Session Cookies: Temporary cookies that are deleted when you close your browser.
• Persistent Cookies: Remain on your device for a specified period (as outlined in Section 4) or until you manually delete them.

3. Cookie Consent and Acceptance

When you first visit our Website, you will see a cookie consent banner/pop-up that clearly explains:

• The types of cookies we use
• The purposes for which we use each type
• How to manage your cookie preferences
• A link to this full Cookie Policy

Your consent is required for non-essential cookies. By:

• Clicking "Accept All" or "Accept Selected" on the consent banner
• Continuing to use our Website after being presented with the consent banner
• Adjusting your preferences through the cookie management tool

You agree to the placement and use of cookies in accordance with this Cookie Policy.

Your consent can be withdrawn at any time (see Section 7 for details on how to manage cookies). Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

4. How Cookies Are Used

• Essential Cookies: Stored for the duration of your browsing session (session cookies) or up to 1 year for persistent essential functions.
• Analytical/Performance Cookies: Stored for a maximum of 2 years from the date of initial installation or last update.
• Marketing/Advertising Cookies: Stored for a maximum of 18 months from the date of initial installation or last update.
• Third-party Cookies: Retention periods may vary and are governed by the third party's own policies.

4.1 Essential Cookies (Technically Necessary)

These cookies are required for the basic functionality of our Website and cannot be disabled. They enable you to:

• Navigate between pages efficiently
• Access secure areas of the Website
• Maintain your session state (e.g., staying logged in)
• Remember your preferences for basic Website functions
• Ensure the Website operates correctly across different devices

Note: No explicit consent is required for essential cookies as they are necessary for the provision of the Website service.

4.2 Non-Essential Cookies

These cookies enhance your browsing experience but are not required for basic Website functionality. Explicit consent is required before using these cookies.

4.2.1 Analytical/Performance Cookies

These cookies help us measure and improve the performance of our Website by collecting anonymous usage data. The information collected does not directly identify individual users.

Purposes include:

• Tracking page visits and user navigation paths
• Measuring the time spent on each page
• Identifying popular content and features
• Detecting and fixing technical issues
• Understanding how users interact with the Website across different devices
• Improving the overall user experience based on usage patterns

4.2.2 Marketing/Advertising Cookies

These cookies enable us to provide personalized content and advertising, and track the effectiveness of our marketing activities. They may track your browsing activity across multiple websites.

Purposes include:

• Delivering personalized content and recommendations
• Providing targeted advertisements based on your interests
• Measuring the effectiveness of marketing campaigns
• Preventing the same advertisement from being shown repeatedly
• Understanding user response to advertising content
• Enabling retargeting based on previous Website visits

5. Specific Cookies We Use

We use both first-party cookies (set by our Website) and third-party cookies (set by external service providers). Below is detailed information about the main cookies we use:

5.1 Google Analytics

We use Google Analytics, a web analytics service provided by:

• Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
• Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland)

Google Analytics uses cookies to collect and analyze the following information (in anonymous form):

• Anonymized IP address (last 3 bytes are masked to protect privacy)
• The specific pages accessed on our Website
• The referral source (website from which you arrived)
• Navigation paths between subpages
• Time spent on the Website and individual pages
• Frequency of Website visits
• Device and browser information (type, version, screen resolution)
• Geographic location (at country/region level, not precise location)

Legal Basis: Your explicit consent. The data collected is transmitted to and stored by Google, including potential transmission to the United States. Google adheres to the EU-US Privacy Shield Framework and GDPR requirements for international data transfers.

Opt-out Options: You can disable Google Analytics tracking by:

• Adjusting your cookie preferences through our Website's consent tool
• Installing the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout)
• Configuring your browser settings to block analytical cookies

5.2 Pixel Cookies and Tags

We use Pixel Cookies (also known as web beacons or tracking pixels) provided by third-party advertising platforms to track user interactions and optimize advertising.

Main Providers:

• Meta Platforms, Inc. (Facebook and Instagram): 1601 Willow Road, Menlo Park, California 94025, USA; and 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
• Other third-party advertising platforms as disclosed in our consent tool

Functions:

• Tracking specific user actions on our Website (e.g., page views, button clicks, form submissions)
• Collecting event data about device usage and interaction patterns
• Enabling personalized advertising and retargeting
• Measuring the effectiveness of advertising campaigns
• Optimizing ad delivery based on user behavior

Legal Basis: Your explicit consent. AiTato and the pixel provider are considered joint controllers for the initial collection of event data. The pixel provider acts as the sole controller for subsequent processing of the data.

Privacy Information: For detailed information on how each provider processes personal data, including their legal bases and your rights, please refer to their official privacy policies:

• Facebook Privacy Policy: https://www.facebook.com/privacy/policy/
• Instagram Privacy Policy: https://help.instagram.com/519522125107875
• Other providers: Links are available in our cookie consent tool

5.3 First-Party Functional Cookies

These cookies are set directly by our Website to enable basic functionality and remember your preferences. Examples include:

• Session ID cookies: Maintain your logged-in state during a browsing session
• Language preference cookies: Remember your preferred language for the Website
• Layout preference cookies: Remember your preferred display settings
• Consent preference cookies: Store your cookie consent choices

6. How to Manage Cookies

You have full control over your cookie preferences and can manage or delete cookies at any time. Below are the main methods:

6.1 Through Our Website's Cookie Consent Tool

Our Website provides a cookie consent tool (accessible via the cookie banner or a dedicated "Cookie Settings" link in the Website footer) that allows you to:

• View the complete list of cookies we use
• Toggle consent for each category of cookies (essential cookies cannot be disabled)
• Update your preferences at any time
• Review the purpose and retention period of each cookie type
• Access this Cookie Policy for reference

Note: Changes to your cookie preferences will take effect immediately, but may require you to refresh the page or restart your browser for full implementation.

6.2 Through Your Web Browser Settings

You can configure your web browser to manage cookies, including blocking specific types or all cookies. Below are links to instructions for popular browsers:

• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Apple Safari: https://support.apple.com/en-us/HT201265
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Important Warning: Blocking all cookies may affect the functionality of our Website. You may not be able to access certain features, stay logged in, or use personalized services if cookies are disabled.

6.3 Opting Out of Behavioral Advertising

To opt out of behavioral advertising and retargeting by multiple providers simultaneously, you can use the following industry-wide tools:

• Your Online Choices (EU/EEA): https://www.youronlinechoices.com/
• Digital Advertising Alliance (US): https://www.aboutads.info/
• Digital Advertising Alliance of Canada: https://youradchoices.ca/
• Network Advertising Initiative (US): https://www.networkadvertising.org/
• European Interactive Digital Advertising Alliance: https://www.edaa.eu/
• Google Ad Settings: https://adssettings.google.com/

Note: These tools typically store your opt-out preferences in a cookie. If you clear your cookies or use a different browser/device, you may need to set your preferences again.

6.4 Deleting Existing Cookies

You can delete all existing cookies stored on your device through your browser settings. This will:

• Remove all tracking data from previous Website visits
• Reset your login status on all websites
• Reset your personalized preferences on all websites
• Require you to provide new cookie consent when visiting websites again

7. Data Protection and Your Rights

In accordance with applicable data protection laws, you have the following rights regarding your personal data collected through cookies:

• Right to Access: Request a copy of the personal data we hold about you collected through cookies
• Right to Correction: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data (where legally permitted)
• Right to Restriction: Request restriction of processing of your personal data
• Right to Data Portability: Request your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Withdraw your consent to non-essential cookies at any time

How to Exercise Your Rights: To exercise any of these rights, please contact us at aitato@seennext.com with the subject line "Cookie Data Rights Request". We will respond to your request within the timeframes required by applicable law.

Data Security: We implement appropriate technical and organizational security measures to protect the personal data collected through cookies against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit (HTTPS)
• Secure storage of cookie data
• Regular security audits and updates
• Access controls to limit who can view cookie data
• Compliance with industry security standards

8. Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in:

• Applicable laws and regulations
• Our business practices
• The types of cookies we use
• Third-party service providers

Notification of Changes: When we make material changes to this Cookie Policy, we will:

• Publish the updated policy on our Website with a new "Effective Date"
• Display a prominent notification on our Website homepage
• Provide a notification through our cookie consent tool
• Where legally required, send a direct notification to users who have provided contact information

Your Responsibility: We encourage you to review this Cookie Policy regularly to stay informed about how we use cookies. Your continued use of our Website after the effective date of an updated policy constitutes acceptance of the changes.

9. Disclaimer and Limitation of Liability

While we take reasonable measures to ensure the accuracy and completeness of the information in this Cookie Policy, we cannot guarantee:

• The absolute security of cookie data (due to inherent risks of internet transmission)
• The complete prevention of third-party access to cookies (despite security measures)
• The continued availability of all opt-out mechanisms (subject to third-party changes)
• The accuracy of third-party privacy policies referenced in this document

Limitation of Liability: To the maximum extent permitted by applicable law, AiTato shall not be liable for any direct, indirect, incidental, consequential, or punitive damages arising from:

• The use or inability to use cookies
• Unauthorized access to or disclosure of cookie data
• Changes to cookie policies or third-party practices
• Errors or omissions in cookie-related information
• The actions of third-party service providers

10. Contact Information

For any questions, concerns, or requests related to this Cookie Policy or our use of cookies, please contact us:

• Email: aitato@seennext.com
• Website: http://aitato.seennext.com/

Response Time: We aim to respond to all cookie-related inquiries within 5 business days. For data protection rights requests, we will respond within the timeframe required by applicable law (typically 30-45 days).