> For the complete documentation index, see [llms.txt](https://docs.bankly.cc/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.bankly.cc/legal/cookie-policy.md). # Cookie Policy *Effective Date: \[date]* ### **Glossary** Capitalised terms have the meanings set out below or in our Privacy Policy. **“Personal Data”** means any information relating to an identified or identifiable natural person.\ \&#xNAN;**“Controller”** means the entity that determines the purposes and means of processing Personal Data.\ \&#xNAN;**“Processor”** means a service provider that processes Personal Data on our behalf and according to our instructions.\ \&#xNAN;**“EEA/UK”** means the European Economic Area and the United Kingdom.\ \&#xNAN;**“KYC/AML”** means know-your-customer and anti-money-laundering compliance checks.\ \&#xNAN;**“Cookies”** includes browser cookies, local and session storage, SDKs, pixels, tags, and similar tracking technologies. *** ### **1. Who We Are** This Cookies Policy (“Policy”) explains how **CavaleroTech** (“CavaleroTech,” “we,” “us,” or “our”) uses Cookies and similar technologies on: * **bankly.cc** and its sub-domains; * the **Bankly** mobile application (iOS) and the Bankly Telegram mini-app; * in-product webviews, widgets, and embedded content operated by or on behalf of CavaleroTech (together with the foregoing, the **“Platform”**); and * third-party tags or software development kits (“SDKs”) integrated into our Services. For details of our broader Personal Data practices, please see the Bankly Privacy Policy. *** ### **2. Controller** For UAE PDPL and UK/EU GDPR purposes, the Controller for data collected via Cookies is: **CavaleroTech**\ \[CavaleroTech registered office — Dubai, United Arab Emirates]\ [support**@bankly.cc**](mailto:support@bankly.cc) *** ### **3. Scope** This Policy applies to all Bankly web and mobile properties where CavaleroTech acts as Controller and Cookies are placed or read. *** ### **4. What Are Cookies and Similar Technologies** Cookies are small text files placed on your device to help websites and apps function, enhance user experience, secure sessions, and collect analytics.\ We also use equivalent technologies such as local storage, SDKs, pixels, and device identifiers. All are collectively referred to as **Cookies** in this Policy. *** ### **5. Our Cookie Principles** * **Data Minimisation:** Only Cookies necessary for operation, security, or user-consented analytics are used. * **No Wallet or Key Access:** We never access or store private keys, seed phrases, or external-wallet signing data via Cookies or SDKs. Your Bankly balance is a US-dollar balance you hold and spend through the Platform and your Bankly Card. * **Transparency and Control:** Users can manage preferences at any time through in-app privacy settings, browser controls, or the Cookie Settings link on our website. *** ### **6. Categories of Cookies We Use** #### **6.1 Strictly Necessary** Essential for secure operation—authentication, load-balancing, session continuity, fraud prevention, and network routing.\ **Legal basis:** Legitimate interests / performance of contract.\ These Cookies do not require consent. #### **6.2 Performance / Analytics** Help us understand how users interact with Bankly so we can improve reliability and UX (e.g., screen views, navigation paths, feature adoption, crash diagnostics).\ Collected via **Firebase Analytics**, **Crashlytics**, or equivalent SDKs.\ **Legal basis:** User consent (where required) or legitimate interest. #### **6.3 Functionality** Remember your preferences (language, theme, device settings) to personalise the experience.\ **Legal basis:** Consent or legitimate interest. #### **6.4 Marketing / Attribution** Used sparingly to measure campaign effectiveness (e.g., referral or sign-up attribution).\ We do **not** use behavioural-advertising or profiling cookies.\ **Legal basis:** Explicit consent. *** ### **7. Information Collected via Cookies** Depending on category and your settings, Cookies may collect pseudonymous data such as: * Device type, OS, and browser information * IP address (truncated or anonymised) * Session identifiers and timestamps * Pages or screens viewed, navigation flows * Referral/UTM parameters * Error logs and crash diagnostics We do **not** collect precise geolocation or financial/private-key data through Cookies. *** ### **8. Legal Basis and Consent Management** * **Essential Cookies:** Processed under legitimate interests. * **Non-Essential Cookies:** Activated only with your consent. * A consent banner provides clear **“Accept All,” “Reject Non-Essential,” and “Manage Settings”** options. * We record consent signals (timestamp, preferences, pseudonymous ID) for compliance and may ask you to refresh choices periodically. * You may withdraw consent anytime via **Cookie Settings** or device/browser controls. * We honour **Global Privacy Control (GPC)** where applicable. Access to Bankly is not conditioned on accepting non-essential Cookies. *** ### **9. Mobile Applications and SDKs** Our app and Telegram mini-app may include SDKs performing functions similar to Cookies.\ Analytics SDKs (e.g., Firebase) may collect pseudonymous usage and crash data as described above.\ You can reset or limit advertising identifiers in your device settings and adjust in-app analytics permissions. *** ### **10. Managing Cookies** You can manage Cookies by: 1. Using our **Cookie Settings** panel; 2. Adjusting browser settings to block or delete Cookies; 3. Managing advertising identifiers in mobile settings. Blocking certain Cookies may affect availability or performance of some features. Strictly necessary Cookies cannot be disabled. Embedded third-party content (e.g., support widgets or media players) may set their own Cookies; please review their individual privacy notices. *** ### **11. Retention** Cookie-derived data are retained only as long as necessary for their purpose: * Session Cookies → deleted when you close your browser or app. * Persistent Cookies → expire within **12 months** unless renewed by interaction.\ Consent records are kept for up to **five (5) years** or as legally required. *** ### **12. International Transfers** Where Cookie-related data are transferred outside the UAE, UK, or EEA, we implement appropriate safeguards such as: * Adequacy decisions recognised by the UAE Data Office or EU Commission; or * Standard Contractual Clauses and transfer-risk assessments.\ Further details appear in our Privacy Policy. *** ### **13. Children** Bankly is **not directed to individuals under 18 years of age**.\ We do not knowingly use Cookies to profile minors.\ If you believe a child has provided consent to non-essential Cookies, contact us and we will remove such data promptly. *** ### **14. Contact Us** If you have questions about this Policy or our use of Cookies, contact: [support**@bankly.cc**](mailto:support@bankly.cc)\ **CavaleroTech**\ \[CavaleroTech registered office — Dubai, United Arab Emirates] *** ### **15. Changes to This Policy** We may update this Policy periodically to reflect legal, technical, or operational changes.\ When we make material updates, we will revise the “Effective Date” and, where required, re-obtain consent. --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://docs.bankly.cc/legal/cookie-policy.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. 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