Cookie Policy

1. Introduction

This Cookie Policy explains how InDevLab Ro S.R.L. (“we,” “us,” or “our”), a company registered in Romania, uses cookies and similar tracking technologies on the Swipenter landing page at swipenter.com (the “Website”).

This Cookie Policy should be read alongside our Privacy Policy and Terms of Service.

By visiting our Website, you will be presented with a cookie consent banner. Cookies will only be placed on your device after you have given your explicit consent, except for cookies that are strictly necessary for the Website to function.

2. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, or smartphone) when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners. Cookies can be “first-party” (set by the website you are visiting) or “third-party” (set by a service other than the website you are visiting). Cookies can also be “session cookies” (deleted when you close your browser) or “persistent cookies” (remaining on your device for a set period or until you delete them).

3. Legal Basis

Our use of cookies is governed by the following EU legislation:

• General Data Protection Regulation (EU) 2016/679 (GDPR) — requires a lawful basis for processing personal data; we rely on your consent (Art. 6(1)(a)) for analytics cookies and on legitimate interest (Art. 6(1)(f)) for strictly necessary cookies.
• ePrivacy Directive 2002/58/EC (as amended by Directive 2009/136/EC) — requires informed consent before placing non-essential cookies on a user's device.
• Romanian Law No. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector — the national transposition of the ePrivacy Directive.

4. Types of Cookies We Use

4.1 Strictly Necessary Cookies

These cookies are essential for the Website to function and cannot be disabled. They do not require your consent under the ePrivacy Directive.

4.2 Analytics Cookies

These cookies help us understand how visitors interact with our Website by collecting and reporting information anonymously. These cookies are only placed after you have given your explicit consent.

Google Analytics Implementation Notes:

• We use Google Analytics 4 (GA4) with IP anonymization enabled by default (GA4 does not log or store full IP addresses).
• We have not enabled Google Signals, User-ID, or any advertising features.
• Data retention is set to 14 months.
• Data sharing with Google for advertising purposes is disabled.
• Google processes this data on our behalf as a data processor under the Google Analytics Data Processing Terms.

For more information on how Google uses data from sites that use its services, visit: policies.google.com/technologies/partner-sites.

5. Cookie Consent Mechanism

5.1 Consent Banner

When you first visit the Website, a clearly visible cookie consent banner will be displayed. The banner provides you with the following options:

• Accept All — enables strictly necessary and analytics cookies.
• Reject All — enables only strictly necessary cookies; no analytics cookies are placed.
• Manage Preferences — allows you to selectively enable or disable analytics cookies.

5.2 Consent Requirements

In compliance with GDPR and the ePrivacy Directive, our consent mechanism meets the following requirements:

• Prior consent — No analytics cookies are placed before you make an active choice.
• Freely given — Access to the Website is not conditional on accepting analytics cookies. Rejecting cookies does not limit your browsing experience.
• Specific and informed — The consent banner clearly identifies each cookie category, its purpose, and the third-party provider involved.
• Unambiguous — Consent is obtained through a clear affirmative action (clicking “Accept All” or toggling on a specific category). Pre-ticked boxes are not used.
• Withdrawable — You can withdraw your consent at any time (see Section 6).
• Documented — We maintain records of consent as required by Art. 7(1) GDPR.

5.3 No Deceptive Patterns

In accordance with EDPB Guidelines 3/2022 on deceptive design patterns, our consent banner:

• Gives equal visual prominence to the “Accept All” and “Reject All” buttons.
• Does not use color contrast or sizing to steer users toward acceptance.
• Does not use “cookie walls” that block access to content.
• Does not repeatedly prompt users who have already made a choice.

6. How to Manage or Withdraw Consent

6.1 Via Our Cookie Settings

You can change your cookie preferences at any time by clicking the “Cookie Settings” link in the footer of the Website. This will re-display the consent banner, allowing you to modify your choices.

6.2 Via Your Browser Settings

You can also manage cookies through your browser. Instructions for common browsers:

• Safari: Settings > Privacy > Manage Website Data
• Chrome: Settings > Privacy and Security > Cookies and Other Site Data
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Edge: Settings > Cookies and Site Permissions > Manage and Delete Cookies

Please note that disabling all cookies via browser settings may affect the functionality of some websites.

6.3 Google Analytics Opt-Out

You can opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on, available at: tools.google.com/dlpage/gaoptout.

6.4 Effect of Withdrawal

When you withdraw consent for analytics cookies, we will immediately stop placing new analytics cookies. Existing analytics cookies will be deleted. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7. International Data Transfers

When you consent to analytics cookies, data collected by Google Analytics may be transferred to and processed on Google's servers located outside the European Economic Area, including in the United States.

These transfers are protected by the following safeguards:

• EU-US Data Privacy Framework — Google LLC is certified under the EU-US Data Privacy Framework.
• Standard Contractual Clauses (SCCs) — Google's data processing agreements incorporate the European Commission-approved Standard Contractual Clauses for international transfers.

For more information, see: business.safety.google/gdpr.

8. Data Retention

You can delete cookies at any time through your browser settings. To request deletion of analytics data held by Google, visit myaccount.google.com or contact us at [email protected].

9. Your Rights Under GDPR

As a visitor from the European Economic Area, you have the following rights regarding your personal data collected through cookies:

• Right of access (Art. 15) — request confirmation of whether we process your data and obtain a copy.
• Right to erasure (Art. 17) — request deletion of your personal data.
• Right to restriction of processing (Art. 18) — request that we limit data processing.
• Right to object (Art. 21) — object to processing based on legitimate interests.
• Right to withdraw consent (Art. 7(3)) — withdraw consent at any time via Cookie Settings.
• Right to lodge a complaint (Art. 77) — lodge a complaint with a supervisory authority.

The Romanian supervisory authority is:

ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal)
B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 București, România
Email: [email protected]
Phone: +40 318 059 211

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Children's Privacy

Our Website is not directed at children under the age of 16 years. We do not knowingly collect personal data through cookies from anyone under 16. In compliance with GDPR Article 8 and Romanian Law No. 190/2018, if we become aware that a child under 16 has interacted with our Website and analytics cookies have been placed, we will take steps to delete that data.

11. Other Tracking Technologies

11.1 Technologies We Do NOT Use

For transparency, we confirm that the Swipenter Website does not use:

• Fingerprinting or device fingerprinting techniques.
• Web beacons / tracking pixels (beyond what is embedded within Google Analytics).
• Local storage or session storage for tracking purposes.
• Third-party advertising cookies or retargeting technologies.
• Social media tracking plugins or embeds that set cookies.

11.2 External Links

The Website may contain links to the Apple App Store, our social media profiles, or other external websites. These third-party sites have their own cookie policies and privacy practices. We are not responsible for their use of cookies.

12. Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our practices. When we make material changes:

• The “Last Updated” date at the top of this policy will be revised.
• For significant changes to cookie categories or data processing purposes, we will reset your cookie consent and present the consent banner again.

We encourage you to review this Cookie Policy periodically.

13. Contact Us

If you have any questions about this Cookie Policy, please contact:

InDevLab Ro S.R.L.
Email: [email protected]