Cookie Policy

1. About This Cookie Policy

This Cookie Policy explains how NOVATRADE SOLUTIONS Sp. z o.o. (“NOVATRADE”, “we”, “us”, or “our”) uses cookies, local storage, session storage, and similar technologies on novatrade-solutions.pl.

These technologies may be used to:

• operate the website;
• maintain security;
• remember user choices;
• support forms and workflows;
• measure website use where permitted;
• support marketing functionality where permitted.

Some technologies are necessary for the website to function properly.

Other technologies are optional and are used only where permitted by applicable law and, where required, after the user has provided an appropriate consent choice.

This Cookie Policy should be read together with our Privacy Policy.

2. Website Operator

The website is operated by:

NOVATRADE SOLUTIONS Sp. z o.o.

Hoża 86 lok. 410, 00-682 Warszawa, Poland

KRS: 0001255864

NIP: 7011324158

REGON: 54531482500000

Email: [email protected]

Phone: +48 22 273 95 89

Additional company information is available in our Legal Notice.

3. What Are Cookies?

Cookies are small pieces of information that a website or related service may store on a user’s device and read during a later request or session.

Cookies can be used for different purposes.

For example, they may help a website:

• maintain a session;
• remember preferences;
• protect forms;
• maintain security;
• understand whether a consent choice has already been made;
• measure how the website is used;
• support advertising or marketing functionality where enabled.

Cookies may be:

Session Cookies

Cookies intended to remain only for a browser session or another short period.

Persistent Cookies

Cookies that may remain on a device beyond the current session until they expire or are removed.

First-Party Cookies

Cookies associated with the website or domain being visited.

Third-Party Cookies

Cookies associated with another provider whose technology is integrated into the website.

The fact that a cookie is first-party or third-party does not by itself determine whether it is necessary or optional.

4. Similar Technologies

Not every browser-storage technology is technically a cookie.

NOVATRADE may also use technologies such as:

• localStorage;
• sessionStorage;
• browser-based identifiers;
• consent-management storage;
• other comparable client-side storage mechanisms.

These technologies may perform functions similar to cookies by storing or accessing information on the user’s device.

For transparency, this Policy refers to cookies and these related technologies together where appropriate.

5. Why We Use These Technologies

NOVATRADE may use cookies and similar technologies for purposes including:

Website Operation

To:

• load pages;
• maintain required website state;
• support navigation;
• operate forms;
• remember technically necessary settings.

Security

To:

• protect forms and sessions;
• detect potentially abusive requests;
• support authentication where applicable;
• reduce fraud or misuse;
• maintain website and account security.

Preferences

To:

• remember a user’s selected settings;
• remember consent preferences;
• preserve optional workflow or interface choices.

Analytics

Where enabled and permitted, to:

• understand how visitors use the website;
• identify frequently used pages;
• identify technical problems;
• evaluate website performance;
• improve content and usability.

Marketing

Where enabled and permitted, to:

• measure marketing activity;
• understand campaign effectiveness;
• support advertising-related functionality;
• limit or personalize marketing activity.

Optional analytics and marketing technologies are not treated as necessary merely because they may be useful to NOVATRADE.

6. Cookie Categories

NOVATRADE organizes website technologies into the following categories.

Essential

Essential technologies are required for the website or a service requested by the user to operate properly.

They may support functions including:

• website operation;
• security;
• fraud prevention;
• session management;
• consent-preference storage;
• form continuity;
• load balancing;
• authentication where applicable;
• other functionality strictly necessary to provide a requested service.

Essential technologies cannot be disabled through the NOVATRADE Cookie Preferences interface where they are required for the relevant website function.

Users may still be able to restrict such technologies through browser or device settings, although doing so may prevent parts of the website from working correctly.

Functional

Functional technologies support additional preferences or convenience features that are not strictly necessary for the basic website to operate.

Examples may include:

• remembering optional interface preferences;
• remembering non-essential display settings;
• supporting optional embedded functionality.

Where consent is required for a functional technology, it will not be activated before the required consent is obtained.

Analytics

Analytics technologies help NOVATRADE understand how the website is used.

Depending on the tools actually enabled, analytics may involve information concerning:

• pages viewed;
• interaction with website elements;
• device or browser information;
• traffic source;
• session information;
• website performance;
• errors;
• approximate geographic information.

Where consent is required, analytics technologies will remain disabled until the user enables the Analytics category.

If NOVATRADE does not currently use analytics technologies requiring consent, the Cookie Preferences interface should state:

“NOVATRADE does not currently use optional analytics technologies in this category.”

Marketing

Marketing technologies may be used to support:

• advertising measurement;
• campaign attribution;
• audience-related functionality;
• marketing optimization;
• similar promotional purposes.

Where consent is required, marketing technologies will remain disabled until the user enables the Marketing category.

If NOVATRADE does not currently use marketing technologies requiring consent, the Cookie Preferences interface should state:

“NOVATRADE does not currently use optional marketing technologies in this category.”

7. Essential Technologies

Essential technologies may be used without an optional marketing or analytics consent where their use is necessary to provide the website, maintain security, remember the user’s consent decision, or provide another function specifically requested by the user.

Examples may include technologies required to:

• maintain security;
• prevent duplicate or abusive requests;
• store cookie-consent preferences;
• preserve an unfinished form locally where that functionality is requested;
• maintain a user session;
• provide authentication;
• route requests;
• maintain essential website functionality.

NOVATRADE does not classify a technology as Essential merely because it is commercially useful or provides analytics, advertising, or marketing value.

8. Optional Technologies

Functional, Analytics, and Marketing technologies may require a user’s consent depending on:

• what the technology does;
• what information it stores or accesses;
• applicable law;
• the context in which it is used.

Where consent is required, the relevant optional technology must remain disabled until the user makes an affirmative choice.

A user’s decision to reject optional technologies does not prevent access to ordinary public website content merely because NOVATRADE would prefer to use those technologies.

Some genuinely optional features may, however, remain unavailable if the technology specifically required for that optional feature has not been enabled.

9. Cookie Consent

Where consent is required, NOVATRADE uses a consent interface to allow users to make choices concerning optional technologies.

The consent interface may allow users to:

• accept all optional categories;
• reject optional categories;
• review individual categories;
• save selected preferences.

Consent should be based on an affirmative user choice.

NOVATRADE does not treat inactivity, silence, continued browsing, or a preselected optional category as an affirmative consent choice where affirmative consent is required.

10. Equal Choice

The initial consent interface provides users with a clear ability to:

Accept All

and

Reject Optional

without requiring the user to navigate through additional preference screens merely to reject optional technologies.

Users who want more granular control may select:

Manage Preferences

Optional categories are not preselected.

Essential technologies remain identified separately.

11. Granular Preferences

The Cookie Preferences interface allows separate choices for relevant optional categories.

Categories should be displayed as:

Essential

Always enabled where required for website operation or a requested service.

Functional

Optional where consent is required.

Analytics

Optional.

Marketing

Optional.

The user may save a combination of optional preferences rather than being forced to accept or reject every optional purpose as a single bundle.

12. Withdrawing or Changing Consent

A user may change or withdraw optional cookie consent at any time by selecting:

Cookie Preferences

in the website footer.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

When a user disables an optional category, NOVATRADE should stop initiating future optional storage or access associated with that category.

Where technically possible and appropriate, NOVATRADE should also remove first-party optional cookies or storage created by the website for that category.

NOVATRADE cannot always directly delete information already stored by an independent third-party system, but withdrawal must prevent further optional use by the NOVATRADE website where the integration is under NOVATRADE’s control.

13. Consent Records

NOVATRADE may maintain information necessary to demonstrate and apply a user’s cookie preferences.

This may include:

• consent-policy version;
• selected categories;
• date or timestamp of the choice;
• consent status;
• technical information necessary to apply the choice.

Consent records are used for purposes such as:

• remembering the user’s choice;
• avoiding repeated unnecessary consent prompts;
• applying the selected settings;
• demonstrating compliance where appropriate.

NOVATRADE does not use a consent-preference record as a hidden advertising identifier.

14. Local Form Drafts and Workflow State

NOVATRADE may use browser storage to preserve unfinished user input or workflow state where this functionality is provided.

Examples may include:

• an unfinished contact form;
• an unfinished qualification process;
• an unfinished demo request;
• another multi-step workflow.

Where information is stored locally in the browser and has not yet been submitted, it may remain on the user’s device until:

• the relevant workflow is completed;
• the website removes it;
• the entry expires;
• the user clears browser storage.

Local draft storage should contain only information reasonably necessary for the relevant workflow.

Successfully submitted information may be transmitted to NOVATRADE separately as explained in the Privacy Policy.

15. Authentication and Account Technologies

Where NOVATRADE provides authenticated customer areas, essential technologies may be required to:

• sign a user in;
• maintain an authenticated session;
• protect account security;
• prevent cross-site attacks;
• enforce session expiration;
• support multi-factor authentication where applicable.

Disabling essential authentication technologies may make it impossible to sign in or use authenticated areas.

Authentication-related technologies must not be repurposed for unrelated advertising merely because they are already present on the device.

16. Payment Technologies

Where a customer enters a payment flow, a payment service provider may use technical storage or similar technologies for purposes including:

• secure payment processing;
• authentication;
• fraud prevention;
• transaction security;
• regulatory or payment-network requirements.

Some payment-related technologies may be necessary to provide a payment function requested by the customer.

Other payment-provider technologies, if used for unrelated analytics or marketing, must be classified according to their actual purpose rather than automatically treated as Essential.

Payment technologies are also subject to the relevant payment provider’s own privacy and technology practices.

17. Embedded Third-Party Content

NOVATRADE may use embedded third-party content or functionality.

Examples may include:

• video;
• maps;
• scheduling tools;
• support widgets;
• external forms;
• other embedded services.

An embedded service may attempt to store or access information on the user’s device.

Where that storage or access is optional and requires consent, the embedded service must not load before the relevant consent has been given.

Where practical, the website may display a placeholder explaining that the user must enable the relevant optional category to access the embedded feature.

18. Analytics

If NOVATRADE uses optional analytics, such technologies must be disclosed in the Current Technology Inventory and categorized accurately.

Optional analytics must not be activated before the required consent.

Analytics should not be described as anonymous merely because the website does not display the visitor’s name.

Technical identifiers, IP-derived information, device information, or other usage information may still be personal data depending on the circumstances.

19. Advertising and Marketing Technologies

If NOVATRADE uses advertising or marketing technologies, they must be disclosed accurately.

Marketing technologies must not be disguised as:

• security;
• essential functionality;
• ordinary session storage;
• necessary website operation

when their actual purpose is advertising, attribution, profiling, remarketing, or comparable marketing activity.

Where consent is required, Marketing remains disabled until the user affirmatively enables it.

20. Browser Settings

Most browsers provide controls that allow users to:

• view stored cookies;
• remove cookies;
• restrict cookies;
• block some or all cookies;
• clear site data.

Browser controls operate separately from the NOVATRADE Cookie Preferences interface.

Blocking all browser storage may affect:

• authentication;
• form functionality;
• saved preferences;
• consent records;
• other website functions.

The fact that a browser technically permits cookies by default does not replace a consent choice where NOVATRADE is legally required to obtain consent.

21. Do Not Track and Browser Privacy Signals

Browsers and devices may provide privacy signals or tracking-preference mechanisms.

The legal and technical effect of these signals may vary by jurisdiction and technology.

Where NOVATRADE is legally required to recognize a particular browser or device signal, NOVATRADE will seek to implement the required behavior.

The Cookie Preferences interface remains the primary website mechanism for managing NOVATRADE optional cookie categories unless another legally required mechanism applies.

22. Current Technology Inventory

The current website technology inventory appears below.

This inventory should identify technologies actually used by the production website and should include, where applicable:

• technology or cookie name;
• provider;
• category;
• purpose;
• type;
• duration or expiration;
• whether it is first-party or third-party.

The inventory must reflect actual implementation rather than generic examples.

NOVATRADE may update the inventory when technologies change.

No third-party analytics, advertising, remarketing, tag-management, chat, video, map, scheduling or social technology is loaded by this website, and no third-party cookie is set through it.

Where a technology is added, this inventory is updated before the technology is enabled.

23. Third-Party Providers

Where a third-party provider places or accesses information through the NOVATRADE website, that provider may also process information according to its own privacy terms.

NOVATRADE seeks to configure third-party technologies consistently with the consent choices available on the website.

A provider’s independent website is outside NOVATRADE’s direct control.

Users should review the relevant provider’s privacy information where appropriate.

24. Personal Data and Cookies

Some cookies or similar technologies may involve personal data.

Where personal data is processed, NOVATRADE processes that information according to the Privacy Policy and applicable data-protection law.

Depending on the technology and purpose, relevant information may include:

• IP address;
• technical identifiers;
• device information;
• browser information;
• usage information;
• timestamps;
• website interactions;
• approximate location;
• consent choices.

The applicable legal basis for the subsequent processing of personal data may depend on the relevant purpose and circumstances.

25. Retention

Different technologies may have different lifetimes.

A technology may remain:

• only for the current session;
• for a defined period;
• until the user changes a preference;
• until the user clears browser data;
• until another configured expiration occurs.

Actual durations for technologies in use should be stated in the Current Technology Inventory where they can be determined.

NOVATRADE does not use one invented universal retention period for all cookies and browser storage.

26. Security

Cookies and browser-storage technologies are not inherently secure merely because they are stored in a browser.

NOVATRADE seeks to configure technologies in a manner appropriate to their purpose.

Depending on the technology, security measures may include settings such as:

• Secure;
• HttpOnly;
• SameSite;
• limited scope;
• limited duration.

The exact technical configuration depends on the relevant technology.

NOVATRADE does not claim that every browser-storage item can or should use every available cookie-security attribute.

27. Changes to Website Technologies

NOVATRADE may:

• add;
• remove;
• replace;
• reconfigure

website technologies as the website and Service develop.

When a change materially affects optional cookie or tracking practices, NOVATRADE will update:

• the applicable consent configuration;
• the Current Technology Inventory;
• this Cookie Policy where appropriate.

A newly introduced optional technology requiring consent must not be treated as authorized merely because a user previously consented to a materially different purpose.

28. Changes to This Cookie Policy

NOVATRADE may update this Cookie Policy to reflect:

• changes in website functionality;
• changes in technologies;
• legal requirements;
• regulatory guidance;
• operational changes.

The current version will be published on this page with its revision date.

Where a change requires a new consent choice, NOVATRADE may ask users to review their preferences again.

29. Contact

Questions about cookies, browser storage, or website privacy may be directed to:

NOVATRADE SOLUTIONS Sp. z o.o.

Hoża 86 lok. 410, 00-682 Warszawa, Poland

Email: [email protected]

Phone: +48 22 273 95 89

For broader information about how NOVATRADE processes personal data, please review our Privacy Policy.

EMAIL

[email protected]

PHONE

+48 22 273 95 89

30. Related Documents

This Cookie Policy should be read together with:

• Privacy Policy;
• Legal Notice;
• Terms & Conditions;
• Billing, Cancellation & Refund Policy;
• Service Delivery & Fulfillment Policy;
• Data Processing information where applicable.