Cookie Policy

Effective Date: August 22, 2026

1. Introduction

This Cookie Policy ("Policy") explains how GRAMBL ("Company", "we", "us", "our") uses cookies and similar technologies on the website grambl.com ("Site").

By using our Site, you confirm that you have read this Policy and agree to the use of cookies in accordance with its terms. If you do not agree to the use of cookies, please configure your browser accordingly or discontinue use of the Site.

2. What Are Cookies

Cookies are small text files that are placed on your device (computer, smartphone, tablet) when you visit websites. Cookies are widely used to enable websites to function or to improve their efficiency, as well as to provide information to site owners.

Similar technologies include web beacons, pixel tags, local storage, and other technologies that collect information about your use of the Site.

3. Types of Cookies Used

3.1 By Duration

Session cookies — temporary files that are deleted after you close your browser.
Persistent cookies — files that remain on your device for a specific period of time or until manually deleted.

3.2 By Purpose

Strictly necessary cookies — ensure basic functionality of the Site, including security, network management, and accessibility. Without these cookies, the Site cannot function properly.

Functional cookies — allow the Site to remember your preferences (e.g., language, region) and provide enhanced personalized features.

Analytical/statistical cookies — help us understand how visitors interact with the Site by collecting and analyzing information anonymously. This data helps us improve the Site's performance.

Marketing/advertising cookies — used to track visitors across websites for the purpose of displaying relevant and engaging advertising to individual users.

3.3 By Source

First-party cookies — set directly by our Site.
Third-party cookies — set by third parties whose services we use on our Site (e.g., analytics services, social networks, advertising platforms).

4. Purposes of Using Cookies

We use cookies for the following purposes:

• Ensuring Site functionality — to provide core functions and services
• Authentication and security — to identify users and protect against fraudulent activities
• Settings and preferences — to save your settings (interface language, currency)
• Analytics and performance — to understand how the Site is used and improve its performance
• Content personalization — to provide relevant content and recommendations
• Marketing and advertising — to display targeted advertising and evaluate the effectiveness of marketing campaigns
• Compliance with legal obligations — to fulfill requirements of applicable law

5. Specific Cookies Used on the Site

We may use the following categories of cookies:

Please note: the specific list of cookies used may change. You can obtain current information through the cookie management settings on the Site or through your browser settings.

6. Legal Basis for Data Processing

Processing of personal data through cookies is carried out on the following legal grounds:

• Consent — in cases where your explicit consent is required under applicable law
• Contract performance — when cookies are necessary to provide services you have requested
• Legitimate interests — when the use of cookies is necessary for our legitimate interests (Site improvement, security, analytics) and does not infringe upon your rights
• Compliance with legal obligations — when required by applicable law

7. Your Rights and Cookie Management

7.1 Management Through Browser

You can control and/or delete cookies at your discretion. You can delete all cookies already on your computer and configure most browsers to block their placement.

7.2 Management Through the Site

Our Site may provide a special cookie consent management tool that allows you to choose which categories of cookies you want to accept or reject.

7.3 Consequences of Disabling Cookies

Please note that if you disable or reject cookies, some features of the Site may be unavailable or function incorrectly. In particular: you may not be able to log into your account, the Site may not remember your preferences, and some features may work slower or be unavailable.

7.4 Your Rights as a Data Subject

In accordance with applicable personal data protection legislation, you have the following rights: right to access your personal data, right to rectify inaccurate data, right to erasure ("right to be forgotten"), right to restriction of processing, right to object to processing, right to withdraw consent, right to data portability, and right to lodge a complaint with a supervisory authority.

To exercise your rights, please contact us using the contact information specified in Section 18.

8. Third-Party Services and Cookies

Our Site may contain integrations with third-party services that set their own cookies. We do not control the use of cookies by third parties.

Third-party services may include: web analytics systems, social networks, payment systems, advertising networks, and cloud infrastructure services.

We recommend that you review the privacy and cookie policies of these third parties for detailed information about their data processing practices.

9. International Data Transfer

Some cookies may involve the transfer of data outside your country, including countries that may not provide the same level of personal data protection as in your jurisdiction.

In such cases, we take necessary measures to ensure appropriate protection of your data in accordance with applicable law, including use of standard contractual clauses, ensuring an adequate level of data protection in the recipient country, and obtaining your explicit consent where required.

10. Data Security

We have implemented appropriate technical and organizational security measures to protect data collected through cookies from unauthorized access, modification, disclosure, or destruction.

However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

11. Changes to the Cookie Policy

We reserve the right to modify this Policy at any time. All changes take effect after publication of the updated Policy on the Site.

We will notify you of significant changes by: posting a notice on the Site, sending a notification to the email address you provided (if applicable), or through a pop-up window on your next visit to the Site.

We recommend that you periodically review this Policy to familiarize yourself with any changes. The date of the last update is indicated at the beginning of the document.

Your continued use of the Site after publication of changes will signify your agreement to the updated Policy.

12. Data Retention Period

Data collected through cookies is stored for various periods depending on the type of cookie and processing purposes: session cookies are deleted when the browser is closed; persistent cookies are stored for the period specified in the cookie itself (from several days to several years); analytical data may be stored in aggregated form for longer periods.

After the retention period expires, data is deleted or anonymized in such a way that you cannot be identified.

13. Minors

Our Site is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors through cookies.

If you are a parent or guardian and have learned that your child has provided us with personal data without your consent, please contact us. If we learn that we have collected personal data from a minor without proper consent, we will take steps to delete that information.

14. Disclaimer and Limitation of Liability

THIS POLICY IS PROVIDED "AS IS" WITHOUT ANY WARRANTIES, EXPRESS OR IMPLIED.

To the maximum extent permitted by applicable law:

1. We are not liable for the actions of third parties that set their cookies on our Site
2. We do not guarantee uninterrupted operation of the Site when cookies are disabled
3. We are not liable for any losses arising from the use or inability to use cookies
4. We are not liable for inaccuracies in information obtained through third-party cookies
5. Our liability is limited in accordance with applicable law and the provisions of our Terms & Conditions

15. Applicable Law

This Policy is governed by and construed in accordance with the laws of the jurisdiction in which GRAMBL is officially registered as a business entity and/or in which its principal officers are based, without regard to conflict of law provisions.

For users from the European Union, the provisions of the General Data Protection Regulation (GDPR) apply. For users from other jurisdictions, the relevant provisions of personal data protection legislation apply.

16. Dispute Resolution

All disputes arising from or in connection with this Policy shall be resolved in the manner provided for in our Terms & Conditions.

Before going to court, the parties undertake to attempt to resolve the dispute by sending a written claim. The response period for a claim is 30 (thirty) calendar days from the date of its receipt.

17. Severability

If any provision of this Policy is deemed invalid, illegal, or unenforceable under applicable law, this does not affect the validity of the remaining provisions of the Policy.

The invalid provision will be replaced by a valid provision that most closely corresponds to the intent and economic meaning of the invalid provision.

18. Contact Information

If you have questions about this Cookie Policy, your rights, or wish to exercise your rights, please contact us:

In complex cases, the response period may be extended by another 30 days, with notification to you of the reasons for the delay.

Last updated: August 22, 2026
Document version: 1.0

Appendix: Glossary of Terms

Cookie (cookies, cookie files) — small text files placed on a user's device when visiting a website.
Personal data — any information relating to a directly or indirectly identified or identifiable natural person.
Processing of personal data — any operation with personal data, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, destruction.
Consent to processing of personal data — voluntary, specific, informed, and conscious expression of the will of the data subject, whereby they consent to the processing of their personal data.
Data subject — a natural person to whom personal data relates.
Data controller — a person who determines the purposes and means of processing personal data.
Anonymization — actions as a result of which it becomes impossible without the use of additional information to determine the belonging of personal data to a specific subject.
GDPR — General Data Protection Regulation of the European Union.

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