COOKIE POLICY

ORYNTECH SRL | Effective Date: May 13, 2026 | Version 1.0

IMPORTANT: ORYNTECH SRL only places non-essential cookies on your device with your prior, informed, freely given, and specific consent. You may withdraw your consent at any time and as easily as you gave it, without detriment to your access to the website or Services. Strictly necessary cookies do not require consent and are always active. This Policy is issued in compliance with Romanian Law no. 506/2004 (Art. 4(5) on storing and accessing information on terminal equipment), the General Data Protection Regulation (EU) 2016/679, ANSPDCP guidance, and the European Data Protection Board (EDPB) Guidelines 03/2022 on deceptive design patterns and on cookies. This Policy must be read together with our Privacy Policy.

1. WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files placed on your device (computer, tablet, or smartphone) by websites you visit. Similar technologies covered by this Policy include:

• Web beacons (pixel images tracking page visits, email opens, or campaign performance);
• Local storage objects (browser-side persistent storage used to retain settings or session data);
• Pixel tags (embedded code used by advertising platforms to track conversions);
• Session storage and IndexedDB entries used by web applications;
• Server-side identifiers transmitted via HTTP headers (e.g. server-side analytics).

In this Policy, all such technologies are collectively referred to as "cookies". The legal regime applicable under Art. 4(5) Law no. 506/2004 and Art. 5(3) ePrivacy Directive applies regardless of whether the technology is technically a cookie or another form of storing or accessing information on the user's terminal equipment.

2. WEBSITE STATUS AND ACTIVE TRACKING TECHNOLOGIES

Notice on current tracking status. ORYNTECH SRL maintains a transparent disclosure of all tracking technologies currently active on its website and Platform. The categories listed in Section 3 below describe both currently active cookies and tracking technologies that may be activated upon Client growth (e.g. Meta Pixel and Google Ads tracking, where used). Non-essential tracking technologies will not be activated without prior, informed user consent collected through the cookie consent banner. Users may verify the current set of active cookies at any time through standard browser developer tools or by contacting oryntechai@gmail.com.

3. CATEGORIES OF COOKIES

ORYNTECH SRL distinguishes between four categories of cookies. Categories 3.2, 3.3, and 3.4 require your prior informed consent before being placed on your device. Category 3.1 cookies are strictly necessary and do not require consent under Art. 4(5)(a) Law no. 506/2004.

3.1 Strictly Necessary Cookies

These cookies are essential for the website and Platform to function correctly. They enable core functionalities including user authentication, session management, security (CSRF protection, fraud prevention), load balancing across hosting infrastructure, and consent recording. These cookies do not require consent and cannot be disabled through the cookie consent banner. Disabling them through browser settings will impair website functionality.

3.2 Analytical Cookies — Require Consent

These cookies collect aggregated, pseudonymised information about how visitors interact with our website. They help us understand traffic sources, page popularity, and user journeys, and improve our content and performance. They are placed only after you give consent through the cookie consent banner. The cookies listed below correspond to tracking that may be active or that may be activated as the website grows; in either case, no analytical cookie is set before consent.

3.3 Marketing and Advertising Cookies — Require Consent

These cookies track visitors across websites to display targeted advertising relevant to your interests and to measure the effectiveness of advertising campaigns. They are set by third-party advertising platforms when relevant features are activated and are placed only with your prior consent. ORYNTECH SRL may activate one or more of the technologies listed below as part of its marketing operations; activation does not occur without consent.

3.4 Preference Cookies — Require Consent

These cookies remember your settings and preferences to personalise your experience, such as language preference, display settings, and UI configurations. They are not strictly necessary for site functionality and are placed only with your prior consent.

4. THIRD-PARTY COOKIES AND DATA TRANSFERS

Some cookies are set by third parties whose services are integrated into our website or Platform. These third parties act as independent data controllers for the purposes of their cookies and you should review their respective policies for full information:

• Google LLC — Google Analytics (web analytics) and Google Ads (advertising). Privacy Policy: https://policies.google.com/privacy. Data transfers to the United States are covered by the EU-US Data Privacy Framework.
• Meta Platforms, Inc. — Meta Pixel (Facebook/Instagram advertising). Privacy Policy: https://www.facebook.com/privacy/policy. Data transfers covered by the EU-US Data Privacy Framework.
• LinkedIn Corp. — LinkedIn Insight Tag (B2B advertising, when activated). Privacy Policy: https://www.linkedin.com/legal/privacy-policy. Data transfers covered by the EU-US Data Privacy Framework.
• Stripe, Inc. — payment processing cookies set during checkout pages only. Privacy Policy: https://stripe.com/privacy. Data transfers covered by Standard Contractual Clauses and the EU-US Data Privacy Framework.
• Hosting and infrastructure providers — set strictly necessary cookies for service delivery, traffic routing, security, and bot mitigation. A detailed sub-processor list is available to active Clients in the Data Processing Agreement and to other interested parties upon written request to oryntechai@gmail.com.

ORYNTECH SRL does not control cookies set by independent third parties and is not responsible for their data processing practices. We strongly recommend reviewing each third party's privacy and cookie policy directly.

5. HOW TO MANAGE YOUR COOKIE PREFERENCES

5.1 Cookie Consent Banner

On your first visit to the website, you will be presented with a cookie consent banner offering three equally prominent options: "Accept All", "Reject All", and "Manage Preferences". In accordance with EDPB Guidelines 03/2022 on deceptive design patterns and CNIL guidance, the option to reject non-essential cookies is presented with the same visibility, prominence, and ease of access as the option to accept. No pre-ticked boxes are used and no implied consent is collected from continued browsing.

You may update your preferences at any time by clicking the "Cookie Settings" link in the website footer, which reopens the consent banner and allows you to change your previously expressed choices.

5.2 Consent Withdrawal

Withdrawing consent is as straightforward as giving it. You may revoke any previously granted consent at any time, with effect for the future, through the "Cookie Settings" link or by contacting oryntechai@gmail.com. Withdrawal does not affect the lawfulness of cookies set during the period when your consent was active. Following withdrawal, ORYNTECH SRL will cease setting non-essential cookies and will, where technically feasible, remove existing non-essential cookies stored on your device.

5.3 Browser Controls

In addition to the consent banner, you may control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when cookies are set. Disabling strictly necessary cookies will impair website functionality (login, security, payment processing). Guidance for managing cookies in major browsers is available at https://www.allaboutcookies.org.

5.4 Do Not Track and Global Privacy Control Signals

Where your browser transmits a Global Privacy Control (GPC) signal, ORYNTECH SRL treats this as a valid signal of refusal of non-essential cookies and tracking technologies, in line with emerging EU and US privacy practice. Where your browser transmits a Do Not Track (DNT) signal, ORYNTECH SRL takes this signal into account but reliance on DNT alone is not currently legally sufficient under EU law; the cookie consent banner remains the primary mechanism for managing your preferences.

5.5 Opt-Out of Interest-Based Advertising

In addition to managing cookies through our consent banner, you may opt out of interest-based advertising directly through the relevant advertising platforms:

• Google: https://www.google.com/ads/preferences
• Meta: https://www.facebook.com/about/ads
• LinkedIn: https://www.linkedin.com/psettings/advertising
• Network Advertising Initiative (industry-wide opt-out): https://www.networkadvertising.org/choices
• Your Online Choices (EU industry-wide opt-out): https://www.youronlinechoices.eu

6. COOKIE CONSENT RECORDS

ORYNTECH SRL maintains records of cookie consent in compliance with Art. 7(1) GDPR and EDPB Guidelines 05/2020. Consent records include:

• The date and time consent was given;
• The version of the consent notice displayed at the time;
• The specific categories of cookies accepted, rejected, or set to default;
• The means through which consent was expressed (e.g. consent banner, settings page);
• Subsequent changes to the user's preferences.

Consent records are retained for a maximum of three (3) years from the date the consent was last refreshed, in accordance with applicable EDPB guidance and ANSPDCP positions on accountability. Renewed consent is requested at intervals not exceeding 12 months for active users, in line with industry best practice.

7. INTERACTION WITH AI FEATURES

Where you interact with AI-driven features on the website or Platform (such as chatbots, conversational AI agents, or AI-assisted content), ORYNTECH SRL provides clear disclosure that you are interacting with an AI system, in accordance with Art. 50 of Regulation (EU) 2024/1689 (AI Act). The cookies and similar technologies used to support these features are limited to those strictly necessary to deliver the conversation, route requests, and prevent abuse, and do not, in themselves, profile users for advertising purposes without separate consent.

8. CHANGES TO THIS COOKIE POLICY

ORYNTECH SRL may update this Cookie Policy from time to time to reflect changes in technology, regulation, or its use of cookies. Material changes will be communicated by updating the policy on the website and, where appropriate, by re-prompting consent through the cookie banner. The date of the latest update is shown at the top of this Policy. Continued use of the website or Platform after the effective date of any change constitutes acceptance of the updated Cookie Policy, except where renewed consent is required by law for any new cookie category or processing purpose.

9. CONTACT AND COMPLAINTS

For questions about our use of cookies, to exercise your data protection rights, or to lodge a complaint, please contact:

If you are not satisfied with our response to a cookie or data protection enquiry, you have the right to lodge a complaint with ANSPDCP or with the supervisory authority of the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

© 2026 ORYNTECH SRL | All rights reserved