Cookies & Tracking Policy

Effective Date: December 7, 2025

Document Version: 1.2

Applies to: All Cosgn Services operated by Cosgn Inc.

1. Overview and Definitions

This Cookies & Tracking Policy (the “Cookies Policy”) explains how Cosgn uses cookies and similar technologies in connection with the Services.

“Cookies” includes browser cookies, local storage objects, pixels, tags, SDK identifiers, device identifiers, and similar technologies that store or access information on a device or enable recognition of a browser or device.

Some Cookies are set by Cosgn (first-party). Others may be set by vendors that provide infrastructure, analytics, security, or measurement services (third-party).

2. Categories of Cookies We Use

2.1 Essential (Strictly Necessary)

Used to operate and secure the Services, including authentication, session continuity, CSRF protections, security controls, load balancing, and core functionality.

Essential Cookies are strictly necessary to provide the Services and cannot be disabled through the consent tool. You may be able to block them through browser settings, but doing so may cause the Services to malfunction.

2.2 Functional (Preferences)

Used to remember user preferences and improve usability, such as language settings, accessibility preferences, and UI configurations.

2.3 Analytics (Performance and Diagnostics)

Used to measure performance, reliability, feature adoption, diagnostics, error tracking, and A/B testing. Where feasible, analytics data is aggregated, minimized, or de-identified.

2.4 Advertising / Measurement (Limited)

Used only for measuring clearly labeled sponsored placements or campaigns using contextual signals and limited first-party data (such as high-level page context or campaign IDs). Cosgn does not use Cookies for cross-context behavioral advertising and does not profile minors for advertising.

No sale or sharing. Cosgn does not use Cookies to “sell” or “share” personal information for cross-context behavioral advertising as defined by certain U.S. state privacy laws.

Cosgn does not use cookies or similar technologies to sell or share personal information for cross-context behavioral advertising as defined under applicable U.S. state privacy laws. Where legally enforceable, Global Privacy Control (GPC) signals are honored for applicable processing.

3. Legal Basis and Consent

Where required by law (including Québec Law 25 and EU/EEA/UK ePrivacy rules), non-essential Cookies are set only after you provide consent via a banner or preferences center. You may withdraw or modify consent at any time using the same tools.

Consent Records

Where required, Cosgn may maintain records of consent choices (such as timestamp, region, and selections) to demonstrate compliance, prevent repeated prompts, and honor withdrawals.

4. Analytics De-Identification and Non-Reidentification

Where feasible, analytics and measurement data is aggregated, minimized, or de-identified. Cosgn does not attempt to re-identify de-identified analytics data except where necessary to:

detect, prevent, or investigate security incidents, fraud, or abuse

comply with legal obligations

maintain service integrity (for example, investigating systematic errors)

5. Managing Cookie Preferences

You can manage Cookies by:

using the cookie banner/preferences center (typically accessible via the site footer), and/or

adjusting browser or device settings to block or delete Cookies

If you block or delete Cookies, some features may not function properly, and your choices may need to be re-applied after clearing browser storage or changing devices/browsers. Platform controls may vary between web, mobile, and embedded environments.

Certain cookie controls may not be available in all environments (such as native mobile applications or embedded webviews). In such cases, tracking controls may be managed through device settings or by contacting [email protected].

Tracking technologies and controls may differ between websites, native applications, and embedded environments. Certain controls available on web browsers may not be available in mobile or in-app contexts and may instead be managed through operating-system or device-level settings.

6. Illustrative Cookies and Retention

Examples of Cookies may include:

Essential: cgn_sess, cgn_csrf (session/authentication and security; session/short-lived)

Functional: cgn_lang, cgn_accessibility (preferences; often up to 12 months)

Analytics: cgn_uaid, cgn_abtest (pseudonymous analytics; often 13–24 months or vendor defaults)

Advertising/Measurement: cgn_adv_ctx (limited measurement; often 90–180 days where used)

Cookie names, durations, and vendors may change as we improve security and performance. Current categories and purposes are reflected in the consent tool where available.

Separately from browser cookies, Cosgn may retain related system logs (security logs and consent logs) for auditing, compliance, and security consistent with the Privacy Policy retention principles.

7. Third Parties and International Transfers

Cosgn may use third-party providers that place or access Cookies under Cosgn’s instructions and contractual safeguards. Data may be processed internationally under safeguards described in the Privacy Policy, including assessments required by Québec Law 25 where applicable.

Upon written request, Cosgn may provide a list of material cookie-related vendors and categories of tools, subject to reasonable confidentiality and security limitations.

8. Global Privacy Control and Do Not Track

There is no single global standard for “Do Not Track” signals. Cosgn primarily relies on:

the consent banner/preferences center; and

your browser and device settings

Where a binding technical signal (such as GPC) is legally enforceable in applicable jurisdictions, Cosgn will honor it for applicable processing to the extent required by law.

9. Children and Teens

Cosgn does not knowingly set non-essential Cookies for minors without appropriate consent mechanisms and does not deliver behaviorally targeted ads to minors.

10. Security

Cosgn applies safeguards proportionate to risk to protect cookie systems and consent mechanisms, including access controls and monitoring.

11. Changes to This Cookies Policy

Cosgn may update this Cookies Policy periodically. Material changes may be surfaced via the banner/preferences center or in-app notice where applicable.

12. Contact

Questions about Cookies or tracking technologies?

Email: [email protected]