COOKIE POLICY

1. What are cookies?

Cookies are small text files saved on your device when you visit a website. Similar technologies (local storage, SDK identifiers) may be used for comparable purposes.

2. Legal Framework

• EU: GDPR and the ePrivacy Directive for storage of, and access to, information on the user's device (applies where Vezpa processes EEA personal data)
• Italy: guidelines of the Italian Data Protection Authority (Garante) on cookies and national implementation
• Germany (where applicable): DSGVO and consent obligation for non-essential cookies under TDDDG (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz)
• Canada - PIPEDA: the Personal Information Protection and Electronic Documents Act is Canada's federal privacy law governing the collection, use and disclosure of personal information in the course of commercial activities, including through cookies and similar technologies
• Quebec - Law 25 (Loi 25): requires express consent before using non-essential cookies and tracking technologies for Quebec residents
• PIPA (British Columbia and Alberta): provides substantially similar privacy protections at the provincial level
• CASL: Canada's Anti-Spam Legislation may apply to certain cookie-based marketing activities involving electronic messages

3. Cookies Used

Vezpa uses only the cookies listed below, all of which are strictly necessary for the operation of the website and platform (Italian Legislative Decree 196/2003 art. 122.1; exempt from consent under PIPEDA/Law 25 where the cookie is strictly necessary to deliver a service requested by the user):

Vezpa does not use Google Analytics, Facebook Pixel, retargeting cookies, advertising cookies or other profiling tools. Any future introduction of non-essential cookies will be preceded by the implementation of a compliant CMP banner.

4. How to Manage Cookies

• As only technical cookies are used, no consent banner is required: only a brief notice is shown on the first visit.
• You can also delete or block cookies from your browser settings (note: some features may not work properly).
• You can opt out of interest-based advertising through the Digital Advertising Alliance of Canada (DAAC).

5. Third-Party Cookies

The only third party that may set cookies is Stripe, exclusively on the platform's payment pages, for anti-fraud purposes. Stripe's cookie notice: stripe.com/cookie-settings.

6. Your rights under Canadian privacy laws

Under PIPEDA and applicable provincial privacy legislation, you have the right to:

• Be informed about the collection, use and disclosure of your personal information, including through cookies
• Withdraw consent for non-essential cookies at any time (subject to legal or contractual restrictions)
• Request access to personal information collected via cookies
• Request correction of inaccurate personal information
• File a complaint with the Office of the Privacy Commissioner of Canada (OPC, www.priv.gc.ca)

Quebec residents have additional rights under Law 25, including the right to express consent before non-essential cookies are placed and the right to data portability. Complaints can also be addressed to Commission d'acces a l'information (CAI, www.cai.gouv.qc.ca).

To exercise these rights, please contact [email protected].

7. Do Not Track

Some browsers offer a "Do Not Track" (DNT) setting. There is currently no universally accepted standard for how companies should respond to DNT signals. We will update this policy if a standard is established.

8. Updates

This Cookie Policy may be updated in case of technological or regulatory changes. The last-updated date is shown at the top of the document.