Cookie Policy

This Cookie Policy (the “Policy”) sets out how cookies and similar technologies are used when the User accesses the ExWell website available on the Internet at https://exwell.io (the “Site”) and when using ExWell Services. The Policy forms an integral part of the contractual framework between the User and ExWell and applies together with the Terms of Use and the Privacy Policy.

1. Terms and definitions

1.1. Unless the context otherwise requires, the following terms have the meanings set out below:

1.1.1. “ExWell” means the operator of the Site and the person providing the Services, as defined in the Terms of Use.

1.1.2. “Terms of Use” means the document published at https://exwell.io/docs/termsAndConditions.

1.1.3. “Privacy Policy” means the document published at https://exwell.io/docs/privacy.

1.1.4. “User” means a person accessing the Site and/or using ExWell Services.

1.1.5. “Services” means ExWell services as defined in the Terms of Use.

1.1.6. “Cookies” means pieces of data sent by the Site, or by a third party on ExWell’s behalf, to the User’s device and stored by software used to access the Internet (a browser) for subsequent use when accessing the Site.

1.1.7. “Similar technologies” means technical means used for purposes comparable to those of cookies, including browser local storage (localStorage / sessionStorage), session identifiers, and other means of storing data on the User’s device.

1.1.8. “Session cookies” means cookies deleted at the end of the browser session.

1.1.9. “Persistent cookies” means cookies stored for a set period or until deleted by the User.

1.1.10. “First-party cookies” means cookies set by the Site.

1.1.11. “Third-party cookies” means cookies set by third-party domains.

2. General provisions

2.1. This Policy governs the use of cookies and similar technologies on the Site. Processing of personal data carried out using them is governed by the Privacy Policy.

2.2. In the event of a conflict between this Policy and the Privacy Policy on matters of personal data processing, the Privacy Policy prevails. In the event of a conflict between this Policy and the Terms of Use on matters of providing the Services, the Terms of Use prevail. On matters of the use of cookies and similar technologies, this Policy prevails.

2.3. Use of the Site constitutes the User’s review of this Policy. Continued use of the Site with browser settings that allow cookies, and/or confirmation of the cookie notice displayed on the Site, constitutes the User’s consent to the use of cookies and similar technologies to the extent and on the terms of this Policy, unless otherwise required by mandatory provisions of applicable law.

2.4. If the User does not agree with the Policy, they must immediately stop using the Site and/or restrict the use of cookies by the means specified in Section 7 of this Policy.

2.5. The Policy applies solely to the Site. ExWell is not responsible for the use of cookies and similar technologies on third-party websites that may be accessible via links published on the Site.

3. Subject of the Policy

3.1. The Policy determines:

3.1.1. the categories of cookies and similar technologies used and the purposes of their use;

3.1.2. the list of principal means used on the Site as of the date of this edition;

3.1.3. the legal bases for using those means, and the procedure for giving and withdrawing consent;

3.1.4. the User’s rights to manage cookies and similar technologies;

3.1.5. the terms of disclosure of information to third parties and retention periods.

3.2. The Site may use session and persistent cookies, first-party cookies, and (where stated in the current edition of this Policy) third-party cookies.

4. Categories of cookies and purposes of use

4.1. ExWell uses or may use cookies and similar technologies of the following categories:

4.1.1. Strictly necessary (technical) — they enable the Site to function and the Services to be provided, including security, authentication in the personal account, request routing, persistence of the selected language, correct display of exchange stages, and other functions without which the Site or particular Services cannot be provided properly. Such means are set in connection with the User’s actions directed at accessing the Site and/or receiving the Services.

4.1.2. Functional — they persist certain preferences and parameters of the User’s interaction with the Site, including a partner (referral) tag. Disabling functional means may limit particular Site functions and does not in itself make the Site inaccessible as a whole.

4.1.3. Analytics (statistics) — they are or may be used to analyse Users’ interaction with the Site, including information on traffic, errors, and interface improvement. As of the date of this edition, third-party web-analytics services that set analytics cookies are not used on the Site. If they are enabled, the list of such means, purposes, and terms of use shall be reflected in the current edition of this Policy.

4.2. ExWell does not use cookies and similar technologies to display personalised third-party advertising, unless expressly stated in the current edition of this Policy.

5. List of principal cookies and similar technologies

5.1. The following is a list of the principal means used on the Site as of the date of this edition. Names, retention periods, and the composition of means may change as the Site develops. The current edition of the Policy is published at https://exwell.io/docs/cookiesPolicy.

5.2. Strictly necessary means include:

5.2.1. AccessToken — a cookie; maintaining the User’s authorised session in the personal account; retention — until the corresponding token expires;

5.2.2. RefreshToken — a cookie; refreshing the authorised session; retention — until the corresponding token expires;

5.2.3. i18n_redirected — a cookie; persisting the selected language locale of the Site; retention is determined by Site and/or browser settings;

5.2.4. cookies of the type exchangeEndTime:… — technical persistence of the exchange order completion time at the performance stage; retention — until the relevant scenario is completed or the set lifetime (max-age) expires.

5.3. Functional means include:

5.3.1. RefereeLink — a cookie; recording a partner (referral) tag; retention — up to one year from the time it is set or until deleted by the User;

5.3.2. cookiesAccepted — a localStorage record; recording that the cookie notice has been acknowledged; stored until deleted by the User or until browser data are cleared.

5.4. In addition to the means specified in clauses 5.2 and 5.3 of this Policy, the browser and Site infrastructure may create technical identifiers required to deliver Site content and to secure the connection.

6. Legal bases. Consent

6.1. Strictly necessary cookies and similar technologies are used as necessary to provide the Services requested by the User and to enable the Site to function.

6.2. Functional and (where used) analytics cookies and similar technologies are used on the basis of the User’s consent and/or other bases provided by applicable personal-data protection law, taking into account the User’s browser settings.

6.3. The User’s consent is deemed given upon any or a combination of the following circumstances, unless otherwise required by mandatory provisions of applicable law:

6.3.1. use of the Site with browser settings that allow cookies;

6.3.2. confirmation of the cookie notice displayed on the Site.

6.4. The User may at any time withdraw consent to the use of means that are not strictly necessary by changing browser settings and/or deleting stored cookies and local-storage data. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

7. Managing cookies

7.1. The User may restrict, block, or delete cookies and data of similar technologies through the settings of the browser and/or device used. The procedure for doing so is determined by the documentation of the relevant browser and/or device.

7.2. Disabling or substantially restricting strictly necessary cookies may make it impossible to sign in to the personal account, complete an exchange, and receive other Services.

7.3. ExWell does not guarantee full availability and correct operation of the Site and the Services if cookies and similar technologies are disabled or substantially restricted.

8. Disclosure of information to third parties

8.1. Information collected by means of cookies and similar technologies is processed by ExWell and may be disclosed to the categories of recipients specified in the Privacy Policy, to the extent necessary for the Site to function and for the Services to be provided, including hosting and communications providers.

8.2. If third-party services that set their own cookies are enabled on the Site, processing of information by those services is governed by their policies. Use of such services shall be reflected in the current edition of this Policy.

9. Retention period

9.1. Cookies and data of similar technologies are stored for the period specified for the relevant means in Section 5 of this Policy, or until deleted by the User, or until expiry of the period necessary to achieve the purpose of their use, unless a longer period is required by applicable law.