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Cookie Policy

Document Version: ALL-CP-v1.0.0 / Legal Pack Version: ALL-LP-v1.0.0

Effective Date: 26 October 2026 | Last Updated: 26 October 2026

1. Introduction

This Cookie Policy describes how All360 Technology S.A., a company incorporated under the laws of the Republic of Panama ("ALL," "we," "us," or "our"), uses cookies and similar tracking technologies on the ALL Platform website, dashboard, and digital properties operated directly by ALL.

This Cookie Policy supplements and should be read together with the ALL Privacy Policy. Capitalised terms not defined here have the meaning given to them in the Privacy Policy or the ALL Terms of Use.

By continuing to use the Platform, you acknowledge that you have read this Cookie Policy. Where applicable law requires prior consent for non-essential cookies, we will request your consent through a cookie consent mechanism before placing such cookies. Strictly necessary cookies are placed without consent, as they are essential to the operation of the Platform.

2. Scope

This Cookie Policy applies exclusively to cookies and tracking technologies placed by ALL on:

  • the ALL Platform website (all.is.one and associated subdomains);
  • the ALL dashboard and account management interface; and
  • other web properties directly operated by ALL.

This Cookie Policy does not apply to the ALL edge network infrastructure (proxy, bandwidth, compute, storage, VPN, or AI services). ALL does not place cookies on end users of services operated by Business Customers using ALL's infrastructure. See Section 9 for further detail.

3. What Are Cookies and Similar Technologies

Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device and collect limited information about how you use the service. We may also use similar technologies, including:

  • web beacons (pixel tags / clear GIFs) — transparent image files that track page or email opens;
  • local storage and session storage — browser-based storage used for functionality and performance; and
  • JavaScript tags and SDKs — code that collects analytics or performance data.

References to "cookies" in this Policy include all of these technologies unless stated otherwise.

Where ALL makes available mobile applications, ALL360 software, Developer SDKs, or similar software-based interfaces, those applications or software may use technologies similar to cookies, including SDKs, local storage, device identifiers, logs, crash reports, performance metrics, or feature interaction data, to support Platform functionality, stability, security, fraud prevention, analytics, and improvement. Such technologies are covered by this Cookie Policy only to the extent they perform cookie-like or tracking functions. Other device, telemetry, operational, or Platform Data is governed by the ALL Privacy Policy and, where applicable, by feature-specific notices.

4. Categories of Cookies We Use

Category Purpose Legal Basis User Control
Strictly Necessary Authentication, session integrity, security controls, load balancing, consent preference storage Legitimate interests / contractual necessity Cannot be disabled
Functional Language and display preferences, dashboard layout, login state persistence Legitimate interests or consent (jurisdiction-dependent) Browser settings / Preference Center
Analytics & Performance Aggregate usage metrics, error tracking, traffic sources, Platform performance measurement Legitimate interests or consent (jurisdiction-dependent) Browser settings / Preference Center / Opt-out tools
Marketing, Targeting & Referral Attribution No third-party behavioural advertising or retargeting currently in use; limited referral, affiliate, campaign, or attribution technologies may be used as described in §4.4 Consent where required; opt-out where applicable Consent withdrawal / Preference Center / opt-out controls where applicable

4.1 Strictly Necessary Cookies

Strictly necessary cookies are essential for the Platform to function and are placed on the basis of ALL's legitimate interests in operating a secure and functional service, or as necessary to perform our contract with you. They enable:

  • user authentication and session management;
  • security controls, including fraud prevention and tamper detection;
  • load balancing and network routing; and
  • storage of your cookie consent choices.

You cannot opt out of strictly necessary cookies. Disabling them through browser settings will impair or prevent use of the Platform.

4.2 Functional Cookies

Functional cookies remember your preferences and enhance your experience. They may store language and display preferences, dashboard layout settings, and login state between sessions. Legal basis: legitimate interests or consent, depending on jurisdiction. You may disable functional cookies in your browser settings; some Platform features may not function as intended if you do so.

4.3 Performance and Analytics Cookies

Performance cookies collect aggregated or pseudonymised information about how users interact with the Platform — including pages visited, time on page, error events, and traffic sources — to help us measure and improve Platform performance. We use analytics service providers to process this data; where feasible, data is aggregated or pseudonymised before further processing.

Legal basis: legitimate interests (where permitted by applicable law) or consent. You may opt out through your browser settings, the Cookie Preference Center (where implemented), or available opt-out tools for specific analytics providers.

4.4 Marketing, Targeting, and Referral Attribution Cookies

As at the date of this Policy, ALL does not use third-party behavioural advertising or retargeting cookies on the Platform. ALL may, however, use limited first-party or provider-assisted referral, affiliate, campaign, or attribution technologies to measure referral links, campaign performance, Affiliate attribution, sign-ups, qualifying revenue, and fraud prevention in connection with the referral program.

Where such technologies are not strictly necessary, ALL will obtain consent where required by applicable law and will provide opt-out controls where required by CCPA/CPRA or similar laws. If ALL introduces third-party behavioural advertising, retargeting, or additional marketing cookies in the future, this Policy will be updated and prior consent will be requested where required by applicable law.

5. Third-party Cookies and Services

Some cookies on the Platform may be set by third-party service providers engaged by ALL, including analytics providers, security and fraud prevention services, content delivery networks (CDNs), and identity verification tool providers. These providers may collect information about your interactions with the Platform in accordance with their own privacy policies.

ALL does not control the tracking practices of third-party providers and recommends that you review their privacy and cookie policies directly. Where a Cookie Preference Center is implemented on the Platform, it will include a list of the principal third-party cookie providers active at that time. ALL does not commit to maintaining a real-time or exhaustive list of all third-party cookies outside of the Preference Center.

ALL may engage or change third-party providers without individual notice, unless prior notice is required under an applicable Data Processing Agreement or mandatory law.

Cookies may be session-based (expiring when you close your browser) or persistent (remaining on your device for a defined period). Indicative durations are as follows:

  • Strictly necessary and functional cookies: up to 12 months, or the duration of your active session.
  • Analytics cookies: up to 13 months (or such shorter period required by applicable law or set by the relevant analytics provider).
  • Consent preference cookies: up to 12 months, to remember your choices without requiring re-consent on each visit.

Actual cookie durations may vary and are subject to change. Where a Cookie Preference Center is implemented, current durations are listed there. ALL does not guarantee that any specific cookie will persist for its maximum indicated duration and may delete or update cookies at any time.

7.1 EU / EEA (ePrivacy Directive and GDPR)

Under the EU ePrivacy Directive and the GDPR, ALL obtains prior, informed, and freely given consent before placing non-essential cookies on your device. Consent is collected through a cookie consent mechanism on your first visit. You may withdraw consent at any time through the Cookie Preference Center or your browser settings. Strictly necessary cookies do not require consent.

7.2 United Kingdom (PECR and UK GDPR)

ALL applies the same consent standard described in §7.1 to users in the United Kingdom, in compliance with PECR and the UK GDPR.

7.3 California (CCPA / CPRA)

ALL does not currently use third-party behavioural advertising or retargeting cookies and does not currently share personal information for cross-context behavioural advertising. If this changes, ALL will provide a Do Not Sell or Share My Personal Information mechanism in accordance with CCPA/CPRA. Certain uses of analytics cookies may constitute "sharing" under California law; where required, ALL will address this through the applicable consent mechanism or opt-out right.

7.4 Panama and Other Jurisdictions

Panama Law No. 81/2019 on Personal Data Protection applies to ALL's processing of personal data. Where other applicable laws impose specific cookie consent requirements, ALL will apply consent mechanisms to the extent required in the relevant jurisdiction. Where no specific cookie consent requirement applies under local law, ALL relies on legitimate interests for non-essential analytics cookies, subject to applicable data protection requirements.

Where ALL uses non-essential cookies in jurisdictions that require prior consent, ALL will provide a cookie consent mechanism or Cookie Preference Center that allows you to accept or reject non-essential cookie categories and to withdraw or modify your consent. Strictly necessary cookies cannot be disabled through the Cookie Preference Center because they are required for core Platform functionality, security, authentication, fraud prevention, consent preference storage, or Platform operation.

Where a Cookie Preference Center is not legally required or not implemented for a specific jurisdiction, you may manage cookies through your browser settings and any provider-specific opt-out tools described in this Policy.

8.2 Browser Settings

Most browsers allow you to block, delete, or receive notifications about cookies. You can typically block all cookies, delete existing cookies, or block third-party cookies while permitting first-party cookies. Blocking cookies may affect Platform functionality. Consult your browser's help documentation for instructions.

8.3 Analytics Opt-Out Tools

Where ALL uses third-party analytics providers on the Platform, opt-out instructions are available on the relevant provider's website or through the Cookie Preference Center where implemented. ALL does not commit to the use of any specific analytics provider and may change providers without individual notice.

8.4 Do Not Track (DNT) and Universal Opt-Out Signals

The Platform does not currently respond to Do Not Track signals due to the absence of a consistent applicable standard. Where required by applicable law, ALL will honor recognized universal opt-out preference signals, such as Global Privacy Control, for applicable sale, sharing, or targeted advertising opt-outs. These signals do not disable strictly necessary cookies or technologies required for security, authentication, fraud prevention, consent storage, or Platform operation. You may also use browser settings, the Cookie Preference Center, or provider-specific opt-out tools to manage cookie preferences.

9. ALL Edge Network — Scope Limitation

Cookies and tracking technologies described in this Policy relate exclusively to your interaction with ALL's own digital properties (website, dashboard, and directly operated interfaces).

ALL does not place cookies on end users of services operated by Business Customers through ALL's edge network infrastructure. ALL's architecture is designed so that ALL does not inspect or intercept traffic content routed through Node Operator devices by Business Customers. If you are an end user of a service provided by a Business Customer that uses ALL's infrastructure, the cookie and privacy policies of that Business Customer apply — not this Policy.

ALL may update this Cookie Policy at any time to reflect changes in the cookies we use, changes in applicable law, or changes in our business practices. The updated Policy will be posted on the Platform website with a new Effective Date and will take effect upon posting, unless a longer notice period is required by applicable law.

For material changes — including the introduction of new categories of non-essential cookies requiring consent — ALL will provide reasonable notice through the Platform or by email to registered account holders. Your continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the changes, to the extent permitted by applicable law. For non-essential cookies introduced after a material change, ALL will seek fresh consent where required.

ALL may add, remove, or change specific cookies, cookie categories, or third-party providers without individual notice, provided the overall category and legal basis described in this Policy remain unchanged.

11. Contact

For questions about this Cookie Policy or our use of cookies, please contact:

All360 Technology S.A.

Republic of Panama

Email: [email protected]

If you are located in the EU/EEA, you may also contact ALL's EU Representative (where appointed), whose details will be published in this Policy upon appointment.

If you are located in the United Kingdom, you may also contact ALL's UK Representative (where appointed), whose details will be published in this Policy upon appointment.

If you are located in Brazil, you may also contact ALL's Encarregado (where appointed), whose details will be published in this Policy upon appointment.

This Cookie Policy forms part of the ALL Legal Pack (ALL-LP-v1.0.0). In the event of conflict between this Cookie Policy and the ALL Privacy Policy, the Privacy Policy prevails for matters relating to personal data processing; this Cookie Policy prevails for matters relating specifically to the use of cookies and similar technologies.