🍪 COOKIE POLICY

This Cookie Policy explains how Whale Group LTD (operating under the trading name Pumio, hereinafter referred to as the "Company", "we", "us", or "our") uses cookies and similar tracking technologies when you visit our website, utilize our platform, or use the Pumio mobile applications (collectively, the "Services").

We process cookie data in compliance with the UK GDPR and the Privacy and Electronic Communications Regulations (PECR). You can manage your preferences at any time via our interactive cookie banner or your browser settings.

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1. What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, or mobile) by your web browser when you visit a website. They are widely used to make websites work more efficiently, improve user experience, and provide analytical data to the website owners.

2. How Pumio Uses Cookies

Pumio utilizes both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) for the following purposes:

• Strictly Necessary Cookies: These are essential for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of Pumio, navigate the platform, and execute internal transactions or content unlocking.
• Performance and Analytics Cookies: We use third-party analytics tools, primarily Google Analytics (GA4), to collect anonymous information about how creators and users interact with Pumio. This helps us measure traffic, understand user behavior, track conversions, and improve platform performance. All data is processed in accordance with our main Privacy Policy.

• Functional Cookies: These are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by name, and remember your preferences (such as your language or region).
• Payment Architecture & Commercial Cookies: All commercial web transactions, subscriptions, and checkout flows on Pumio are handled by our Merchant of Record, Lemon Squeezy, LLC. Lemon Squeezy deploys its own necessary and functional cookies during the billing process to ensure secure transaction routing, fraud prevention, and accurate tax calculations.

3. Third-Party Cookies on Our Platform

Please note that third parties (including our infrastructure partners, payment processors, and Content Delivery Networks (CDNs) used to host media assets) may also use cookies, over which we have no direct control. These cookies are likely to be analytical, performance, or targeting cookies governed by those respective third parties' privacy policies.

4. Managing and Disabling Cookies

You have the right to choose whether or not to accept non-essential cookies.

• Cookie Consent Banner: Upon your first visit to Pumio, a pop-up banner will request your explicit consent for analytical and functional cookies. Strictly necessary cookies do not require prior consent as the platform cannot technically function without them.
• Browser Settings: You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of Pumio.
• Mobile Settings: On iOS and Android devices, you can manage privacy and tracking permissions within your system settings (such as Apple's App Tracking Transparency framework).

5. Changes to This Policy

We may update this Cookie Policy from time to time to reflect changes in our operational practices or for legal and regulatory reasons. Any changes will be indicated by an updated "Last Updated" date at the top of this page.

6. Contact Us

If you have any questions about our use of cookies, please contact us at:

• Data Controller: Whale Group LTD (Company Number: 17318249)
• Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
• Email: support@pumio.io