1. WHAT ARE COOKIES?

Cookies are small text files that websites place on your computer, mobile device or other internet-connected device.

They allow a website to:

• recognise your device;
• remember your preferences;
• maintain login sessions;
• improve security;
• understand how users interact with the website;
• improve performance; and
• provide relevant functionality.

2. WHY FRAMELAPAY USES COOKIES

FrameLaPay uses cookies and similar technologies for several purposes, including:

3. TYPES OF COOKIES WE USE

We may use the following categories.

3.1 Strictly Necessary Cookies

These cookies are required for essential functions of the platform.

They may support:

• login;
• authentication;
• account sessions;
• security;
• fraud prevention;
• transaction functionality;
• load balancing;
• network security;
• form submissions; and
• maintaining user preferences necessary for the service.

4. FUNCTIONAL COOKIES

Functional cookies allow FrameLaPay to remember choices you make.

For example:

• language preference;
• region;
• display settings;
• session preferences;
• interface configuration; and
• other customisation choices.

Disabling these cookies may cause certain features to operate differently.

5. ANALYTICS AND PERFORMANCE COOKIES

These cookies help us understand how users interact with FrameLaPay.

They may collect information such as:

• pages visited;
• time spent on pages;
• navigation patterns;
• browser information;
• device type;
• approximate location;
• referral sources;
• errors;
• performance information; and
• interactions with features.

We may use this information to:

• improve the platform;
• identify technical problems;
• understand user behaviour;
• improve navigation;
• measure performance; and
• develop new features.

6. SECURITY AND FRAUD-PREVENTION TECHNOLOGIES

Because FrameLaPay provides financial and technology services, security technologies are particularly important.

We may use cookies and similar technologies to help:

• identify suspicious activity;
• detect automated attacks;
• prevent account takeover;
• identify unusual device behaviour;
• protect login sessions;
• detect fraud;
• protect transactions; and
• maintain platform security.

These technologies may collect information about:

• device characteristics;
• browser;
• IP address;
• session activity;
• authentication events;
• network information; and
• interaction patterns.

7. MARKETING COOKIES

Where permitted by applicable law and subject to your preferences, FrameLaPay may use marketing cookies to:

• measure advertising campaigns;
• understand marketing performance;
• display relevant advertisements;
• measure conversions;
• limit repeated advertisements; and
• understand how users interact with promotional content.

We will obtain consent where applicable before using non-essential marketing cookies.

8. THIRD-PARTY COOKIES

Some cookies may be placed by third-party service providers.

These providers may assist us with:

• analytics;
• security;
• payment processing;
• customer support;
• fraud detection;
• marketing;
• authentication;
• performance monitoring; and
• other platform functions.

9. PAYMENT AND FINANCIAL SERVICES

Some FrameLaPay services may require cookies or similar technologies to maintain secure sessions and facilitate transactions.

These technologies may be used to:

• maintain authenticated sessions;
• protect payment pages;
• prevent fraudulent transactions;
• maintain transaction continuity; and
• provide secure connections to third-party financial providers.

Where financial services are provided by a third-party regulated institution, that institution may use its own cookies and tracking technologies.

10. AUTHENTICATION COOKIES

Authentication cookies help us recognise that you have successfully logged into your FrameLaPay account.

They may help maintain:

• login sessions;
• authentication status;
• security tokens;
• account preferences; and
• session continuity.

Without appropriate authentication technologies, certain account features may not function.

11. COOKIE DURATION

Cookies may remain on your device for different periods.

The duration of each cookie depends on its purpose.

12. SIMILAR TECHNOLOGIES

FrameLaPay may also use technologies that perform functions similar to cookies.

These may include:

• pixels;
• web beacons;
• SDKs;
• local storage;
• session storage;
• device identifiers;
• software development kits;
• authentication tokens; and
• similar technologies.

These technologies may be governed by the same privacy principles described in this Policy.

13. MOBILE APPLICATIONS

If FrameLaPay provides mobile applications, the applications may use technologies similar to cookies.

These may include:

• mobile SDKs;
• device identifiers;
• authentication tokens;
• analytics technologies;
• crash-reporting technologies;
• security technologies; and
• push-notification identifiers.

You may be able to manage certain permissions through your mobile-device settings.

14. HOW WE USE INFORMATION COLLECTED THROUGH COOKIES

Information collected through cookies may be used to:

• provide our Services;
• authenticate users;
• secure accounts;
• prevent fraud;
• monitor platform performance;
• understand usage;
• personalise services;
• improve user experience;
• troubleshoot problems;
• conduct analytics;
• measure marketing campaigns; and
• comply with legal obligations.

We may combine cookie information with other information we hold about you where permitted by applicable law.

15. PERSONAL INFORMATION

Some cookies may collect information that can identify or reasonably relate to an individual.

We do not treat cookie information as automatically anonymous simply because it is collected through a cookie.

16. YOUR COOKIE CHOICES

Depending on your location, you may be able to control non-essential cookies through our cookie-consent banner or preference centre.

You may be able to:

• accept all cookies;
• reject non-essential cookies;
• customise cookie categories; or
• change your preferences later.

Your choices may vary depending on applicable law.

17. BROWSER CONTROLS

Most modern browsers allow you to control cookies through their settings.

You may be able to:

• block cookies;
• delete cookies;
• receive notifications when cookies are placed;
• restrict third-party cookies; or
• clear stored website data.

18. ESSENTIAL COOKIES CANNOT ALWAYS BE DISABLED

Some cookies are essential to the operation and security of FrameLaPay.

For example, disabling authentication or security cookies could prevent you from:

• logging in;
• accessing your account;
• completing transactions; or
• using certain secure services.

19. DO NOT TRACK SIGNALS

Some browsers offer a "Do Not Track" (DNT) feature.

Because there is currently no universally accepted standard for responding to DNT signals across all technologies and jurisdictions, FrameLaPay may not respond to all DNT signals.

Where legally required, we will honour applicable privacy preferences and signals.

20. THIRD-PARTY WEBSITES

FrameLaPay may contain links to third-party websites.

Once you leave FrameLaPay, the third party may use its own cookies and similar technologies.

21. SOCIAL MEDIA TECHNOLOGIES

If FrameLaPay integrates social-media functionality, third-party platforms may place cookies or similar technologies on your device.

These technologies may allow the third party to:

• measure interactions;
• recognise users;
• personalise content; or
• measure advertising.

The third party's own privacy policy will govern its processing.

22. ANALYTICS SERVICES

FrameLaPay may use third-party analytics services to understand how users interact with the platform.

These services may collect information about:

• page views;
• clicks;
• sessions;
• devices;
• browser types;
• geographic information;
• referral sources; and
• interactions with features.

We may use analytics information to improve our Services.

23. FRAUD AND RISK ANALYTICS

As a financial technology platform, FrameLaPay may use advanced analytics to detect suspicious behaviour.

Cookie and device information may contribute to:

• fraud detection;
• account-risk assessment;
• bot detection;
• transaction-risk assessment;
• security monitoring; and
• prevention of account takeover.

This information may be combined with other information for security and compliance purposes.

24. ARTIFICIAL INTELLIGENCE AND COOKIES

FrameLaPay may use artificial intelligence and machine-learning technologies to analyse signals collected through cookies and similar technologies.

These systems may help identify:

• unusual behaviour;
• suspicious login activity;
• automated attacks;
• fraudulent patterns;
• abnormal device activity; and
• security threats.

AI systems may support, but do not necessarily replace, human review.

25. COOKIE CONSENT

Where applicable law requires consent, FrameLaPay will request your consent before placing non-essential cookies.

You may withdraw consent at any time through the available cookie-preference mechanisms.

26. DATA PROTECTION

Information collected through cookies is protected in accordance with our security practices.

We may use measures including:

• encryption;
• access controls;
• authentication;
• monitoring;
• secure infrastructure;
• logging;
• vulnerability management; and
• other technical and organisational safeguards.

27. INTERNATIONAL DATA TRANSFERS

Some third-party cookie and technology providers may process information outside your country of residence.

Where required by applicable law, appropriate safeguards will be implemented for international data transfers.

Further information is available in the FrameLaPay Privacy Policy.

28. DATA RETENTION

Cookie information will generally be retained only for as long as necessary for the purposes for which it was collected.

Retention periods may vary depending on:

• cookie type;
• purpose;
• legal requirements;
• security requirements; and
• business needs.

29. CHILDREN

FrameLaPay's Services are not intended for individuals below the applicable minimum legal age.

We do not knowingly use cookies to collect personal information from children in violation of applicable law.

30. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy periodically to reflect:

• technological changes;
• new services;
• changes to cookies;
• changes in applicable law;
• regulatory guidance; or
• changes to our privacy practices.

The Last Updated date will indicate when this Policy was most recently revised.

31. CONTACT US

If you have questions about this Cookie Policy or our use of cookies, contact:

32. RELATED POLICIES

This Cookie Policy should be read together with:

• Terms of Service
• Privacy Policy
• Acceptable Use & Prohibited Activities Policy
• KYC/AML & CFT Policy
• Payment & Transaction Terms
• Refund, Cancellation & Dispute Policy
• Data Processing Agreement