Cookie Policy

1About This Cookie Policy

This Cookie Policy explains how ZIRCA SOFTWARE SOLUTIONS - FZCO, operating under the brand name Zirca ("Zirca", "we", "us" or "our"), uses cookies and similar technologies when you access or use our websites, web applications, mobile applications and other online services that link to this Cookie Policy (collectively, the "Services").

Zirca is an AI-powered financial ecosystem designed to bring financial information together into one secure platform. Our Services may allow users to connect financial accounts, track assets and liabilities, monitor investments, analyse transactions, understand their financial position, establish goals and receive AI-powered financial insights.

Because Zirca operates in the financial-data environment, we take a privacy-by-design approach to cookies and similar technologies. We seek to use only those technologies that are reasonably necessary for the operation, security, performance and improvement of the Services.

This Cookie Policy should be read together with Zirca's Privacy Policy and Terms & Conditions.

2What Are Cookies and Similar Technologies?

A cookie is a small text file or similar identifier that may be stored on your computer, smartphone, tablet or other device when you access a website.

Cookies can allow a service to recognise a device, maintain a session, remember preferences, provide security, measure performance and, where permitted, understand how users interact with a service.

Zirca may also use technologies that perform functions similar to cookies, including:

• Local storage
• Session storage
• Software development kits ("SDKs")
• Pixels and tags
• Application identifiers
• Device identifiers
• Authentication tokens
• Session identifiers
• Log files
• Scripts
• Similar storage and access technologies

Where this Policy refers to "cookies", that term includes these similar technologies where appropriate.

3Why Zirca Uses Cookies

Depending on the Service and your choices, Zirca may use cookies and similar technologies for the following purposes:

3.1 Security

To:

• Protect accounts and sessions
• Detect and prevent fraudulent or malicious activity
• Protect against unauthorised access
• Maintain session integrity
• Support multi-factor authentication
• Detect abnormal or suspicious activity
• Prevent abuse
• Protect the Services and our infrastructure

3.2 Authentication and Account Access

To:

• Keep you securely signed in
• Maintain your authenticated session
• Recognise an authenticated device or session where appropriate
• Protect login and account-management functions

3.3 Core Platform Functionality

To enable features that you have requested, including:

• Navigating the Services
• Maintaining application state
• Remembering necessary settings
• Maintaining secure connections
• Delivering requested functionality
• Maintaining service availability

3.4 Preferences

Where enabled, to remember choices such as:

• Language
• Currency
• Display preferences
• Interface settings
• Cookie preferences
• Other settings you choose

3.5 Performance and Reliability

To understand and improve:

• Page and application loading
• System performance
• Service reliability
• Error rates
• Crash rates
• Technical failures
• API performance
• Infrastructure performance

3.6 Analytics

Where permitted and where you have provided the required consent, Zirca may use analytics technologies to understand how users interact with the Services.

This may include information such as:

• Pages or screens viewed
• Features used
• Navigation paths
• Session duration
• Interaction events
• Device and browser information
• Application version
• Approximate geographic region
• Performance information

Analytics information may be aggregated or otherwise de-identified where appropriate.

3.7 Marketing and Attribution

If Zirca introduces marketing or advertising technologies that require consent, Zirca may use them to:

• Measure marketing campaigns
• Attribute visits or registrations
• Measure advertising effectiveness
• Understand which marketing channels generate traffic
• Measure conversions

4Categories of Cookies

Zirca categorises cookies and similar technologies according to their purpose.

The cookies and measurement technologies currently used on the Zirca website are:

5Cookies Used Within the Zirca Financial Platform

Zirca's financial platform is fundamentally different from a conventional advertising or content website.

The core purpose of Zirca is to securely consolidate and analyse a user's financial information.

Accordingly, cookies and similar technologies used within authenticated areas of Zirca are intended primarily to support:

• Authentication
• Security
• Session management
• Platform functionality
• Reliability
• User-selected preferences

Financial information is maintained within Zirca's appropriate application and data infrastructure rather than being intentionally stored in ordinary browser cookies.

6Financial Information and Sensitive Data

Zirca may process highly sensitive financial information through the Services, including information relating to:

• Bank accounts
• Financial accounts
• Transactions
• Investments
• Cryptocurrency holdings
• Assets
• Liabilities
• Income
• Spending
• Financial goals
• Net worth
• Cash flow

Where possible, Zirca will minimise the amount of financial information exposed to client-side storage and use appropriate technical and organisational safeguards.

The processing of financial information is governed primarily by Zirca's Privacy Policy and applicable data-protection requirements.

7Bank and Financial Account Connections

Zirca may allow users to connect supported financial accounts through third-party financial-data providers or regulated open-banking infrastructure.

These connections are separate from Zirca's use of cookies.

Where you connect a financial account, access is established through the applicable connection provider and according to the permissions and authentication process associated with that connection.

Zirca's intended architecture is based on secure, read-only financial-data connections where applicable to the Service.

Zirca does not use cookies to obtain your banking password.

8First-Party and Third-Party Technologies

8.1 First-Party Technologies

First-party cookies are technologies placed by Zirca or by a service operating on Zirca's behalf.

They may support:

• Authentication
• Security
• Preferences
• Platform functionality
• Analytics
• Service performance

8.2 Third-Party Technologies

Zirca may use carefully selected third-party service providers to provide functions such as:

• Analytics
• Application performance monitoring
• Error and crash monitoring
• Security
• Authentication
• Customer support
• Communications
• Infrastructure
• Fraud prevention
• Marketing attribution

Where a third party uses storage or access technologies through Zirca's Services, Zirca will assess the applicable privacy and consent requirements and implement appropriate contractual and technical safeguards.

Where applicable law requires third-party technologies to be disclosed before consent is obtained, Zirca will provide the relevant information through its cookie-management interface.

The actual third parties used by Zirca may change over time as the Services develop.

9Cookie Consent

Where applicable law requires consent for a cookie or similar technology, Zirca will request consent before activating that technology.

Our consent mechanism may allow you to:

• Accept optional technologies
• Reject optional technologies
• Select individual categories
• Change your preferences
• Withdraw previously provided consent

Consent must be voluntary, informed and based on a clear affirmative action where required by applicable law.

For users subject to UK PECR, for example, continuing to browse a website does not constitute valid consent for non-exempt technologies, and non-essential technologies should not be enabled before the required consent has been obtained.

On the Zirca website, the consent banner asks for your choice on analytics cookies and offers Accept and Reject options. Google Analytics is not loaded unless you select Accept.

10Rejecting Cookies

Where consent is required, you may reject optional cookies and similar technologies.

Rejecting optional technologies should not prevent you from accessing core Zirca functionality unless a particular technology is technically necessary to provide the functionality you have requested.

Some functionality may be limited if you disable technologies that are required for that particular functionality.

11Withdrawing or Changing Consent

Where Zirca relies on your consent for cookies or similar technologies, you may withdraw or change your consent at any time.

Zirca will provide an appropriate mechanism through which you can manage your preferences.

Where consent is required, withdrawal should be as easy as giving consent.

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

This approach is consistent with the UAE Personal Data Protection Law, which provides for withdrawal of consent and requires that withdrawal be capable of being exercised easily.

For users subject to UK or EU requirements, Zirca will also provide appropriate mechanisms for withdrawing consent to non-essential storage and access technologies.

On the Zirca website, you can change or withdraw your analytics choice at any time using Cookie Settings, the floating control at the bottom left of every page. If you change your choice from Accept to Reject, the Google Analytics cookies are removed.

12Cookie Preference Centre

Where Zirca operates a cookie preference centre, you may use it to review and modify your choices.

The preference centre may present categories such as:

The precise technologies and categories presented to you may vary depending on the Zirca Service you are using, your jurisdiction and the technologies active at the time.

13Cookie Duration

Cookies may be either:

Session Cookies

These are generally deleted when your browsing session ends or when the relevant session expires.

Persistent Cookies

These remain on your device for a defined period or until you delete them.

Zirca determines retention periods based on the purpose of the technology, security requirements, operational needs and applicable legal requirements.

Zirca does not retain cookies indefinitely where there is no legitimate operational or legal reason to do so.

14Device and Application Technologies

The Zirca mobile application may use technologies that perform functions similar to cookies.

These may include:

• Secure local storage
• Session identifiers
• Application identifiers
• SDKs
• Push-notification tokens
• Device information
• Authentication tokens
• Diagnostic information

Where applicable law regulates these technologies as storage or access technologies, Zirca will apply the appropriate consent and transparency requirements.

The ICO's current guidance expressly recognises that these rules can apply to mobile applications as well as websites.

15Do Not Track and Similar Browser Signals

Some browsers provide privacy signals or "Do Not Track" functionality.

Because browser privacy signals are not implemented consistently across all browsers, devices and legal regimes, Zirca may not treat every such signal as equivalent to withdrawal of consent unless applicable law requires it to do so.

Where Zirca is legally required to recognise a particular privacy signal, Zirca will implement it in accordance with applicable requirements.

On the Zirca website, a Global Privacy Control (GPC) signal is treated as a rejection of analytics cookies. While the signal is active, Google Analytics is not loaded and its cookies are not set.

16Browser Controls

Most browsers allow you to:

• View cookies
• Delete cookies
• Block cookies
• Restrict third-party cookies
• Clear local storage
• Delete browsing data
• Control certain tracking technologies

You should consult your browser or device provider for instructions on managing these settings.

Blocking all cookies may affect the operation of Zirca, particularly authentication and security functionality.

17Legal Basis for Processing

Cookies themselves are technologies; where their use involves processing personal data, that processing must also have an appropriate legal basis under applicable data-protection law.

Depending on the circumstances, Zirca may rely on:

• Consent
• Performance of a contract or steps taken at your request
• Compliance with a legal obligation
• Legitimate interests, where permitted and appropriate
• Protection of rights, security or other legally recognised interests

The legal basis will depend on the specific processing activity and the law applicable to you.

Where consent is required for storing or accessing information on your device, Zirca will obtain the required consent separately from any underlying data-processing legal basis.

18Privacy and Data Protection

Information collected through cookies or similar technologies may constitute personal data.

Where this occurs, Zirca will process that information in accordance with its Privacy Policy and applicable data-protection legislation.

Depending on where you are located, this may include:

• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data
• UK GDPR
• EU GDPR
• Applicable electronic-communications and cookie legislation
• Other applicable local privacy and data-protection laws

The UAE Personal Data Protection Law establishes requirements concerning lawful processing, consent, security, purpose limitation and data-subject rights.

For users in the UK, cookie and similar-technology requirements may arise under PECR alongside UK GDPR requirements.

For users in the EU, the use of cookies and similar technologies may be subject to the ePrivacy framework together with the GDPR where personal data is processed.

19International Data Transfers

Zirca may use technology and service providers located in countries outside your country of residence.

Where personal data collected through cookies or similar technologies is transferred internationally, Zirca will implement applicable safeguards required by relevant data-protection law.

Further information about international transfers is provided in Zirca's Privacy Policy.

20Security

Zirca applies appropriate technical and organisational measures designed to protect information against:

• Unauthorised access
• Unauthorised disclosure
• Loss
• Destruction
• Alteration
• Misuse
• Other unlawful processing

Security measures may include:

• Encryption
• Access controls
• Authentication controls
• Session controls
• Monitoring
• Logging
• Security testing
• Infrastructure protections

No internet-based system can be guaranteed to be completely secure. Zirca therefore continually reviews and improves its security controls as the Services develop.

21Cookies and Zirca's Privacy Principles

Zirca's approach to cookies reflects the broader principles underlying our platform.

Zirca's business model is based on providing financial-management functionality through its subscription plans and is not based on selling users' financial information.

Zirca does not use cookies as a mechanism to sell your financial data.

Zirca's privacy approach is designed around:

• Data minimisation
• Purpose limitation
• Security
• Transparency
• User control
• Responsible use of technology

22Children

Zirca's Services are not intended for individuals who are below the minimum age permitted to use the Services under applicable law.

Zirca does not knowingly use cookies or similar technologies for the purpose of collecting personal information from children in circumstances where such collection is prohibited.

If you believe a child has provided personal information to Zirca inappropriately, please contact us.

23Changes to This Cookie Policy

Zirca may update this Cookie Policy from time to time.

Changes may be required because of:

• Changes to the Services
• New technologies
• New service providers
• Changes to our business model
• Changes to applicable law
• Regulatory guidance
• Security requirements
• Changes to how cookies or similar technologies are used

When we make material changes, we may provide additional notice where required by law.

The "Last Updated" date at the beginning of this Policy indicates when it was most recently revised.

24Your Privacy Rights

Depending on your jurisdiction, you may have rights relating to your personal data, including rights to:

• Access your personal data
• Correct inaccurate information
• Request deletion
• Restrict processing
• Object to certain processing
• Withdraw consent
• Request data portability
• Exercise other rights provided by applicable law

The availability and scope of these rights depend on the law applicable to you.

Please refer to Zirca's Privacy Policy for a complete description of your privacy rights and how to exercise them.

25Regulatory Review

This Cookie Policy is intended to provide clear and comprehensive information about Zirca's use of cookies and similar technologies.

It is designed with reference to applicable privacy and electronic-communications requirements, including the UAE Personal Data Protection Law and, where applicable, the EU and UK privacy frameworks.

Because cookie compliance depends on the actual technologies deployed, their configuration, the identity and role of third-party providers, the jurisdictions in which users are located and the purposes for which information is processed, this Policy must be implemented together with an accurate and current Cookie Inventory and Consent Management Platform (CMP).

If the technologies used by Zirca change, this Policy and the consent mechanism should be reviewed and updated accordingly.

26Important Implementation Principle

This Policy describes categories of technologies rather than claiming that Zirca currently uses every technology described above.

Zirca should maintain an internal cookie and technology register identifying, for every cookie or similar technology:

1. Name
2. Provider
3. First-party or third-party status
4. Technology type
5. Purpose
6. Data collected
7. Whether personal data is processed
8. Whether the technology is strictly necessary
9. Applicable legal basis
10. Whether consent is required
11. Duration
12. Where data is transferred
13. Relevant third-party recipient
14. How the technology can be disabled or withdrawn

The public Cookie Policy should be updated whenever material changes are made to this inventory.

@Contact Details

Website

www.zirca.co

Email

info@zirca.co

Registered Legal Entity

ZIRCA SOFTWARE SOLUTIONS - FZCO

Registered Address

IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates

Licence Number

91222