SKRAGGLE – COOKIE POLICY

Effective date: 22nd February 2026

  1. INTRODUCTION

This Cookie Policy explains how SKRAGGLE (“SKRAGGLE,” “we,” “us,” or “our”) uses cookies and similar technologies in connection with:

  • The SKRAGGLE website;
  • The SKRAGGLE platform and dashboards;
  • Tracking technologies provided to Customers for deployment on their own digital properties.

This Cookie Policy should be read together with our Privacy Policy.

  1. WHAT ARE COOKIES?

Cookies are small text files placed on a device (computer, tablet, mobile device) when a website is visited. Cookies enable websites and platforms to:

  • Recognize devices;
  • Store preferences;
  • Enable authentication;
  • Collect analytics data;
  • Facilitate secure session management.

In addition to cookies, similar technologies such as pixels, web beacons, SDKs, and server-side tracking mechanisms may be used.

For purposes of this Policy, the term “cookies” includes these similar technologies unless otherwise specified.

  1. TYPES OF COOKIES WE USE ON OUR WEBSITE AND PLATFORM

SKRAGGLE may use the following categories of cookies on its own website and hosted dashboards:

3.1 Strictly Necessary Cookies

These cookies are required for:

  • Website functionality
  • Secure login
  • Session authentication
  • Fraud prevention
  • Load balancing
  • Security monitoring

These cookies cannot be disabled as they are essential to provide the requested services.

Legal basis (EU/UK): Legitimate interests or performance of a contract.

3.2 Functional Cookies

These cookies enable:

  • Remembering user preferences
  • Language settings
  • Interface customization
  • Dashboard configuration retention

Legal basis (EU/UK): Legitimate interests or consent, where required.

3.3 Analytics Cookies

SKRAGGLE may use analytics tools to collect aggregated data about:

  • Page visits
  • Navigation paths
  • Platform performance
  • Error rates
  • Usage metrics

Analytics data is used solely to improve performance, security, and functionality.

Where required by applicable law, analytics cookies are deployed only with user consent.

3.4 Security and Monitoring Technologies

SKRAGGLE may use monitoring technologies to:

  • Detect suspicious activity
  • Prevent fraud
  • Identify abuse or unauthorized access
  • Protect infrastructure

These technologies may include device fingerprinting or IP-based risk assessment where legally permitted.

Legal basis (EU/UK): Legitimate interests in securing the Platform.

  1. COOKIES USED IN THE SKRAGGLE PLATFORM (B2B USERS)

When business users log into the SKRAGGLE dashboard:

  • Authentication cookies maintain secure sessions.
  • Security cookies prevent session hijacking.
  • System performance cookies assist in debugging and performance monitoring.

These cookies are strictly necessary for platform operation.

SKRAGGLE does not use advertising cookies within its authenticated dashboard environment.

  1. TRACKING TECHNOLOGY PROVIDED TO CUSTOMERS

This section is critical for your liability protection.

5.1 Customer-Controlled Tracking Code

SKRAGGLE provides Tracking Code, APIs, server-side integrations, and form-building tools that Customers may deploy on their own websites, applications, or digital properties.

Customers independently determine:

  • Whether to deploy Tracking Code
  • What data is collected
  • Which cookies or identifiers are activated
  • Whether server-side tracking is implemented
  • Retention periods

SKRAGGLE does not independently deploy tracking technologies on third-party websites for its own marketing purposes.

5.2 Controller Responsibility

Where Tracking Code is deployed on a Customer’s website:

  • The Customer acts as data controller;
  • SKRAGGLE acts as data processor;
  • The Customer is responsible for compliance with applicable cookie, ePrivacy, and marketing laws.

This includes responsibility for:

  • Providing cookie notices;
  • Implementing consent banners;
  • Managing consent withdrawal;
  • Establishing lawful bases for processing.

5.3 First-Party Data Model

SKRAGGLE’s tracking technology is designed to support first-party data collection by Customers. Data collected via such deployments is processed solely in accordance with Customer instructions and contractual agreements.

SKRAGGLE does not use such data for independent cross-site behavioral advertising.

5.4 Server-Side Tracking

Where Customers configure server-side tracking, data may be transmitted directly from Customer servers to the SKRAGGLE infrastructure.

Customers remain responsible for ensuring lawful data collection and transparency to their end users.

  1. THIRD-PARTY COOKIES AND INTEGRATIONS

SKRAGGLE may integrate with third-party service providers for:

  • Cloud hosting
  • Infrastructure monitoring
  • Analytics services
  • Payment orchestration routing
  • CRM integrations

Such third parties may place cookies or use similar technologies in accordance with their own privacy policies.

SKRAGGLE does not control third-party cookie practices outside of its direct platform environment.

Customers who integrate third-party services through the Platform are responsible for reviewing and complying with the terms and privacy practices of those providers.

  1. PAYMENT ORCHESTRATION CONTEXT

SKRAGGLE provides payment orchestration functionality that routes transaction requests to independent Payment Providers.

SKRAGGLE does not:

  • Store full cardholder data by default;
  • Set advertising cookies in connection with payment routing;
  • Conduct independent profiling based on transaction data.

Any cookies or tracking technologies deployed by Payment Providers are governed by the policies of those providers.

  1. LEGAL BASES FOR COOKIE USE (EU/UK)

Where applicable under EU or UK law:

  • Strictly necessary cookies are deployed under legitimate interests or contractual necessity.
  • Non-essential cookies (such as analytics cookies) are deployed only where valid consent is obtained.
  • Consent can be withdrawn at any time through applicable consent management mechanisms.

Customers deploying SKRAGGLE Tracking Code on their own digital properties are responsible for establishing the appropriate legal basis for cookie deployment.

  1. HOW TO MANAGE OR DISABLE COOKIES

Users may manage cookies through:

  • Browser settings
  • Device settings
  • Consent management platforms (where implemented)

Disabling certain cookies may affect platform functionality.

Business users accessing the SKRAGGLE dashboard cannot disable strictly necessary authentication cookies.

  1. DATA RETENTION RELATED TO COOKIES

Cookie-related data may be retained for varying periods depending on:

  • Cookie type
  • Platform configuration
  • Customer-defined retention policies
  • Legal obligations

Session cookies expire automatically when a session ends.

Persistent cookies remain for a defined period unless deleted earlier.

Customer-deployed tracking retention is determined by the Customer’s configuration and contractual terms.

  1. INTERNATIONAL DATA TRANSFERS

Cookie-related data may be processed in jurisdictions outside the user’s country of residence.

Where required by applicable law, SKRAGGLE implements appropriate safeguards, including:

  • Standard Contractual Clauses
  • UK Addendum
  • Contractual protections with subprocessors

Customers are responsible for ensuring lawful transfers related to their own Tracking Code deployments.

  1. UPDATES TO THIS COOKIE POLICY

SKRAGGLE may update this Cookie Policy to reflect:

  • Changes in technology
  • Regulatory developments
  • Changes in platform functionality

Updated versions will be published with a revised effective date.

Continued use of the website or Platform after updates constitutes acknowledgment of the revised Policy.

  1. CONTACT INFORMATION

For questions regarding this Cookie Policy:

Email: SUPPORT@SKRAGGLE.COM

EU Entity Address: SUPPORT@SKRAGGLE.COM

U.S. Entity Address: SUPPORT@SKRAGGLE.COM