Policies

Cookies Policy

This Cookies Policy explains what cookies are, which cookies we use on our website (the "Website"), why we use them, the legal basis for each category of cookies, and how you can control your cookie preferences. This Policy forms part of our Privacy Policy and should be read alongside it.

We are committed to using cookies and similar tracking technologies only in accordance with applicable law, in particular § 25 of the Telekommunikation-Telemedien-Datenschutz-Gesetz (TTDSG) and the General Data Protection Regulation (EU) 2016/679 (GDPR).

1. What Are Cookies?

Cookies are small text files that a website place on your computer or device when you visit it. They allow the website to recognize your device on subsequent visits, to remember your preferences, and to facilitate the functions described below. Cookies can also be used to record how you navigate a website and to analyze usage patterns.

In addition to cookies, we may use similar technologies such as pixel tags (web beacons), local storage (HTML5), and session storage. References to "cookies" in this Policy include all such technologies unless otherwise stated.

2. Legal Basis for Cookies

Under § 25(1) TTDSG, storing information on — or accessing information already stored on — your end device requires your prior, explicit, freely-given, specific, informed, and unambiguous consent, unless one of the limited exceptions in § 25(2) TTDSG applies.

The requirements for valid consent under § 25(1)(2) TTDSG are the same as under Art. 4(11) and Art. 6(1)(a) GDPR. Consent must be given by way of an active, affirmative act — pre-ticked boxes, default opt-in settings, continued use of the Website, or user inactivity do not constitute valid consent. Consent must also be capable of being withheld without detriment, and you must be offered a genuine, equivalent, and equally prominent option to reject non-essential cookies.

The only exceptions from the consent requirement are strictly necessary cookies which are technically indispensable for providing the service you have explicitly requested (§ 25(2)(2) TTDSG). These exceptions are interpreted narrowly; cookies serving analytics, advertising, or commercial purposes do not fall within this exception.

We operate a Consent Management Platform ("CMP") which presents you with a clear, layered, and equal-choice cookie banner when you first visit our Website. You may withdraw your consent at any time with effect for the future by accessing the [Cookie Settings] link in the footer of our Website. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

We bear the burden of demonstrating that valid consent was obtained for each non-essential cookie we use.

3. Categories of Cookies We Use

We categorize our cookies as follows. The cookie table in Section 4 below identifies the specific cookie name, owner, duration, purpose, and applicable legal basis for each cookie.

3.1 Strictly Necessary Cookies

These cookies are essential for the Website to function and to provide the services you have requested. They enable core functions such as page navigation, authentication, session management, and security. They cannot be switched off.

  • Legal basis: § 25(2)(2) TTDSG — no consent required, as these cookies are technically indispensable for providing the service you have explicitly requested.

  • GDPR basis (where personal data is processed): Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interests in operating a secure, functional website).

3.2 Analytics / Performance Cookies

These cookies allow us to count visits and traffic sources, to measure and improve the performance of our Website, and to understand which pages are most and least popular. The information collected is typically aggregated and, where possible, pseudonymised.

  • Legal basis: § 25(1) TTDSG — your prior consent is required before these cookies are set. They are only placed on your device following your active, affirmative acceptance via our CMP.

  • GDPR basis: Art. 6(1)(a) GDPR (consent).

3.3 Targeting / Advertising Cookies

These cookies are set by our advertising partners to build a profile of your interests and to show you relevant advertisements on other websites. They work by uniquely identifying your browser and device. We do not control how third-party advertising partners use the data they collect.

  • Legal basis: § 25(1) TTDSG — your prior consent is required. These cookies are only set following your active, affirmative acceptance.

  • GDPR basis: Art. 6(1)(a) GDPR (consent).

  • Note on third-party data sharing: Where consent is given, data may be shared with multiple third-party vendors. You are informed of the relevant vendors and the scope of data sharing through our CMP.

3.4 Functional / Preference Cookies

These cookies enable enhanced functionality and personalization of the Website, such as remembering your language preference, display settings, or account preferences. They may be set by us or by third-party providers whose services we have incorporated.

  • Legal basis: § 25(1) TTDSG — your prior consent is required for non-essential functional cookies. Strictly necessary functional cookies (e.g., session state) fall under § 25(2)(2) TTDSG.

  • GDPR basis: Art. 6(1)(a) GDPR (consent) for non-essential functional cookies.

3.5 Customer Support and Operational Cookies

These cookies are set up by our customer support and operational tools (e.g., live chat providers, analytics platforms) to enable us to provide customer support services and to ensure the operational integrity of the Website.

  • Legal basis: § 25(1) TTDSG — your prior consent is required for non-essential support cookies.

  • GDPR basis: Art. 6(1)(a) GDPR (consent) or Art. 6(1)(b) GDPR (contract performance) where the cookies are necessary for the provision of a service you have requested.

4. Cookie Table

The following table identifies each cookie currently in use on our Website. Duration values marked "Session" indicate that the cookie is deleted when you close your browser. The legal basis column applies the framework described in Section 3 above.

Cookie Name

Owner / Provider

Duration

Category

Description and Purpose

Legal Basis

SAPISID, APISID, SSID, HSID, SID

Google LLC

2 years

Functional / Targeting

Stores user preferences and account information including preferred language, search result display settings, and SafeSearch filter preference. Also used by Google to link your activity to your Google account for advertising personalisation.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

SIDCC

Google LLC

1 day

Strictly Necessary (Security)

Security cookie protecting user account data from unauthorised access.

§ 25(2)(2) TTDSG; Art. 6(1)(f) GDPR

__Secure-3PSID, __Secure-3PAPISID, __Secure-1PAPISID, __Secure-1PSID

Google LLC

2 years

Targeting / Advertising

Builds a profile of website visitor interests to enable the delivery of relevant and personalised advertisements through cross-site retargeting. Third-party access: Google LLC and its advertising partners.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

__Secure-3PSIDCC, __Secure-1PSIDCC

Google LLC

1 year

Targeting / Advertising

Builds a profile of website visitor interests for the purposes of cross-site retargeting and personalised advertising. Third-party access: Google LLC and its advertising partners.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

NID

Google LLC

6 months

Targeting / Advertising

Stores visitor preferences and personalises advertisements displayed on Google websites and services based on recent searches and interactions. Third-party access: Google LLC.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

_ga

Google LLC

2 years

Analytics / Performance

Google Analytics persistent cookie used to distinguish unique users and to analyse how visitors use the Website. Data collected includes: number of visitors, traffic sources, and pages visited in pseudonymised form. Third-party access: Google LLC (Google Analytics).

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

_gid

Google LLC

1 day

Analytics / Performance

Installed by Google Analytics. Used to store information about how visitors use the Website and to generate analytics reports. Collects data including number of visitors, traffic sources, and pages visited. Third-party access: Google LLC.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

1P_JAR

Google LLC

1 week

Targeting / Advertising

Used to show customised advertisements on Google sites based on recent searches and previous interactions with Google advertising services. Third-party access: Google LLC.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

OTZ

Google LLC

1 month

Targeting / Advertising

Links the activity of website visitors across devices that are logged into the same Google account, enabling cross-device advertising personalisation. Third-party access: Google LLC.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

MUID

Microsoft / Bing Ads

1 year

Targeting / Advertising

Microsoft User Identifier tracking cookie used by Bing Ads to track users across websites and to display targeted advertisements. Third-party access: Microsoft Corporation (Bing Ads).

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

_EDGE_S

Microsoft / Bing

Session

Targeting / Advertising

Used to retarget website visitors via the Bing Ads advertising network and to track visitor behaviour across multiple websites. Third-party access: Microsoft Corporation.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

_uetvid

Microsoft / Bing

1 year

Targeting / Advertising

Used to track visitors across multiple websites in order to present relevant advertisements based on visitor preferences. Third-party access: Microsoft Corporation (Bing Ads).

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

_uetsid

Microsoft / Bing

1 day

Targeting / Advertising

Collects data on visitor behaviour from multiple websites in order to present more relevant advertisements. Also used to limit the frequency with which a visitor is shown the same advertisement ("frequency capping"). Third-party access: Microsoft Corporation.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

fp_token_*, io_token_*

Iovation (TransUnion)

Session

Strictly Necessary (Security / Fraud Prevention)

Used for device analytics and fraud prevention to protect the security and integrity of the platform and to support customer verification. No tracking or advertising purpose.

§ 25(2)(2) TTDSG; Art. 6(1)(f) GDPR (legitimate interest in fraud prevention and platform security)

incap_ses_*, visid_incap_*

Optimove

Session / Persistent

Analytics / Marketing

Used for marketing purposes including campaign management, user segmentation, and customer engagement analytics. Third-party access: Optimove Ltd.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

intercom-id-, intercom-session-

Intercom, Inc.

9 months / Session

Customer Support (Functional)

Used to enable the live chat and customer support functionality provided by Intercom. These cookies are necessary for the delivery of the customer support service you have requested. Third-party access: Intercom, Inc.

§ 25(1) TTDSG; Art. 6(1)(b) GDPR (contract/service delivery) — or Consent where not strictly necessary for a service you have explicitly requested

mp_*_mixpanel

Mixpanel, Inc.

1 year

Analytics / Marketing

Used for product analytics, user behaviour tracking, and marketing purposes including funnel analysis, cohort analysis, and conversion tracking. Third-party access: Mixpanel, Inc.

Consent (§ 25(1) TTDSG; Art. 6(1)(a) GDPR)

Note on durations: Cookie durations are set by the relevant first-party or third-party provider and are subject to change. We will update this table when we become aware of material changes. You may at any time view the cookies currently active on your device through your browser settings.

Note on third-party cookies: Where cookies are set by third-party providers, we are responsible as joint controllers (Art. 26 GDPR) for ensuring that valid consent is obtained prior to enabling those providers to store or access information on your device. Each provider's own privacy policy governs the subsequent processing of data by that provider.

5. How to Manage Your Cookie Preferences

5.1 Our Consent Management Platform (CMP)

When you first visit our Website, you will be presented with our cookie banner, which allows you to:

  • Accept all cookies (including non-essential cookies);

  • Reject all non-essential cookies (while keeping strictly necessary cookies active); or

  • Manage your preferences on a category-by-category or cookie-by-cookie basis.

The rejection option is presented in a form, function, and prominence that is equivalent to the acceptance option, in accordance with § 25(1) TTDSG and Art. 4(11) GDPR. You are not required to accept non-essential cookies in order to access the Website.

You may change your cookie preferences at any time by clicking the [Cookie Settings] link in the footer of our Website. Withdrawing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

5.2 Google Analytics Opt-Out

In addition to managing your preferences through our CMP, you may prevent your data from being collected and used by Google Analytics across all websites by installing the Google Analytics Opt-out Browser Add-on, available at:https://tools.google.com/dlpage/gaoptout

This add-on prevents the Google Analytics JavaScript from sharing information with Google Analytics. It does not affect the use of the Website in any other way.

For further information on Google Analytics and privacy, please see:https://policies.google.com/privacy

5.3 Browser-Level Cookie Controls

You may also restrict, block, or delete cookies at the browser level. Please note that disabling cookies through your browser settings may affect the functionality of our Website. For guidance on managing cookies in your specific browser, please refer to:

Important: Disabling cookies at browser level is distinct from withdrawing consent through our CMP and may not prevent all forms of tracking. For full control over non-essential cookies on our Website, please use the [Cookie Settings] tool.

6. Contact and Communication

Users who contact us through our Website do so at their own discretion. Any personal information provided in the course of such contact will be processed in accordance with our Privacy Policy, which is available at [link to Privacy Policy].

We use information submitted through our Website contact forms to respond to your enquiries, to provide you with information about our services, and, where you have given your express, separately-obtained consent, to subscribe you to our email communications. Subscription to email communications is never a condition of accessing our services and will only occur where this has been made clear to you and your prior affirmative consent has been obtained, in accordance with Art. 6(1)(a) GDPR and the applicable requirements for electronic direct marketing.

Your contact details are not shared with third parties for their own marketing purposes.

7. External Links

Our Website may contain links to external websites that are not operated or controlled by us. We are not responsible for the content, privacy practices, or cookie policies of any external website. We recommend that you review the privacy and cookie policies of any external website you visit.

Clicking on an external link is at your own risk. We accept no liability for any damages or consequences arising from your use of or reliance on any externally linked website.

8. Social Media Platforms

Where we operate accounts or pages on social media platforms (including but not limited to Facebook, X/Twitter, Instagram, and YouTube), any interactions you make on those platforms are subject to the terms of service and privacy policies of the relevant platform. We encourage you to review those policies carefully.

We will never ask you to provide personal or sensitive information through social media platforms. Users wishing to discuss sensitive matters are encouraged to contact us through our primary communication channels (email or telephone).

Our Website may include social sharing buttons that allow you to share content directly from our Website to a social media platform. You are advised that by using these features, the relevant social media platform may track and record the action through your social media account, regardless of whether you are logged in. Use of social sharing buttons is entirely voluntary.

9. Shortened URLs in Social Media

We and our representatives may share shortened URLs through our social media accounts. You are advised to exercise caution before clicking on shortened URLs, as the destination may not always be apparent. Despite our efforts to share only legitimate URLs, we cannot be held liable for any damages or consequences arising from following shortened links published on social media platforms, including where such platforms have been subject to spam or unauthorised access.

10. International Data Transfers

Several of the third-party providers listed in Section 4 are based outside the European Economic Area (EEA), including in the United States. Where cookies or associated tracking technologies result in the transfer of personal data to a third country, we ensure that an appropriate safeguard applies in accordance with Chapter V GDPR. This may include:

  • An adequacy decision adopted by the European Commission (e.g., the EU-US Data Privacy Framework for US-based recipients certified thereunder);

  • Standard Contractual Clauses (SCCs) adopted by the European Commission; or

  • Another applicable mechanism under Art. 46 GDPR.

Details of the applicable transfer mechanism for each provider, where relevant, are available upon request from [privacy@stake.eu ].

11. Updates to This Policy

We may update this Cookies Policy from time to time to reflect changes in our practices, the cookies we use, or applicable law. Material changes will be communicated to you by updating the "Last Updated" date at the top of this page and, where appropriate, by displaying a notice on our Website or through our CMP. We encourage you to review this Policy periodically.

12. Contact Us

If you have any questions about this Cookies Policy, or wish to exercise any rights in relation to personal data processed through our use of cookies, please contact our Data Protection Officer at:

Email: privacy@stake.eu Postal address: [Registered Address]