Cookie Policy

Effective Date: 1 May 2026

1. Introduction

SHARESHIFT - FZCO ("ShareShift", "we", "our", or "us"), a Freezone Company incorporated in Dubai, UAE (DIEZA License No. 66567), uses cookies and similar tracking technologies on our website (shareshift.io) and platform (app.shareshift.io). This Cookie Policy explains what cookies are, which cookies we use, why we use them, and how you can manage your preferences.

This Cookie Policy should be read alongside our Privacy Policy (available at shareshift.io/legal/privacy). Where personal data is collected through cookies from users in the European Union or European Economic Area, we comply with the EU ePrivacy Directive (2002/58/EC, as amended by 2009/136/EC) and the General Data Protection Regulation (EU) 2016/679 (GDPR). ShareShift is subject to the GDPR by virtue of Article 3(2) (extra-territorial scope), as it offers services to individuals and organisations in the EU/EEA.

2. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, or smartphone) by a website you visit. They are widely used to make websites function efficiently, improve the user experience, and provide reporting information to site operators.

Cookies can be distinguished as follows:

• Session cookies: Temporary files that are deleted automatically when you close your browser.

• Persistent cookies: Files that remain on your device for a set period or until you manually delete them.

• First-party cookies: Set directly by ShareShift from our own domain (shareshift.io or app.shareshift.io).

• Third-party cookies: Set by external services whose features are embedded in our website or platform (e.g., analytics or advertising tools).

3. Similar Technologies We Use

In addition to cookies, ShareShift may use the following technologies:

• Local Storage / Session Storage: Browser-based storage used to retain application state and user interface preferences within app.shareshift.io. This data is not transmitted to third parties.

• Pixel Tags / Web Beacons: Small transparent image files embedded in pages or emails, used to confirm content loading or email open events. Only used with consent where required.

• Server-Side Logging: When you access our services, our servers automatically record technical metadata (IP address, browser type, referring URL, timestamps) for security, fraud prevention, and platform performance monitoring. This is not cookie-based and is covered by our Privacy Policy.

4. Categories of Cookies We Use

4.1 Strictly Necessary Cookies

These cookies are essential to operate our website and platform. They enable core functions such as user authentication, maintaining your session, and security protections (e.g., CSRF prevention). Without these cookies, the Service cannot be delivered.

Strictly necessary cookies do not require your consent under the ePrivacy Directive, as they are technically essential to the service you have requested. We do not use these cookies for any analytics or marketing purpose.

4.2 Functional Cookies

Functional cookies allow us to remember your preferences and personalise your experience — for example, your preferred market view, dashboard layout, or language setting. These cookies are not essential to the basic operation of the Service but significantly improve usability.

Functional cookies require your consent before being placed.

4.3 Analytics Cookies

Analytics cookies help us understand how visitors interact with our website and platform — which pages are visited, how users navigate between features, session duration, and error events. This allows us to identify improvements and prioritise development.

ShareShift uses privacy-respecting, EU-hosted analytics tools that aggregate usage data without tracking individuals across external websites or selling data to third parties. Analytics data is not used for advertising purposes. Analytics cookies require your consent.

4.4 Marketing Cookies

Marketing cookies track browsing behaviour to enable personalised advertising and remarketing. We place marketing cookies only with your explicit, freely given consent. If you do not consent, no marketing cookies will be placed and you will not receive targeted advertising based on your browsing behaviour.

We will update the full list of marketing tools and associated cookies prior to the effective date. Any change to the marketing cookies we use will be reflected in this Policy and in the consent manager.

5. Cookie Inventory

The table below sets out the cookies currently in use on shareshift.io and app.shareshift.io. This inventory is reviewed and updated regularly. The marketing cookie row will be populated upon final tool selection before launch.

For questions about a specific cookie, contact [email protected].

6. Legal Basis for Cookie-Based Processing

Where cookies involve processing personal data of EU/EEA data subjects, we rely on the following legal bases under GDPR:

• Legitimate interests (Article 6(1)(f) GDPR): For strictly necessary cookies required to deliver and secure the Service you have requested (e.g., session management, CSRF protection). Our legitimate interest is to operate a functional and secure platform.

• Consent (Article 6(1)(a) GDPR): For all non-essential cookies — functional, analytics, and marketing. Consent is obtained via our cookie consent banner before any such cookies are placed. Consent is freely given, specific, informed, and unambiguous, as required by the GDPR and the ePrivacy Directive. You may withdraw consent at any time without detriment.

For users located outside the EU/EEA, cookie use is governed by applicable local data protection law and our Privacy Policy.

7. Your Cookie Choices and Controls

7.1 Cookie Consent Banner

When you first visit shareshift.io or app.shareshift.io, a cookie consent banner will appear. You can choose to:

• Accept all cookies: All categories will be placed on your device.

• Accept necessary only: Only strictly necessary cookies will be placed.

• Customise preferences: Select individual categories (functional, analytics, marketing) you consent to.

Your preferences are stored in a first-party cookie (ss_consent) and respected for up to 12 months, after which we will ask for your consent again.

7.2 Changing or Withdrawing Consent

You can update or withdraw your cookie consent at any time by:

• Clicking the "Cookie Preferences" or "Manage Cookies" link in the footer of any page on shareshift.io or app.shareshift.io;

• Contacting us at [email protected].

Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal. Note that disabling certain cookie categories (particularly functional cookies) may affect platform performance.

7.3 Browser-Level Controls

Most browsers allow you to manage cookies through their settings, including blocking or deleting cookies. Links to guidance for common browsers:

• Google Chrome: support.google.com/chrome/answer/95647

• Mozilla Firefox: support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

• Apple Safari: support.apple.com/guide/safari/manage-cookies-sfri11471

• Microsoft Edge: support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge

Please note: blocking strictly necessary cookies will prevent you from logging in or using the ShareShift platform.

7.4 Opting Out of Analytics

To opt out of analytics specifically, update your preferences in the cookie consent manager (footer link). Where our analytics tool supports a browser-level Do Not Track (DNT) signal, we will honour it.

7.5 Opting Out of Interest-Based Advertising

For marketing and advertising cookies, you may also use the following industry opt-out tools in addition to our consent manager:

• Network Advertising Initiative: optout.networkadvertising.org

• European Interactive Digital Advertising Alliance: youronlinechoices.eu

• Digital Advertising Alliance: optout.aboutads.info

Note: these tools prevent data collected by cookies from being used for targeted advertising, but do not remove the cookies themselves from your device.

8. Third-Party Cookies and Services

Where we integrate third-party services that place their own cookies (e.g., analytics providers, embedded tools), those parties operate under their own privacy and cookie policies, which we encourage you to review. We aim to use only third-party services that commit to GDPR compliance when processing EU/EEA data.

A list of third-party sub-processors and integrated services is maintained at shareshift.io/sub-processors.

9. Cookies and Children

Our website and platform are not directed at individuals under the age of 18. We do not knowingly place cookies on the devices of children. If you believe we have inadvertently done so, please contact [email protected].

10. International Transfers

ShareShift's own cookies and data are processed and stored within the European Union. Where third-party cookie providers transfer data outside the EEA, ShareShift ensures that appropriate safeguards are in place (such as Standard Contractual Clauses approved by the European Commission), consistent with our Privacy Policy.

11. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in the cookies we use, technology developments, or changes in applicable law. Material updates will be communicated via notice on our website and, where appropriate, through the cookie consent banner prompting you to review and re-confirm your preferences. The Effective Date at the top of this document reflects the most recent revision.

12. Contact Us

For questions or concerns regarding this Cookie Policy or our cookie practices, please contact:

SHARESHIFT - FZCO

Email: [email protected]

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

Website: https://shareshift.io/legal/cookies

EU/EEA residents may also contact our EU Representative (details at shareshift.io/legal/privacy) or their local EU supervisory authority.

Last updated: 1 May 2026