1. Scope and Interpretation
This Cookie Policy explains how GENZA Inc. (“GENZA”, “we”, “us”) uses cookies, software development kits, pixels, local storage, device identifiers, and comparable technologies (“Cookies and Similar Technologies”) on the GENZA website, mobile application, and Telegram Mini App (together, the “Service”). It applies to technology that we control or deploy through the Service and does not govern third-party websites, applications, wallets, marketplaces, or app stores that we do not control. Terms capitalized but not defined here have the meanings given in our Privacy Policy and Terms and Conditions. Where this Cookie Policy conflicts with the Privacy Policy on matters of Cookies and Similar Technologies, this Cookie Policy controls; otherwise, the Privacy Policy applies.


2. Technologies Covered
Cookies and Similar Technologies include small text files placed on a browser, software libraries embedded in an app, pixels and beacons that record interactions, local or session storage in a browser or app, device and advertising identifiers provided by operating systems, and server-side logging tied to such identifiers. In the Telegram Mini App, storage and identification may rely on Telegram’s platform mechanisms rather than conventional browser cookies; in native mobile apps, we may use operating system storage and SDK-based telemetry in lieu of cookies.


3. Where These Technologies Operate
On the website, we may set and read first-party cookies and local storage and allow certain approved third parties to set cookies in connection with services they provide to us. In the mobile application, we may use in-app storage, device identifiers, and SDKs that perform functions analogous to cookies. In the Telegram Mini App, we may rely on Telegram’s platform storage and identifiers exposed to mini-apps; where Telegram limits cookie use, our implementation is adapted accordingly. Preferences configured on one surface (web, app, or Mini App) may not automatically propagate to others.


4. Purposes of Use
We use Cookies and Similar Technologies to provide the Service and maintain its security; to enable essential functionality such as authentication, load balancing, fraud detection, and prevention of abuse; to remember preferences and settings; to measure performance, analyze usage, diagnose problems, and improve features; to support limited personalization consistent with our Privacy Policy; and to comply with legal obligations and enforce our Terms. We do not use third-party advertising cookies for cross-context behavioral advertising, and we do not sell or “share” personal information for such advertising as those terms are defined by California law. If our practices change, we will update this Cookie Policy in advance and obtain any consents required by law.


5. Legal Bases and Compliance
In jurisdictions applying the GDPR/UK GDPR and the ePrivacy rules, strictly necessary Cookies and Similar Technologies are used on the basis of our legitimate interests in providing and securing the Service and in performing a contract with you, while non-essential technologies (such as analytics not strictly necessary) are used only with your prior consent. In other jurisdictions, we deploy Cookies and Similar Technologies in accordance with applicable law and, where consent is required, only after obtaining it. Records of consent and preference signals are maintained to the extent required by law.


6. Consent and Preference Management
Where required, a consent interface is presented before non-essential technologies are set. You may at any time withdraw or modify your choices through the “Cookie Settings” or equivalent control made available on the website and, where feasible, within the mobile app. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. Because the Telegram Mini App may rely on Telegram’s storage and consent framework, cookie-banner controls may not appear in that environment; where Telegram exposes consent controls, we honor them, and where it does not, we limit processing to what is strictly necessary to operate the Mini App.


7. Browser, Device, and Platform Controls
You may configure your browser to block or delete cookies and manage site data; you may limit analytics and diagnostic collection at the browser or operating system level; you may reset mobile advertising identifiers or limit ad tracking in your device settings. Doing so may degrade functionality or prevent access to portions of the Service that rely on strictly necessary technologies. Preferences set at the browser or device level are environment-specific and may not affect use of the Telegram Mini App.


8. Global Privacy Control and Do Not Track
Where the law requires recognition of Global Privacy Control or similar opt-out signals, we honor those signals in the contexts to which they legally apply. Traditional “Do Not Track” signals are not standardized and may not be acted upon; this does not affect your ability to exercise any opt-out or consent choices provided by law or this Cookie Policy.


9. Third Parties and International Transfers
We may permit approved service providers to deploy Cookies and Similar Technologies on our behalf for hosting and content delivery, security and anti-fraud, analytics and diagnostics, crash reporting, message delivery, and similar operational purposes. These providers process data under our instructions pursuant to appropriate data-processing agreements; some may process data in countries other than yours, including the United States. Where required for users in the EEA/UK/Switzerland, international transfers are subject to Standard Contractual Clauses (with applicable addenda) and appropriate technical and organizational safeguards. Third parties that act as independent controllers, such as Telegram, Apple, and Google, may set or read identifiers within their ecosystems under their own policies; we do not control their practices.


10. Retention and Expiry
Cookies set in a browser may expire at the end of a session or persist for a defined period; analytics and preference cookies, where used with consent, are typically configured to expire no later than thirteen months from the time of last use unless a shorter duration is warranted. Local storage and SDK identifiers in apps may persist until you clear the app’s data or uninstall the app. Consent records and withdrawal logs are retained for the period required by law or, if longer, for up to twenty-four months to demonstrate compliance. Server logs associated with Cookie-based identifiers are retained in accordance with the retention practices described in our Privacy Policy.


11. Children and Age Restrictions
The Service is intended solely for individuals eighteen years of age or older. We do not knowingly place or use Cookies and Similar Technologies to collect personal information from children under thirteen. If you believe a minor has engaged with the Service in a manner resulting in collection contrary to this Policy, contact us and we will take appropriate steps.


12. Relationship to the Privacy Policy
This Cookie Policy forms part of, and should be read together with, our Privacy Policy. That Policy provides additional information about how we process personal data, our legal bases, your rights, international transfers, security, and contact details. If you require more detail about how data collected via Cookies and Similar Technologies is handled, refer to the Privacy Policy.


13. Updates to this Cookie Policy
We may amend this Cookie Policy from time to time. Material changes will be announced at least thirty days in advance through an in-Service notice and/or by email where available and will take effect on the stated effective date. Continued use of the Service after that date signifies acceptance of the updated Cookie Policy.


14. Contact
Questions or requests concerning this Cookie Policy or your choices regarding Cookies and Similar Technologies may be sent to: GENZA Inc., 1201 N. Orange Street Suite 7587, Wilmington, DE, USA, zip code 19801-1186; email: compliance@genza.io. Where required by law, we will publish the contact details of our EU/UK representative.