1. Introduction

1.1 About This Policy

The Network Bank Ltd. Co. & The Network Labs Ltd. Co., herein referred to as The Network Bank Group uses cookies and similar tracking technologies on our websites, mobile applications, and platforms (collectively, the "Platform"). The Network Bank Group comprises:

• The Network Bank (The Network Bank Ltd. Co.) - International banking services
• The Network Labs Ltd. Co. - Brokerage and custody services
• Network Clearing LLC - US payment and money services

(Collectively, "we," "us," or "our").

This Cookies Policy explains:

• What cookies are
• How we use cookies
• Types of cookies we use
• Third-party cookies
• How to manage your cookie preferences

1.2 Consent

By using our Platform, you consent to our use of cookies as described in this Cookies Policy, except where your consent is specifically required or where you have opted out. You can manage your cookie preferences at any time as described in Section 6 below.

2. What Are Cookies?

2.1 Definition

Cookies are small text files that are stored on your device (computer, smartphone, tablet) when you visit a website. Cookies allow the website to recognize your device and remember information about your visit, such as your preferences or login status.

2.2 Similar Technologies

In addition to cookies, we use similar technologies, including:

• Web beacons (pixel tags): Small graphic images embedded in web pages or emails that track user behavior
• Local storage objects (LSOs): Data stored locally on your device (e.g., HTML5 local storage, Flash cookies)
• Software Development Kits (SDKs): Tools embedded in mobile applications to collect usage data
• Session replay tools: Technologies that record user interactions with our Platform For simplicity, this policy refers to all these technologies as "cookies."

2.3 Session vs. Persistent Cookies

• Session cookies: Temporary cookies that are deleted when you close your browser. They remember information during a single browsing session.
• Persistent cookies: Cookies that remain on your device for a specified period or until you delete them. They remember information across multiple sessions.

2.4 First-Party vs. Third-Party Cookies

• First-party cookies: Set by us (The Network Bank Group) on our own Platform
• Third-party cookies: Set by external parties (e.g., analytics providers, advertisers) on our Platform

3. How We Use Cookies

We use cookies to:

• Enable core functionality of our Platform (e.g., authentication, security)
• Improve user experience by remembering your preferences
• Analyze Platform usage and performance
• Personalize content and recommendations
• Measure the effectiveness of marketing campaigns
• Prevent fraud and enhance security

4. Types of Cookies We Use

4.1 Strictly Necessary Cookies

Purpose: Essential for the Platform to function properly.

‍Description:

• Enable core features such as login, account access, and secure areas
• Authenticate users and prevent fraudulent use
• Remember security settings and preferences
• Enable payment processing and transaction execution
• Maintain session state

‍Consent: Strictly necessary cookies are essential and do not require your consent. They are automatically enabled.

‍Examples:

• Session IDs
• Authentication tokens
• Security flags
• CSRF (Cross-Site Request Forgery) protection tokens

Lifespan: Typically session cookies (deleted when you close your browser) or short-term persistent cookies.

4.2 Performance and Analytics Cookies

Purpose: Collect information about how you use our Platform to help us improve performance and user experience.

‍Description:

• Track which pages or features are most popular
• Monitor Platform performance (load times, errors)
• Identify navigation patterns and user behavior
• Measure the effectiveness of features or changes
• Conduct A/B testing and experiments

‍Consent: Required in some jurisdictions. You can opt out of performance cookies.

‍Examples:

• Google Analytics
• Hotjar or similar session replay tools
• Custom analytics platforms
• Heatmaps and click tracking

Data Collected:

• Pages visited and time spent
• Click paths and navigation
• Device and browser information
• Geolocation (country/city level)
• Aggregated usage statistics

‍Lifespan: Typically up to 2 years.

4.3 Functionality Cookies

Purpose: Remember your preferences and settings to provide a personalized experience.

‍Description:

• Remember your language preference
• Remember your location or timezone
• Save your display settings (dark mode, currency, layout)
• Remember your choice to accept or decline cookies
• Store items in your watchlist or favorites
• Prefill forms with your information

‍Consent: Required in some jurisdictions. You can opt out, but this may affect functionality.

‍Examples:

• Language preference cookies
• Currency display cookies
• Theme or display mode cookies
• Saved preferences Lifespan: Typically up to 1 year.

4.4 Targeting and Advertising Cookies

Purpose: Deliver personalized advertising and measure the effectiveness of marketing campaigns.

‍Description:

• Track your browsing behavior across websites
• Build a profile of your interests
• Deliver relevant advertisements based on your interests
• Limit the number of times you see an advertisement
• Measure the effectiveness of advertising campaigns
• Conduct retargeting (showing ads for products you viewed) ‍

Consent: Required in most jurisdictions. You can opt out of advertising cookies. ‍

Examples:

• Google Ads / DoubleClick
• Facebook Pixel
• LinkedIn Insight Tag
• Twitter Conversion Tracking
• Retargeting pixels from advertising networks

‍Data Collected:

• Browsing history and activity
• Products or services viewed
• Advertisements clicked
• Conversions and actions taken
• Inferred interests and demographics

‍Lifespan: Typically up to 1-2 years.

‍Note: We do not use advertising cookies unless you provide consent (where required).

4.5 Social Media Cookies

Purpose: Enable integration with social media platforms and track social media interactions.

‍Description:

• Allow you to share content on social media
• Enable social media login (e.g., "Sign in with Google")
• Track social media referrals and engagement
• Display social media content (e.g., embedded posts)

‍Consent: Required in some jurisdictions. You can opt out, but social features may not work.

‍Examples:

• Facebook Social Plugins
• Twitter Widgets
• LinkedIn Share Buttons
• Google Sign-In

‍Data Collected:

• Social media profile information (if you use social login)
• Content you share
• Social interactions (likes, shares, comments)

‍Lifespan: Varies by platform, typically up to 1 year.

5. Third-Party Cookies

5.1 Third-Party Services

We use third-party services that set cookies on our Platform, including:

• Analytics providers: Google Analytics, Mixpanel
• Marketing platforms: Google Ads, Facebook, LinkedIn, Twitter
• Customer support tools: Zendesk
• Payment processors: Stripe, PayPal (may set cookies during payment)
• Content delivery networks (CDNs): Cloudflare, Amazon CloudFront
• Security services: Recaptcha, fraud detection tools

5.2 Third-Party Privacy Policies

Third-party cookies are governed by the privacy policies of those third parties, not by our Privacy Policy or Cookies Policy. We encourage you to review the privacy policies of third-party services:

• Google Privacy Policy: https://policies.google.com/privacy
• Facebook Data Policy: https://www.facebook.com/privacy/explanation
• LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy

5.3 Control Over Third-Party Cookies

You can opt out of third-party cookies through:

• Browser settings (see Section 6.1)
• Third-party opt-out tools (see Section 6.3)
• Cookie consent banner (see Section 6.4)

6. Managing Your Cookie Preferences

6.1 Browser Settings

Most web browsers allow you to control cookies through settings. You can:

• Block all cookies
• Block third-party cookies only
• Delete cookies after each browsing session
• Receive notifications before cookies are set
• ‍How to manage cookies in popular browsers:
  
  • Google Chrome: Settings > Privacy and Security > Cookies and other site data
  • Mozilla Firefox: Settings > Privacy & Security > Cookies and Site Data
  • Safari: Preferences > Privacy > Manage Website Data
  • Microsoft Edge: Settings > Cookies and site permissions > Cookies and site data
  • Opera: Settings > Privacy & Security > Cookies

‍Note: Blocking all cookies may prevent our Platform from functioning properly. Strictly necessary cookies are required for core functionality.

6.2 Mobile Devices

On mobile devices, you can manage cookies through:

• iOS (Safari): Settings > Safari > Block All Cookies
• Android (Chrome): Settings > Site Settings > Cookies
• Mobile apps: May have in-app settings for tracking preferences You can also:
• Reset your advertising ID (iOS: Settings > Privacy > Advertising > Reset Advertising Identifier; Android: Settings > Google > Ads > Reset advertising ID)
• Opt out of personalized advertising (iOS: Settings > Privacy > Advertising > Limit Ad Tracking; Android: Settings > Google > Ads > Opt out of Ads Personalization)

6.3 Third-Party Opt-Out Tools

You can opt out of certain third-party cookies using:

• Network Advertising Initiative (NAI): http://optout.networkadvertising.org/
• Digital Advertising Alliance (DAA): http://optout.aboutads.info/
• European Interactive Digital Advertising Alliance (EDAA): http://www.youronlinechoices.eu/
• Google Ads Settings: https://adssettings.google.com/
• Facebook Ad Preferences: https://www.facebook.com/ads/preferences/

6.4 Cookie Consent Banner

When you first visit our Platform, you will see a cookie consent banner asking for your consent to use certain cookies (e.g., analytics, advertising). You can:

• Accept all cookies
• Reject non-essential cookies
• Customize your preferences by cookie category You can change your cookie preferences at any time by:
• Clicking the "Cookie Settings" link in the footer of our website
• Accessing the cookie preferences tool in your account settings
• Clearing your browser cookies and revisiting the site

6.5 Do Not Track (DNT)

Some browsers support "Do Not Track" (DNT) signals, which request that websites not track your browsing behavior. Our Platform does not currently respond to DNT signals, as there is no industry consensus on how to interpret them. However, you can control tracking through:

• Browser cookie settings
• Third-party opt-out tools
• Our cookie consent banner