Cookie Policy

Last updated: 2025-12-08

Cookie and Tracking Technologies Policy

1. Purpose and Scope

1.1. This Cookie and Tracking Technologies Policy (“Policy”) explains how INAI SASU (“inAi”, “we”, “us”, “our”) uses cookies and similar tracking technologies on:

• our public websites, including https://www.inai.fr, https://www.inai.world, https://www.pagemind.fr and https://www.emplo.fr, and all associated pages (the “Sites”), and
• our web applications and product interfaces, including, without limitation, the Emplo and PageMind applications accessible from the Sites (the “Apps”).

1.2. This Policy complements our Privacy Policy (also sometimes called our Privacy Notice) and our product‑specific Terms and Conditions (including, in particular, the terms for Emplo and PageMind) available via our Legal Hub. In case of inconsistency, the Privacy Policy governs how we process personal data, and this Policy governs how we use cookies and similar technologies.

1.3. This Policy applies to any visitor or user who accesses the Sites or Apps from any device (computer, smartphone, tablet, etc.), whether as a prospective customer, an Emplo user, a PageMind customer, a partner, or any other visitor.

1.4. This Policy does not apply to:

• third‑party websites or services that may be linked from our Sites or Apps;
• tracking technologies placed independently by third parties on their own domains, even if you access them via our content or links.

Such third parties are responsible for their own cookies and policies. We encourage you to review their privacy and cookie policies separately.

1.5. Once you have set your choices in our cookie banner or cookie settings interface, those choices will govern the placement and use of cookies and similar technologies on your device, as described in this Policy. If you later change your choices, the updated choices will apply from that moment onwards.

1.6. This Policy is provided to comply with applicable information and transparency obligations regarding cookies and similar technologies. It does not, by itself, create any contractual rights or obligations beyond those arising from applicable law and from the contracts and terms that govern your relationship with inAi.

1.7. Where this Policy is made available in several languages, the French‑language version (Politique « Cookies et technologies de suivi ») shall prevail in case of discrepancy, unless otherwise required by mandatory applicable law.

2. Definitions

For the purpose of this Policy:

2.1. “Cookies” are small text files stored on your device (computer, smartphone, tablet, etc.) when you visit a website or use an application. They are widely used to make websites and applications work, or work more efficiently, as well as to provide reporting and personalised services.

2.2. “Similar technologies” include technologies that allow information to be stored or accessed on your device or browser, such as:

• browser local storage and session storage;
• software development kits (SDKs) embedded in our Apps;
• tracking pixels, tags, web beacons and clear GIFs;
• device identifiers and fingerprinting techniques.

Where we refer to “cookies” in this Policy, this should be understood to include similar technologies, unless clearly stated otherwise.

2.3. “First‑party cookies” are cookies set directly by inAi (or on our behalf) when you visit our Sites or use our Apps.

2.4. “Third‑party cookies” are cookies set by domains other than those of inAi, typically by service providers that provide us with analytics, advertising, video hosting, chat tools or other functionalities.

2.5. “Session cookies” are cookies that expire when you close your browser.

2.6. “Persistent cookies” are cookies that remain stored on your device for a defined period or until you delete them via your browser settings.

2.7. “Strictly necessary cookies” (also called “essential cookies”) are cookies that are technically necessary to provide a service you have explicitly requested or to ensure the basic functioning and security of our Sites or Apps (for example, to maintain a logged‑in session, to route traffic across servers, or to remember your cookie choices).

2.8. “Non‑essential cookies” are any cookies that are not strictly necessary, including, for example:

• preference cookies (e.g. language and UI settings that are not strictly required);
• analytics and performance cookies (e.g. measuring traffic and usage to improve our services);
• functional cookies (e.g. enabling certain embedded content or tools);
• marketing and advertising cookies (e.g. measuring conversions, retargeting).

2.9. “Tracking technologies” is a generic term covering both cookies and similar technologies which can be used to collect and process information about you, your device, and your interaction with our Sites or Apps.

2.10. Capitalised terms not defined in this Policy have the meaning given in our Privacy Policy or the relevant product‑specific Terms and Conditions.

3. Controller and Contact Details

3.1. The entity responsible for the use of cookies and tracking technologies on the Sites and Apps, and the processing of personal data associated with them, is:

INAI Société par actions simplifiée à associé unique (SASU) Registered with the RCS Lille Métropole under number 987 977 386 Registered office: 142 rue d’Iéna, apt. 21, 59000 Lille, France Domains: inai.fr, inai.world, pagemind.fr, emplo.fr

3.2. inAi is an EU‑based company and designs its services with the applicable European regulatory and data‑protection framework in mind. We apply similar safeguards across all of our products, including Emplo and PageMind.

3.3. For any questions about this Policy, our use of cookies or how we process your personal data, you may contact us using the contact details indicated in our Privacy Policy and Legal Hub (for example, the dedicated privacy/contact email address).

3.4. Where required by applicable law, inAi appoints a Data Protection Officer or equivalent contact person whose details are provided in the Privacy Policy. You may contact that person for any question relating specifically to data protection and privacy rights.

4. Types of Cookies and Tracking Technologies We Use

We group the cookies and tracking technologies used on our Sites and Apps into several categories. In the detailed cookie table (see Section 8), we provide more information about each specific cookie or tracker, including provider, purpose, and duration.

4.1. Strictly Necessary Cookies

4.1.1. These cookies are essential for the proper functioning of our Sites and Apps and cannot be disabled through our cookie settings interface. Without them, services you have requested may not work correctly.

4.1.2. We use strictly necessary cookies to:

• allow you to navigate between pages and use essential features;
• maintain secure sessions when you log into Emplo, PageMind or other areas that require authentication;
• apply basic security measures (e.g. CSRF protection, rate‑limiting, fraud detection);
• remember your cookie choices so that we do not ask for your consent again on every page;
• ensure proper routing of traffic between our servers and maintain load balancing.

4.1.3. These cookies may be first‑party or, in limited cases, third‑party (for example, where we rely on a third‑party service to provide core security or routing features). In all cases, they are strictly limited to what is technically necessary to provide the service.

4.1.4. Because these cookies are necessary to provide services you have explicitly requested or to ensure the security and basic functionality of our Sites and Apps, they are exempt from the requirement to obtain your prior consent under applicable ePrivacy rules. However, we still describe them in our cookie list for transparency.

4.2. Preference and Settings Cookies

4.2.1. Preference cookies enable us to remember choices you make (such as language, region, or interface options) and to provide enhanced, more personalised features.

4.2.2. Examples of their use include:

• remembering your preferred language on the public website (e.g. French vs. English);
• remembering certain display choices or filters in Emplo or PageMind dashboards, where not strictly necessary for the service;
• remembering that you have already seen certain one‑time informational banners.

4.2.3. Where these cookies are not strictly necessary for the service, we only place them based on your prior consent. You can withdraw this consent at any time via the cookie settings interface or your browser settings.

4.3. Analytics and Performance Cookies

4.3.1. Analytics cookies help us understand how visitors and users interact with our Sites and Apps, so that we can measure and improve performance, usability and reliability.

4.3.2. Subject to your consent, we may use analytics tools to:

• measure traffic and page views on our public website (for example, visits to the Emplo and PageMind product pages);
• understand which features of Emplo and PageMind are used most frequently and where users encounter friction;
• detect recurring technical issues, navigation problems or bottlenecks in our user flows (such as sign‑up or onboarding);
• perform aggregated, anonymised or pseudonymised statistical analyses of usage trends.

4.3.3. Where possible, we endeavour to use privacy‑preserving analytics solutions (for example, tools that support aggregation, IP‑anonymisation or self‑hosting) in order to minimise the amount of personal data processed.

4.3.4. Analytics cookies are never strictly necessary for the basic provision of our services and are therefore only placed with your prior consent. You can accept or refuse analytics cookies independently of other cookie categories.

4.4. Functional Cookies and Tools

4.4.1. Functional cookies and similar technologies enable certain additional features which are not strictly necessary but can improve your experience, for example:

• embedding videos or interactive demos from third‑party platforms;
• enabling support or chat widgets when offered;
• integrating forms or scheduling tools for demos, pilots or partnerships.

4.4.2. These functionalities may rely on third‑party cookies set by the relevant providers. In such cases, the third‑party provider may also process your data for its own purposes as a separate controller, in accordance with its own policies.

4.4.3. We only enable such functional tools that require non‑essential cookies after you have provided your consent in the cookie settings interface. If you refuse or later withdraw consent, some embedded or enhanced content may not be available or may require a separate action from you (for example, clicking to load the content and accept the third party’s cookies).

4.5. A/B Testing and Product Improvement Cookies

4.5.1. From time to time, we may use cookies or similar identifiers to run controlled experiments (A/B tests) on our Sites or Apps. These tests help us decide between alternative designs or flows and improve our products and user experience over time.

4.5.2. In such cases, we may:

• assign your browser or account to a variant group (e.g. “Version A” or “Version B” of a page or step);
• measure how often certain actions occur in each variant (for example, completion of a form or time spent on a step).

4.5.3. Unless the experiment is strictly necessary for the basic functioning of the service (which is rare), we treat A/B testing cookies as non‑essential and require your prior consent.

4.6. Marketing and Advertising Cookies

4.6.1. If and when we run marketing or advertising campaigns, we may use cookies and similar technologies for:

• measuring the effectiveness of digital campaigns (e.g. whether a visitor who came from a particular campaign later requested a demo or signed up);
• managing basic conversion tracking across our marketing channels (e.g. newsletter sign‑ups, pilot requests, Emplo onboarding);

4.6.2. We do not use cookies to create profiles about sensitive categories of data (such as health status, political opinions, or religious beliefs), and we do not sell personal data collected via cookies and similar technologies.

4.6.3. Where we use third‑party advertising or social media platforms (for example, for retargeting campaigns), cookies from those platforms may be placed on your device only after you have explicitly consented to marketing cookies in our cookie settings interface.

4.6.4. Marketing and advertising cookies are always optional and are only activated with your explicit consent, which you can withdraw at any time via the cookie settings interface.

5. Legal Bases and Consent Model

5.1. Our use of cookies and tracking technologies is governed by:

• the EU ePrivacy rules as implemented in the European Union and European Economic Area (EEA), and, where applicable, in other countries whose rules apply to our activities; and
• the EU General Data Protection Regulation (“GDPR”), where cookies or trackers involve the processing of personal data.

5.2. Under these rules, strictly necessary cookies may be used without your prior consent where they are:

• used solely for the purpose of carrying out the transmission of a communication over an electronic communications network; or
• strictly necessary in order for us to provide an online service explicitly requested by you.

5.3. For all other cookies and tracking technologies (including preference, analytics, functional, A/B testing and marketing cookies), we rely on your prior consent before placing or reading them on your device.

5.4. The main legal bases we rely on under GDPR for processing data linked to cookies and tracking technologies are:

• Article 6(1)(b) GDPR – Contract: where processing is necessary to provide the services you request through our Apps (for example, to maintain your authenticated session in Emplo or PageMind).
• Article 6(1)(f) GDPR – Legitimate interests: for strictly necessary cookies and security measures that protect our Sites, Apps and users (for example, preventing abuse and ensuring integrity of sessions), provided these interests are not overridden by your rights and interests.
• Article 6(1)(a) GDPR – Consent: for any non-essential cookies and tracking technologies, such as analytics, functional, A/B testing and marketing cookies, which are only used after you have given your express, informed consent.

5.5. When consent is required:

• it is presented in a clear and understandable way;
• it is given by a clear affirmative action (for example, clicking “Accept all” or activating specific categories in our cookie settings centre);
• it is granular, meaning you can choose to consent to some categories of cookies and not others;
• it is freely given, meaning that refusing non-essential cookies does not prevent you from accessing the core content or services, except where a specific feature strictly depends on such cookies.

5.6. You can withdraw your consent at any time via our cookie settings interface (described in Section 6) without affecting the lawfulness of processing based on consent before its withdrawal.

5.7. Where we process data collected through cookies or tracking technologies based on our legitimate interests, we have balanced those interests against your rights and freedoms, and we consider them proportionate and expected in the context of using our Sites and Apps. You may object to such processing in accordance with our Privacy Policy.

5.8. We do not use data collected via cookies and similar technologies to take decisions about you that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR. In particular, decisions relating to job offers, hiring, contracts or access to our paid services are not based solely on data obtained through cookies or similar tracking technologies.

6. Cookie Banner and Settings Centre

6.1. Initial banner on first visit

6.1.1. When you visit our Sites for the first time, or when your previous choices have expired or been deleted, we display a cookie banner that:

• briefly explains that we use cookies and similar technologies and for what general purposes;

• provides a link to this Policy and to our Privacy Policy;

• offers you three main options:

  • “Accept all” non-essential cookies;
  • “Reject all” non-essential cookies; and
  • “Manage settings” (or equivalent) to choose specific categories.

6.1.2. The “Accept all” and “Reject all” options are presented in a way that is intended to be visually and functionally equivalent (for example, similar size and prominence), so that you are not nudged into giving consent through misleading design or “dark patterns”.

6.1.3. Until you have made a choice, we only place strictly necessary cookies on your device.

6.2. Cookie settings centre

6.2.1. At any time, you can change your cookie preferences via our cookie settings interface, which is accessible:

• from the banner when you first visit; and
• later via a permanent link or icon (for example, “Cookie settings”) on the Sites and, where relevant, within the Apps.

6.2.2. In the settings centre, cookies and trackers are grouped into categories, such as:

• Strictly necessary (pre-activated and not configurable, but described for transparency);
• Preferences / settings;
• Analytics and performance;
• Functional;
• A/B testing and product improvement;
• Marketing and advertising.

6.2.3. For each category, we provide:

• a short description of the purposes;
• information on whether the category is optional or necessary;
• a toggle that you can switch on or off for optional categories.

6.2.4. By default:

• only strictly necessary cookies are activated;
• all other categories are off until you switch them on.

6.2.5. When you confirm your choices (for example, by clicking “Save my preferences”):

• your choices are stored in a consent cookie or equivalent mechanism;
• our systems will apply these choices to future requests from the same browser or device, until they expire, you delete cookies, or you change your settings.

6.3. Duration of consent and renewal

6.3.1. We generally remember your choices regarding non-essential cookies for a limited period that is consistent with applicable guidance from European supervisory authorities. As of the date indicated at the top of this Policy, this period normally does not exceed six (6) months. After that period, or if we make significant changes to the categories or purposes of cookies, we may ask you to confirm or renew your choices.

6.3.2. If you delete cookies or use tools that automatically clear them, our banner will appear again because we no longer have the technical means to remember your previous choices.

6.4. Withdrawing or modifying consent

6.4.1. You can withdraw or modify your consent at any time via the settings centre. Your new choices will apply from that moment onwards and will not affect the processing that took place before you changed your settings.

6.4.2. If you withdraw consent for certain categories (for example, analytics or functional cookies), some features may no longer be available or may function in a degraded manner. This is a direct consequence of your choice, and we cannot guarantee the same experience without those cookies.

6.5. Logged-in users (Emplo, PageMind)

6.5.1. When you access our Apps as a logged-in user (for example, Emplo and PageMind dashboards), we may present a banner or settings centre integrated into the App interface.

6.5.2. In these environments:

• strictly necessary cookies and tokens are required for authentication, security and essential operations (see Section 10);
• analytics or product-improvement tracking that is not strictly necessary is still subject to your consent and follows the same logic as on the public Sites.

7. Browser, Device Settings and Global Privacy Controls

7.1. Browser and device settings

7.1.1. In addition to our cookie banner and settings centre, most web browsers allow you to:

• view which cookies are stored on your device;
• delete existing cookies;
• block cookies from specific sites;
• block third-party cookies;
• configure your browser to reject all or some cookies by default.

7.1.2. You can usually find these settings in your browser’s “Options”, “Settings” or “Preferences” menu. Help pages for common browsers (such as Chrome, Firefox, Safari, Edge, etc.) provide instructions for managing cookies.

7.1.3. If you choose to block or delete cookies via your browser or device settings:

• you may still be able to use our Sites and Apps, but some features may not function correctly;
• we may not be able to remember your preferences or your decision regarding cookies, which can result in our banner being displayed again.

7.1.4. We are not responsible for how your browser or device implements these settings or for any malfunctions resulting from third-party tools or configurations you choose.

7.2. Do Not Track and similar signals

7.2.1. Some browsers offer a “Do Not Track” (DNT) setting. There is currently no common industry standard for how to interpret DNT signals, and our Sites and Apps do not respond to DNT signals in a consistent, automated manner.

7.3. Global Privacy Control (GPC) and equivalent signals

7.3.1. Certain browsers and extensions support Global Privacy Control (GPC) or similar mechanisms designed to signal a user’s preference not to be tracked across websites.

7.3.2. Where technically feasible and appropriate, we treat a valid Global Privacy Control (GPC) signal or equivalent as an indication that you do not wish us to set certain non-essential cookies (in particular, marketing and advertising cookies) on your browser.

7.3.3. If we receive a clear GPC or similar signal that conflicts with a previous choice you made in our cookie settings centre (for example, you had accepted marketing cookies), we will normally apply the more privacy‑protective option for non-essential cookies (for example, by treating the signal as a refusal for marketing cookies) or invite you to reconfirm your preferences.

7.3.4. Because implementation of such signals varies by browser and extension, and there is currently no harmonised legal standard in the EU for their use, we cannot guarantee that we will always correctly receive or interpret them. For this reason, we strongly recommend that you also use our own cookie settings centre to manage your preferences on our Sites and Apps.

7.3.5. Nothing in this section limits your rights under applicable data‑protection law, as described in our Privacy Policy and in Section 13 of this Policy.

8. Detailed Cookie and Tracker List

8.1. For transparency, we maintain an up-to-date list of the main cookies and tracking technologies used on our Sites and Apps. This list is available:

• directly within the cookie settings centre; and/or
• via a link in this Policy (for example, to a “Cookie List” page).

8.2. For each cookie or tracker, we indicate at least:

• Name or identifier of the cookie or tracker;
• Provider (inAi or third party);
• Category (e.g. strictly necessary, preferences, analytics, functional, A/B testing, marketing);
• Purpose (short description of what the cookie is used for);
• Retention period or expiration (session or specific duration);
• Whether it involves data transfers outside the European Economic Area and, if so, on what basis (for example, Standard Contractual Clauses).

8.3. Because the tools and services we use may evolve, the list of cookies and tracking technologies can change over time. We aim to keep the list accurate and up-to-date but cannot guarantee that it reflects every technical change in real time, particularly where third-party providers alter their own cookies.

8.4. When we introduce new cookies or significantly change the purpose, category or retention of existing cookies in a way that is not compatible with your existing consent, we will:

• update the cookie list; and
• where required by law, present you with a new banner or settings prompt so that you can review and update your choices.

8.5. The presence of a cookie or tracker in the list does not necessarily mean it is currently active on your device. Whether a cookie is set or read depends on:

• the type of page or feature you are using (e.g. visiting a marketing page vs. being logged into Emplo); and
• the choices you have made in the cookie settings centre.

9. Third-Party Cookies, Advertising and International Transfers

9.1. Some cookies and tracking technologies on our Sites and Apps are provided by third-party vendors. These may include, for example:

• analytics service providers;
• providers of embedded content (such as video or code hosting);
• providers of chat, support widgets or scheduling tools;
• advertising or marketing platforms, where used.

9.2. These third parties may, in some cases, process data collected via their cookies for their own purposes as independent controllers (for example, to improve their own services, comply with their legal obligations, or compile aggregated statistics). In such cases, their own privacy and cookie policies apply in addition to this Policy.

9.3. We select our third-party providers with care, taking into account:

• their role (processor or independent controller);
• their security and confidentiality practices;
• the locations where they process data;
• the contractual protections they offer, including data-processing agreements and, where relevant, data-transfer safeguards.

9.4. Where third-party cookies or tracking technologies involve transfers of personal data outside the European Economic Area (for example, to service providers based in countries without an adequacy decision), we implement appropriate safeguards as required by applicable law, such as:

• entering into Standard Contractual Clauses with the provider;
• assessing whether additional technical and organisational measures are necessary;
• limiting the scope of data shared and, where possible, using pseudonymisation or aggregation.

9.5. The cookie list or the settings centre indicates, for each third-party cookie or tracker, the identity of the provider and, where appropriate, provides a link to their own privacy or cookie policy so that you can understand how they handle your data.

9.6. When marketing or advertising cookies are used:

• we only activate them after you have consented to the relevant category in our cookie settings centre;
• you can disable them at any time via the same interface;
• your choice may not automatically extend to all interactions you have with the third-party provider outside our Sites or Apps (for example, on other websites where that provider is present), and you may need to manage your preferences directly with the provider or through broader industry tools.

9.7. While we have contractual and technical controls in place, some third-party providers may also act as independent controllers for part of the processing they perform. In those cases, they are responsible for complying with their own legal obligations. To the maximum extent permitted by applicable law, we are not responsible for processing that such third-party providers carry out for their own purposes and outside our documented relationship with them, except where applicable law expressly requires us to share responsibility for such processing. This does not affect any mandatory rights you may have under applicable data‑protection law, nor does it limit any responsibilities we have where we act as a (joint) controller together with those providers.

10. Product-Specific Behaviour: Emplo and PageMind

10.1. Emplo

10.1.1. Emplo is an AI-assisted job-search service provided through our Apps. When you use Emplo, we rely on certain cookies and similar technologies that are strictly necessary to provide the service securely and reliably. For example, we use:

• session cookies and tokens to authenticate you and keep you logged in to your Emplo dashboard;
• security cookies to protect against unauthorised access, abuse or fraudulent use of your account;
• technical cookies to route your requests to the correct backend services and maintain service availability.

10.1.2. These strictly necessary cookies cannot be deactivated via the cookie settings interface, as deactivating them would prevent you from using Emplo. If you do not wish to use such cookies, you must refrain from using Emplo or log out and manage cookies via your browser.

10.1.3. Subject to your consent, we may also use additional, non-essential tracking technologies within Emplo for:

• usage analytics (for example, to understand which steps of the Emplo flow are most used or where users encounter difficulties);
• product improvement and A/B testing (for example, evaluating different onboarding screens or dashboard layouts);
• optional functional tools (for example, in-app help or support widgets).

10.1.4. These non-essential Emplo cookies and trackers follow the same consent logic as on the public Sites:

• they are disabled until you consent to the relevant category;
• you can withdraw consent at any time via the cookie settings interface;
• withdrawing consent may limit our ability to improve Emplo based on your usage, but will not affect essential service functions.

10.1.5. Telemetry or logs strictly required to operate Emplo (for example, server-side logs of when applications are created or sent) are primarily stored on our servers and, where possible, are implemented without relying on third-party cookies.

10.2. PageMind

10.2.1. PageMind is a product that allows users to work with documents, files and AI agents. When you access PageMind, we use strictly necessary cookies and technical mechanisms to:

• authenticate you and maintain your session with the PageMind workspace;
• manage access to projects, branches and resources;
• ensure the security and integrity of operations, including rate-limits and session protection.

10.2.2. As with Emplo, these strictly necessary cookies cannot be disabled without preventing the use of PageMind.

10.2.3. With your consent, we may use non-essential tracking within PageMind, such as:

• analytics to understand how features are used and to prioritise improvements;
• functional cookies or SDKs that enable help, feedback or support modules;
• A/B testing to compare different flows or UI for specific features.

10.2.4. These non-essential PageMind trackers are fully optional and controlled through the same categories and consent mechanisms described in Sections 5 and 6.

10.3. General Disclaimers for Product-Specific Cookies

10.3.1. If you configure your browser or device to block all cookies, including strictly necessary cookies, you may not be able to log in to or use Emplo, PageMind or other secured areas of our Apps. In such cases:

• we cannot guarantee the availability, security or proper functioning of our products; and
• to the maximum extent permitted by applicable law, any malfunction or degraded performance that results solely from your choice to block strictly necessary cookies is outside our responsibility.

10.3.2. You are responsible for:

• keeping your login credentials confidential;
• logging out when using shared or public devices;
• ensuring that any local security, privacy or content-filtering tools you use are compatible with the secure operation of our Apps and do not block strictly necessary cookies or scripts required for basic functionality.

10.3.3. Where your organisation provides you with access to Emplo or PageMind (for example, as an employer or partner), your organisation may have its own responsibilities regarding user information and device management. InAi is not responsible for your organisation’s internal policies or compliance obligations.

11. Children and Special Categories of Data

11.1. Our Sites and Apps, including Emplo and PageMind, are intended primarily for adult users and professional or business use. They are not directed at children below the minimum age required by applicable law in their country of residence to consent to online services.

11.2. We do not knowingly place cookies or use tracking technologies for the purpose of specifically profiling or targeting children. If we become aware that a child’s data is being collected through cookies or similar technologies in a way that is inconsistent with applicable law, we will take reasonable steps to delete such data and, where necessary, disable the relevant account or functionality.

11.3. We do not intend to use cookies or tracking technologies to infer special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation). If, in specific cases, we need to process such data (for example, if you voluntarily provide it in Emplo as part of your CV or job preferences), this processing is covered by our Privacy Policy and not by cookies.

12. Retention and Expiry of Cookies and Related Data

12.1. Cookies and tracking technologies are stored on your device for different periods of time, depending on their type and purpose:

• Session cookies are deleted when you close your browser.
• Persistent cookies remain on your device until they expire or you delete them via your browser or device settings.

12.2. We do not keep cookies or tracking technologies longer than necessary for the purposes for which they are used. In particular:

• strictly necessary cookies are kept only for the duration needed to provide the service or secure your session;
• preference cookies are kept for a limited period that reflects the nature of the preference (for example, language settings may be kept for a moderate period to avoid asking you again too frequently);
• analytics, functional, A/B testing and marketing cookies are kept for limited periods that are consistent with applicable legal and regulatory guidance and, as of the date indicated at the top of this Policy, do not normally exceed thirteen (13) months, after which they are automatically deleted or refreshed.

12.3. The specific retention period for each cookie or tracker is indicated in the detailed cookie list (see Section 8). Where exact retention cannot be expressed as a fixed number of days (for example, when a provider uses a dynamic mechanism), we indicate the typical range or the criterion used to determine the period.

12.4. Data collected through cookies and tracking technologies may be kept beyond the lifetime of the cookie itself, but only for as long as necessary to fulfil the purposes for which it was collected and in accordance with our general data-retention rules described in our Privacy Policy.

12.5. You can delete cookies at any time via your browser or device settings. Doing so may erase preferences and identifiers associated with those cookies (including your cookie choices), which may result in our banner being displayed again and in the loss of certain saved settings.

13. Your Rights and How to Exercise Them

13.1. Depending on the laws applicable to you, you may have various rights regarding your personal data, including data collected via cookies and tracking technologies. These rights typically include:

• the right of access to your personal data;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure (“right to be forgotten”) in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to data portability where legally applicable;
• the right to object to certain processing activities based on legitimate interests;
• the right to withdraw consent at any time, where processing is based on consent.

13.2. You can exercise your right to withdraw consent for cookies at any time via our cookie settings centre, as described in Sections 5 and 6. This will affect the placement and use of non-essential cookies going forward.

13.3. To exercise other rights in relation to personal data collected through cookies and tracking technologies, you may use the contact details provided in our Privacy Policy or Legal Hub. We may ask you to provide certain information to verify your identity before responding to your request.

13.4. You also have the right to lodge a complaint with the competent data protection authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement. Information about how to contact the relevant authority is provided in our Privacy Policy.

13.5. We will handle your requests in accordance with applicable law. Some rights may be subject to conditions or limitations, and in certain cases we may be permitted or required to retain certain data despite your request (for example, for legal, security or accounting reasons). In all cases, we will explain the reasons for our response.

14. Liability and User Responsibilities

14.1. We implement appropriate technical and organisational measures to:

• manage cookies and tracking technologies in a way that is consistent with this Policy;
• protect the confidentiality and integrity of the data processed via such technologies;
• select third-party providers that offer appropriate guarantees with respect to data protection and security.

14.2. To the maximum extent permitted by applicable law, and without limiting any mandatory statutory rights you may have as a consumer, we are not responsible for:

• any malfunction or degraded performance of our Sites or Apps that results solely from your decision to block or delete strictly necessary cookies;
• any consequences arising from misconfiguration of your browser, device or third-party tools that you choose to install (for example, blockers that interfere with essential scripts or security measures);
• independent processing or misuse of your data by third-party providers that goes beyond our documented, lawful instructions and/or outside the scope of our contractual relationship with them, except to the extent that applicable law requires us to share responsibility for such processing.

14.3. You are responsible for:

• keeping your credentials and devices secure;
• logging out from shared or public devices;
• configuring your browser and device settings in a way that reflects your privacy preferences while allowing you to access the services you wish to use;
• reviewing and managing your preferences directly with third-party providers when you interact with their services outside of our Sites and Apps.

14.4. Nothing in this Policy is intended to exclude or limit our liability where such exclusion or limitation would be unlawful, for example in cases of fraud, wilful misconduct, or where mandatory consumer protection rules prohibit it. Any limitations of liability set out in this Policy should be read together with the relevant limitations in our Terms and Conditions and Privacy Policy.

15. Changes to This Policy

15.1. We may update this Cookie and Tracking Technologies Policy from time to time, in particular to:

• reflect changes in applicable law or regulatory guidance;
• reflect changes in the cookies, tracking technologies or services we use;
• improve the clarity and transparency of our explanations.

15.2. When we make changes, we will update the “Last updated” date at the top of this Policy. If we make material changes that significantly affect your rights or the way we use cookies, we will take additional steps to inform you, such as:

• displaying a prominent notice on our Sites or Apps;
• presenting an updated banner or cookie settings prompt;
• contacting you by email if we have your contact details and if the change is relevant to your existing relationship with us.

15.3. Where required by law, we will seek your renewed consent before applying changes that materially affect the categories, purposes or providers of non-essential cookies used on your device.

15.4. Your continued use of our Sites or Apps after a change becomes effective will be subject to the updated Policy. This does not replace or override any requirement to obtain your consent for specific categories of cookies where such consent is mandated by law.

16. Governance and Internal Controls

16.1. The management of cookies and tracking technologies at inAi forms part of our broader data-protection and security governance framework. We maintain internal processes to:

• review and approve the introduction of new cookies, trackers or related tools;
• assess their necessity, proportionality and legal basis;
• verify that appropriate consent mechanisms and disclosures are in place;
• ensure that contracts with third-party providers include required data-protection and security clauses.

16.2. We endeavour to periodically review the cookies and tracking technologies actually present on our Sites and Apps, including, where appropriate, by using technical scanning tools, to check for consistency between:

• what is implemented in practice; and
• what is described in this Policy and the detailed cookie list.

16.3. Where we identify discrepancies, we aim to correct them promptly, either by:

• updating the Policy and cookie list; or
• adjusting our configuration to align with the documented policy and consents.

16.4. Staff involved in product, engineering, marketing, data and compliance activities receive appropriate guidance on when and how cookies and tracking technologies may be used, and on the need to involve privacy and security functions when new tools or providers are considered.

16.5. This Policy should be read together with our Privacy Policy, Terms and Conditions, and security and AI-responsibility information. Together, these documents describe how inAi designs its services, including Emplo and PageMind, to align with applicable European rules on privacy, data protection and responsible use of AI.