Cookie Policy

Effective Date: 1 July 2026

Last Updated: 1 July 2026

This Cookie Policy (the “Policy”) explains how IN SPOT SLU, with registered office at Carretera d’Engolasters 27A 2-1, Andorra, tax / registration number L-919089-T (“OXLY,” “Company,” “we,” “us,” or “our”), uses cookies, SDKs, pixels, local storage, and similar technologies on the OXLY platform (the “Platform”).

This Policy applies to:

• oxly.eu;
• related or future domains, including without limitation oxly.eu, oxly.eu, and localized or partner versions operated by us;
• any OXLY mobile application;
• related landing pages, dashboards, booking flows, messaging tools, support flows, and other digital interfaces operated under the OXLY brand.

This Policy should be read together with our Privacy Policy, Terms of Platform Use, and any other applicable Platform policies.

1. What Are Cookies and Similar Technologies?

Cookies are small text files placed on your browser or device when you visit a website. Similar technologies may include:

• software development kits (SDKs) used in mobile apps;
• tracking pixels or tags;
• local storage;
• session storage;
• device identifiers;
• scripts that store or read information on your device.

In this Policy, we use the term “cookies” broadly to refer to cookies and similar technologies unless the context requires otherwise.

2. Why We Use Cookies

We may use cookies and similar technologies for one or more of the following purposes:

• to make the Platform function properly;
• to maintain login sessions;
• to remember user preferences;
• to protect security and prevent fraud;
• to measure performance and usage;
• to improve product functionality;
• to support customer support and troubleshooting;
• to understand how users interact with the Platform;
• to deliver or measure marketing or advertising, where applicable and permitted.

Some cookies are strictly necessary for the operation of the Platform. Others are optional and are used only if you give the relevant consent where required.

3. Categories of Cookies We Use

Depending on the feature set and product version, we may use the following categories of cookies.

3.1 Strictly Necessary Cookies

These cookies are necessary for the Platform to work properly and may include cookies used for:

• session management;
• authentication;
• account login;
• security and fraud prevention;
• load balancing;
• technical service delivery;
• booking flow continuity;
• saving consent preferences.

These cookies cannot usually be switched off through the Platform’s cookie controls because the relevant service may not function properly without them.

3.2 Functional Cookies

These cookies help remember choices you make, such as:

• language settings;
• region or localization preferences;
• interface preferences;
• account-related convenience settings.

3.3 Analytics / Performance Cookies

These cookies help us understand how users interact with the Platform, such as:

• which pages are visited;
• how users move through the product;
• whether errors occur;
• how features perform.

These cookies may be first-party or third-party analytics technologies.

3.4 Advertising / Marketing Cookies

Where applicable, these cookies may be used to:

• measure campaign performance;
• limit the number of times you see an ad;
• help deliver relevant advertising;
• support remarketing or audience measurement;
• measure conversion events.

3.5 Third-Party Cookies

Some cookies may be placed by third-party providers integrated into the Platform, such as:

• analytics providers;
• authentication providers;
• support tools;
• payment-related providers;
• advertising or measurement partners;
• embedded content or social-media tools.

We do not control all third-party cookies directly. Their use may also be governed by the privacy and cookie policies of the relevant third parties.

4. Duration of Cookies

Cookies may remain on your device for different periods of time.

4.1 Session Cookies

These are temporary cookies that are deleted when you close your browser or end your session.

4.2 Persistent Cookies

These remain on your device for a longer period or until they expire or are deleted manually.

The actual lifespan of a cookie may depend on its purpose, technical settings, browser behavior, and the policies of the relevant provider.

5. First-Party and Third-Party Cookies

5.1 First-Party Cookies

These are cookies set directly by OXLY.

5.2 Third-Party Cookies

These are cookies set by a third party through our Platform, such as analytics, payment, identity, support, or advertising partners.

Third-party providers may process information collected through their cookies according to their own privacy notices.

6. Legal Basis and Consent

Where required by applicable law, we will ask for your consent before placing or reading non-essential cookies on your device.

Strictly necessary cookies may be used without consent where they are exclusively technical, security-related, or necessary to provide the service you requested.

For non-essential cookies, we rely on your consent where required. You can choose whether to accept or reject those cookies through our cookie settings tool, banner, or consent management interface.

7. How We Present Cookie Choices

When required, we provide a cookie banner, preferences panel, or similar tool that allows you to:

• accept all relevant optional cookies;
• reject all relevant optional cookies;
• customize your preferences by category, where available;
• revisit and change those choices later.

Where we offer category-based controls, the available categories may include:

• strictly necessary;
• functional;
• analytics;
• advertising / marketing.

Some features or categories may vary depending on the version of the Platform, jurisdiction, and tools enabled at a given time.

8. Withdrawal of Consent

You may withdraw or change your cookie choices at any time by:

• using the cookie settings or privacy settings tool made available on the Platform;
• clicking the persistent cookie preferences link, where available;
• changing your browser settings;
• adjusting your device or app permissions, where relevant.

Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

If you reject or disable certain cookies, some parts of the Platform may function differently or may become unavailable.

9. Browser and Device Controls

Most browsers allow you to manage cookies through browser settings, including by:

• viewing stored cookies;
• deleting cookies;
• blocking cookies;
• limiting certain types of tracking.

For mobile applications, similar controls may be available through:

• device privacy settings;
• ad identifier settings;
• app-level permissions;
• operating system privacy controls.

Please note that blocking all cookies, including necessary cookies, may affect the availability and functionality of the Platform.

10. Information We May Collect Through Cookies

Depending on the technology used, cookies and similar tools may collect information such as:

• IP address;
• device or browser identifiers;
• browser type;
• operating system;
• language preferences;
• pages visited;
• timestamps;
• referring URLs;
• clicks and navigation behavior;
• login/session status;
• app diagnostics and usage events;
• approximate location derived from IP, where applicable.

Some of this information may qualify as personal data under applicable law and will then also be governed by our Privacy Policy.

11. Cookies Used by Third-Party Tools

The Platform may use third-party services that place or read cookies or similar technologies, including services related to:

• analytics;
• authentication;
• fraud prevention;
• hosting and content delivery;
• customer support;
• payment processing;
• marketing and campaign measurement;
• embedded content or social integrations.

Because these tools may change over time, we may update this Policy, our cookie banner, or our cookie tables periodically.

12. Cookie Table

Depending on the final implementation, the Platform may provide a cookie table or cookie center including information such as:

• cookie or tracker name;
• provider;
• purpose;
• category;
• duration;
• whether it is first-party or third-party.

This information may appear in:

• this Policy;
• a layered cookie notice;
• a consent management panel;
• a just-in-time notice;
• a linked cookie preference center.

13. Do Not Track and Similar Signals

Browsers and devices may offer “Do Not Track” or similar privacy signals. Because there is no universally consistent technical standard for such signals across all services and jurisdictions, the Platform may not respond to all such signals in a uniform way unless and until a legally required standard applies.

Where legally required, we will implement the relevant controls or recognition mechanisms accordingly.

14. Contextual Advertising

Where applicable, the Platform may display contextual or non-personalized promotional content that does not depend on tracking your browsing behavior across time or services.

Such contextual content may be shown without using advertising cookies where technically feasible.

15. Children

The Platform is not intended to be used by persons who cannot lawfully enter into binding agreements under applicable law.

We do not knowingly use optional cookies based on unlawfully collected children’s data. If you believe that such data has been provided to us improperly, please contact us.

16. Changes to This Policy

We may update this Policy from time to time to reflect:

• legal or regulatory changes;
• product changes;
• changes in the tools we use;
• changes in cookie categories or providers;
• changes in consent practices.

If we make material changes, we may notify users by:

• updating the Effective Date or Last Updated date;
• posting the updated version on the Platform;
• showing an in-app or on-site notice;
• refreshing the cookie banner or preferences tool;
• using another reasonable communication method.

17. Contact Us

If you have questions about this Cookie Policy or our use of cookies, contact:

IN SPOT SLU

Carretera d’Engolasters 27A 2-1, Andorra

Tax / Registration No.: L-919089-T

Legal contact: a.samoylov@inspot.ad

Support contact: help@oxly.eu

Privacy contact: privacy@oxly.eu