COOKIE POLICY

Version: 1.0.0 Effective Date: September 1, 2026 Last Updated: September 2026

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1. INTRODUCTION

This Cookie Policy explains how Devi Devs Technologies S.R.L. ("DeviDevs", "we", "us") uses cookies and similar technologies on ClevMail ("Platform") and our website(s).

This Policy is provided in compliance with:

• Legea nr. 506/2004 Art. 4 alin. (5) (Romania — transposing ePrivacy Directive Art. 5(3))
• Directive 2002/58/EC Art. 5(3) (ePrivacy Directive)
• Regulation (EU) 2016/679 Art. 6(1)(a), Art. 7 (GDPR — consent)
• EDPB Guidelines 05/2020 on consent under Regulation 2016/679
• EDPB Guidelines 2/2023 on the technical scope of Art. 5(3) of the ePrivacy Directive

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2. WHAT ARE COOKIES

Cookies are small text files stored on your device when you visit a website. This Policy also covers similar technologies such as Local Storage and tracking pixels (collectively referred to as "cookies").

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3. CATEGORIES OF COOKIES WE USE

3.1. Strictly Necessary Cookies

These cookies are essential for the Platform to function properly. They cannot be switched off because the Platform would not work without them. These cookies do not require your consent under Legea 506/2004 Art. 4 alin. (5) and ePrivacy Art. 5(3) (exemption for cookies strictly necessary for the provision of a service explicitly requested by the user).

3.2. Functional Cookies

These cookies enable enhanced functionality and personalisation, such as remembering your preferences. These cookies require your consent.

3.3. Analytics

We use Vercel Analytics for privacy-friendly page view analysis. Vercel Analytics does not use cookies or collect personal data.

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4. CONSENT MECHANISM

4.1. Cookie Consent Banner

When you first visit the Platform, a cookie consent banner is displayed. This banner:

• (a) informs you about the use of cookies;
• (b) provides you with the option to Accept All, Reject All (non-essential cookies), or Manage Preferences (granular, per-category selection);
• (c) ensures that the "Reject" option is equally prominent and accessible as the "Accept" option (EDPB Guidelines 05/2020);
• (d) does not use dark patterns, deceptive design, or other techniques to steer your choice.

4.2. No Cookies Before Consent

Non-essential cookies are NOT placed on your device before you have given your consent. Analytics, functional, and marketing cookies are only activated after you explicitly consent to the relevant category.

4.3. Granular Consent

You can choose which categories of cookies to accept. Your choices are respected, and only the cookies in accepted categories are activated.

4.4. Withdrawing Consent

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

• (a) clicking the "Cookie Settings" link available in the footer of every page;
• (b) clearing your browser cookies (this will reset all cookies and trigger a new consent request on your next visit).

Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal (GDPR Art. 7(3)).

4.5. Consent Record

We log your consent choice (accepted/rejected categories, date, and time) as required by GDPR Art. 7(1) for demonstrating that consent was given.

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5. THIRD-PARTY COOKIES

Some cookies on the Platform are placed by third parties. These third parties have their own privacy and cookie policies:

We do not control third-party cookies. Please refer to the respective privacy policies for information about how these providers handle your data.

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6. EMAIL TRACKING TECHNOLOGIES

When emails are sent through the Platform on behalf of our clients (email controllers), the following tracking technologies may be used:

Important:

• These tracking technologies are used by the email controller (our client) under their own privacy policy and legal basis.
• The email controller is responsible for informing their subscribers about email tracking in their own privacy policy.
• DeviDevs processes this engagement data as a data processor on behalf of the email controller.
• Subscribers can prevent open tracking by disabling remote image loading in their email client.

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7. HOW TO MANAGE COOKIES IN YOUR BROWSER

In addition to using our consent banner, you can control cookies through your browser settings:

Note: Blocking or deleting strictly necessary cookies may prevent the Platform from functioning correctly.

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8. CHANGES TO THIS POLICY

We may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our practices. Material changes will be communicated through the Platform (e.g., an updated consent banner) at least thirty (30) days before they take effect.

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9. CONTACT

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

• Email: salut@clevmail.ro
• Address: Aleea Textiliștilor 7, Bl. MY12, Sc. 2, Et. 8, Ap. 63, Sector 3, București

For data protection inquiries, you may also contact ANSPDCP (Romania's Data Protection Authority):

• Website: https://www.dataprotection.ro
• Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336, Bucharest, Romania

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10. LEGAL REFERENCES

• Legea nr. 506/2004 (Romania) — Art. 4 alin. (5)
• Directive 2002/58/EC (ePrivacy) — Art. 5(3)
• Regulation (EU) 2016/679 (GDPR) — Art. 6(1)(a), Art. 7
• EDPB Guidelines 05/2020 on consent
• EDPB Guidelines 2/2023 on the technical scope of Art. 5(3)
• CJEU C-673/17 Planet49 (consent for cookies)

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Document ID: CP-v1.0.0 Classification: Public This document does NOT constitute legal advice and should be reviewed by a qualified legal professional before publication.