COOKIES POLICY

IDEOGEN Group GmbH Version 2.0 | March 2026

Table of Contents

  • What Are Cookies?
  • How We Use Cookies
  • Cookies Used on This Website
  • Cookie Categories Explained
  • Your Consent and How to Manage It
  • How to Manage and Delete Cookies
  • Third-Party Cookies and Services
  • Do Not Track (DNT)
  • Updates to This Policy
  • Cookie Consent Banner — Technical Implementation Note
  • Contact

1. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, or smartphone) when you visit a website. They are stored in your web browser and retrieved on subsequent visits to the same website, allowing the site to recognise your device and remember certain information about your preferences or browsing session.

In addition to traditional cookies, we may use related tracking technologies, including:

  • Web beacons / pixels: Transparent image files embedded in web pages or emails that register whether a page has been opened or an email read.
  • Local storage: A web browser feature that stores data locally on your device without an expiry date (used, for example, to remember language preferences).
  • Session storage: Similar to local storage but cleared when the browser tab is closed.

This Cookie Policy applies to all of the above technologies and to their use on www.ideogen.com and the IDEOGEN Partner Platform. It should be read alongside our Privacy Policy.

2. How We Use Cookies

We use cookies and similar technologies for the following purposes:

  • Ensuring the website functions correctly — certain cookies are technically essential and cannot be disabled without affecting how the site works;
  • Remembering your preferences — such as your language selection (EN/FR/DE/IT) and cookie consent choice;
  • Measuring and analysing website usage — to understand how visitors interact with our content so we can improve user experience;
  • Supporting the Partner Platform — maintaining authenticated sessions for logged-in partners;
  • Complying with our legal obligations — recording and evidencing your consent choices in accordance with Swiss nFADP requirements.

We do not use cookies for the following purposes: advertising profiling, behavioural targeting for third-party advertising, or the placement of persistent cross-site tracking cookies.

3. Cookies Used on This Website

The following table lists all cookies currently placed by or on behalf of IDEOGEN on www.ideogen.com and the Partner Platform, as of the effective date of this Policy.

> Note: The exact list of cookies may change with software updates. The authoritative, live list of cookies is maintained within our Consent Management Platform (CMP) and accessible at any time via the "Cookie Settings" link in the footer of www.ideogen.com. We will update this Policy to reflect material changes within 30 days of their introduction.

4. Cookie Categories Explained

We classify our cookies into four categories. Whether your consent is required depends on the category:

4.1 Strictly Necessary Cookies

What they are: Cookies that are essential for the website to operate and for core security functions. Without these cookies, services you have explicitly requested (such as logging into the Partner Platform or submitting a contact form) cannot be delivered.

Consent required? No. Strictly necessary cookies do not require your consent under Recital 25 of the (2002/58/EC), and Swiss nFADP provisions. They are placed automatically when you visit the site.

Examples: Session cookie, CSRF protection token, consent preference record.

4.2 Functional Cookies

What they are: Cookies that enhance the functionality and personalisation of the website but are not strictly necessary for its operation. They remember choices you make (such as your preferred language).

Consent required? Yes. Functional cookies that are not strictly necessary for a service you have explicitly requested require your prior consent under the ePrivacy Directive and GDPR Article 6(1)(a). Under the Swiss 's guidance of February 2025, an opt-in approach is the recommended standard for functional cookies in Switzerland.

Examples: Language preference cookie (`ideogen_lang`), Partner Platform display preferences.

4.3 Analytics Cookies

What they are: Cookies used to collect information about how visitors use our website, which pages are visited most, and where users come from. This information is used in aggregate to improve our website and content. Analytics cookies identify individual browsers but do not identify individual persons by name.

Consent required? Yes. Analytics cookies that involve the transmission of data to third parties (such as Google) or that track behaviour over time require your prior consent under GDPR Article 6(1)(a), the ePrivacy Directive, and the FDPIC's February 2025 guidance on cookies. Analytics cookies will not be placed until you have provided valid consent via our CMP banner.

Examples: Google Analytics cookies (`ga`, `gid`, `gat`, `ga_[id]`).

4.4 Marketing / Targeting Cookies

What they are: Cookies used to track visitors across websites to display relevant advertisements, or to build profiles for direct marketing purposes.

Consent required? Yes. Marketing cookies require explicit opt-in consent under GDPR Article 6(1)(a) and the ePrivacy Directive.

Current status: As of the date of this Policy, IDEOGEN does not place marketing or advertising cookies on www.ideogen.com. If we introduce such cookies in the future, we will update this Policy, update our CMP configuration, and request your consent before any such cookies are placed.

5. Your Consent and How to Manage It

5.1 Our Consent Mechanism

When you first visit www.ideogen.com, a Cookie Consent Banner is displayed. The banner:

  • Clearly identifies the categories of cookies used and their purposes;
  • Provides a genuine, easy choice between "Accept All", "Reject Non-Essential", and "Customise Settings";
  • Does not use pre-checked boxes or default acceptance for non-essential cookies — in accordance with , Recital 32, and the GDPR and ePrivacy-compliant approach confirmed by the EDPB and the Swiss (guidance, February 2025);
  • Provides an equally prominent "Reject" option alongside "Accept All" — consistent with CJEU case law (Case , *Planet49*) and EDPB guidance;
  • Records the scope and timestamp of your consent for our records.

Only strictly necessary cookies are placed before you interact with the consent banner.

5.2 Granular Opt-In

The "Customise Settings" option allows you to accept or reject individual cookie categories (functional, analytics, marketing) independently. You are not required to accept any non-essential category in order to access the website.

5.3 Geolocation-Based Approach

Our CMP is configured to detect your geographic location:

  • EU/EEA visitors: Full opt-in consent is required for all non-essential cookies, in compliance with the and GDPR.
  • Swiss visitors: Full opt-in consent is applied, consistent with the FDPIC's recommended approach in its February 2025 cookie guidance under the nFADP.
  • Other visitors: Opt-in consent is applied as the default standard across our website.

5.4 Withdrawing or Changing Your Consent

You may update or withdraw your cookie consent at any time by:

  • Clicking the "Cookie Settings" link in the footer of any page on www.ideogen.com;
  • Using your browser settings to delete existing cookies (see Section 6);
  • Contacting us at [email protected].

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, once consent is withdrawn, the relevant cookies will not be re-set on future visits.

5.5 Consent Records

We maintain records of consent in accordance with GDPR Article 7(1) and nFADP requirements. Consent records include: the date and time consent was given, the version of the notice presented, the categories consented to, and (where technically required) the applicable user identifier or session reference. These records are retained for 3 years.

6. How to Manage and Delete Cookies

In addition to our CMP controls, you can manage cookies directly through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

6.1 Google Chrome

  • Open Chrome and click the three-dot menu () in the top right.
  • Select Settings > Privacy and security > Cookies and other site data.
  • Choose your preferred setting or click "See all cookies and site data" to delete specific cookies.

Help page: https://support.google.com/chrome/answer/95647

6.2 Mozilla Firefox

  • Open Firefox and click the menu icon () in the top right.
  • Select Settings > Privacy & Security.
  • Under Cookies and Site Data, click "Manage Data" or "Clear Data".

Help page: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

6.3 Apple Safari (macOS)

  • Open Safari and select Safari > Settings (or Preferences) > Privacy.
  • Click "Manage Website Data" to view and delete cookies by site.

Help page: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

6.4 Apple Safari (iOS / iPadOS)

  • Open Settings > Safari.
  • Tap "Clear History and Website Data" (clears all) or "Advanced" > "Website Data" (per-site removal).

Help page: https://support.apple.com/en-gb/HT201265

6.5 Microsoft Edge

  • Open Edge and click the three-dot menu (...) in the top right.
  • Select Settings > Privacy, search, and services > Clear browsing data > Choose what to clear.
  • For persistent blocking: Settings > Cookies and site permissions > Cookies and data stored.

Help page: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

6.2 Opt-Out Tools

For Google Analytics specifically, you may also install the Google Analytics Opt-Out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout

7. Third-Party Cookies and Services

7.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) / Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).

Google Analytics uses cookies (listed in Section 3) to generate reports about website usage. The information generated by the cookie about your use of our website is transmitted to and stored on Google's servers. We have enabled IP anonymisation on our Google Analytics implementation, so that your full IP address is truncated before transmission to Google's servers.

Google processes this data as a data processor under Google's Data Processing Terms and applicable Standard Contractual Clauses. More information: https://policies.google.com/privacy

Google Analytics cookies are placed only with your prior consent via our CMP.

7.2 Embedded Content

Our website does not currently embed third-party content (e.g., YouTube videos, social media widgets) that would set third-party cookies by default. If such content is introduced, this Policy will be updated, and any associated third-party cookies will be subject to your consent.

8. Do Not Track (DNT)

Some browsers include a "Do Not Track" (DNT) feature that transmits a DNT signal to websites you visit. There is currently no legally binding standard that specifies how websites must respond to DNT signals.

Our current position: we do not alter our data collection practices in response to browser DNT signals, as there is no consistent technical standard for their implementation. We instead rely on the granular consent mechanism described in Section 5, which provides you with direct control over non-essential cookies.

We will continue to monitor regulatory and industry developments in this area and update our approach if a recognised standard is established.

9. Updates to This Policy

We review this Cookie Policy periodically and update it when:

  • We add, modify, or remove cookies from our website;
  • The applicable legal requirements or regulatory guidance changes (including updates from the , EDPB, or national supervisory authorities);
  • Our CMP configuration is materially changed.

When we make updates, we will:

  • Revise the "Version" number and "Date" at the top of this Policy;
  • Publish the updated Policy on www.ideogen.com/cookies;
  • Where updates are material and affect your consent choices, reset the CMP consent banner so that you are presented with the updated notice on your next visit.

The current, authoritative version of this Policy is always available at www.ideogen.com/cookies.

10. Cookie Consent Banner — Technical Implementation Note

> This section is addressed to IDEOGEN's technical and compliance teams responsible for website implementation.

10.1 Recommended Consent Management Platform (CMP)

IDEOGEN must implement a Consent Management Platform (CMP) to manage cookie consent in compliance with GDPR Articles 6 and 7, Recital 32, the (2002/58/EC), and the Swiss 's guidance on cookies (February 2025). We recommend one of the following solutions:

All recommended solutions support:

  • IAB Transparency and Consent Framework (TCF) 2.2 compliance;
  • Geo-targeting to display differentiated banners for EU and Swiss visitors;
  • Consent record storage and audit-trail functionality;
  • Multilingual banners (required for EN/FR/DE/IT language variants);
  • Opt-in by default for non-essential cookies (no pre-ticked boxes).

10.2 Required Banner Configuration

The CMP must be configured with the following minimum requirements:

  • Conditional loading: Non-essential JavaScript tags (including Google Analytics gtag.js) must be blocked until consent is obtained. The CMP should use a tag manager integration (e.g., Google Tag Manager with CMP-integrated blocking) to ensure no analytics or functional cookies fire before consent.
  • Equal prominence: The "Accept All" and "Reject All" buttons must be equally prominent in terms of size, colour, and position. The "Reject All" button must not be visually suppressed.
  • Geo-targeting rules:
  • EU/EEA visitors (detected by IP geolocation): Opt-in banner; no non-essential cookies without consent.
  • Swiss visitors: Opt-in banner; opt-in approach per FDPIC guidance (February 2025).
  • All other visitors: Opt-in banner (uniform global standard).
  • Cookie scan frequency: Automated cookie scanning should be scheduled at minimum quarterly to detect new or changed cookies and update the CMP cookie declaration accordingly.
  • Consent record retention: The CMP must retain consent records for a minimum of 3 years, accessible for supervisory authority inspection.
  • Version management: Each material update to the cookie notice must increment the consent version number, triggering re-consent from returning visitors.
  • Language matching: The consent banner must display in the same language as the visitor's selected site language (EN, FR, DE, IT).

10.3 Google Tag Manager Integration

Google Analytics and any other analytics or marketing tools must be loaded exclusively via Google Tag Manager (GTM) with CMP-controlled triggers. Tags should be configured to fire only when the applicable consent category is granted. GTM's Consent Mode v2 should be implemented to correctly communicate consent signals to Google's tags.

11. Contact

For questions about this Cookie Policy or to exercise your rights in relation to cookie-based data processing, please contact:

Data Protection Officer [Name to be appointed] [email protected]

IDEOGEN Group GmbH Hurdnerstrasse 119 CH-8640 Hurden SZ Switzerland

You also have the right to lodge a complaint with the ** (FDPIC)** (www.edoeb.admin.ch) or, if you are located in an EU member state, with the relevant national data protection supervisory authority.

This Cookie Policy was last revised in March 2026 (Version 2.0). IDEOGEN Group GmbH, Hurdnerstrasse 119, CH-8640 Hurden SZ, Switzerland.