Cookie & Tracking Policy

For purposes of this Policy, "Tracking Technologies" includes, without limitation:

• Cookies: Small text files stored on your device by your browser
• Pixels/Web Beacons: Transparent images that track page views and email opens
• Local Storage: Browser-based data storage mechanisms (localStorage, sessionStorage, IndexedDB)
• Mobile SDKs: Software development kits embedded in our mobile applications
• Device Fingerprinting: Collection of device attributes to create unique identifiers
• ETags/Cache Markers: HTTP cache identifiers that may persist after cookie deletion

This Policy applies to all Tracking Technologies deployed by Nowah or authorized third parties across all platforms where our Services are accessed.

We process data collected through Tracking Technologies under the following legal bases:

• Strictly Necessary: Processing is essential for service delivery and requires no consent under Article 6(1)(b) GDPR and ePrivacy Directive Article 5(3)
• Consent: For non-essential Tracking Technologies, we rely on your affirmative consent under Article 6(1)(a) GDPR
• Legitimate Interest: Where permitted, we may process analytics data under Article 6(1)(f) GDPR to improve our Services

For users in the European Economic Area (EEA), United Kingdom, or jurisdictions requiring prior consent, non-essential Tracking Technologies are activated only upon affirmative opt-in.

Certain Tracking Technologies are deployed by third-party service providers over whom Nowah exercises no direct control. These third parties operate under their own privacy policies, and Nowah disclaims all liability for their data collection and processing practices.

Third-party providers include, but are not limited to:

You may be subject to these third parties' terms and privacy policies when their Tracking Technologies are activated. Nowah is not responsible for the privacy practices or content of third-party services.

You may manage Tracking Technologies through the following mechanisms:

Important: Opt-out mechanisms are cookie-based and must be repeated on each device/browser. Opting out does not delete existing data already collected. Some Tracking Technologies may persist despite opt-out efforts due to technical limitations beyond Nowah's control.

Data collected through Tracking Technologies is retained as follows:

• Session Data: Deleted upon browser/app closure
• Persistent Cookies: Retained for the duration specified in Section 3, unless deleted by user
• Analytics Data: Aggregated and anonymized after 26 months
• Advertising Data: Subject to third-party retention policies

Upon account deletion, we will remove or anonymize data associated with your account within 90 days, except where retention is required by law or for legitimate business purposes (e.g., fraud prevention, legal compliance).

Data collected through Tracking Technologies may be transferred to, stored, and processed in the United States or other jurisdictions where Nowah or its service providers operate. By using our Services, you consent to such transfers.

For transfers from the EEA/UK, we rely on Standard Contractual Clauses approved by the European Commission and/or the UK Information Commissioner's Office. We do not guarantee that all third-party providers maintain equivalent data protection standards.

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

• Nowah disclaims all liability for data collection by third-party Tracking Technologies
• Nowah is not responsible for the effectiveness of browser-based or industry opt-out mechanisms
• Nowah shall not be liable for any technical limitations preventing complete tracking cessation
• Your sole remedy for objection to this Policy is to discontinue use of our Services

Nowah's total liability under this Policy shall not exceed one hundred U.S. dollars ($100.00) in the aggregate.

Some browsers transmit "Do Not Track" (DNT) signals. There is no industry consensus on how to respond to DNT signals. Nowah does not currently respond to DNT signals. This Policy describes our tracking practices regardless of your DNT settings.

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of categories and specific pieces of personal information collected
• Right to Delete: Request deletion of personal information, subject to exceptions
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information
• Right to Non-Discrimination: Not receive discriminatory treatment for exercising privacy rights

To exercise these rights, contact us at [email protected] or submit a request through our Privacy Center. We will verify your identity before processing requests.

Nowah reserves the right to modify this Policy at any time. Changes become effective upon posting to this page with an updated "Effective Date." Your continued use of our Services after any modifications constitutes acceptance of the revised Policy.

We may, but are not obligated to, notify you of material changes via email or in-app notification. It is your responsibility to review this Policy periodically.