COOKIE POLICY

1. Introduction

1.1 This Cookie Policy (“Cookie Policy”) explains how LUDENS S.A. (“we”, “us”, “our”) uses cookies and similar technologies when you visit www.marketonline.me, access our digital advertising campaign-management platform, or use any related websites, applications, dashboards, tools, products, or services operated by us collectively referred to as the “Platform” or the “Services”.

1.2 This Cookie Policy should be read together with our Privacy Policy and Terms & Conditions. It provides additional information about:

• what cookies and similar technologies are;
• the types of cookies we may use;
• why we use them;
• how third parties may use cookies through our Platform;
• how long cookies may remain on your device; and
• how you can manage or withdraw your cookie preferences.

1.3 Where cookies or similar technologies collect information that identifies, relates to, describes, or may reasonably be linked to an individual, that information will be treated as Personal Data in accordance with our Privacy Policy and applicable data-protection laws.

1.4 References to “you” or “your” in this Cookie Policy include visitors to our website, Clients, advertisers, agencies, authorised Platform users, and, where relevant, End Users who interact with content or campaigns delivered through the Platform.

2. Who We Are

The Platform and Services are operated by:

LUDENS S.A. provides a digital advertising campaign-management Platform that enables Clients to create, manage, monitor, optimise, and report on advertising campaigns across third-party advertising networks and publishing platforms.

3. What Are Cookies?

3.1 Cookies are small text files containing information that is stored on your computer, smartphone, tablet, or other device when you visit a website or use an online service.

3.2 Cookies allow websites and online services to recognise a device, remember user actions or preferences, maintain authenticated sessions, protect accounts, measure website performance, and provide relevant functionality.

3.3 Cookies may contain or generate information such as:

• a randomly generated identifier;
• session information;
• browser and device information;
• language or display preferences;
• authentication status;
• pages viewed and features used;
• timestamps and interaction information;
• referral-source information;
• advertising or campaign identifiers; and
• approximate location derived from an IP address.

3.4 Cookies do not necessarily identify you directly by name. However, cookie identifiers and related information may constitute Personal Data when they identify or can be linked to an individual or device.

4. Similar Technologies

4.1 In addition to cookies, we and our service providers may use other technologies that perform similar functions, including:

• tracking pixels or web beacons;
• software development kits;
• tags and scripts;
• local storage and session storage;
• browser cache technologies;
• device or browser identifiers;
• server-side tracking technologies;
• conversion-tracking technologies;
• embedded content and plug-ins; and
• application programming interfaces used to transmit measurement or event data.

4.2 References to “cookies” in this Cookie Policy include these similar technologies unless the context requires otherwise.

5. First-Party and Third-Party Cookies

5.1 First-party cookies

First-party cookies are placed directly by LUDENS S.A. through the Platform or Services. We may use first-party cookies to operate the Platform, authenticate users, maintain sessions, remember settings, protect accounts, analyse usage, or manage cookie preferences.

5.2 Third-party cookies

Third-party cookies are placed or controlled by organisations other than LUDENS S.A. These may include hosting providers, security providers, analytics companies, payment-service providers, customer-support tools, embedded-content providers, or Ad-Networks.

Third parties may use information collected through their cookies in accordance with their own privacy and cookie policies. We do not control the duration, operation, or subsequent use of information collected directly by third-party cookies.

6. Session and Persistent Cookies

6.1 Cookies may be either session cookies or persistent cookies.

6.2 Session cookies

Session cookies are temporary and are generally deleted when you close your browser or end your Platform session. They may be used to:

• maintain your authenticated session;
• enable navigation between pages;
• preserve temporary Platform settings;
• process forms or requests; and
• help prevent unauthorised access.

6.3 Persistent cookies

Persistent cookies remain on your device after you close your browser, until they expire or are deleted manually. They may be used to:

• remember your preferences;
• recognise returning devices;
• retain cookie-consent choices;
• measure usage over time;
• support security and fraud prevention; and
• perform analytics or advertising measurement where permitted.

7. Categories of Cookies We Use

Depending on the part of the Platform you access, your location, your consent choices, and the Services enabled at the relevant time, we may use the following categories of cookies.

7.1 Strictly Necessary Cookies

Strictly Necessary Cookies are required for the Platform or Services to function securely and correctly. Without these cookies, certain Services cannot be provided.

They may be used to:

• authenticate users and maintain login sessions;
• remember security or privacy settings;
• prevent fraudulent, malicious, or unauthorised activity;
• distribute traffic and maintain Platform stability;
• enable account, billing, or campaign-management functions;
• process forms and user requests;
• remember items or actions during a session;
• record cookie-consent preferences; and
• comply with security or legal requirements.

These cookies do not ordinarily require consent where they are strictly necessary to provide a service expressly requested by the user. They cannot generally be disabled through our cookie-preference tool, although they may be blocked through your browser. Blocking them may prevent the Platform from operating correctly.

7.2 Functional or Preference Cookies

Functional Cookies allow the Platform to remember choices you make and provide enhanced or more personalised functionality.

They may be used to remember:

• language preferences;
• time zone or regional settings;
• display and interface preferences;
• previously selected Platform options;
• saved filters or dashboard configurations; and
• customer-support or communication preferences.

If these cookies are disabled, some personalised or enhanced features may not function correctly.

7.3 Analytics and Performance Cookies

Analytics and Performance Cookies help us understand how visitors and authorised users interact with the Platform.

They may collect information about:

• pages or screens visited;
• features used;
• navigation paths;
• visit duration;
• clicks, scrolls, and other interactions;
• browser and device characteristics;
• referral sources;
• errors, failures, and loading times;
• aggregated usage patterns; and
• Platform or campaign-management performance.

We use this information to measure traffic, understand user behaviour, diagnose technical problems, improve usability, assess the effectiveness of Platform features, and develop aggregated or anonymised statistics.

Where required by applicable law, Analytics and Performance Cookies will only be activated after you provide consent.

7.4 Advertising and Targeting Cookies

Advertising and Targeting Cookies may be used to measure, attribute, personalise, limit, or optimise advertising.

They may be used to:

• measure impressions, clicks, and conversions;
• determine whether an advertisement resulted in an action;
• prevent the same advertisement from being shown excessively;
• build or use interest-based audience segments;
• support retargeting or remarketing;
• attribute activity to particular campaigns or traffic sources;
• measure advertising reach, frequency, and effectiveness;
• connect activity across websites, applications, browsers, or devices; and
• support reporting by Ad-Networks or advertising partners.

These cookies may be placed by us or by third-party Ad-Networks, including, depending on the Services used, providers such as Meta, Google, or Taboola.

Advertising and Targeting Cookies are not strictly necessary. Where required by applicable law, they will only be activated after you provide consent.

7.5 Security and Fraud-Prevention Cookies

Security and Fraud-Prevention Cookies help us protect the Platform, Clients, accounts, campaigns, and End Users.

They may be used to:

• detect suspicious login activity;
• identify automated or abusive behaviour;
• prevent account takeover;
• enforce rate limits;
• protect forms and authentication processes;
• identify potentially fraudulent transactions or activity;
• maintain service integrity; and
• investigate security incidents.

Some Security Cookies may be considered Strictly Necessary where they are essential to protect the Platform and its users.

7.6 Customer-Support and Communication Cookies

Where customer-support, chat, scheduling, contact, or communication tools are enabled, cookies may be used to:

• maintain a support session;
• remember previous conversations;
• route communications;
• monitor support quality;
• process contact requests; and
• provide contextual assistance.

Depending on their function, these cookies may be classified as Necessary, Functional, or Analytics Cookies.

8. Cookie Inventory

8.1 The specific cookies used by the Platform may vary depending on:

• the page or Platform feature accessed;
• whether you are logged in;
• the third-party integrations enabled;
• your geographic location;
• your cookie-consent choices;
• the Ad-Networks connected to a Client account; and
• changes to our technical infrastructure.

8.2 Our cookie-preference tool, where available, may display an updated list of cookies detected or used on your device.

8.3 The following table describes the types of cookies that may be used. The exact cookie name, provider, purpose, and duration displayed by the Platform or consent-management tool will prevail where it provides more specific or up-to-date information.

8.4 We recommend periodically reviewing the cookie-preference tool and this Cookie Policy because cookies may be added, removed, or modified as the Platform and its integrations develop.

9. Ad-Network and Campaign Cookies

9.1 The Platform allows Clients to create, manage, monitor, and report on advertising campaigns delivered through third-party Ad-Networks.

9.2 When a Client connects an Ad-Network account, uses advertising-measurement functionality, installs a tracking pixel or tag, or launches a campaign through the Platform, the relevant Ad-Network may place or read cookies or use similar technologies.

9.3 These technologies may be used by an Ad-Network to:

• deliver advertisements;
• measure campaign activity;
• attribute conversions;
• create audiences;
• perform retargeting;
• prevent fraud;
• enforce frequency controls;
• personalise advertisements; and
• provide campaign reporting.

9.4 The relevant Client is responsible for ensuring that its campaigns, websites, landing pages, consent notices, tags, pixels, and use of Ad-Network tools comply with applicable privacy, electronic-communications, advertising, and data-protection laws.

9.5 Each Ad-Network is a separate and independent organisation. Its use of cookies and Personal Data is governed by its own privacy policy, cookie policy, platform terms, and technical settings.

9.6 LUDENS S.A. does not control cookies placed directly by an Ad-Network on an external website, application, advertisement, publisher property, or Client landing page.

10. Embedded Content and External Services

10.1 Pages within our website or Platform may contain embedded or linked content from third-party services, such as videos, dashboards, payment providers, social-media services, maps, customer-support tools, or Ad-Network interfaces.

10.2 When you interact with embedded content, the relevant third party may receive information about your device and interaction and may place its own cookies.

10.3 We encourage you to review the privacy and cookie policies of those third parties before interacting with their content or enabling related cookie categories.

11. Legal Basis and Consent

11.1 We use Strictly Necessary Cookies where they are required to:

• provide a Service expressly requested by you;
• maintain the security and integrity of the Platform;
• authenticate users and preserve sessions;
• comply with legal obligations; or
• perform essential technical functions.

11.2 Where applicable law requires consent, we will request your consent before placing or accessing non-essential cookies, including certain Functional, Analytics, Advertising, and Targeting Cookies.

11.3 Consent must be freely given, specific, informed, and indicated through a clear affirmative action.

11.4 Non-essential cookies should not be placed merely because you continue browsing, scroll through a page, close a banner, or fail to change a default setting.

11.5 Where our cookie banner or preference centre is available, you may be offered options to:

• accept all cookies;
• reject non-essential cookies;
• select individual cookie categories; or
• save customised preferences.

11.6 Rejecting non-essential cookies will not prevent access to the basic website or Platform, although features that depend on those cookies may be unavailable or operate differently.

11.7 Your consent choices will apply to the browser and device on which they were made. You may need to repeat your selections if you:

• use another browser or device;
• delete cookies or browser storage;
• use private or incognito browsing;
• reset browser settings; or
• access a different Platform domain or environment.

12. Withdrawing or Changing Consent

12.1 You may withdraw or change your consent at any time.

12.2 Where available, you may do so by selecting the “Cookie Settings”, “Privacy Settings”, or equivalent link displayed in the website footer or cookie banner.

12.3 Withdrawing consent will not affect the lawfulness of processing carried out before consent was withdrawn.

12.4 After you withdraw consent, we will stop using the relevant non-essential cookies where technically possible. Existing cookies may remain on your device until they expire or are manually deleted, but they should no longer be used for purposes requiring consent.

13. Managing Cookies Through Your Browser

13.1 Most browsers allow you to view, block, delete, or limit cookies through their settings.

13.2 Depending on your browser, you may be able to:

• block all cookies;
• block third-party cookies;
• delete cookies when the browser closes;
• delete cookies from particular websites;
• receive a notification before a cookie is placed; or
• restrict local storage and tracking technologies.

13.3 Browser settings differ and may change over time. You should consult the help or privacy section of your browser for current instructions.

13.4 Blocking or deleting Strictly Necessary Cookies may cause login, dashboard, campaign-management, security, billing, preference, or other Platform features to stop functioning correctly.

14. Global Privacy Controls and Browser Signals

14.1 Some browsers, devices, or extensions may transmit privacy signals, including Global Privacy Control or “Do Not Track” signals.

14.2 Legal requirements and technical standards concerning these signals differ between jurisdictions and continue to evolve.

14.3 Where required by applicable law and technically feasible, we will process recognised browser-based opt-out signals as required.

14.4 Unless legally required, the Platform may not respond to all “Do Not Track” signals because there is not a universally accepted technical standard governing their interpretation.

15. International Data Transfers

15.1 Cookies and similar technologies may involve the transfer of information to service providers, Ad-Networks, or other recipients located outside Uruguay or outside the country in which you are located.

15.2 Where the GDPR or another law governing international transfers applies, we will implement appropriate safeguards, such as:

• adequacy decisions;
• Standard Contractual Clauses;
• contractual and organisational safeguards;
• supplementary technical measures; or
• another lawful transfer mechanism.

15.3 Additional information about international data transfers is available in our Privacy Policy.

16. Data Retention

16.1 Cookies remain on your device for the period specified in the relevant cookie, cookie-preference tool, or cookie inventory.

16.2 Cookie durations may vary according to their purpose. Session cookies generally expire when you close your browser, while persistent cookies may remain for a defined period.

16.3 Information derived from cookies may be retained separately from the cookie itself where necessary to:

• provide the Services;
• maintain security;
• resolve disputes;
• comply with legal obligations;
• maintain business records;
• investigate fraud or abuse; or
• produce aggregated or anonymised analytics.

16.4 We will not retain Personal Data derived from cookies for longer than reasonably necessary for the purposes for which it was collected, subject to applicable legal, security, contractual, or regulatory requirements.

17. Data Sharing

17.1 Information collected through cookies may be disclosed to:

• hosting and cloud-infrastructure providers;
• information-security and fraud-prevention providers;
• analytics and performance-measurement providers;
• customer-support and communication providers;
• payment and billing providers;
• technical contractors and subcontractors;
• Ad-Networks and advertising-measurement providers;
• professional advisers;
• competent authorities where required by law; and
• parties involved in a merger, acquisition, financing, restructuring, or sale of all or part of our business.

17.2 Recipients may act as our service providers, data processors, independent data controllers, or joint controllers, depending on the relevant activity and applicable law.

17.3 Additional information about disclosures is available in our Privacy Policy.

18. Security

18.1 We use reasonable technical and organisational measures designed to protect cookie information and related Personal Data against unauthorised access, alteration, loss, misuse, or disclosure.

18.2 These measures may include access controls, encryption, secure authentication, monitoring, logging, firewalls, backup procedures, and contractual confidentiality obligations.

18.3 No method of transmission or storage is completely secure. Therefore, we cannot guarantee absolute security.

19. Children’s Privacy

19.1 The Platform and Services are not directed to individuals under 18 years of age.

19.2 We do not knowingly use cookies to profile or target individuals under 18 through the Platform.

19.3 If we become aware that we have collected Personal Data from a person under 18 without an appropriate lawful basis, we will take reasonable steps to delete or restrict that information.

20. Your Data-Protection Rights

20.1 Depending on your location and applicable law, you may have rights concerning Personal Data collected through cookies, including the right to:

• request access;
• request correction;
• request deletion;
• restrict processing;
• object to processing;
• request data portability;
• withdraw consent;
• opt out of certain advertising or profiling activities; and
• lodge a complaint with a competent data-protection authority.

20.2 These rights may be subject to conditions, limitations, exemptions, or identity-verification requirements under applicable law.

20.3 To exercise your rights, contact us using the information in Section 23.

21. Third-Party Policies

21.1 Third-party providers may modify their cookies, technologies, purposes, or retention periods independently of LUDENS S.A.

21.2 We encourage you to review the privacy and cookie policies made available by any third-party provider with which you interact, including connected Ad-Networks.

21.3 We are not responsible for the privacy or cookie practices of third-party websites, services, publishers, Ad-Networks, or Client-controlled landing pages.

22. Changes to This Cookie Policy

22.1 We may amend this Cookie Policy from time to time to reflect:

• changes to the Platform or Services;
• changes to the cookies or technologies we use;
• changes to third-party integrations;
• legal or regulatory developments;
• changes to our data-processing practices; or
• security or operational requirements.

22.2 The revised Cookie Policy will be posted on the Platform with an updated “Last updated” date.

22.3 Where required by applicable law, we will provide additional notice or request renewed consent before making material changes that affect how non-essential cookies are used.

22.4 We encourage you to review this Cookie Policy periodically.

23. Contact Information

If you have questions about this Cookie Policy, our use of cookies, or your data-protection rights, please contact:

For matters specifically relating to GDPR compliance, you may also contact:

Email: info@ludens.com.uy

24. Relationship With Other Policies

24.1 This Cookie Policy supplements our Privacy Policy and should be interpreted together with it.

24.2 If information collected through a cookie constitutes Personal Data, the processing of that information will also be governed by our Privacy Policy.

24.3 Our Terms & Conditions continue to govern access to and use of the Platform and Services.