1. Introduction

This Cookie Policy explains how TERALEX PAY LIMITED, a company incorporated in Canada, registration number BC1536949, office address 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada, uses cookies and similar technologies on its website, client portal and other online interfaces operated by or on behalf of TERALEX PAY LIMITED. In this Policy, TERALEX PAY LIMITED is referred to as "TERALEX", "we", "us" or "our".

This Policy should be read together with our Privacy Policy, Terms and Conditions and Regulatory Disclosures. The Privacy Policy explains how we collect, use, disclose, retain and protect personal information. This Cookie Policy focuses on cookies, local storage, device identifiers, logs and similar technologies used in connection with our online services.

Because TERALEX operates in a regulated financial services environment, certain technologies are necessary to operate our website and client portal securely, support login sessions and authentication, prevent fraud, maintain system integrity, keep audit records and comply with legal and regulatory requirements.

This Policy is prepared primarily for a Canadian business context. If privacy or electronic communications laws outside Canada apply to a specific user, service or technology, TERALEX will comply with those requirements to the extent required by applicable law. This Policy does not, by itself, mean that any non-Canadian privacy or electronic communications regime applies to all users or all services.

2. What Cookies and Similar Technologies Are

Cookies are small text files placed on your browser or device when you visit a website or use an online service. Cookies allow a website to recognize your browser or device, remember preferences, support login sessions, secure the service and understand whether the website or portal is working properly.

We may also use similar technologies, including web beacons, pixels, tags, scripts, software development kits, local storage, session storage, device identifiers and server-side logging tools. These technologies may collect or store information about your device, browser, online activity, website interactions and technical environment.

Cookies do not necessarily identify you by name. However, cookie data, device data, IP addresses or online identifiers may be personal information where they can be linked to you, your device, your account or your use of the Services. Where cookie information is personal information, we handle it in accordance with our Privacy Policy and applicable law.

3. Our Current Cookie Approach

Our website and client portal are intended primarily to support access to regulated services, account login, onboarding, secure communications, notices and client service functionality. The core technologies used for this purpose are expected to relate mainly to session management, authentication, security controls, fraud prevention, basic page views, error logs, diagnostics, preference management, notice records and service availability.

We do not use cookies to collect sensitive identity documents, private keys, full KYC or KYB files, AML case materials, full financial credentials or full transaction files. Those categories of information are processed under separate security and compliance controls described in our Privacy Policy and internal compliance framework.

We do not use marketing or behavioural advertising cookies unless such technologies are clearly disclosed and used with any consent, opt-out or preference controls required by applicable law. If our cookie practices materially change, we will update this Policy and, where required, provide additional notice or controls.

4. Information Collected Through Cookies

Depending on how you interact with our website, client portal or online services, cookies and similar technologies may collect or generate the following types of information:

• IP address, approximate location derived from IP address, device identifier, browser type, operating system, language settings and time zone.
• Date and time of visit, session duration, pages viewed, referring website, navigation path and page interaction data.
• Login, session, authentication, security status, failed login attempts and other access-related signals.
• Cookie preferences, privacy choices and consent or withdrawal records where applicable.
• Website performance data, page views, error logs, diagnostic information and service availability data.
• Fraud prevention, cybersecurity, risk, abuse prevention and account protection signals.
• Analytics or marketing identifiers, only where such cookies or similar technologies are enabled, disclosed and permitted.

5. Why We Use Cookies

We use cookies and similar technologies for the following purposes:

• To operate the website, client portal and online services;
• to authenticate users and maintain secure sessions;
• to remember cookie preferences and basic user settings;
• to protect accounts, systems and transactions from fraud, abuse, unauthorized access and cyber threats;
• to support security, audit, logging, troubleshooting and regulatory recordkeeping processes;
• to understand website performance, page views, errors and service usability;
• to provide support features such as forms, secure communications, help desk tools or client support channels;
• to measure the effectiveness of communications or website content where permitted;
• to deliver analytics, marketing or advertising functionality only where permitted and subject to applicable consent, opt-out or preference requirements.

6. Categories of Cookies We Use

We classify cookies and similar technologies as follows.

Strictly necessary cookies. Required to operate the website, client portal and online services, maintain security, support authentication and remember essential settings. Examples: session identifiers, authentication tokens, security controls, load balancing, cookie preference storage. Consent and control: necessary for the service. They cannot be disabled through our cookie tool, although your browser may allow you to block them. Blocking them may affect the service.

Security and fraud prevention. Help protect accounts, systems, transactions and regulatory records from unauthorized access, fraud, abuse and cyber threats. Examples: device and login signals, anomaly detection, abuse prevention, risk indicators, access logs. Consent and control: used where necessary for security, fraud prevention, regulatory compliance and service integrity.

Functional cookies. Enable optional features and personalization requested or enabled by the user. Examples: language settings, saved form preferences, support chat, interface preferences. Consent and control: used where enabled by you, reasonably necessary for the requested feature or otherwise permitted by applicable law.

Analytics, performance and diagnostic. Help us understand whether the website and portal operate correctly and how performance can be improved. Examples: page views, traffic sources, error diagnostics, service availability metrics, user journey metrics. Consent and control: used in accordance with applicable consent, opt-out or preference requirements where they are not strictly necessary.

Marketing and advertising cookies. Help measure campaigns or deliver communications about services, only if such technologies are enabled. Examples: campaign attribution, advertising pixels, remarketing identifiers. Consent and control: used only where enabled, disclosed and permitted, and where applicable controls are provided.

Third-party cookies. Set by selected service providers that support website functionality, analytics, security, communications or other services. Examples: analytics providers, hosting providers, security tools, support tools, communications tools. Consent and control: controlled by the relevant third party and our vendor arrangements. Browser and cookie tools may allow you to manage these cookies.

7. Strictly Necessary Cookies and Security Technologies

Strictly necessary cookies and security technologies are required for the website, client portal and related online services to function. They may be used to authenticate users, keep users logged in, maintain session integrity, prevent unauthorized access, process forms, detect abuse, support basic service functionality and maintain audit or security logs.

If you disable strictly necessary cookies through your browser, some parts of our website or client portal may not operate correctly, and you may be unable to log in, submit information, access account features or use secure services.

8. Analytics, Performance and Diagnostic Technologies

Analytics, performance and diagnostic technologies help us understand how visitors use our website and online services, whether pages load properly, whether users encounter errors and whether the service is available and stable.

Where analytics or performance technologies are not strictly necessary for service operation, security, fraud prevention or diagnostics, we use them in accordance with applicable consent, opt-out or preference requirements.

9. Functional Cookies and Support Tools

Functional cookies allow the website or portal to provide additional features, such as remembering selected preferences, enabling secure forms, supporting customer communications or integrating help desk and support tools. If these cookies are disabled, some optional features may not function properly.

If we use third-party communication or support tools, those providers may set their own cookies or similar technologies. Their processing may be governed by their own privacy and cookie notices. We require service providers to process information in accordance with appropriate contractual and security obligations.

10. Marketing and Advertising Cookies

We do not use marketing or advertising cookies to make AML, KYC, KYB, sanctions, credit, onboarding, account restriction, transaction monitoring or account closure decisions.

If marketing or advertising cookies are enabled in the future, they will be disclosed and used only where permitted by applicable law and subject to any consent, opt-out or preference controls required for the relevant technology and jurisdiction.

11. Cookie Choices and Controls

Where applicable law requires consent, opt-out or other preference controls for non-essential cookies or similar technologies, we will provide an appropriate mechanism before or when those technologies are used.

Where consent is required for non-essential cookies, those cookies should not be enabled until the required consent has been obtained or another lawful basis is available. You may withdraw or change optional cookie preferences through available cookie controls, browser settings, device settings or other tools we make available, subject to technical feasibility and Applicable Law.

Preference changes do not disable strictly necessary technologies required for security, authentication, fraud prevention, audit, compliance, notice delivery, recordkeeping or service operation. If a preference centre is not available for a particular technology, you may use your browser or device settings to block or delete cookies. Some choices may need to be reset if you clear cookies, use a different device or use a different browser.

12. Third-Party Cookies and Service Providers

We may allow selected service providers to use cookies or similar technologies on our website or online services to support hosting, analytics, security, customer support, communications, fraud prevention, performance monitoring and related functions.

These providers may process information on our behalf or as independent service providers depending on the nature of the service. Where personal information is processed by a service provider, we use contractual, organisational and technical measures designed to protect that information and restrict its use to authorised purposes.

Where third-party technologies support regulated services, security, authentication, notices, fraud prevention, audit logs, complaint handling or compliance evidence, related records may be retained or made available as described in the Privacy Policy, Terms and Conditions and applicable internal recordkeeping requirements.

Examples of third-party services that may use cookies or similar technologies include analytics tools, cloud hosting services, security monitoring tools, customer support tools, marketing technology providers and communication integrations. The exact providers used may change from time to time as our services develop.

13. Cross-Border Processing

Information collected through cookies and similar technologies may be processed or stored in Canada or in other jurisdictions where we or our service providers operate. If information is processed outside Canada, it may be subject to the laws of that jurisdiction, including lawful access requests by courts, law enforcement or regulatory authorities.

We remain responsible for personal information under our control and use contractual and other safeguards to require an appropriate level of protection by service providers. Further information about cross-border processing is provided in our Privacy Policy.

14. Browser and Device Settings

Most browsers allow you to manage cookies through their settings. The exact process depends on your browser and device. You may generally use your browser settings to see what cookies are stored, delete cookies, block third-party cookies, block all cookies or receive warnings before cookies are stored.

Guidance is usually available through the Help, Settings, Privacy, Security or Preferences section of your browser. Common browsers include Google Chrome, Apple Safari, Mozilla Firefox, Microsoft Edge and Opera. Browser controls may change from time to time, and you should refer to the current instructions provided by your browser provider.

15. Do Not Track and Preference Signals

Some browsers or devices may transmit Do Not Track, Global Privacy Control or similar signals. There is currently no single universal standard for responding to all such signals across jurisdictions and technologies.

You should use our available cookie controls, preference tools, browser settings or contact channels to manage your choices. If a legally recognized signal applies in your jurisdiction, we will handle it in accordance with applicable law and technical feasibility.

16. Retention

Cookies remain on your device for different periods depending on their purpose. Session cookies are deleted when you close your browser. Persistent cookies remain until they expire or are deleted. We retain cookie-related records only as long as reasonably necessary for the purposes described in this Policy, including security, audit, compliance, analytics, preference management, notice records, dispute resolution and legal obligations.

Where cookie or online activity data forms part of security, audit, AML, fraud prevention, transaction, Travel Rule, account access, incident response, complaint, notice, safeguarding or regulatory records, it may be retained for the period required by applicable law or our internal recordkeeping policies.

17. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our services, technology, legal requirements, service providers or business practices. The updated version will be posted on our website with a revised effective date. Where required by law, we will provide additional notice or seek consent for material changes.

If we introduce material new non-essential analytics, marketing, behavioural advertising or similar technologies, we will provide any consent, opt-out or preference controls required by applicable law before or when those technologies are used.

We may also update this Policy to reflect future developments in Canadian privacy, electronic communications or online tracking requirements, and other applicable laws where they become relevant to our services.

18. Contacts

If you have any questions about this Cookie Policy or our use of cookies and similar technologies, you may contact us at:

• Company: TERALEX PAY LIMITED
• Registration number: BC1536949
• Office address: 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada
• Website: https://teralex.com/
• Contact email: support@teralex.com

19. Applicable Legal Framework

This Cookie Policy has been prepared for a Canadian business context and should be read in light of applicable Canadian privacy and electronic communications requirements, including the Personal Information Protection and Electronic Documents Act, Canada's Anti-Spam Legislation where relevant, and guidance issued by the Office of the Privacy Commissioner of Canada and the Canadian Radio-television and Telecommunications Commission.

Where cookies or similar technologies involve personal information, we apply privacy principles including accountability, transparency, appropriate purposes, consent where required, safeguards, access and retention limitation. Where another privacy or electronic communications law applies to a specific user, service or technology, we will apply those requirements to the extent required by law.

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