Cookie Policy

Effective Date: 01 January, 2026

This Cookie Policy should be read together with the Novagates Privacy Policy. Novagates ("Novagates", "we", "us", or "our") uses cookies and similar tracking technologies on its website [www.______.com] and related platforms (the "Website") to ensure proper functionality, improve user experience, analyze performance, and support marketing activities, where permitted by law.

1.WHAT ARE COOKIES?

1.1 Cookies are small text files placed on your device (computer, smartphone, tablet, headset, or other internet-enabled device) when you access our websites or Services. 1.2 Cookies allow us to: Recognize your device on subsequent visits; Remember preferences or settings; Track usage patterns and site performance; Improve user experience and Service functionality; 1.3 Types of Cookies: (a) Session Cookies: Temporary cookies that are deleted automatically when you close your browser. Used to maintain session state, e.g., keeping you logged in during navigation. (b) Persistent Cookies: Remain on your device for a set period or until manually deleted. Used to remember preferences, authentication, or settings across visits. (c) First-Party Cookies: Set directly by Novagates. Enable essential functions, preferences, and analytics on our platforms. (d) Third-Party Cookies: Set by authorized third-party service providers, such as analytics, payment processors, marketing, or advertising platforms. Used to support tracking, statistical analysis, and Service optimization.

2.PURPOSES OF COOKIES AND TRACKING

Novagates utilizes cookies, web beacons, and similar tracking technologies ("Cookies") on our websites, SaaS platforms, and integrated Services. These Cookies are used to collect information necessary for providing, optimizing, and securing our Services. The purposes include the following categories: (a) Essential / Functional Cookies Purpose: Ensure proper operation of Novagates' websites and Services; Maintain session state, login credentials, and account authentication during use; Remember user preferences such as language selection, display settings, or feature configurations. Examples of Use: Keeping a user logged in while navigating between pages; Retaining selections made in a SaaS dashboard or during a demo request; Enabling secure access to enterprise client portals and subscription services. Legal Basis: Contractual necessity to provide subscribed SaaS Services; Legitimate interest to ensure stable and secure Service operation. Retention: Only retained for the duration of the user session or as required for account functionality. (b) Performance and Analytics Cookies Purpose: Collect anonymized or pseudonymized data regarding usage patterns, traffic volumes, page views, and interactions; Enable Novagates to monitor Service performance, identify errors, and optimize user experience; Support internal reporting and strategic decision-making regarding Service enhancements. Examples of Use: Tracking which pages or features are most frequently accessed; Measuring time spent on particular AR/VR tools or AI-driven simulations; Monitoring load times and technical performance of the website or SaaS platform. Legal Basis: Legitimate interest in improving Services, analyzing traffic, and enhancing user experience; Consent may be required if personal identifiers are included in analytics. Retention: Aggregated or pseudonymized analytics data may be retained for up to ___ months for trend analysis and reporting purposes. (c) Marketing and Advertising Cookies Purpose: Deliver targeted marketing campaigns and promotional content based on user interests and engagement; Measure effectiveness of email campaigns, advertisements, and social media campaigns; Track user interaction with third-party advertising networks or retargeting campaigns. Examples of Use: Displaying personalized product bundles, SaaS plans, or demo invitations; Measuring clicks, conversions, or engagement metrics from campaigns; Retargeting users who visited Novagates' Services but did not complete registration or purchase. Legal Basis: Consent is required for any marketing or profiling activities. Users may withdraw consent at any time through cookie management tools or browser settings. Retention: Data collected via marketing cookies will not exceed ___ months unless consent is renewed. (d) Security and Fraud Prevention Cookies Purpose: Detect, prevent, and mitigate unauthorized access, abuse, or fraudulent activity on Novagates' Services; Protect accounts, transactions, and confidential information; Ensure the integrity and operational security of AR, AI, and VR functionalities. Examples of Use: Monitoring unusual login attempts, IP addresses, or device fingerprints; Preventing automated attacks or unauthorized data scraping; Supporting regulatory compliance obligations and risk management. Legal Basis: Legitimate interest in protecting the confidentiality, integrity, and availability of Services; Contractual necessity where security safeguards are required to deliver SaaS functionalities. Retention: Security-related data may be retained for up to ___ months or longer as required for fraud investigation, dispute resolution, or legal obligations.

3.Third-Party Cookies

3.1 Purpose: Novagates may permit authorized third-party service providers to place cookies or similar tracking technologies on your device to provide, enhance, or support the Website and Services. 3.2 Examples of Third-Party Cookies: Analytics providers (e.g., Google Analytics), for measuring traffic, use compliance, and performance; CRM and marketing automation tools, for managing leads, campaigns, and customer interactions; Cloud and hosting providers, for Service delivery and system optimization; Security and fraud prevention services, to detect and prevent unauthorized access or abusive activity. 3.3 Data Protection & Legal Obligations: 3.3.1 All third-party providers are bound by contractual obligations to process personal data in compliance with applicable laws, including Kuwait's Personal Data Protection Law and the EU GDPR. 3.3.2 Third-party cookies may process personal data on behalf of Novagates only for the purposes explicitly authorized. 3.4 Control and Consent: 3.4.1 Novagates does not control the management or content of cookies set by third parties. 3.4.2 Users are encouraged to review third-party privacy and cookie policies for detailed information on their data practices. 3.4.3 Where personal data is processed, explicit consent is obtained prior to setting third-party cookies, and users may withdraw consent at any time through browser settings or the cookie consent manager. 3.5 Retention: Data collected via third-party cookies is retained in accordance with Novagates' contractual agreements with service providers and applicable data protection laws, typically not exceeding ___ months, unless anonymized.

4.Cookie Consent Management

4.1 Consent Banner: Upon your first visit to the Website, Novagates will present a cookie banner notifying you of our use of cookies and similar tracking technologies. The banner allows you to: (a) Accept all cookies, including functional, performance, marketing, and security cookies; (b) Reject non-essential cookies, retaining only those strictly necessary for the operation of the Website and Services; (c) Customize cookie preferences, selecting which categories of cookies you consent to. 4.2 Updating Preferences: You may modify or withdraw your cookie consent at any time via the Website's cookie settings panel or through your browser settings. 4.3 Changes to your preferences will be applied prospectively; cookies previously set may continue to operate until they expire, unless manually deleted. 4.4 Processing of non-essential cookies (performance, marketing, analytics) is based on user consent as required under GDPR and Kuwait's data protection laws. 4.5 Essential/functional cookies necessary for the operation of the Website are processed without consent but are clearly disclosed. 4.6 Novagates retains a record of your cookie consent choices to demonstrate compliance with applicable data protection laws. 4.7 You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. 4.8 Upon withdrawal, Novagates will disable non-essential cookies and cease related data processing wherever technically feasible.

5.How To Control Or Delete Cookies

5.1 You may exercise control over cookies through your web browser or device settings. Most browsers provide options to: View cookies currently stored on your device; Block all cookies or cookies from specific websites or domains; Delete cookies currently stored on your device. 5.2 Please note that disabling or deleting certain cookies, particularly essential or functional cookies, may affect the functionality, performance, or availability of the Website and Services. Some features may not operate correctly without these cookies. 5.3 Your ability to manage, restrict, or delete cookies constitutes a withdrawal of consent for non-essential cookies, in accordance with GDPR and applicable Kuwaiti data protection laws. Novagates will respect these choices to the extent technically feasible.

6.Data Subject Rights

Novagates recognizes and respects the rights of data subjects under applicable data protection laws, including the European Union General Data Protection Regulation (GDPR) and relevant State of Kuwait privacy and personal data protection principles (as embodied in Kuwait: Constitution Article 37, Kuwait Cybercrime Law No. 63 of 2015, E-Transactions Law No. 20 of 2014, and related regulatory guidance). 6.1 Rights Under GDPR and Applicable Law: Where GDPR is relevant, or by virtue of the processing of personal data of data subjects protected under GDPR, you have the following rights: (a) Right of Access: You may request confirmation of whether your Personal Data is being processed and obtain a copy of that data. (b) Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. (c) Right to Erasure: You may request deletion of your Personal Data in certain circumstances, except in circumstances where there is no overriding legal basis to retain it. (d) Right to Restriction of Processing: You may request that Novagates restrict processing where accuracy is contested, processing is unlawful, or Novagates no longer needs the data but you require it to establish, exercise, or defend legal claims. (e) Right to Data Portability: Where processing is based on consent or performance of a contract and is carried out by automated means, you may request transfer of your Personal Data to yourself or another controller in a structured, commonly used, machine-readable format. (f) Right to Object: You may object to processing of your Personal Data for direct marketing purposes or on other lawful grounds where the processing is based on legitimate interests. (g) Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. (h) Right to Lodge a Complaint: You may lodge a complaint with a competent supervisory authority if you believe processing of your personal data violates applicable law. 6.2 Under Kuwaiti privacy and data protection principles: (a) You have the right to request access to your Personal Data held by Novagates. (b) You have the right to request correction or deletion of Personal Data that is inaccurate, unlawfully collected, outdated, or no longer necessary. (c) You have the right to object to processing that is unlawful or infringes on your privacy rights. (d) You have the right to be informed of the purposes for which your Personal Data is being processed and the identity of the data controller. (e) You have the right to request deletion of data processed in violation of applicable Kuwaiti laws, subject to legal exceptions. Novagates will process requests under Kuwaiti law in accordance with applicable statutory procedures and timelines. 6.3 To exercise any of the rights described above, please submit a written request to: support@novagates.com. Your request should include: (a) Your full name and contact information. (b) A clear description of the Personal Data involved. (c) The specific rights you wish to exercise; and (d) Any supporting documentation necessary to verify your identity. (e) Novagates may require reasonable proof of identity to protect your Personal Data against unauthorized disclosure. 6.4 Novagates will respond to verified requests without undue delay and in accordance with applicable laws. Generally, responses will be issued within ___ calendar days of receipt of a valid request. In complex cases or where required by local law, Novagates may extend this period up to ___ calendar days, with notice to the requester explaining the reasons for the delay. 6.5 The rights set forth in this Section are subject to limitations and exceptions under applicable law, including but not limited to: Protection of trade secrets or intellectual property; Compliance with legal or regulatory obligations; Public interest requirements; Defense of legal claims or enforcement of contracts. Where applicable, Novagates will inform you of the legal basis for any denial or limitation of a requested right. 6.6 Novagates will not retaliate against you for exercising your privacy rights.

7.Data Retention

7.1 Novagates retains cookie and tracking data only for as long as necessary to fulfill the purposes for which it was collected, in accordance with applicable law, including GDPR and Kuwaiti Data Privacy Protection Regulation (CITRA Regulation No. 26 of 2024). Retention periods are as follows: (a) Session Cookies: Temporary cookies that maintain session state, login authentication, or service preferences. Retention period: Automatically deleted when the browser session ends. (b) Persistent Cookies: Cookies that store user preferences, language, or regional settings for enhanced functionality. Retention period: Retained for up to 24 months unless deleted earlier by the user. (c) Analytics and Performance Cookies: Cookies used to measure website usage, performance, and user behavior. Data is anonymized or aggregated wherever possible to prevent identification of individual users. Retention period: Retained for a maximum of ___ months or until anonymized/aggregated, whichever occurs first. (d) Marketing and Advertising Cookies: Cookies used for personalized content delivery, campaign tracking, or remarketing. Retention period: Retained for up to ___ months, subject to user consent, unless otherwise required by law. (e) Legal or Regulatory Retention: Where cookies or data derived from cookies are required to comply with legal obligations, regulatory investigations, or dispute resolution, such data may be retained beyond the periods above only for the duration necessary to satisfy such obligations. All cookie and tracking data may be deleted at any time by the user through browser settings or by adjusting cookie consent preferences on the Website. Novagates may transfer cookie and tracking data collected through the Website or Services to recipients located outside Kuwait or the European Economic Area (EEA) for the purposes described in this Policy. Any such transfers are conducted in full compliance with applicable data protection laws, including GDPR and Kuwait Data Privacy Protection Regulation (CITRA Regulation No. 26 of 2024).

8.Safeguards For International Transfers Include

8.1 All third-party recipients of cookie data outside Kuwait or the EEA are contractually bound to: (a) Process the data only for specified purposes; (b) Implement appropriate technical and organizational measures to protect the data; (c) Comply with applicable data protection security requirements under GDPR and Kuwaiti data protection law. 8.2 Where required by law, user consent is obtained before transferring cookie or tracking data internationally. 8.3 Novagates shall not be responsible for third-party actions after lawful transfer, provided that.

9.Changes To This Cookie Policy

9.1 Novagates reserves the right to modify, update, or amend this Cookie Policy at any time to reflect changes in: (a) Applicable laws or regulations, including GDPR and the Kuwait Data Privacy Protection Law (CITRA Regulation No. 26 of 2024); (b) The scope or functionality of our Website or Services; (c) Industry best practices for cookie management, data protection, or security. 9.2 Material changes will be communicated to users through the Website, either via a prominent banner, notification message, or email (if applicable). 9.3 Users will be provided with an opportunity to review and manage their cookie preferences following any material changes. 9.4 Your continued access or use of the Website or Services after the publication of updates constitutes your acknowledgement, acceptance, and consent to the revised Cookie Policy. 9.5 If you do not agree with any updated terms, you must disable or delete cookies, adjust your cookie preferences, or stop using the Website. 9.6 Novagates will maintain a version history of this Cookie Policy, including the effective date of each revision, to ensure transparency and accountability.

10.Disclaimer Of Warranties

For questions regarding this Cookie Policy or cookie usage, contact: Novagates Email: info@novagates.com Address: State of Kuwait