1. Purpose

Scintilla Network FZE (“Scintilla”) uses cookies and similar technologies on its website (the “Site”) to improve functionality, analyse usage, comply with regulatory obligations, and, where applicable monitor engagement with investor materials in line with the Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks.

This Cookie Policy explains what cookies are, how Scintilla uses them, and your choices regarding their use. It forms part of our Privacy Policy and supports compliance with the UAE Personal Data Protection Law (PDPL) and the VARA AML and Issuance Rulebooks.

2. What Are Cookies and Tags?

Cookies are small text files placed on your device when you visit the Site. Scintilla also uses Tags (such as web beacons, pixel tags, or click-through URLs) to track activity in emails, documents, and downloads.

These technologies help us:

• remember preferences and settings;

• monitor logins and account security;

• measure interest in whitepapers, offerings, and investor communications;

• detect fraud, abuse, or suspicious behaviour.

3. Types of Cookies We Use

a. Essential Cookies

• Required for secure login, account sessions, and core functionality.

• Cannot be disabled.

b. Analytics and Performance Cookies

• Monitor how visitors use the Site.

• Includes session IDs, traffic statistics, and user journeys.

• Supports VARA requirements for monitoring suspicious access patterns.

c. Compliance Cookies

• Used to support AML/CFT and sanctions screening obligations.

• Record device identifiers, IP addresses, and login behaviour.

• Retained for at least 8 years per VARA AML Rulebook.

d. Marketing and Issuance Cookies

• With your explicit consent, track engagement with Scintilla content such as newsletters, event registrations, or token whitepaper downloads.

• Tags may cross-reference your contact details when you click links in our emails or visit investor pages.

• Used to measure demand for Virtual Asset issuances and to comply with VARA disclosure obligations.

4. Profiling Safeguards

Where marketing or issuance cookies generate analytics about investor interest:

• Scintilla will not use such data to offer inappropriate products.

• Data will only be used for regulatory-compliant issuance activities.

• Automated profiling for risk appetite is limited and subject to human oversight.

5. How We Use Cookie Data

Cookie and Tag data may be used to:

• verify identity and prevent account misuse;

• log access for audit and AML/CFT record-keeping;

• analyse demand for issuance documents (e.g. downloads of whitepapers);

• improve Site performance and security.

6. Third-Party Cookies

Some cookies are placed by trusted third-party providers (e.g. analytics, cloud hosting, or communication platforms). All such providers are subject to contractual obligations to comply with PDPL and VARA standards.

7. Retention

• Session cookies: deleted when you close your browser.

• Persistent cookies: kept for no longer than 24 months unless required for compliance.

• AML/CFT and Issuance cookies/Tags: retained for a minimum of 8 years to meet VARA and regulatory record-keeping obligations.

8. Consent and Control

• Essential and compliance cookies cannot be disabled.

• Analytics and issuance/marketing cookies require explicit consent.

• You can manage or delete cookies at any time via browser settings.

• Withdrawing consent will not affect the legality of processing carried out before withdrawal.

9. Changes to This Policy

Scintilla may update this Cookie Policy to reflect regulatory, technical, or business changes. Significant updates will be communicated via the Site.

10. Contact Us

For questions about this Cookie Policy or to exercise your rights under PDPL, contact:

Privacy@scintillanetwork.com (Data Protection Officer)
Mlro@scintillanetwork.com (Money Laundering Reporting Officer)