> For the complete documentation index, see [llms.txt](https://docs.spendl.money/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.spendl.money/spendl-compliance-pack/spendl-cookie-policy.md). # Spendl Cookie Policy 1\. Document Control | **Version** | 1.2 | | ------------------ | ------------------------------------------------------- | | **Effective Date** | 1 July 2026 | | **Approved By** | Board of Directors | | **Owner** | Chief Compliance Officer | | **Next Review** | July 2027 or sooner on regulatory or operational change | ### 2. Introduction This Cookie Policy explains how Light Fusion (Pty) Ltd t/a Spendl Technologies (SPENDL) uses cookies and similar technologies when you access our Website, and related Services as defined in the Terms and Conditions. This policy works alongside our Privacy Policy and is provided in line with the Protection of Personal Information Act, 2013 (POPIA), the Electronic Communications and Transactions Act 25 of 2002 (ECTA), and the FSCA Treating Customers Fairly (TCF) outcomes. By using our Services, you consent to the use of cookies as described in this policy. You can withdraw or change your cookie preferences at any time. ### 3. What Are Cookies? Cookies are small text files placed on your device when you use a website. They help us recognise your device, improve functionality, and provide you with a better, more secure experience. We also use similar technologies, such as: * Local storage / web storage: Persistent browser storage with larger capacity. * Web beacons (pixels/tags): Small images or code that track interactions. ### 4. Why We Use Cookies * Enable secure access to our Services, including multi-factor authentication and session management. * Remember your preferences (e.g., language, device type). * Monitor performance and improve user experience. * Analyse how our Services are used and measure engagement. * Protect against fraud, phishing, and enhance security (consistent with the security obligations set out in the Terms and Conditions). * Deliver and measure relevant advertising campaigns. We do not use cookies to collect sensitive personal information such as financial, health, political, or religious data. ### 5. Types of Cookies We Use * Strictly Necessary Cookies: Required for our Services to function. Cannot be disabled. * Functional Cookies: Remember your preferences and improve personalisation. * Performance/Analytical Cookies: Help us understand usage patterns and improve functionality. * Advertising/Targeting Cookies: Provide tailored advertising and measure marketing effectiveness. * Session Cookies: Temporary; deleted when you close your browser. * Persistent Cookies: Remain until deleted manually or expired. ### 6. Information Collected Cookies may collect information such as your device and browser type, operating system, IP address, pages visited, time spent, navigation paths, and interaction with content, ads, and features. Where such data is linked to you, it will be treated as Personal Information under POPIA and processed in accordance with our Privacy Policy. ### 7. Managing Your Cookie Preferences You can manage or disable cookies via your browser or device settings. Please note: disabling cookies may affect functionality and restrict access to parts of our Services. You may withdraw consent for non-essential cookies at any time by updating your settings. SPENDL will respect your cookie preferences in line with POPIA and the TCF principle of not imposing unreasonable post-sale barriers. ### 8. Third-Party Websites Our Services may link to third-party websites. We are not responsible for the cookie practices of external websites. Please review their policies before use. ### 9. Policy Review and Updates This Cookie Policy will be reviewed at least annually or sooner if there are regulatory changes, new technologies, or changes to the Services. Updates will be published on our Website, and the effective date will be updated. Material changes are communicated in accordance with the Terms and Conditions. ### 10. Contact Us For any questions about this Cookie Policy, please contact us at: * Email: * Website: [www.spendl.money](http://www.spendl.money/) ### 11. Version Control | **Version** | **Effective Date** | **Summary of Changes** | **Reason for Changes** | **Approved By** | | ----------- | ------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------ | | 1.1 | 1 September 2025 | Founding version - initial Cookie Policy issued | Initial Cookie Policy compliance requirement upon platform launch | Board of Directors | | 1.2 | 1 July 2026 | Added formal Document Control and Version Control sections. Introduced ECTA as an additional legal basis alongside POPIA and FSCA TCF. Rescoped the policy to Website-based Services and aligned defined terms and cross-references with the Terms and Conditions (removing the standalone mobile-app/SDK content and Mobile Applications section). Expanded stated security purposes (MFA, session management, anti-phishing) and cookie-preference handling. Shortened the review cycle from two years to annual. | Periodic review to strengthen regulatory alignment (POPIA, ECTA, FSCA TCF), integrate the policy with the updated Terms and Conditions, and improve governance through formal document and version control. | Board of Directors |