Cookie Policy

Draft, pending legal review.

This document has been prepared for review by Canadian financial services counsel and is not yet in force. Items in square brackets are unconfirmed and must not be relied upon. It will be published with a version and an effective date before the service accepts customers.

1. What cookies are

A cookie is a small text file placed on your device when you visit a website. Cookies let a site recognise your device, remember your preferences, keep you signed in and understand how the site is used.

This policy also covers similar technologies that do comparable things, including pixels, web beacons, tags, software development kits, local storage and session storage. We refer to all of them as "cookies" below.

2. First-party and third-party cookies

First-party cookies are set by Nomos Pay. Third-party cookies are set by another organisation whose service we use, for example an analytics or security provider. Third-party cookies are governed by that provider's own privacy policy as well as this one.

3. The categories we use

Strictly necessary. Required for the site and the application to work, including signing in, maintaining your session, routing traffic, balancing load and protecting against attacks. These cannot be switched off through our consent tool, because the service would not function without them.
Security and fraud prevention. Used to detect unusual activity, protect against automated abuse, and verify that a request comes from a genuine browser.
Functional. Remember choices such as your language, region or display preferences.
Analytics and performance. Help us understand which pages are visited, how the site performs, and where people encounter difficulty, so we can improve it.
Marketing and advertising. Used to measure campaigns and, where applicable, to show relevant content. We only use these where you have consented, and only if we have deployed them at all.

4. Cookies used on this site

The table below describes the categories we use and the technologies deployed in each. Specific provider names and durations are marked as placeholders until the final analytics, consent and security tooling is confirmed for launch.

Cookie or category	Purpose	Provider	Party	Typical duration	Required
Session and authentication	Keeps you signed in and maintains your session securely	Nomos Pay	First party	Session, or until sign-out	Required
Security and anti-abuse	Detects automated abuse and protects against attacks	Nomos Pay and [SECURITY PROVIDER IF USED]	First and third party	Session to 12 months	Required
Load balancing and routing	Routes your request to the correct server	[HOSTING PROVIDER]	First party	Session	Required
Consent preferences	Remembers your cookie choices so we do not ask again	[COOKIE CONSENT PLATFORM]	First party	Up to 12 months	Required
Language and display preferences	Remembers your chosen language and display settings	Nomos Pay	First party	Up to 12 months	Optional
Product analytics	Measures page views, feature use and performance	[GOOGLE ANALYTICS IF USED]	Third party	Up to 24 months	Optional
Campaign measurement	Measures the effectiveness of marketing campaigns	[META PIXEL IF USED], [LINKEDIN INSIGHT TAG IF USED]	Third party	Up to 13 months	Optional
Other tracking technologies	Any additional tool deployed after launch	[OTHER THIRD-PARTY TRACKING TOOL]	Third party	[DURATION]	Optional

Placeholders in this table are deliberate. We will not name an analytics, advertising or consent provider until it is actually deployed, and this table will be updated whenever the tooling changes.

5. Why we use cookies

To operate the website and keep you signed in securely.
To protect your account and our systems against fraud and automated abuse.
To remember your preferences so the site behaves predictably.
To understand how the site is used and to improve it.
To measure marketing where you have consented.

6. How to control cookies

When you first visit the site you will be offered a choice about optional cookies through our consent tool. You can change your choice at any time using the cookie settings link in the footer.

You can also control cookies in your browser. Most browsers let you see what cookies are stored, delete them, block them from specific sites, or block all of them. The controls differ by browser, and the browser's own help pages explain how.

Some browsers offer a "Do Not Track" or global privacy control signal. Where applicable law requires us to honour such a signal, we will. Our treatment of these signals will be confirmed before launch.

If you block strictly necessary cookies, parts of the site and the application will not work. You may not be able to sign in, and security controls that protect your account may fail.

7. Third-party tracking and advertising

Where third-party cookies are deployed, the provider may combine information collected on our site with information it holds from other sites and services. We do not control that processing, and you should read the provider's own privacy policy.

We do not sell personal information. Where a targeted advertising tool is deployed, it will be listed in the table above and will require your consent.

8. Changes and contact

We will update this policy whenever the cookies or technologies we use change. The date at the top of the page shows when it was last revised.

For questions about this policy, contact [PRIVACY EMAIL]. For how we handle personal information more generally, see our Privacy Policy.

Entity and contact details

These details will be completed and confirmed by counsel before publication. Where a placeholder appears below, the information has not yet been confirmed and must not be relied upon.

Item	Detail
Legal entity	[LEGAL ENTITY NAME]
Trading name	Nomos Pay
Registered office	[REGISTERED ADDRESS]
Incorporation number	[INCORPORATION NUMBER]
FINTRAC MSB registration	[FINTRAC MSB REGISTRATION NUMBER]
Website	nomos-pay.com
General support	[SUPPORT EMAIL]
Legal	[LEGAL CONTACT EMAIL]
Privacy	[PRIVACY EMAIL]
Complaints	[COMPLAINTS EMAIL]
Compliance	[COMPLIANCE EMAIL]
Telephone	[PHONE NUMBER]
Effective date	[DATE]
Last updated	[DATE]

Questions about this document, or need it for a diligence process? Contact [LEGAL CONTACT EMAIL] . To raise a formal complaint, see our complaints policy.