Cookie Policy

Applies to: speassy.com and all Speassy mobile applications
Governing law: GDPR (RODO) Regulation 2016/679 · ePrivacy Directive 2002/58/EC · Polish Electronic Communications Act 2024

1. Introduction

Speassy operates the website speassy.com and the Speassy mobile application (the “Platform”). This Cookie Policy explains what cookies are, which cookies we use, why we use them, and how you can control them. It forms part of our Privacy Policy and should be read alongside it.

2. What Are Cookies?

Cookies are small text files stored on your device when you visit a website or use an application. First-party cookies are set by Speassy directly. Third-party cookies are set by external services such as Google Analytics or Mixpanel.

3. What Speassy Currently Uses Cookies For

In its current version, Speassy uses cookies for three purposes only:

• Keeping you logged in (strictly necessary).
• Remembering your language preference (preferences).
• Understanding how the Platform is used (analytics via Google Analytics and Mixpanel).

Speassy does not currently use any marketing or advertising cookies. There are no third-party advertising networks active on the Platform.

4. The Two-Gate Rule

Analytics cookies at Speassy follow a strict two-gate rule. Both gates must be passed before any non-essential cookie is placed on your device:

• Gate 1 — Age verification: analytics cookies are never set for sessions where registration was blocked due to being under 16. No tracking scripts fire before age is confirmed server-side.
• Gate 2 — Cookie consent: even for verified 16+ users, analytics cookies are only set after you have explicitly accepted them via our cookie consent banner.

Strictly necessary cookies are not subject to either gate — they are required for the Platform to function and do not need consent.

5. Cookies We Use

5.1 Strictly Necessary and Preference Cookies

These cookies are essential for the Platform to work or to remember your preferences. They do not require your consent and cannot be switched off via the cookie banner.

5.2 Analytics and Error Monitoring Cookies

We use Google Analytics (GA4), Mixpanel, and Sentry for analytics and error monitoring. These are only activated after your age has been verified (16+) and you have given consent via our cookie banner.

Sentry may capture IP address, user ID, and browser information as part of error reports. Data transfers to Sentry (US) are covered by Standard Contractual Clauses (SCCs). Mixpanel is configured not to track users who have not consented and is only initialised after both age verification and cookie consent are confirmed.

5.3 Marketing Cookies

Speassy does not currently use any marketing or advertising cookies. No advertising networks or retargeting pixels are active on the Platform. This section will be updated with at least 14 days notice if marketing cookies are introduced in the future.

6. Third-Party Services

The following third-party services set cookies on your device when you use Speassy:

7. Your Rights and Controls

7.1 Cookie Consent Banner

When you first visit the Platform, our cookie consent banner will appear. You can accept all cookies, reject all non-essential cookies, or manage your preferences by category. You can change your preferences at any time by clicking the “Cookie Settings” link in the footer of the website.

7.2 How Our Banner Works

• Non-essential cookies are blocked before consent is given — analytics scripts do not load until you opt in.
• Accept All and Reject All are presented with equal visual prominence.
• No pre-ticked boxes — nothing is enabled by default except strictly necessary cookies.
• A link to this Cookie Policy is included on the banner.
• Your consent choice is recorded with a timestamp for GDPR accountability.

7.3 GDPR Rights Regarding Cookie Data

You may request access to personal data collected via cookies, request its deletion, or object to processing based on legitimate interest. Email privacy@speassy.com. We will respond within 30 days.

7.4 Browser-Level Controls

• Google Chrome: chrome://settings/cookies
• Mozilla Firefox: about:preferences#privacy
• Apple Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: edge://settings/privacy

Blocking strictly necessary cookies may prevent the Platform from working correctly, including login and session management.

7.5 Analytics Opt-Out

• Google Analytics opt-out add-on: https://tools.google.com/dlpage/gaoptout
• Mixpanel opt-out: https://mixpanel.com/optout
• Your Online Choices (EU): https://www.youronlinechoices.eu

8. International Data Transfers

Your primary data is stored on a VPS server in Frankfurt, Germany — within the EEA. Google Analytics, Mixpanel, and Sentry are US-based and receive cookie data covered by Standard Contractual Clauses (SCCs) under GDPR Art. 46(2)(c).

9. Retention

• Session cookies are deleted when you close your browser.
• Persistent cookies remain until their expiry date or until you delete them manually.
• Consent records are retained for a minimum of 3 years as evidence of compliance under GDPR Art. 5(2).

10. Changes to This Policy

We will update this Cookie Policy if new cookies are introduced. We will update the effective date and notify registered users by email at least 14 days before material changes take effect.

11. Contact and Supervisory Authority

Contact: privacy@speassy.com
Website: https://speassy.com

Urząd Ochrony Danych Osobowych (UODO)
Address: ul. Stawki 2, 00-193 Warsaw, Poland
Website: https://uodo.gov.pl
Email: kancelaria@uodo.gov.pl

This Cookie Policy was prepared in accordance with GDPR Regulation 2016/679, the ePrivacy Directive 2002/58/EC, and the Polish Electronic Communications Act of 10 November 2024.