Cookie Policy — pocket.ceo

Effective date: 2026-06-21 Last updated: 2026-06-21

This Cookie Policy describes how the pocket.ceo service (the “Service”, “we”, “us”) uses cookies and similar information-storage technologies on the user’s device. This document should be read together with the pocket.ceo Privacy Policy and Terms of Service.

This Policy covers:

• the pocket.ceo landing page, on which the Google Analytics 4 (GA4) analytics tool operates, and
• the pocket.ceo web application (in preparation), in which — once launched — a first-party login session cookie will be used.

This Policy does not cover advertising cookies or marketing profiling — the Service does not use cookies for advertising purposes.

1. Data controller / operator of the Service

The operator of the Service and the controller of personal data processed in connection with cookies is:

VALITY Łukasz Wątroba — sole proprietorship (jednoosobowa działalność gospodarcza, JDG) Registered address: Kretowskie 44, 43-436 Górki Wielkie, Poland NIP (Polish tax ID): 5472086879 REGON (Polish business register no.): 24361592800000 Registered in CEIDG (the Polish business register) Website: https://pocket.ceo

For any matters concerning cookies and the protection of personal data, please contact: hi@pocket.ceo.

With respect to data collected via Google Analytics, the provider of that tool (Google) may act as a separate controller or joint controller of certain processing operations under its own terms; details are set out in Google’s privacy policy (see section 6).

2. What cookies are

Cookies are small text files stored on the user’s end device (computer, phone, tablet) when using the Service. Among other things, they allow a logged-in user’s session to be maintained and — subject to consent — visit statistics to be collected.

In this Policy, “cookies” also means other comparable technologies used to store or access information on the end device (e.g. local storage mechanisms) where they are used for the same purposes.

We distinguish:

• first-party cookies — set by the Service itself (the pocket.ceo domain),
• third-party cookies — set by external providers whose services we use (here: Google, as part of Google Analytics 4).

By purpose, we distinguish:

• strictly necessary cookies — required for the Service to function correctly (e.g. maintaining the login session); their use does not require user consent,
• analytics (statistical) cookies — used to measure traffic and how the Service is used; their use requires the user’s prior consent.

3. List of cookies used

3.1. Strictly necessary cookies (no consent required)

The session cookie is strictly necessary: without it, logging in and using the account in the application is impossible. For this reason, its use does not depend on consent and it cannot be disabled through the consent-management mechanism without losing the ability to use the post-login service.

3.2. Analytics cookies (consent required)

On the landing page of the Service we use Google Analytics 4, provided by Google. It is used to analyse traffic to the page and how it is used, for statistical purposes.

Data collected by Google Analytics is used solely for statistical purposes (measuring the number and behaviour of visitors). We do not use it for advertising or marketing profiling.

Consent gate. The Google Analytics script on the landing page is loaded only after the user has given prior consent, via a consent-management mechanism (CMP) with Google Consent Mode v2 in place. Before consent is given, analytics cookies are not set and no analytics data is collected.

4. Purposes and legal bases

Analytics cookies are activated only after the user has given consent. Withholding consent does not limit access to the Service’s content — it merely means that visit statistics are not collected.

The obligation to obtain consent for storing and accessing information on the user’s end device (other than where strictly necessary) follows from the telecommunications / electronic-communications rules implementing Directive 2002/58/EC (ePrivacy); the processing of personal data linked to cookies is governed by the GDPR. As at the publication date, the national basis in force is the Polish Electronic Communications Law (Prawo komunikacji elektronicznej, PKE), Article 399, which has been in force since 10 November 2024.

5. Consent and its withdrawal

5.1. Giving consent

Consent to analytics cookies should be given freely, on an informed basis and unambiguously — through a consent-management mechanism (banner / CMP) in which:

• the “Accept all” and “Reject all” options are equivalent and available at the first level (rejecting consent is just as easy as giving it),
• analytics cookies are not activated before consent is given.

The above consent mechanism (banner/CMP with Google Consent Mode v2) is in place on the landing page — see section 3.2.

5.2. Withdrawing consent

Consent to analytics cookies may be withdrawn at any time, just as easily as it was given. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal.

Consent may be withdrawn:

• by reopening the consent panel at any time via the “Cookie settings” link in the page footer, and
• through the web browser settings (see section 7).

6. Transfer of data outside the EEA (Google Analytics)

Using Google Analytics involves transferring data to Google and may include its processing on infrastructure located in the United States (USA) — a country outside the European Economic Area (EEA).

The basis for such a transfer is the EU–US Data Privacy Framework (DPF): Google LLC holds an active DPF certification. Details of Google’s data-transfer frameworks are available at https://policies.google.com/privacy/frameworks.

Detailed information about Google’s data processing is available in Google’s privacy policy: https://policies.google.com/privacy.

Note. This Cookie Policy describes only transfers connected with cookies (Google Analytics → USA). Other data transfers relating to the operation of the pocket.ceo application (including to AI model providers based in the USA) are described in the Privacy Policy and are outside the scope of this document.

7. Managing cookies in the browser

Regardless of the consent mechanism in the Service, the user may manage cookies independently via their browser settings — including blocking, deleting or restricting their storage. The configuration method differs depending on the browser; instructions are available in the help sections of the most popular browsers (Google Chrome, Mozilla Firefox, Safari, Microsoft Edge).

Please note that:

• blocking strictly necessary cookies (including the session cookie) may make it impossible to log in and use the account in the web application,
• blocking or deleting analytics cookies does not affect the ability to use the Service.

With regard to Google Analytics, the user may additionally use the browser add-on for blocking Google Analytics provided by Google: https://tools.google.com/dlpage/gaoptout.

8. User rights

With respect to personal data processed in connection with cookies, the user has the rights described in detail in the Privacy Policy, including the right of access, rectification, erasure, restriction of processing, objection, and the right to lodge a complaint with the supervisory authority (in Poland: the President of the Personal Data Protection Office, UODO).

9. Changes to the Cookie Policy

This Cookie Policy may be updated if the technologies used, providers, applicable law, or scope of the Service change. We will inform users of material changes within the Service. The current version of the Policy applies from the publication date indicated at the beginning of the document.