Cookie Policy

1. Introduction

TAVO ("we", "us"), operated by CL Lumina, LLC, uses cookies and similar technologies (pixels, web beacons, local storage, tracking SDKs, and server-side tracking tools) when you access our website and platform.

This Cookie Policy is designed to comply with:

• The General Data Protection Regulation (GDPR)
• The EU ePrivacy Directive (Cookie Law)
• The UK GDPR (where applicable)
• The California Consumer Privacy Act (CCPA), as amended by the CPRA
• Applicable U.S. privacy laws

By using our services, you consent to the use of cookies as described in this policy, subject to your cookie preferences.

2. What are cookies?

Cookies are small text files stored on your device when you visit a website. They help websites function properly, improve security, optimize the user experience, and provide analytical and marketing information.

In addition to traditional cookies, we may use:

• Pixels: code snippets that track interactions on pages or emails
• Web beacons: transparent images used to record access
• Local storage: data saved in the browser without automatic expiration
• Tracking SDKs: third-party libraries integrated into the platform
• Server-side tracking: activity logs processed on our servers

3. Types of cookies we use

3.1 Strictly necessary cookiesNo consent required

These are essential for the service to function and cannot be disabled. Without these cookies, the platform cannot operate correctly.

• Authentication and session management cookies
• Security and fraud prevention cookies
• Load balancing cookies
• Infrastructure and hosting cookies (including those required by our backend infrastructure providers)
• JWT tokens and security validation tokens
• Server-generated session identifiers
• CSRF protection

Legal basis (GDPR): Article 6(1)(b) — Contractual necessity. No consent required.

3.2 Functional cookiesMay require consent (EU/UK)

These allow us to remember user preferences and improve the experience.

• Language preferences
• Dashboard settings
• Interface personalization

Legal basis: Article 6(1)(f) GDPR — Legitimate interest. In the EU/UK, they may require consent depending on the specific implementation.

3.3 Analytics cookiesRequire consent (EU/UK)

We use analytics tools to understand how users interact with the service and improve its performance.

Google Analytics (Google LLC) — Typical cookies: _ga, _ga*, _gid, _gat

• Measure traffic and engagement
• Analyze service performance
• Improve functionality based on actual behavior

Data may be transferred to the United States. We implement Standard Contractual Clauses (SCCs) and additional safeguards. Legal basis (EU/UK): Consent — Article 6(1)(a) GDPR. Disable Google Analytics →

3.4 Advertising and marketing cookiesRequire explicit consent (EU/UK)

We may use marketing technologies for advertising and remarketing.

Google Ads — Cookies: _gcl_au, IDE, conversion cookies

• Conversion tracking
• Remarketing and retargeting
• Campaign performance analysis

Meta Pixel (Facebook) — Cookies: _fbp, fr

• Ad personalization
• Behavioral targeting
• Conversion measurement

Meta Platforms, Inc. may process data in the United States or other jurisdictions. Legal basis (EU/UK): Explicit user consent. Manage Meta preferences →

3.5 Infrastructure and platform cookies

TAVO relies on infrastructure and backend service providers that install technical cookies necessary for:

• API session integrity
• Authentication tokens
• CSRF protection
• Load balancing and scalability
• Error and performance monitoring
• CDN caching and rate limiting

These cookies are strictly necessary for the secure and stable operation of the platform. Legal basis: Article 6(1)(b) GDPR (contract execution). No consent required.

4. Summary of cookie categories

5. Third-party cookies

Third parties may set cookies when you use our service. These include:

• Google LLC (Google Analytics, Google Ads, DoubleClick)
• Meta Platforms, Inc. (Facebook Pixel)
• Hosting and cloud service providers
• Backend infrastructure providers
• Security and monitoring providers

We do not control third-party cookies. Their use is governed by their respective privacy policies. See: Google · Meta

6. International data transfers

When cookies involve transfers of personal data outside the European Economic Area (EEA), we implement appropriate safeguards:

• Standard Contractual Clauses (SCCs)
• Data Processing Agreements
• Transfer risk assessments
• Supplementary technical measures where necessary

7. Retention periods

• Session cookies: deleted when the browser is closed
• Analytics cookies: up to 24 months
• Marketing cookies: up to 24 months
• Security cookies: as needed for system protection

Exact periods may vary depending on provider configuration.

8. Your rights under the GDPR (EU/UK users)

If you are in the EU, EEA, or United Kingdom, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request deletion of data ("right to be forgotten")
• Restrict processing
• Object to processing
• Withdraw consent at any time (without affecting the lawfulness of prior processing)
• File a complaint with the relevant supervisory authority

Requests: clluminallc@gmail.com

9. Your rights under U.S. law (including California)

If you are a California resident, you may have the right to:

• Know what personal information is collected about you
• Request deletion of your personal information
• Opt-out of the sale or sharing of personal information
• Not be discriminated against for exercising your rights

TAVO does not sell personal information in the traditional sense. If data sharing for advertising qualifies as "sharing" under the CPRA, you can opt out through our cookie preferences manager.

10. Managing your cookie preferences

You can control cookies in the following ways:

• Adjust your browser settings to block or delete cookies
• Use our cookie consent banner when accessing the site
• Opt-out of targeted advertising at: optout.aboutads.info · youronlinechoices.eu
• Disable Google Analytics: tools.google.com/dlpage/gaoptout
• Manage Meta preferences: facebook.com/settings/?tab=ads

Note: Disabling certain cookies may affect the functionality of the platform.

11. Updates to this policy

We may update this Cookie Policy periodically to reflect legal, technological, or operational changes. The updated version will be published with a new effective date. Continued use of the service after changes are published constitutes acceptance of the updated policy.

12. Contact