Last updated on June 01, 2025

 

Cookies Policy

INTRODUCTION

This Cookies Policy (hereinafter referred to as the “Policy”) provides a clear and comprehensive explanation of how Viabanko s.r.o. , a company incorporated under the laws of the Slovakia, under the Company number 56 700 474 , having its legal and business address at: Malinová 2802/35 Dunajská Lužná 900 42, represented by Chairman of the Board Oleg Vernygora (hereinafter referred to as the “Company”, “We”, or “Us”).

Operating as a digital over-the-counter (“OTC”) asset trading Platform We use cookies and similar tracking technologies to ensure secure functionality, enhance Client experience, monitor Platform activity, and meet legal obligations under:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as the “GDPR”);
• Directive 2002/58/EC of the European Parliament and of the Council (hereinafter referred to as the “ePrivacy Directive”);
• Act No. 18/2018 Coll. on Personal Data Protection of the Slovak Republic (as amended) (Zákon o ochrane osobných údajov a o zmene a doplnení niektorých zákonov);
• Act No. 452/2021 Coll. on Electronic Communications of the Slovak Republic (Zákon o elektronických komunikáciách).

For the purposes of this Policy, the Platform refers to the technological and communication environment used by the Company to deliver its Services. This includes, without limitation the Platform, any Client dashboards or interfaces (if applicable), communication tools such as Telegram bots or chats, and any other means by which the Company interacts with Clients (hereinafter referred to as the “Platform”).

This Cookies Policy explains how and why We use these technologies and informs you about your rights and options to manage them.

Terms in this Policy are defined in accordance with our OTC Service Terms of Use (Public Offer Agreement), Privacy Policy, and relevant data protection laws.

 

If you have any questions about this Policy, please contact Us via E-mail:

Info@viabanko.com 

1. DEFINITION OF COOKIES

1.1. Cookies are small text files that are stored on your device (such as a computer, tablet, or smartphone) when you access our Platform. These files are used to store or retrieve information that helps ensure proper functionality of the site, enhance security, personalize content, and improve Client experience.

1.2. Cookies enable the Platform to recognize your browser, remember your preferences, authenticate sessions, and collect statistical data. Some cookies may involve the processing of personal data, including identifiers linked to your device or browsing behavior.

1.3. Under Article 55(5) of Act No. 452/2021 Coll. and Article 4(1) of GDPR, any data collected through cookies that can directly or indirectly identify a natural person constitutes personal data and must be handled in accordance with applicable data protection legislation.

1.4. Cookies may only be stored or accessed on your device based on your explicit consent, unless they are strictly necessary for the operation of the Platform, in line with Section 55(5) of Act No. 452/2021 Coll. and Article 5(3) of the ePrivacy Directive.

2. INFORMATION ABOUT COOKIES 

2.1. In accordance with Article 5(3) of the ePrivacy Directive, Section 55(5) of Act No. 452/2021 Coll., and Articles 6 and 7 of the GDPR, We categorize cookies used on our Platform as follows:

2.1.1. Strictly Necessary Cookies

These cookies are essential for the operation of our Platform and OTC services. They ensure basic Platform functionality such as secure login, fraud prevention, and order/session continuity. These cookies do not require your consent and are installed automatically.

They are typically used to:

• Authenticate and maintain active Client sessions;
• Secure payment and identity verification flows;
• Store Client consent for cookie preferences.

Examples: 

• session_id
• csrf_token
• secure_auth_token

2.1.2. Functional Cookies

These cookies remember your settings and choices (e.g., preferred language, interface options) to improve your experience. They do not affect core functionality but personalize your interaction with the Platform.

They may be used to:

• Remember the selected language, interface theme;
• Save login options or location to display localized content;
• Preserve settings between sessions for a smoother experience.

Examples:

• user_language
• interface_theme

2.1.3. Analytical / Performance Cookies

These cookies collect aggregated, statistical data on how visitors use our Platform. We analyze this information to optimize Client flows, improve page loading times, detect bugs, and evaluate Client engagement with features. They may be used to: 

• Track which pages or instruments are most visited;
• Monitor the duration of Client sessions and bounce rates;
• Measure the effectiveness of product and UX design changes.

Despite anonymization, the identifiers used (e.g. IP address, device ID) may still fall under the definition of personal data and therefore require prior consent.

Examples:

• _ga
• _git
• _gat
• mouseflow_id
• clarity

2.1.4. Marketing / Targeting Cookies

Marketing cookies are used to track browsing behavior across platforms in order to build Client profiles, which are then used to display relevant financial content or promotional offers. They may be set by Us or integrated ad/analytics partners.

Their use allows:

• Delivering ads based on previous interactions;
• Measuring the performance of ad campaigns
• Running A/B tests on Client targeting
• Linking Client behavior to affiliate partners or conversion tracking tools.

Examples:

• _fbp
• linkedin_insight_tag
• retargeting_otc_id

3. COOKIE MANAGEMENT

3.1. We are committed to ensuring full transparency and Client control over how cookies are used on our Platform. Except for cookies that are essential to the operation on our Platform, you have the choice to allow or decline the use of all other types.

3.1.1. Consent Upon First Visit

When you first visit our Platform, a cookie banner will appear. The banner explains what cookies We use and why; allows you to accept, reject, or customize your cookie preferences; saves your choices for future visits.

Non-essential cookies (such as functional, analytical, or marketing cookies) are activated only after you provide your consent.

3.1.2. How to Change or Withdraw Your Consent

You may update your preferences at any time by:

• using the cookie settings panel available on our Platform;
• adjusting your browser settings to block or delete cookies;
• withdrawing your consent entirely — this will not affect any processing already carried out before withdrawal.

3.1.3. Managing Cookies via Your Browser

Most browsers allow you to manage cookies manually — for example, by deleting previously saved cookies, blocking new ones, or setting up notifications for cookie activity. These settings give you an additional level of control over your browsing experience. Keep in mind, however, that disabling or restricting some cookies — particularly those related to authentication or Client preferences — may affect the way our Platform functions.

Instructions how to manage cookies in popular browsers can be found here:

• Google Chrome
• Microsoft Edge 
• Mozilla Firefox
• Opera
• Safari

For more details, visit Your browser’s help section.

 

4. TYPES OF COOKIES WE USE

We use the following cookies:

 

Cookie Type	Purpose	Expiration
_fbp	Enables recognition of returning Clients and assesses the reach and performance of online advertising campaigns.	90 days
_ym_d	Captures the date of the Client’s initial interaction with the Platform to support long-term analytics tracking.	1 year
_ym_uid	Assigns a persistent anonymous identifier to distinguish individual Clients for behavior analysis, without linking to personal identity.	1 year
tildauid	Generates a technical Client ID used by the Tilda platform to maintain Platform performance and support aggregated visitor statistics.	A few months
tildasid	Preserves a unique session key that helps manage session continuity and deliver a smoother browsing experience during active visits.	Session
previousUrl	Stores the address of the previously visited page to help enhance navigation paths and analyze Client flow through the Platform.	Session

 

5. DATA RETENTION

5.1. We are committed to applying the principles of data minimization, proportionality, and storage limitation when processing any data derived from cookies and similar technologies.

5.2.   All cookie data collected via our Platform is retained only for the period strictly necessary to fulfill its intended purpose.

5.3.   Types of Retention:

5.3.1 We distinguish between different retention behaviors depending on the cookie’s function and ownership:

• Session cookies: Automatically deleted when you close your browser. These are used for temporary purposes such as secure session maintenance or one-time authentication.
• Persistent cookies: Remain stored on your device for a fixed duration, typically ranging from a few days to two years, unless manually deleted earlier. These cookies allow Us to remember your settings and preferences across visits.
• Consent cookies: Store your acceptance or rejection of non-essential cookies, they are retained for up to 12 months to avoid asking for repeated consent unless there is a material change in our Policy or technology.
• Third-party cookies (e.g., analytics or marketing trackers) are subject to the retention schedules defined by the respective providers. You may consult their cookie policies for more precise expiration terms.

5.4.  Purpose-Linked Retention

5.4.1. We only store cookie data for the duration necessary to achieve one of the following clearly defined purposes:

• Maintaining security and session integrity;
• Improving Client interface and personalized experience;
• Conducting aggregate analytics to enhance Platform performance;
• Tracking marketing effectiveness and Client engagement;
• Storing your cookie preferences to honor your consent choices.
• Once the purpose has been fulfilled — or you withdraw your consent — the corresponding cookie data will either be deleted or anonymized.

5.5. Ongoing Review

5.5.1. Our cookie usage and retention practices are reviewed periodically. Cookies that are no longer needed, or whose retention is not justified, are promptly removed from our systems and interfaces.

6. YOUR RIGHTS

6.1. The Company is fully committed to protecting the rights of individuals whose personal data it processes. In accordance with GDPR and Act No. 18/2018 Coll. on Personal Data Protection of Slovakia, data subjects are entitled to exercise specific rights concerning their personal information. These rights may be exercised at any time and without charge, unless otherwise permitted by law, and are handled in a timely and transparent manner.

6.2. Requests may be submitted to the Company’s designated contact point for data protection matters and will be responded to within one month of receipt, or within an extended period where permitted by law, with clear reasoning provided.

6.3. Right to Rectification

6.3.1. Data subjects may request the correction of inaccurate or incomplete personal data concerning them. Rectification will be carried out without undue delay, provided that the request is verifiable and justified.

6.4. Right to Erasure

6.4.1. Data subjects may request the deletion of their personal data under specific legal grounds, such as:

6.4.2. where the data is no longer necessary for the purposes for which it was collected;

6.4.3. where consent has been withdrawn and there is no other legal basis for processing;

6.4.4. where processing is unlawful;

6.4.5. where erasure is required by applicable law.

6.5. Right to Restriction of Processing

6.5.1 Processing may be restricted under certain conditions, such as when the accuracy of the data is contested, the processing is unlawful and the data subject opposes deletion, or pending verification of an objection request.

6.6. Right to Data Portability

6.6.1. Where the legal basis for processing is consent or contract, and the data is processed by automated means, data subjects have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller without hindrance.

6.7. Right to Object to personal data processing

6.7.1. Data subjects may object to the processing of their data at any time where the processing is based on the legitimate interests of the Company or performed for direct marketing purposes. In such cases, the processing shall cease unless compelling legitimate grounds override the interests of the individual.

6.8. Right of Access to Personal Data

6.8.1. The data subjects have the right to request confirmation as to whether their personal data is being processed by Our Company. 

6.8.2. Where processing is confirmed, they are entitled to access that data and receive relevant information, including: 

• the purposes of processing, 
• the categories of data involved, 
• the recipients (including international transfers, where applicable),
• the intended retention period, 
• their rights regarding rectification, erasure, objection, or restriction, 
• the right to lodge a complaint with a supervisory authority, 
• the source of the data (if not obtained directly from the individual),
• the existence of any automated decision-making, including profiling, along with its significance and potential consequences.

 

7. CHANGES TO THIS COOKIES POLICY

7.1. We may update or amend this Cookies Policy periodically in response to changes in applicable data protection laws, guidance from supervisory authorities, technological developments, or changes in the functionality of our Platform and services. In the event of such updates, the “Last Updated” date at the top of this page will be amended accordingly.

7.2. We encourage you to review this Policy regularly to stay informed about how We use cookies and how you can manage your preferences.