Effective Date: September 21, 2026 for any Account created on or after that date. For an Account existing on that date, this version takes effect thirty (30) days after itogai gives notice under the Customer Terms of Service, and the version in effect before this one governs until then. Last Modified: September 21, 2026 Document Version: CP-2026-09-21 v5.0
This Cookie Policy explains how Itogai LLC (“itogai”) uses cookies and comparable technologies. It is incorporated into the Privacy Policy and the Customer Terms of Service by reference.
1. What this Policy covers
“Cookies” in this Policy means cookies, local storage, session storage, web beacons, pixels, tags, software development kits and comparable technologies that store or read information on a device.
First-party Cookies are set by the itogai surface you are using. Third-party Cookies are set by another domain, usually a provider itogai engages for a specific function. The table in Section 2 says which party sets each category.
This Policy applies to every itogai surface that stores or reads anything on a device, including the marketing website, the authenticated platform, and any itogai application. A surface that stores nothing is not covered, because there is nothing to cover, and the Product Surface Register records which surfaces offer notifications.
On an itogai application, the technologies in scope are those the operating system provides rather than browser cookies: the local store that keeps you signed in, and the push subscription identifier the notification provider issues, where a surface offers notifications and you enable them. The Product Surface Register records which surfaces do. itogai places no advertising, attribution or analytics software in any itogai application obtained from an application marketplace, so no category below other than strictly necessary applies to one.
2. The categories itogai uses
The specific technologies inside each category change as providers update their products, which is why this Policy states categories and locates the providers in the Sub-processors register. Where presented, the preference control described in Section 4 lists what is live at the moment of your visit.
| Category | What it does | Party | Typical lifespan | Consent |
|---|---|---|---|---|
| Strictly necessary | Authenticates you, keeps your session intact, routes requests, and protects against forgery and abuse. The Subscription Service does not work without these | First-party, plus the identity and security providers in the Sub-processors register | Session to 30 days, and up to 1 year for the record of your cookie choice | Not required. These fall within the strict-necessity exemption in applicable ePrivacy law, and cannot be switched off |
| Functional | Remembers a preference you set: language, time zone, the view you were last in, whether you dismissed a notice | First-party | Up to 1 year | Required where applicable law requires it |
| Analytics and performance | Shows itogai how the service is used, which features are reached, and where something is failing. Includes error monitoring and a masked session replay of the authenticated platform | Third-party | Up to 2 years | Required where applicable law requires it |
| Marketing | Not in use. itogai sets no marketing cookie on the marketing website or anywhere else, and places no advertising tracker inside the authenticated platform | None | None | Not applicable |
Lifespans are maximums, not commitments to keep anything that long, and a provider may set a shorter one.
itogai places no advertising tracker on any surface. The marketing website sets no marketing cookies, and sets analytics cookies only after a visitor agrees through the preference control in Section 4.
3. What itogai does not do
- itogai does not sell personal information, and does not share it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act.
- itogai does not use cookies to build an advertising profile of you, and does not participate in an advertising exchange.
- itogai does not fingerprint a device as a substitute for a cookie.
- itogai does not use a cookie to read the contents of any message, on any surface, ever.
4. Your choices
4.1 Where consent is required. In the European Economic Area, the United Kingdom, Switzerland and any other jurisdiction whose law requires it, itogai obtains your consent before setting any cookie outside the strictly necessary category. Until you give it, only strictly necessary cookies are set.
4.2 The preference control. On a surface that sets a cookie outside the strictly necessary category, itogai presents a preference control on your first visit, through which you may accept all categories, reject all non-essential categories, or choose category by category. Rejecting all non-essential categories leaves the service fully usable. Where a surface sets cookies in only one category outside the strictly necessary category, the control offers that one choice, to accept it or reject it. The control remembers your choice on that device for up to one year, and then asks again.
4.3 Changing your mind. Where a preference control is presented, it is reachable at any time from the Cookie preferences link in the footer of every page of that surface, and your choice can be changed as often as you like. Withdrawing consent stops the relevant cookies from that point and does not affect the lawfulness of processing that happened before you withdrew it.
4.4 Browser controls. Most browsers let you block or delete cookies for a site. Blocking strictly necessary cookies will prevent you from signing in.
4.5 Global Privacy Control. itogai treats a Global Privacy Control signal as a valid opt-out wherever applicable law gives it that effect, and honors it without requiring you to interact with the preference control.
4.6 Do Not Track. itogai does not respond to a Do Not Track header, because no common standard for interpreting one was ever adopted. Section 4.5 describes the signal itogai does honor.
4.7 Industry opt-out mechanisms. Independently of itogai’s own control, two industry bodies operate opt-outs covering many marketing providers at once: the Network Advertising Initiative at optout.networkadvertising.org and the Digital Advertising Alliance at optout.aboutads.info. These are outside itogai’s control and itogai does not guarantee their coverage or availability.
5. Cookies set by a third party
Some cookies in the analytics category are set by a provider itogai engages rather than by itogai itself. Each such provider is listed in the Sub-processors register, together with what it receives and where it processes it, and each is bound by a written agreement limiting it to the service it provides to itogai.
Adding a provider that sets cookies in a category already listed in Section 2 is an update to that register, with the advance notice that register gives. Adding a category to Section 2 is a material change and follows Section 7.
A provider’s own cookies are also governed by that provider’s policy, and most publish their own opt-out.
6. Children
The Subscription Service is a business product and is not directed to children. itogai does not knowingly set a cookie on the device of anyone under the age of eighteen (18), or such higher age as local law sets.
7. Changes to this Policy
One definition governs every itogai register and every legal document wherever a change affects personal data. Where a document turns on something else, it states its own trigger, and the same thirty (30) days’ notice applies:
A change is material when it expands the categories of personal data processed, expands the purposes of processing, expands the categories of recipients, or reduces a right the customer holds.
Material: thirty (30) days’ advance notice, by publication and, where you hold an account, by email. Adding a category to Section 2 is material. So is narrowing the choices available in Section 4.
Routine: published immediately with the Document Version incremented. Adding or replacing a provider within a category already listed changes no word of this Policy; the Sub-processors register records it, with the advance notice that register gives.
8. Contact
privacy@itogai.com for questions about this Policy and for privacy rights requests. legal@itogai.com for legal notices.
Postal address: Itogai LLC Attn: Privacy 4821 Jumping Way Lake Worth, Florida 33467 United States of America
Changelog
What changed from CP v2.0, May 11, 2026, and why.
The scope now covers any itogai application, not only browsers, and says what is in scope on one.
The category table adds the party and the lifespan for each category.
Named providers left this Policy for the Sub-processors register, so that adding one no longer requires amending this document.
The claim that no third-party cookie runs inside the authenticated platform was removed. It was not true.
The age floor is eighteen (18), raised from sixteen. itogai applies eighteen wherever a lower figure would otherwise apply, because eighteen is the age of majority in most jurisdictions itogai serves.
Amended September 21, 2026, before first publication. Section 5 names the analytics and marketing categories only, because functional cookies are first-party, as Section 2 states.
A copy of the prior version is available on written request to legal@itogai.com.
Document version: CP-2026-09-21 v5.0. Published at itogai.app/legal/cookie-policy.
© 2026 Itogai LLC. All rights reserved. itogai, the itogai logo, Trustbound, TrustGraph, TrustRings, TrustReach, and Akai are trademarks of Itogai LLC.
