## 1. In general
1. As a general rule, terms starting with an upper-case letter convey the meaning attributed to them in our general terms and conditions or otherwise in this *Cookie Management Policy*.
2. ***Relation with the general terms and conditions.*** This *Cookie Management Policy* applies in addition to the general terms and conditions and other documents included in the Contractual Documentation, including the Privacy Policy. In the event of any discrepancies between the general terms and conditions and this *Cookie Management Policy*, this *Cookie Management Policy* shall prevail.
3. A summary table of the Cookies (term defined below) used by Sway is attached to this *Cookie Management Policy*.
## 2. Purpose
1. The purpose of this *Cookie Management Policy* is to inform Users about the nature of the Cookies used by Sway and certain third parties and their use.
2. In case of disagreement with the present *Cookie Management Policy*, the User may, from their browser or device, block the use of Cookies. In this case, it is possible that all or part of the Site, the Platform or the Services may be inaccessible or unusable.
## 3. Definition and function
1. By "Cookies" it is understood a cookie or any similar technology, i.e., the equivalent of a small text file, stored on the User's access terminal to the Site or Platform (computer, tablet, telephone, etc...).
2. Cookies are placed by Sway or by third parties on the terminals used by the User to consult the Site or the Platform in order to collect information relating to his navigation or to optimize/personalize their experience. Cookies are either necessary for the use of Sway’s Services or ultimately used to make the User's visit to the Provider's Site and Platform more enjoyable and more relevant.
## 4. Cookies - issuers
1. ***Sway's cookies.*** These are Cookies deposited by Sway Finance.
2. ***Third party cookies.*** These are Cookies deposited by third parties (such as Google, Webflow, and other third parties listed in the Table 2 of Privacy Policies).
## 5. Cookies - types and usefulness
1. ***Cookies strictly necessary.*** Some Cookies are necessary to use our Services. These are mainly Sway's Cookies. These Cookies are used in particular to enable the User to access the Platform securely.
2. ***Analytical cookies.*** Certain Cookies allow Sway to understand the User's use and performance of the Platform. These are both Sway's Cookies and third-party Cookies. These Cookies allow Sway to recognize and count the number of Users of the Site or Platform and to determine how Users use the Site or the Platform. This allows Sway to improve the Site, the Platform and the Services it offers.
3. ***Functional cookies.*** Certain Cookies are used to enable the Platform to improve the user experience, such as using a default language or simplifying their access to their active session. These are mainly Sway's Cookies.
4. ***Cookies related to bank account information and payment submission.*** Some Cookies are used to secure data exchange between the Platform and bLink. These cookies are mainly third-party Cookies issued by Sway's financial partners. Sway has no control over these Cookies.
## 6. Cookie management
1. Users can set up the use of Cookies by choosing at any time to enable or disable the use of all or part of Sway's and/or third-party Cookies.
2. Cookies are set through each of the terminals used for browsing the Site or Platform and according to the terms and conditions given for these platforms in their respective documentation.
3. You are reminded that certain Cookies are necessary for the use of certain Services (art. 5.1) and that the deactivation of all or part of them may result in the impossibility to access or use certain Services.
4. The non or de-activation of Analytical Cookies (art. 5.2) has the consequence of preventing the User's browser from sending information to the issuers of said Cookies and does not in principle prevent the use of the Platform.
5. Disabling Functional Cookies (art. 5.3) may prevent access to all or part of the Services offered by the Platform.
6. Disabling Payment Security Cookies (Section 5.4) may prevent the use of certain Sway's Services.
7. Sway cannot be held responsible for the Use of data collected by third parties and/or for Cookies deposited by them. It is the User's responsibility to manage Cookies in accordance with each issuer. For more information regarding third party Cookies, please refer to the cookie management policy of each of these issuers.
## Appendix to the Cookie Management Policy
### Summary Table of Cookies Used by Sway
| Cookies | Type | Issuer | Purpose |
|---------------------|-----------------------------|------------------|-------------------------------------------------------------------|
| Analytics cookie(s) | Analytical cookies | Google Analytics | Usage measurement of the Platform and Site |
| Webflow cookies | Analytical & functional | Webflow | Usage measurement and potential usage improvement of the Site |
| Marketing cookies | Marketing analytics cookies | Hubspot | Lead source attribution and communication performance measurement |
