OPINCUR HUB / COOKIE & TRACKING POLICY

Effective Date: 14 April 2026

Entity: MONOLITH LABS LTD (Co. No. 17154388)

ICO Registration: ZC126753

Registered Address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: info@monolithlabs.uk

Preamble

MONOLITH LABS LTD (the "Company", "we", or "us") operates the OPINCUR HUB application (the "Application"). This Cookie & Tracking Policy explains how the Application uses cookies, mobile advertising identifiers, software development kits (SDKs), and similar tracking technologies in compliance with the Privacy and Electronic Communications Regulations 2003 (PECR) and the UK General Data Protection Regulation (UK GDPR) as incorporated into UK law by the European Union (Withdrawal) Act 2018.

This Policy forms an inseparable part of the OPINCUR HUB Legal Framework and should be read alongside the Terms of Service and the Privacy Policy, both available within the Application's legal section.

Because the Application is a native mobile application rather than a web browser environment, the tracking technologies described in this Policy operate primarily through mobile advertising identifiers and third-party SDKs rather than traditional HTTP cookies. All references to "cookies" in this Policy encompass all such equivalent tracking technologies as deployed in the mobile application context.

Article 1. Technologies We Deploy

1.1. Essential Application Storage. The Application uses local device storage strictly necessary for the Application to function. This includes session tokens that maintain your login state between uses of the Application, preventing the requirement for repeated OAuth authentication; local preference storage retaining your interface settings and Application configuration; and security tokens provided by our infrastructure layer that distinguish human users from automated access. These mechanisms are strictly necessary for the provision of the Application and are deployed without consent under Regulation 6(4) of PECR.

1.2. Mobile Advertising Identifiers. Subject to your consent, the Application accesses your device's mobile advertising identifier — the Identifier for Advertisers (IDFA) on iOS devices and the Google Advertising ID (GAID) on Android devices. These identifiers are used by third-party advertising networks integrated into the Application to serve personalised advertisements based on your prior activity and interests. On iOS, access to the IDFA requires your explicit consent via Apple's App Tracking Transparency (ATT) framework, presented upon first use of the Application. On Android, equivalent consent mechanisms apply in accordance with Google Play policy.

1.3. Third-Party Advertising Network SDKs. The Application integrates third-party advertising network SDKs to serve advertisements. A current list of advertising network partners is available upon request at info@monolithlabs.uk. These networks may collectively collect your IDFA or GAID, IP address, device information, and interaction data to serve personalised advertisements and measure advertising performance, subject to your consent as described in Article 2.

The Meta Audience Network SDK (Meta Platforms Inc.) is one such integrated network, enabling the serving of advertisements from the Meta advertising ecosystem including Facebook and Instagram. Meta's data practices are governed by Meta's Privacy Policy available at facebook.com/privacy/policy. Each advertising network partner's data practices are governed by that network's own privacy policy, details of which are available upon request.

1.4. Analytics and Performance Monitoring. The Application may use anonymised, aggregated telemetry to monitor Application stability, identify technical errors, and improve performance. This data does not identify individual users and is processed on the basis of the Company's legitimate interests in maintaining a functional and stable Application.

1.5. Proprietary Advertising Infrastructure. The Company may operate its own internal advertising service within the Application as described in the Terms of Service. The Company's proprietary advertising infrastructure does not deploy additional third-party tracking technologies beyond those described in this Policy.

Article 2. Your Consent — How It Works

2.1. iOS — App Tracking Transparency. In accordance with Apple's App Tracking Transparency (ATT) framework and Apple App Store guidelines, the Application will present you with an ATT permission prompt upon first launch. This prompt asks for your permission to track your activity across other companies' apps and websites for the purpose of serving personalised advertisements. You may select "Allow Tracking" or "Ask App Not to Track." If you select "Ask App Not to Track," the Application will not access your IDFA and will serve only contextual (non-personalised) advertisements.

2.2. Android — Consent Mechanism. On Android devices, the Application presents an equivalent in-app consent mechanism prior to accessing your GAID for advertising purposes. You may grant or decline consent at the point of first use.

2.3. Effect of Declining Consent. If you decline tracking consent on any platform, you will continue to receive advertisements within the Application. These advertisements will be contextual — based on the content of the Application — rather than personalised based on your prior activity. Declining tracking consent does not affect your access to any core feature of the Application, including the CIO Points system, community features, or ecosystem news.

2.4. Withdrawing Consent. You may withdraw your tracking consent at any time through your device settings. On iOS, navigate to Settings → Privacy & Security → Tracking and toggle off OPINCUR HUB. On Android, navigate to Settings → Google → Ads and reset or opt out of your Advertising ID. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

Article 3. What We Do Not Deploy

The Company expressly declares that the Application does not deploy the following tracking technologies.

The Application does not use web browser cookies, as it is a native mobile application operating outside a browser environment. The Application does not deploy keylogging, screen recording, or session replay tools of any kind. The Application does not use cross-site tracking pixels or web beacons. The Application does not build or maintain behavioural profiles for sale to data brokers. The Application does not deploy any tracking technology not described in this Policy without prior notice and, where required, updated consent.

Should the Company determine it necessary to integrate any additional tracking technology or advertising network partner in future, the list of partners available upon request at info@monolithlabs.uk will be updated accordingly. Where required by PECR or UK GDPR, your renewed consent will be sought before any new tracking technology is deployed.

Article 4. Third-Party Services and Protocol Interactions

You acknowledge that the Application may provide access to or information about third-party Web3 protocols, platforms, and services within the OPINCUR ecosystem. This Cookie & Tracking Policy applies strictly to the OPINCUR HUB Application operated by the Company. The Company cannot govern, control, or accept responsibility for the tracking practices, cookie policies, or data architectures of any third-party service or protocol you access through or in connection with the Application. Your interaction with any third-party service is governed by that provider's own terms and privacy documentation.

Article 5. Updates to This Policy

The Company reserves the right to update this Policy to reflect changes in applicable law, regulatory guidance, the Application's technical infrastructure, or the Company's advertising network partnerships. Material changes will be communicated via an in-application notification in accordance with the Terms of Service. The Effective Date at the top of this document will be updated to reflect any amendments. Continued use of the Application following notification of any material change constitutes your acknowledgment of the revised Policy.

Article 6. Contact and Enquiries

If you have questions regarding the Company's use of tracking technologies, your consent choices, or any aspect of this Policy, please contact:

Email: info@monolithlabs.uk

Post: MONOLITH LABS LTD, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: info@monolithlabs.uk

CONTACT