NeuralShift, Deep Learning Services, Lda. ("NeuralShift", "we", "us" or "our"), with its registered office at Rua João Saraiva 38, 1700-051 Lisbon, Portugal, uses cookies and similar technologies on its Website (www.affine.law) and in Affine's Software (affine.neuralshift.ai), jointly referred to as the "Platform". This Cookie Policy explains what cookies are, how we use them, what choices you have in relation to cookies, and other information relevant to these technologies. It should be read together with ourPrivacy Notice, which describes how we process personal data more generally.

§ 1What cookies are & how we use them

Cookies are small text files stored on your device (computer, tablet or smartphone) when you visit a website. These files enable the website to recognise your device on subsequent visits, remembering certain information such as browsing preferences (for example, language, font size, display options) and, in some cases, authentication data.

Our Platform uses cookies and similar technologies (such as local storage) in order to:

• Ensure the proper functioning of the Platform;
• Enhance the user experience;
• Analyse usage patterns and traffic; and
• Strengthen security.

Only strictly necessary cookies are set by default. All other cookies are activated only with your prior express consent.

§ 2Types of cookies

Strictly Necessary Cookies

Essential for the operation of the Platform. They allow browsing and access to secure areas (e.g., login). As the operation of the Platform depends on these cookies and, consequently, the services cannot be provided without them, they do not require consent.

Performance/Analytics Cookies

These cookies collect information about how you interact with the Platform (such as pages visited, navigation paths, time spent, and error diagnostics) in order to measure audience reach, understand usage patterns, and improve performance and user experience. They may also support session recording and heatmap features, which capture how pages are used, in order to diagnose errors and improve usability. The data are processed in aggregate and/or pseudonymised form; we do not use these cookies to identify you directly, except in the Affine software application, where analytics events are associated with your user account once you sign in, as described in our Privacy Notice. In no case do we use these technologies to take decisions producing legal or similarly significant effects. These cookies are deployed only with your prior express consent. If you decline them, the Platform will remain available, but analytics-based improvements may be limited.

Functionality Cookies

When you access the Platform, these cookies enable your browser to remember choices you have made (for example, language preferences, region) to provide a more personalised experience. These require consent.

Advertising/Targeting Cookies

Not used by the Platform.

§ 3Retention periods

Cookies have different retention periods:

• Session Cookies: Automatically deleted when you close your browser;
• Persistent Cookies: Remain on your device for the period defined below or until manually deleted.

The retention periods for each cookie are indicated below.

§ 4Detailed cookie list

Below we provide a detailed and up-to-date list of the specific cookies and equivalent technologies (such as local storage entries) used on the Platform, together with their purposes and durations:

This list is reviewed whenever the cookies and technologies used on the Platform change and, in any event, by the date indicated as "Last Reviewed" at the top of this Policy.

§ 5Cookie management

Consent. When you first access the Platform, a cookie banner will be displayed, requesting your consent to the use of non-essential cookies. You may accept all cookies, reject all (except those that are necessary), or manage your preferences individually.

Browser settings. You may configure your browser to block cookies or alert you when cookies are being set. Please consult your browser's help section:

• Chrome: support.google.com/chrome/answer/95647
• Firefox: support.mozilla.org
• Safari: support.apple.com/guide/safari
• Edge: support.microsoft.com/help/4027947

Changing or withdrawing consent. You may change or withdraw your cookie preferences at any time, with the same ease with which you gave it, through the cookie settings available on the Platform, which reopen the consent banner. Withdrawing your consent does not affect the lawfulness of the use of cookies prior to such withdrawal. Your preferences (whether consent or refusal) are stored for 12 (twelve) months, after which the banner will be displayed again so that you may renew your choices.

§ 6Third-party tools & content

The Platform contains links or buttons that lead to third-party services. The use of these features may result in the collection of personal data. Interacting with such buttons, tools or content may automatically send certain information from your browser to the entities operating those websites.

PostHog

NeuralShift uses PostHog, through cookies and similar technologies, to analyse the use of the Platform and to generate reports on its activity. The information generated by the cookies regarding your use of the Platform (including your IP address) is transmitted to and stored by PostHog on servers in the European Union. PostHog may also record user sessions and generate heatmaps, which capture how pages are used, in order to diagnose errors and improve usability. For more information on the use of PostHog and how it collects and processes data, please visit: posthog.com/privacy.

New Relic

NeuralShift uses New Relic to monitor the performance, availability and stability of the Affine software application, including the detection and diagnosis of technical errors. The information generated for these purposes (such as access logs, error events and the replay of sessions affected by application errors) is processed as Platform Analytics Data, as described in our Privacy Notice, and, where NeuralShift acts as Processor on behalf of the Client, as Service Operations and Security Data, in accordance with the applicable Data Processing Addendum. This information is transmitted to and stored by New Relic on servers in the European Union.

HubSpot

The Website includes a meeting-scheduling link operated by HubSpot. When you schedule a demonstration through that link, you are directed to HubSpot's own domain, where HubSpot sets its own cookies under its responsibility. For more information on how HubSpot processes your personal data, see: legal.hubspot.com/privacy-policy.

Social media buttons

The Website includes buttons linking to NeuralShift's profiles on X, LinkedIn, GitHub and Hugging Face. When you interact with any of these buttons, your browser establishes a connection with the servers of the platform concerned, which may identify the website you are visiting and collect other personal data, such as your IP address.

For more information on how each platform processes your personal data, see:

• X: x.com/en/privacy
• LinkedIn: linkedin.com/legal/privacy-policy
• GitHub: docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement
• Hugging Face: huggingface.co/privacy

§ 7International transfers

Some of our providers of cookies and similar technologies may be located outside the European Economic Area (EEA). Where this involves the transfer of personal data, we ensure the implementation of appropriate safeguards as required by applicable law, namely:

• European Commission adequacy decisions;
• Standard Contractual Clauses (SCCs);
• Other mechanisms recognised by applicable law.

§ 8Your rights

In connection with the use of cookies and similar technologies, you have the right, among other things, to:

• Consent to or refuse the use of non-essential cookies via the banner or the preference settings provided;
• Change or withdraw consent at any time by accessing the cookie-management options on the Platform;
• Obtain information about the types of cookies used, their purposes, duration and providers;
• Lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados - CNPD, www.cnpd.pt) if you consider that your rights have not been duly safeguarded.

§ 9Amendments to this Policy

This Cookie Policy may be updated from time to time, in particular to reflect material legal, technical or operational changes. Whenever material changes are made, we will inform you by:

• A prominent notice on the Platform;
• An update to the "Last Reviewed" date at the top of this Policy;
• A renewed request for consent, where applicable.

§ 10Governing law

This Policy is governed by Portuguese law, in particular Law No. 41/2004 of 18 August, which transposes Directive 2002/58/EC (the ePrivacy Directive), Regulation (EU) 2016/679 (the GDPR), as well as other relevant legislation on privacy and electronic communications.

§ 11Contact

For any questions about this Policy or about the use of cookies and similar technologies on the Platform, you may contact NeuralShift through the contact channels indicated in our Privacy Notice.

For further information about our providers and the description of safeguards implemented for international transfers of personal data, contact channels or for exercising of rights, please refer to our Privacy Notice.