Cookie Policy

1. Introduction

This Cookie Policy explains how Flex Online (Pty) Ltd (“Flex”, “we”, “our” or “us”) uses cookies and similar technologies in connection with:

the Flex website available at www.flexonline.io and related public web pages operated by Flex (the “Website”); and
the cloud-based software platform and related services developed and operated by Flex (the “Flex Platform”).

This Cookie Policy should be read together with our Privacy Policy, which explains more broadly how Flex collects, uses, stores, discloses and protects Personal Information.

Where a Customer operates a white-labelled implementation of the Flex Platform, that Customer may also provide its own privacy or cookie information. Any Customer-specific notice applies alongside this Cookie Policy and does not replace Flex’s responsibilities in respect of technologies controlled by Flex.

2. What Are Cookies?

Cookies are small text files placed on a computer, mobile device or other device when a person visits a website or uses an online service.

Cookies allow a website or platform to recognise a browser or device, remember certain information and support functions such as:

maintaining a secure user session;
authenticating a Platform User;
remembering preferences;
protecting against fraud or misuse;
understanding how a service is used;
measuring performance; and
improving user experience.

Some cookies remain on a device only for the duration of a browsing session. Others remain for a defined period or until they are deleted.

3. Similar Technologies

References to “cookies” in this Policy also include comparable technologies used to store or access information on a device, such as:

local storage;
session storage;
software development kits;
pixels;
tags;
scripts;
web beacons;
mobile identifiers;
embedded content technologies; and
similar device or browser storage mechanisms.

The particular technologies used may vary depending on whether you access the Website, the Flex Platform, a mobile application or a Customer-enabled integration.

4. First-Party and Third-Party Cookies

4.1 First-Party Cookies

First-party cookies are placed directly by the Website or Flex Platform you are using.

Flex may use first-party cookies to:

operate the Website or Flex Platform;
provide secure access;
maintain sessions;
remember settings;
record consent choices; and
monitor technical performance.

4.2 Third-Party Cookies

Third-party cookies are placed or accessed by an organisation other than Flex.

They may be used where the Website or Flex Platform includes:

analytics services;
embedded videos or media;
customer-support tools;
security or fraud-prevention services;
payment services;
social-media functionality;
maps;
integrations; or
other externally supplied features.

Third parties may process information in accordance with their own terms and privacy policies. Flex seeks to assess and manage third-party providers appropriately but does not control technologies placed independently by a third party outside Flex’s reasonable control.

5. Categories of Cookies We Use

The cookies and similar technologies used by Flex may fall into the following categories.

5.1 Strictly Necessary Cookies

Strictly necessary cookies are required for the Website or Flex Platform to function securely and correctly.

They may be used to:

authenticate Platform Users;
maintain secure sessions;
enable page navigation;
balance system traffic;
protect accounts and systems;
prevent fraudulent or malicious activity;
remember privacy and cookie choices;
support essential accessibility functions; and
provide features expressly requested by the user.

Because these technologies are necessary to provide the relevant service, they cannot ordinarily be disabled through Flex’s cookie-preference controls.

Disabling them through browser or device settings may prevent parts of the Website or Flex Platform from functioning properly.

5.2 Functional and Preference Cookies

Functional cookies allow the Website or Flex Platform to remember choices and provide enhanced functionality.

They may be used to remember:

language;
region;
display preferences;
accessibility settings;
interface configuration;
previously selected options; and
other user preferences.

Where required by applicable law, these cookies will be used only after consent has been provided.

If they are disabled, some preferences may need to be selected again and certain enhanced features may not operate as intended.

5.3 Analytics and Performance Cookies

Analytics and performance cookies help Flex understand how the Website and Flex Platform are used and how well they perform.

They may collect information about:

pages or screens visited;
features used;
navigation paths;
session duration;
page-loading times;
error events;
browser and device characteristics;
approximate geographic region; and
aggregated usage patterns.

Flex uses this information to:

improve usability;
diagnose technical problems;
assess system performance;
understand demand for features;
improve Website content; and
develop and improve the Flex Platform.

Where reasonably possible, Flex uses aggregated, pseudonymised or de-identified analytics information.

Where consent is required by applicable law, analytics and performance cookies will not be activated until consent has been provided.

5.4 Marketing and Advertising Cookies

Marketing cookies may be used to:

measure the effectiveness of campaigns;
understand whether Website content leads to an enquiry or other interaction;
limit repeated advertising;
support audience measurement; and
provide more relevant communications or advertising.

Flex will not use non-essential marketing cookies without consent where consent is required by applicable law.

Flex does not use cookies to sell Personal Information.

5.5 Security Cookies

Security cookies and similar technologies may be used to:

identify suspicious login attempts;
detect automated attacks;
protect user accounts;
prevent misuse;
support authentication;
preserve audit information; and
maintain the confidentiality, availability and integrity of the Website and Flex Platform.

Security cookies that are essential to the safe operation of the service are treated as strictly necessary.

5.6 Customer-Configured and Integration Cookies

Customers may enable integrations, embedded services or additional functionality within their implementation of the Flex Platform.

These services may place or use their own cookies or similar technologies.

Where a Customer independently selects or configures such a service:

the Customer is responsible for ensuring that its use is lawful;
the Customer should provide Platform Users with appropriate information;
the third-party provider’s terms and privacy practices may apply; and
the Customer may be responsible for obtaining any consent required for technologies under its control.

Flex remains responsible for technologies that Flex itself selects and controls.

6. Cookies Used on the Website

The Website may use cookies to:

operate and secure public web pages;
remember cookie preferences;
process contact or enquiry forms;
measure Website traffic and performance;
improve Website content;
support embedded media or third-party services; and
understand the effectiveness of communications and campaigns.

A current list of cookies used on the Website should be made available through the Website’s cookie-preference tool or the cookie register attached to this Policy.

7. Cookies Used on the Flex Platform

The Flex Platform may use cookies and similar technologies to:

authenticate Platform Users;
maintain active sessions;
remember platform settings;
manage access permissions;
protect against unauthorised access;
support workflows and navigation;
monitor performance and reliability;
diagnose errors;
preserve security and audit information; and
provide features requested by a Customer or Platform User.

Many cookies used by the Flex Platform are strictly necessary because the Flex Platform cannot provide secure authenticated services without them.

Optional analytics, functional or third-party cookies will be managed in accordance with applicable law and the relevant configuration.

8. Legal Basis and Consent

Flex is established in the Republic of South Africa and primarily processes Personal Information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”).

Where cookies collect or generate Personal Information, Flex will ensure that an appropriate lawful ground exists for the Processing.

Depending on the technology and context, that ground may include:

consent;
performance of a contract;
compliance with a legal obligation;
protection of a legitimate interest of a user;
the legitimate interests of Flex, a Customer or a third party, where those interests are not overridden by the rights and interests of the Data Subject; or
another lawful ground recognised under applicable law.

Where the laws of another jurisdiction apply, including the EU GDPR, UK GDPR or applicable electronic-communications legislation, Flex will obtain consent for non-essential cookies or similar technologies where required.

Consent must be:

freely given;
specific;
informed;
unambiguous; and
indicated through an affirmative action.

Flex will not treat inactivity, silence, continued browsing or a pre-selected option as consent where an affirmative choice is legally required.

Strictly necessary cookies may be used without optional consent where permitted by applicable law because they are required to provide a service requested by the user or to maintain the essential security and operation of the service.

9. Cookie Consent and Preference Management

Where applicable, Flex will provide a cookie banner or preference-management tool that allows users to:

accept optional cookies;
reject optional cookies;
select particular categories;
review information about the technologies used; and
change or withdraw their choices later.

Rejecting optional cookies should be as straightforward as accepting them.

Withdrawing consent does not affect the lawfulness of Processing that occurred before consent was withdrawn.

A cookie or similar technology may be used to remember your privacy choices. This preference cookie is generally considered strictly necessary because it prevents you from being repeatedly asked to make the same choice and allows Flex to honour your preferences.

10. Browser and Device Controls

Most browsers and devices allow users to:

view stored cookies;
delete cookies;
block all cookies;
block third-party cookies;
receive a warning before a cookie is stored; or
restrict site-specific storage.

The method for changing these settings varies by browser and device.

Blocking all cookies may affect:

login and authentication;
session continuity;
saved preferences;
secure navigation;
forms;
integrations; and
other essential Website or Flex Platform functionality.

Browser settings do not always control all similar technologies, particularly those used in mobile applications, embedded content or local storage. Separate device, application or consent settings may therefore also need to be used.

11. Do Not Track and Global Privacy Signals

Some browsers or devices transmit “Do Not Track”, Global Privacy Control or similar preference signals.

Where legally required and technically supported, Flex will take reasonable steps to recognise applicable preference signals.

Because there is not yet a single universally adopted technical standard for all such signals, their effect may differ across browsers, services and jurisdictions.

Users should also use the available cookie-preference tool to ensure that their choices are recorded for the relevant Website or Flex Platform environment.

12. Cookie Duration

Cookies may be either:

12.1 Session Cookies

Session cookies operate only while a browser or application session remains active and are ordinarily deleted when that session ends.

12.2 Persistent Cookies

Persistent cookies remain on a device for a defined period or until the user deletes them.

Flex seeks to ensure that cookie lifetimes are proportionate to their purpose.

The duration of a particular cookie depends on:

its function;
security requirements;
the service in which it is used;
contractual requirements;
the settings of a third-party provider; and
applicable legal requirements.

The current duration of individual cookies should be recorded in the applicable cookie register.

13. Personal Information Collected Through Cookies

Depending on the cookie or similar technology used, information collected may include:

internet protocol address;
device or browser identifier;
operating system;
browser type and settings;
login or session identifier;
date and time of access;
pages or features accessed;
referring page;
actions performed;
language and region;
approximate location;
consent preferences;
error or performance information; and
security-related information.

Where this information identifies or can reasonably be linked to an individual, Flex treats it as Personal Information and processes it in accordance with the Privacy Policy.

14. International Processing

Some service providers that support cookies or similar technologies may process information outside South Africa or outside the country from which the user accesses the relevant service.

Where such international Processing occurs, Flex will take reasonable steps to ensure that appropriate contractual, organisational and technical safeguards are implemented as described in the Privacy Policy.

Where EU or UK privacy law applies, an appropriate international-transfer mechanism will be used where required.

15. Children

The Flex Platform may be used by Customers that provide services to children.

Where cookies or similar technologies process information relating to a child:

Flex will apply appropriate privacy and security safeguards;
optional technologies will be limited where appropriate;
the Customer must ensure that its use of the Flex Platform is lawful;
any consent or authorisation required from a competent person must be obtained; and
Customer-specific notices should clearly explain the technologies used.

Flex does not knowingly use children’s information collected through cookies for behavioural advertising.

16. Third-Party Websites and Embedded Content

The Website or Flex Platform may link to, embed content from or integrate with third-party services.

Interacting with such content may allow the third party to place cookies or collect information directly from the user’s device.

Examples may include:

embedded videos;
conferencing tools;
social-media content;
maps;
analytics services;
payment services;
customer-support tools; and
Customer-enabled integrations.

Flex does not control cookies placed independently by third-party services.

Users should review the relevant third party’s cookie and privacy information before interacting with its service.

17. Cookie Register

Flex will maintain a cookie register identifying, where applicable:

the cookie or technology name;
the provider;
whether it is first-party or third-party;
its purpose;
its category;
the information processed;
its duration; and
whether consent is required.

The register may be displayed:

within the cookie-preference tool;
as an appendix to this Policy; or
on a separate Trust Centre page linked from this Policy.

18. Changes to this Cookie Policy

Flex may update this Cookie Policy from time to time to reflect:

changes to the Website or Flex Platform;
new or removed technologies;
changes to third-party service providers;
changes to legal requirements;
security requirements; or
operational improvements.

The latest version will be published with its effective date and version number.

Where a change materially affects how optional cookies or similar technologies are used, Flex may request renewed consent where required by law.

19. Related Policies

This Cookie Policy should be read together with the following Flex documents:

Privacy Policy;
Website Terms;
Platform Terms;
Acceptable Use Policy;
Responsible AI Policy;
Security Overview; and
Information Security documentation.

20. Contact Us

Questions, requests or complaints regarding this Cookie Policy or Flex’s use of cookies and similar technologies may be directed to:

Effective Date:[Effective Date]
Last Updated:[Last Updated Date]
Version: 1.0
Document Owner: Flex Online (Pty) Ltd

1. Introduction

This Cookie Policy explains how Flex Online (Pty) Ltd (“Flex”, “we”, “our” or “us”) uses cookies and similar technologies in connection with:

the Flex website available at www.flexonline.io and related public web pages operated by Flex (the “Website”); and
the cloud-based software platform and related services developed and operated by Flex (the “Flex Platform”).

This Cookie Policy should be read together with our Privacy Policy, which explains more broadly how Flex collects, uses, stores, discloses and protects Personal Information.

2. What Are Cookies?

Cookies are small text files placed on a computer, mobile device or other device when a person visits a website or uses an online service.

Cookies allow a website or platform to recognise a browser or device, remember certain information and support functions such as:

maintaining a secure user session;
authenticating a Platform User;
remembering preferences;
protecting against fraud or misuse;
understanding how a service is used;
measuring performance; and
improving user experience.

Some cookies remain on a device only for the duration of a browsing session. Others remain for a defined period or until they are deleted.

3. Similar Technologies

References to “cookies” in this Policy also include comparable technologies used to store or access information on a device, such as:

local storage;
session storage;
software development kits;
pixels;
tags;
scripts;
web beacons;
mobile identifiers;
embedded content technologies; and
similar device or browser storage mechanisms.

The particular technologies used may vary depending on whether you access the Website, the Flex Platform, a mobile application or a Customer-enabled integration.

4. First-Party and Third-Party Cookies

4.1 First-Party Cookies

First-party cookies are placed directly by the Website or Flex Platform you are using.

Flex may use first-party cookies to:

operate the Website or Flex Platform;
provide secure access;
maintain sessions;
remember settings;
record consent choices; and
monitor technical performance.

4.2 Third-Party Cookies

Third-party cookies are placed or accessed by an organisation other than Flex.

They may be used where the Website or Flex Platform includes:

analytics services;
embedded videos or media;
customer-support tools;
security or fraud-prevention services;
payment services;
social-media functionality;
maps;
integrations; or
other externally supplied features.

5. Categories of Cookies We Use

The cookies and similar technologies used by Flex may fall into the following categories.

5.1 Strictly Necessary Cookies

Strictly necessary cookies are required for the Website or Flex Platform to function securely and correctly.

They may be used to:

authenticate Platform Users;
maintain secure sessions;
enable page navigation;
balance system traffic;
protect accounts and systems;
prevent fraudulent or malicious activity;
remember privacy and cookie choices;
support essential accessibility functions; and
provide features expressly requested by the user.

Because these technologies are necessary to provide the relevant service, they cannot ordinarily be disabled through Flex’s cookie-preference controls.

Disabling them through browser or device settings may prevent parts of the Website or Flex Platform from functioning properly.

5.2 Functional and Preference Cookies

Functional cookies allow the Website or Flex Platform to remember choices and provide enhanced functionality.

They may be used to remember:

language;
region;
display preferences;
accessibility settings;
interface configuration;
previously selected options; and
other user preferences.

Where required by applicable law, these cookies will be used only after consent has been provided.

If they are disabled, some preferences may need to be selected again and certain enhanced features may not operate as intended.

5.3 Analytics and Performance Cookies

Analytics and performance cookies help Flex understand how the Website and Flex Platform are used and how well they perform.

They may collect information about:

pages or screens visited;
features used;
navigation paths;
session duration;
page-loading times;
error events;
browser and device characteristics;
approximate geographic region; and
aggregated usage patterns.

Flex uses this information to:

improve usability;
diagnose technical problems;
assess system performance;
understand demand for features;
improve Website content; and
develop and improve the Flex Platform.

Where reasonably possible, Flex uses aggregated, pseudonymised or de-identified analytics information.

Where consent is required by applicable law, analytics and performance cookies will not be activated until consent has been provided.

5.4 Marketing and Advertising Cookies

Marketing cookies may be used to:

measure the effectiveness of campaigns;
understand whether Website content leads to an enquiry or other interaction;
limit repeated advertising;
support audience measurement; and
provide more relevant communications or advertising.

Flex will not use non-essential marketing cookies without consent where consent is required by applicable law.

Flex does not use cookies to sell Personal Information.

5.5 Security Cookies

Security cookies and similar technologies may be used to:

identify suspicious login attempts;
detect automated attacks;
protect user accounts;
prevent misuse;
support authentication;
preserve audit information; and
maintain the confidentiality, availability and integrity of the Website and Flex Platform.

Security cookies that are essential to the safe operation of the service are treated as strictly necessary.

5.6 Customer-Configured and Integration Cookies

Customers may enable integrations, embedded services or additional functionality within their implementation of the Flex Platform.

These services may place or use their own cookies or similar technologies.

Where a Customer independently selects or configures such a service:

the Customer is responsible for ensuring that its use is lawful;
the Customer should provide Platform Users with appropriate information;
the third-party provider’s terms and privacy practices may apply; and
the Customer may be responsible for obtaining any consent required for technologies under its control.

Flex remains responsible for technologies that Flex itself selects and controls.

6. Cookies Used on the Website

The Website may use cookies to:

operate and secure public web pages;
remember cookie preferences;
process contact or enquiry forms;
measure Website traffic and performance;
improve Website content;
support embedded media or third-party services; and
understand the effectiveness of communications and campaigns.

A current list of cookies used on the Website should be made available through the Website’s cookie-preference tool or the cookie register attached to this Policy.

7. Cookies Used on the Flex Platform

The Flex Platform may use cookies and similar technologies to:

authenticate Platform Users;
maintain active sessions;
remember platform settings;
manage access permissions;
protect against unauthorised access;
support workflows and navigation;
monitor performance and reliability;
diagnose errors;
preserve security and audit information; and
provide features requested by a Customer or Platform User.

Many cookies used by the Flex Platform are strictly necessary because the Flex Platform cannot provide secure authenticated services without them.

Optional analytics, functional or third-party cookies will be managed in accordance with applicable law and the relevant configuration.

8. Legal Basis and Consent

Flex is established in the Republic of South Africa and primarily processes Personal Information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”).

Where cookies collect or generate Personal Information, Flex will ensure that an appropriate lawful ground exists for the Processing.

Depending on the technology and context, that ground may include:

consent;
performance of a contract;
compliance with a legal obligation;
protection of a legitimate interest of a user;
the legitimate interests of Flex, a Customer or a third party, where those interests are not overridden by the rights and interests of the Data Subject; or
another lawful ground recognised under applicable law.

Consent must be:

freely given;
specific;
informed;
unambiguous; and
indicated through an affirmative action.

Flex will not treat inactivity, silence, continued browsing or a pre-selected option as consent where an affirmative choice is legally required.

9. Cookie Consent and Preference Management

Where applicable, Flex will provide a cookie banner or preference-management tool that allows users to:

accept optional cookies;
reject optional cookies;
select particular categories;
review information about the technologies used; and
change or withdraw their choices later.

Rejecting optional cookies should be as straightforward as accepting them.

Withdrawing consent does not affect the lawfulness of Processing that occurred before consent was withdrawn.

10. Browser and Device Controls

Most browsers and devices allow users to:

view stored cookies;
delete cookies;
block all cookies;
block third-party cookies;
receive a warning before a cookie is stored; or
restrict site-specific storage.

The method for changing these settings varies by browser and device.

Blocking all cookies may affect:

login and authentication;
session continuity;
saved preferences;
secure navigation;
forms;
integrations; and
other essential Website or Flex Platform functionality.

11. Do Not Track and Global Privacy Signals

Some browsers or devices transmit “Do Not Track”, Global Privacy Control or similar preference signals.

Where legally required and technically supported, Flex will take reasonable steps to recognise applicable preference signals.

Because there is not yet a single universally adopted technical standard for all such signals, their effect may differ across browsers, services and jurisdictions.

Users should also use the available cookie-preference tool to ensure that their choices are recorded for the relevant Website or Flex Platform environment.

12. Cookie Duration

Cookies may be either:

12.1 Session Cookies

Session cookies operate only while a browser or application session remains active and are ordinarily deleted when that session ends.

12.2 Persistent Cookies

Persistent cookies remain on a device for a defined period or until the user deletes them.

Flex seeks to ensure that cookie lifetimes are proportionate to their purpose.

The duration of a particular cookie depends on:

its function;
security requirements;
the service in which it is used;
contractual requirements;
the settings of a third-party provider; and
applicable legal requirements.

The current duration of individual cookies should be recorded in the applicable cookie register.

13. Personal Information Collected Through Cookies

Depending on the cookie or similar technology used, information collected may include:

internet protocol address;
device or browser identifier;
operating system;
browser type and settings;
login or session identifier;
date and time of access;
pages or features accessed;
referring page;
actions performed;
language and region;
approximate location;
consent preferences;
error or performance information; and
security-related information.

Where this information identifies or can reasonably be linked to an individual, Flex treats it as Personal Information and processes it in accordance with the Privacy Policy.

14. International Processing

Some service providers that support cookies or similar technologies may process information outside South Africa or outside the country from which the user accesses the relevant service.

Where EU or UK privacy law applies, an appropriate international-transfer mechanism will be used where required.

15. Children

The Flex Platform may be used by Customers that provide services to children.

Where cookies or similar technologies process information relating to a child:

Flex will apply appropriate privacy and security safeguards;
optional technologies will be limited where appropriate;
the Customer must ensure that its use of the Flex Platform is lawful;
any consent or authorisation required from a competent person must be obtained; and
Customer-specific notices should clearly explain the technologies used.

Flex does not knowingly use children’s information collected through cookies for behavioural advertising.

16. Third-Party Websites and Embedded Content

The Website or Flex Platform may link to, embed content from or integrate with third-party services.

Interacting with such content may allow the third party to place cookies or collect information directly from the user’s device.

Examples may include:

embedded videos;
conferencing tools;
social-media content;
maps;
analytics services;
payment services;
customer-support tools; and
Customer-enabled integrations.

Flex does not control cookies placed independently by third-party services.

Users should review the relevant third party’s cookie and privacy information before interacting with its service.

17. Cookie Register

Flex will maintain a cookie register identifying, where applicable:

the cookie or technology name;
the provider;
whether it is first-party or third-party;
its purpose;
its category;
the information processed;
its duration; and
whether consent is required.

The register may be displayed:

within the cookie-preference tool;
as an appendix to this Policy; or
on a separate Trust Centre page linked from this Policy.

Because technologies may change as the Website and Flex Platform evolve, the live cookie-preference tool or current online register should be treated as the most current operational record.

Cookie Register Template

Cookie or Technology

Provider

18. Changes to this Cookie Policy

Flex may update this Cookie Policy from time to time to reflect:

changes to the Website or Flex Platform;
new or removed technologies;
changes to third-party service providers;
changes to legal requirements;
security requirements; or
operational improvements.

The latest version will be published with its effective date and version number.

Where a change materially affects how optional cookies or similar technologies are used, Flex may request renewed consent where required by law.

19. Related Policies

This Cookie Policy should be read together with the following Flex documents:

Privacy Policy;
Website Terms;
Platform Terms;
Acceptable Use Policy;
Responsible AI Policy;
Security Overview; and
Information Security documentation.

20. Contact Us

Questions, requests or complaints regarding this Cookie Policy or Flex’s use of cookies and similar technologies may be directed to:

Flex Online (Pty) Ltd
Information Officer: D Viljoen - Executive Director
Email: trust@flexonline.io
Physical Address: 13 Umgazi Street, Menlo Park, Pretoria, South Africa, 0081
Website: www.flexonline.io

Where your query concerns cookies or technologies introduced through a Customer-selected integration or Customer-controlled configuration, Flex may refer the matter to the relevant Customer or third-party provider.