This policy is provided in English, which is the authoritative and binding version.
This Cookie Policy should be read together with the ActON Privacy Policy. It explains how Share IT Smart S.R.L. uses cookies and similar technologies in connection with the ActON platform (acton-now.com).
01What Are Cookies?
Cookies are small text files stored on your device (computer, tablet, or mobile) when you visit a website or use a web-based application. Cookies are widely used to enable core functionality, enhance security, and improve user experience.
In addition to cookies, similar technologies such as browser local storage, session storage, and pixel tags may be used. This Policy covers all such technologies collectively referred to as “cookies.”
02Legal Framework
Cookies are used in accordance with:
- Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR);
- Directive 2002/58/EC (ePrivacy Directive), as implemented in Romanian law through Law no. 506/2004;
- Romanian Law no. 190/2018 implementing GDPR;
- Guidelines 03/2022 of the European Data Protection Board (EDPB) on deceptive design patterns and consent.
All non-essential cookies are placed only after the user has provided prior, freely given, specific, informed, and unambiguous consent through the cookie consent banner. Consent can be withdrawn at any time without affecting the lawfulness of processing performed before withdrawal.
03Types of Cookies We Use
3.1 Strictly Necessary Cookies — Always Active, No Consent Required
These cookies are essential for the operation and security of the Service. They are processed based on necessity for service provision and legitimate interest (GDPR Art. 6(1)(b) and (f); ePrivacy Directive Art. 5(3) exemption for cookies strictly necessary for a service explicitly requested by the user).
| Cookie | Purpose | Duration |
|---|---|---|
| authToken | User authentication and secure session management (JWT) | Session |
| refreshToken | Secure session renewal without re-authentication | Session |
| cookieConsent | Stores user cookie preferences to comply with legal obligations | 12 months |
| XSRF-TOKEN | CSRF protection — prevents cross-site request forgery attacks | Session |
Disabling strictly necessary cookies will prevent access to core features, including authentication and secure communication with the platform.
3.2 Analytics Cookies — Optional, Explicit Consent Required (Opt-In)
We use Google Analytics 4 (GA4), provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), to understand how the Service is used and to improve its performance and usability.
Google Analytics cookies are placed only after explicit user consent through the cookie consent banner. Consent Mode v2 is implemented, ensuring no analytics or advertising cookies are placed before consent is granted.
| Cookie | Purpose | Duration |
|---|---|---|
| _ga | Distinguishes unique users by assigning a randomly generated client identifier | 2 years |
| _ga_<container-id> | Persists session state for GA4 | 2 years |
| _gcl_au | Used by Google Conversion Linker (set only if conversion tracking is enabled) | 3 months |
Data collected is pseudonymized (pages visited, approximate city/region-level location with IP anonymization, device and browser type, referring source, and interactions such as clicks and scrolls — without capturing form contents).
International transfer: Google may transfer data to Google LLC in the United States under the EU–U.S. Data Privacy Framework and Standard Contractual Clauses, with IP anonymization enabled. Analytics data retention in GA4 is configured to 14 months.
You can opt out at any time by withdrawing consent via the Cookie Settings link, installing the Google Analytics Opt-Out Browser Add-on, or configuring “Do Not Track” where supported.
3.3 Third-Party Cookies — Payment Processing
When using paid features (ActON Starter, Standard, Professional, or Enterprise plans), our payment provider places cookies required for secure payment processing and fraud prevention.
| Provider | Purpose | Privacy Policy |
|---|---|---|
| Polar (Polar Software, Inc., USA) | Subscription billing, payment processing, fraud prevention, and tax compliance (Polar acts as Merchant of Record). | polar.sh/legal/privacy |
Polar cookies are set only when you initiate a payment-related action (e.g., upgrading, managing a subscription, or accessing the customer portal) and are governed by Polar’s own privacy policy. Polar may use Stripe as a downstream payment infrastructure provider; in such case, Stripe processes data as a sub-processor of Polar.
04Local Storage and Similar Technologies
In addition to cookies, ActON uses browser local storage and session storage for functional purposes only. These technologies are exempt from consent requirements when used strictly for service functionality requested by the user. Local storage is used exclusively for:
- Privacy notice acknowledgment (one-time per browser)
- User interface preferences (theme, layout state, language selection)
- Cookie consent preferences (mirrored from the cookieConsent cookie)
- Draft autosave for in-progress tasks and reports (per organization, per user)
- Per-organization access tokens (encrypted, scoped to the active session)
Local storage data is not used for tracking, marketing, or behavioral profiling, is scoped to your browser, and is not transmitted to third parties.
05Managing Your Cookie Preferences
You can manage your cookie preferences at any time via the Cookie Settings link in the website footer, the cookie banner (re-openable at any time), or your account settings (Privacy & Cookies section, where available). Changes take effect immediately; withdrawing consent for analytics cookies results in their deletion from your browser within the next page load.
You may also control cookies through your browser settings (Chrome, Firefox, Safari, Edge). Disabling strictly necessary cookies may impact core functionality, including the ability to log in.
06Your Rights Under GDPR
In addition to managing cookies, you have the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), objection (Art. 21), and withdrawal of consent (Art. 7(3)) regarding personal data processed through cookies, as well as the right to lodge a complaint with ANSPDCP (dataprotection.ro) or the supervisory authority in your country of residence.
07Changes to This Cookie Policy
We may update this Cookie Policy to reflect legal or regulatory changes, technical or operational changes, or updates to cookies or third-party services used. Material changes will be communicated by updating the “Last Updated” date, displaying an in-application notice for significant changes, and re-prompting for consent where required by law.
08Contact Information
- Company: Share IT Smart S.R.L.
- Registered office: Arad, Arad County, Romania
- Data Protection Email: gdpr@share-it-smart.com
- Platform: acton-now.com
- Supervisory Authority: ANSPDCP — dataprotection.ro