Cookies Policy

1. Introduction

This Cookie Policy explains how All Things Universal LLC (“ATU,” “Company,” “we,” “our,” or “us”) uses cookies and similar technologies when you access or use the All Things Universal website, marketplace platform, vendor pages, mobile applications, tools, communications, advertisements, and related services, collectively referred to as the “Platform.”

This Cookie Policy should be read together with ATU’s Privacy Policy, Terms of Use, Vendor Marketplace Agreement, and any other policies published by ATU.

This Policy should also be read with ATU’s Master Terms of Use, Vendor Marketplace Agreement, Prohibited and Restricted Products & Services Policy, and any cookie banner, cookie preference center, privacy notice, or consent notice displayed on the Platform.

This Policy explains:

• What cookies are.
• What types of cookies ATU may use.
• Why ATU uses cookies.
• How third parties may use cookies through the Platform.
• How users can manage cookie preferences.
• How ATU handles cookie consent where required by law.

Where required by applicable law, ATU will request user consent before placing non-essential cookies or similar tracking technologies on a user’s device.

2. What Are Cookies?

Cookies are small text files placed on your browser, computer, tablet, mobile phone, or other device when you visit a website or use an online service.

Cookies may help websites and platforms:

• Recognize users.
• Keep users logged in.
• Remember preferences.
• Improve functionality.
• Support security.
• Prevent fraud.
• Analyze performance.
• Measure advertising.
• Personalize user experience.

Cookies may be set directly by ATU, known as first-party cookies, or by third parties that provide services to ATU, known as third-party cookies.

Cookies do not always identify a person directly, but they may be linked to personal information, device information, browsing behavior, account activity, advertising identifiers, or other data.

3. Similar Technologies

ATU may also use technologies that function in similar ways to cookies, including:

• Pixels.
• Web beacons.
• Tracking tags.
• Scripts.
• Local storage.
• Session storage.
• Software development kits.
• Device identifiers.
• Advertising identifiers.
• Log files.
• Embedded content technologies.
• Analytics technologies.

For purposes of this Policy, references to “cookies” include cookies and similar technologies unless otherwise stated.

4. Types of Cookies ATU May Use

ATU may use the following categories of cookies and similar technologies.

A. Strictly Necessary Cookies

These cookies are required for the Platform to function properly.

They may be used for:

• User login and authentication.
• Account security.
• Fraud prevention.
• Session management.
• Shopping cart or inquiry functionality.
• Payment-related security.
• Load balancing.
• Cookie consent settings.
• Platform availability.
• Legal and compliance functions.

Because these cookies are necessary for the Platform to operate, they may be used without prior consent where permitted by law.

If users block strictly necessary cookies, parts of the Platform may not work correctly.

B. Functional Cookies

Functional cookies allow the Platform to remember choices and preferences.

They may be used for:

• Language preferences.
• Currency preferences.
• Region or country settings.
• Accessibility preferences.
• Saved login settings.
• Display preferences.
• Form completion support.
• User interface settings.

These cookies help improve user experience and make the Platform easier to use.

Where required by law, ATU will request consent before using functional cookies that are not strictly necessary.

C. Analytics and Performance Cookies

Analytics and performance cookies help ATU understand how users interact with the Platform.

They may collect information such as:

• Pages visited.
• Time spent on pages.
• Click activity.
• Search activity.
• Error messages.
• Traffic sources.
• Browser type.
• Device type.
• Approximate location.
• Performance data.
• Session behavior.

ATU may use this information to:

• Improve Platform performance.
• Understand user behavior.
• Identify technical issues.
• Improve search and navigation.
• Measure content effectiveness.
• Optimize vendor pages and Platform features.

Analytics data may be aggregated or anonymized where possible.

Where required by law, ATU will request consent before using non-essential analytics cookies.

D. Advertising and Targeting Cookies

Advertising and targeting cookies may be used to deliver, measure, and improve advertisements.

They may be used for:

• Showing relevant advertisements.
• Measuring ad performance.
• Limiting repeated advertisements.
• Creating audience insights.
• Understanding campaign performance.
• Retargeting users who interacted with the Platform.
• Measuring sponsored listings or paid placements.
• Supporting vendor advertising or promoted listings.

These cookies may be placed by ATU or by approved advertising, analytics, social media, or marketing partners.

Advertising and targeting cookies may involve the sharing of personal information, device identifiers, browsing activity, or online identifiers with third parties.

Where required by applicable law, ATU will request consent before using advertising or targeting cookies and will provide applicable opt-out rights.

E. Security and Fraud Prevention Cookies

Security cookies help ATU protect users, vendors, accounts, payments, data, and the Platform.

They may be used to:

• Detect suspicious activity.
• Prevent unauthorized access.
• Identify fraud attempts.
• Protect user accounts.
• Monitor login activity.
• Detect abuse, spam, scams, or harmful activity.
• Support vendor verification and compliance reviews.
• Protect against cyberattacks.

Some security cookies may be strictly necessary for Platform protection.

F. Social Media and Embedded Content Cookies

The Platform may include social media features, share buttons, embedded videos, maps, reviews, third-party widgets, or other embedded content.

These third-party tools may place cookies or collect information about your activity, even if you do not interact directly with the feature.

Examples may include:

• Social media plugins.
• Embedded videos.
• Maps.
• Third-party login tools.
• Review widgets.
• Chat tools.
• Advertising pixels.

These third parties may use cookies according to their own privacy policies and cookie policies.

5. Why ATU Uses Cookies

ATU may use cookies and similar technologies to:

• Operate the Platform.
• Keep users logged in.
• Authenticate accounts.
• Protect accounts and data.
• Prevent fraud and abuse.
• Remember user preferences.
• Support vendor pages and marketplace features.
• Support inquiries, carts, bookings, messages, or account tools.
• Measure Platform performance.
• Understand user activity.
• Improve services.
• Personalize content.
• Deliver and measure advertising.
• Support sponsored listings and paid placements.
• Analyze marketing campaigns.
• Comply with legal and regulatory obligations.
• Store cookie consent choices.

6. First-Party and Third-Party Cookies

First-Party Cookies

First-party cookies are placed directly by ATU or by service providers acting on ATU’s behalf.

These cookies may support:

• Platform operation.
• Login.
• Security.
• Preferences.
• Analytics.
• Consent management.
• Vendor tools.
• Customer support.

Third-Party Cookies

Third-party cookies are placed by external companies that provide services, features, analytics, advertising, payment processing, fraud prevention, social media tools, embedded content, or other functionality.

Third parties may include:

• Payment processors.
• Analytics providers.
• Advertising networks.
• Social media platforms.
• Fraud prevention providers.
• Security providers.
• Customer support tools.
• Hosting and infrastructure providers.
• Embedded content providers.
• Marketing automation providers.

ATU does not control all third-party cookie practices. Users should review the privacy and cookie policies of those third parties.

7. Cookie Consent

Where required by applicable law, ATU will provide a cookie consent mechanism before placing non-essential cookies on your device.

The cookie consent mechanism may allow users to:

• Accept all cookies.
• Reject non-essential cookies.
• Customize cookie preferences.
• Change consent choices.
• Withdraw consent.
• View cookie categories.
• Review information about cookie purposes.

Strictly necessary cookies may remain active because they are required for the Platform to function.

ATU should not activate non-essential analytics, advertising, targeting, or similar cookies before consent where applicable law requires prior consent.

8. Cookie Preference Center

ATU may provide a Cookie Preference Center that allows users to manage cookie settings.

The Cookie Preference Center may allow users to control categories such as:

• Strictly necessary cookies.
• Functional cookies.
• Analytics cookies.
• Performance cookies.
• Advertising and targeting cookies.
• Social media and embedded content cookies.

Users may return to the Cookie Preference Center at any time to update their choices where available.

Changes to cookie preferences may not remove cookies already stored on a user’s browser. Users may need to delete existing cookies through browser or device settings.

8A. Consent Records and Cookie Preference Logs

Where ATU uses a cookie banner, consent management tool, or Cookie Preference Center, ATU should maintain reasonable records of cookie choices, consent changes, and consent withdrawals where required or appropriate.

Consent or preference records may include:

• Date and time of consent or preference selection.
• Cookie categories accepted, rejected, customized, withdrawn, or changed.
• Consent method or tool used.
• Country, region, browser, device, or technical information where lawful and necessary for consent records.
• Cookie banner, cookie table, consent notice, or policy version presented at the time of the choice.
• Records of withdrawal, preference updates, or opt-out requests.

Consent records should be retained only as long as reasonably necessary for legal, compliance, audit, security, dispute-resolution, and operational purposes, and should be protected in accordance with ATU’s Privacy Policy, Information Security Policy, and applicable law.

8B. Cookie Consent Implementation and IT Alignment

Where ATU uses a cookie banner, consent management platform, Cookie Preference Center, analytics tools, advertising pixels, remarketing tools, embedded content, or similar tracking technologies, ATU should coordinate legal, compliance, marketing, and IT implementation before activating non-essential cookies or tracking tools.

The live cookie banner, cookie table, consent records, preference controls, opt-out mechanisms, and script-blocking settings should match the actual cookies, pixels, tags, software development kits, and third-party tools used on the Platform.

Before publication or major marketing activation, ATU should test whether non-essential analytics, advertising, targeting, remarketing, and social media cookies are blocked until the required consent or preference choice is obtained where applicable law requires prior consent.

9. Withdrawing Consent

Where ATU relies on consent for cookies or similar technologies, users may withdraw consent at any time.

Withdrawal methods may include:

• Cookie Preference Center.
• Browser settings.
• Device settings.
• Privacy settings.
• Opt-out links provided on the Platform.
• Contacting ATU where applicable.

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

Some Platform features may not function properly if certain cookies are disabled.

10. Browser and Device Controls

Most browsers allow users to manage cookies.

Depending on the browser or device, users may be able to:

• Block cookies.
• Delete cookies.
• Receive cookie alerts.
• Restrict third-party cookies.
• Clear browsing data.
• Disable tracking technologies.
• Manage site permissions.
• Control mobile advertising identifiers.
• Adjust privacy settings.

Users should review their browser or device instructions for more information.

Blocking or deleting cookies may affect Platform functionality, user experience, account access, saved preferences, security tools, carts, forms, or vendor features.

11. Do Not Track and Opt-Out Preference Signals

Some browsers may send “Do Not Track” signals.

Because there is not one universally accepted standard for responding to Do Not Track signals, ATU may not respond to all Do Not Track signals unless required by applicable law.

Some privacy laws may require businesses to honor certain opt-out preference signals or global privacy controls.

ATU should seek legal counsel to determine whether it must recognize browser-based opt-out preference signals, including Global Privacy Control or similar tools, based on the jurisdictions where ATU operates or targets users.

12. Do Not Sell or Share and Targeted Advertising Choices

ATU does not sell personal information for money.

However, some privacy laws define “sale,” “sharing,” or “targeted advertising” broadly. Certain advertising, analytics, tracking, retargeting, or third-party cookie activities may be considered a “sale,” “sharing,” or targeted advertising under applicable law.

Where required by law, ATU will provide users with a way to opt out of applicable sale, sharing, targeted advertising, or profiling activities.

This may include a link or mechanism such as:

• “Do Not Sell or Share My Personal Information.”
• “Your Privacy Choices.”
• “Cookie Preferences.”
• “Manage Tracking Preferences.”

Legal counsel should confirm whether ATU requires these links or controls based on its users, markets, data practices, and advertising tools.

13. Cookies and Vendor Advertising

ATU may offer sponsored listings, paid placements, promoted vendor pages, display advertisements, affiliate links, or other promotional features.

Cookies and similar technologies may be used to:

• Measure impressions.
• Measure clicks.
• Track campaign performance.
• Understand user engagement.
• Prevent ad fraud.
• Limit repeated ads.
• Improve ad relevance.
• Measure promoted vendor visibility.

Where required by law, sponsored content, paid placements, or promotional content should be disclosed clearly.

Where required by law, advertising cookies should only be used with proper consent or applicable opt-out rights.

14. Cookies and Mobile Applications

If ATU offers mobile applications, similar technologies may be used within those applications.

These may include:

• Mobile software development kits.
• Device identifiers.
• Advertising identifiers.
• Push notification identifiers.
• App analytics tools.
• Crash reporting tools.
• Fraud prevention tools.
• Location-related settings where enabled.

Users may manage certain app tracking preferences through device settings.

Mobile app tracking practices should also be reviewed under applicable app store requirements and privacy laws.

15. International Users

ATU may operate internationally and may process cookie-related information in the United States or other countries where ATU, its vendors, partners, service providers, or technology providers operate.

These countries may have data protection laws that differ from those in your country.

Where required by applicable law, ATU will use appropriate safeguards for international transfers of personal information associated with cookies and similar technologies.

More information is provided in ATU’s Privacy Policy.

16. Cookie Retention

Cookies may be stored for different periods depending on their purpose.

Session Cookies

Session cookies are temporary and are generally deleted when you close your browser.

Persistent Cookies

Persistent cookies remain on your device until they expire or are deleted by the user.

Cookie retention periods may vary based on:

• Cookie category.
• Cookie provider.
• Cookie purpose.
• Browser settings.
• Consent settings.
• Legal requirements.
• ATU’s operational needs.

ATU should maintain a cookie table or cookie list identifying specific cookies, providers, purposes, categories, and retention periods.

17. Cookie Table

ATU should maintain an updated cookie table or cookie list.

The cookie table may include:

This table should be completed after ATU confirms the actual cookies, pixels, analytics tools, advertising tools, payment tools, and third-party integrations used on the Platform.

17A. Third-Party Cookie Tools and Data Processing Controls

ATU should maintain an internal register of third-party cookie, analytics, advertising, fraud-prevention, security, embedded-content, chat, consent-management, and similar technology providers used on the Platform.

The register should identify the tool or provider, cookie or tracking technology used, category, purpose, data collected, first-party or third-party status, retention period, countries where data may be processed, and whether the provider requires a Data Processing Agreement, service-provider terms, processor terms, confidentiality obligations, or other contractual controls.

ATU should not rely on generic cookie language alone where actual tools, pixels, tags, plugins, or integrations collect personal information. The cookie table and privacy disclosures should be updated to reflect the live technical setup before publication.

18. Security of Cookie Data

ATU uses reasonable safeguards designed to protect information associated with cookies and similar technologies.

These may include:

• Secure transmission protocols.
• Access controls.
• Security monitoring.
• Authentication protections.
• Encryption where appropriate.
• Service provider review.
• Limited internal access.
• Logging and audit controls.

No website, platform, device, browser, or transmission method can be guaranteed completely secure.

19. Relationship to the Privacy Policy

Cookie-related information may be personal information under applicable privacy laws.

ATU’s collection, use, sharing, retention, and protection of personal information is described in ATU’s Privacy Policy.

Users should review the Privacy Policy for more information about:

• Categories of personal information collected.
• Purposes of processing.
• Information sharing.
• International transfers.
• Data retention.
• User rights.
• Privacy request procedures.
• Security practices.
• Contact information.

20. Changes to This Cookie Policy

ATU may update this Cookie Policy from time to time.

When changes are made, ATU may update the “Last Updated” date, post the revised Cookie Policy on the Platform, and take any additional steps required by applicable law.

Users are encouraged to review this Cookie Policy periodically.

Continued use of the Platform after changes are posted means you acknowledge the updated Cookie Policy, subject to any consent choices required by applicable law.

21. Contact Information

Questions about this Cookie Policy or cookie preferences may be directed to:

Privacy Office
All Things Universal LLC
Website: www.allthingsuniversal.com
Email: privacy@allthingsuniversal.com
Hours: Mon-Fri 9.00 am – 6.00 pm EST
Telephone: 1(786) 743-7526
Business Address: 1688 Meridian Avenue, Suites 600 & 700, Miami Beach, Miami, 33139, United States of America