Cookie Policy

Last updated: 9 April 2026

This Cookie Policy explains how TMN Société Anonyme (“ApexGuard,” “we,” “us,” or “our”) uses cookies and similar technologies on our websites, portals, dashboards, landing pages, and other online services where this Cookie Policy is made available (collectively, the “Websites”).

It also explains what choices you have in relation to these technologies.

For the purposes of this Cookie Policy, the data controller is:

TMN Société Anonyme
Rue du Grand-Chêne 5
1003 Lausanne
Switzerland

1. Introduction

We use cookies and similar technologies to make our Websites function, protect our services, remember your preferences, understand how our Websites are used, and, where permitted, improve our communications and marketing.

We are committed to using these technologies in a manner consistent with Swiss data protection law, including the Swiss Federal Act on Data Protection (“FADP”), its implementing framework, and applicable guidance of the Federal Data Protection and Information Commissioner (“FDPIC”) concerning cookies and similar technologies. Under current Swiss guidance, website operators must provide transparent information, enable users to manage their settings, and obtain consent where required, particularly for non-essential tracking and certain third-party or advertising-related technologies.

By continuing to use our Websites after being informed of our use of cookies, and by making choices through our cookie banner or settings tools where applicable, you acknowledge this Cookie Policy.

2. What are cookies and similar technologies?

Cookies are small text files placed on your device when you visit a website. They help websites recognize your device, remember certain information, and support site functionality.

We may also use similar technologies, including:

• local storage;
• session storage;
• pixels or tags;
• SDK-based identifiers;
• server-side identifiers;
• log-based event correlation tools; and
• similar tracking or storage technologies.

For simplicity, this Cookie Policy refers to all such technologies as “cookies,” unless the context requires otherwise.

3. Why we use cookies

We may use cookies for the following purposes:

3.1 Strictly necessary cookies

These cookies are required for the operation, security, and integrity of our Websites and related systems. They may be used to:

• maintain session state;
• authenticate users;
• enable secure log-in areas;
• prevent abuse, fraud, and malicious activity;
• support load balancing and website availability;
• remember privacy choices; and
• ensure the proper delivery of requested services.

Because these cookies are necessary to provide the Website or a service expressly requested by you, they are generally enabled by default.

3.2 Preference and functionality cookies

These cookies allow our Websites to remember choices you make, such as language, region, interface settings, or other preferences, in order to improve your user experience.

3.3 Analytics and performance cookies

These cookies help us understand how users interact with our Websites, such as which pages are visited, how features are used, whether errors occur, and how performance can be improved.

We use this information in aggregated or otherwise limited form where possible. Where analytics cookies are not strictly necessary, we will use them in accordance with applicable consent requirements.

3.4 Security and fraud-prevention cookies

Some cookies are deployed to detect suspicious traffic patterns, protect accounts, enforce platform integrity, and mitigate abuse. Given the nature of ApexGuard’s services, some website-side security technologies may also help us assess attacks, protect sign-in flows, and preserve service continuity.

3.5 Marketing cookies

Where used, these cookies help us measure the effectiveness of campaigns, understand whether a visitor arrived from a partner or campaign source, and improve the relevance of our communications.

We do not treat marketing cookies as strictly necessary. Where Swiss law or applicable guidance requires consent, such cookies will not be activated before that consent is obtained. Current FDPIC guidance expressly emphasizes that consent may be required in particular where third parties gain access to visitor data for personalized advertising or comparable cross-site tracking purposes.

4. Legal basis and consent under Swiss law

Where cookies are necessary for the secure operation and delivery of our Websites or for a service explicitly requested by you, we may rely on our legitimate operational interest in providing a secure and functional service environment, interpreted in accordance with Swiss law.

Where cookies are not strictly necessary, especially analytics, personalization, advertising, social plug-ins, tracking pixels, or other third-party technologies that are not essential to the service requested by you, we will provide clear information and, where required, request your consent before such processing occurs.

In line with current FDPIC guidance, non-essential processing that depends on consent should not be activated by default before the user has had an opportunity to review the information and make a choice. We may therefore use a consent banner or comparable preference tool that allows you to accept, reject, or customize non-essential cookies.

5. Types of cookies we may use

Cookies may differ by duration and source.

5.1 Session cookies

These cookies expire when you close your browser or end the relevant browsing session.

5.2 Persistent cookies

These remain on your device for a defined period or until deleted manually.

5.3 First-party cookies

These are set by ApexGuard directly.

5.4 Third-party cookies

These are set by third-party services integrated into our Websites, such as analytics providers, embedded content providers, communication tools, or marketing partners.

Where third-party cookies are used, those providers may process personal data according to their own privacy documentation and may act either as our processors/service providers or, in some situations, as independent controllers, depending on the service and legal setup.

6. Information collected through cookies

Depending on the cookie and your settings, cookies may process information such as:

• IP address or truncated IP-related data;
• device type, browser type, and operating system;
• language and region preferences;
• session identifiers;
• website navigation events;
• timestamps and referral URLs;
• approximate geolocation derived from technical signals;
• campaign or affiliate identifiers;
• error diagnostics; and
• user preferences and security-related events.

Where such information identifies or relates to an identifiable natural person, it constitutes personal data and is handled in accordance with our Privacy Policy and applicable Swiss data protection law. The FADP protects the personality and fundamental rights of natural persons whose personal data is processed.

7. How to manage your cookie choices

You can manage cookies in several ways:

7.1 Cookie banner or privacy settings

Where available, our Websites provide a cookie banner, consent management platform, or privacy settings interface that allows you to:

• accept all cookies;
• reject non-essential cookies; or
• customize your preferences by category.

You may update your choices at any time through the relevant “Cookie Preferences,” “Privacy Preferences,” or similar link on the Website.

7.2 Browser settings

Most browsers allow you to control cookies through browser settings. You may be able to block or delete cookies, or receive alerts before cookies are stored.

Please note that blocking strictly necessary cookies may cause parts of the Websites not to function properly.

7.3 Device and platform settings

Where technologies are used in apps or device environments, your device or application settings may also provide additional privacy controls.

Swiss public guidance also notes that users can manage cookies via banners and browser-based controls.

8. Third-party services

We may use carefully selected third-party service providers to support:

• website analytics;
• fraud prevention;
• customer communications;
• embedded content;
• performance monitoring; and
• marketing attribution.

Where third parties set or read cookies through our Websites, they may process data in accordance with their own terms and privacy notices, subject to the role they play and applicable law.

We seek to configure third-party technologies in a privacy-conscious manner and to limit activation of non-essential third-party tracking until any required consent has been obtained.

9. Cross-border processing

Because some of our technology providers may operate internationally, information collected through cookies may be processed outside Switzerland.

Where we transfer personal data abroad, we take appropriate steps to ensure an adequate level of protection under applicable Swiss law, including by relying, where appropriate, on recognized safeguards, contractual measures, and organizational protections.

10. Data retention

Cookie retention periods vary depending on the type and purpose of the cookie.

Some cookies remain only for the duration of a browsing session, while others may remain on your device for a longer period until they expire or are deleted. We aim to configure retention periods proportionately and in line with the purpose for which the cookie is used.

Information derived from cookies may also be retained in logs, analytics systems, or security records for as long as reasonably necessary for the relevant purpose, including security, fraud prevention, legal compliance, dispute resolution, and service improvement.

11. Legal requests and disclosures under Swiss procedure

We may disclose limited information derived from cookie-related processing where required by applicable law, regulation, binding court order, or enforceable request from a competent authority.

As a Swiss company, ApexGuard handles such requests in accordance with Swiss law and applicable Swiss legal procedure. We do not voluntarily disclose user-related information outside an applicable legal basis. Requests from Swiss authorities must follow the relevant Swiss legal process. Requests from foreign authorities must be made through applicable legal channels recognized under Swiss law, such as mutual legal assistance, letters rogatory, or other formally valid cross-border procedures, where required.

Each request is assessed on its legal basis, scope, jurisdiction, and proportionality. Where permitted, we may challenge, narrow, or reject requests that are overbroad, defective, or inconsistent with applicable law.

12. Your rights

Subject to applicable law, you may have rights in relation to personal data processed through cookies and related technologies, including the right to:

• request information about personal data processed about you;
• request correction of inaccurate personal data;
• request deletion where applicable;
• object to certain processing;
• withdraw consent where processing is based on consent; and
• lodge a complaint with the competent supervisory authority.

In Switzerland, the competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC). The revised FADP has been in force since 1 September 2023, and the FDPIC is the Swiss authority responsible for supervising compliance in this area.

13. Children

Our Websites and services are not directed to children in violation of applicable law, and we do not knowingly use cookies to intentionally profile children through our Websites for non-essential purposes.

14. Changes to this Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our technology, legal obligations, service providers, or business operations.

When we make material changes, we will publish the updated version on the relevant Website and revise the “Last updated” date above. Where required, we will seek renewed consent or provide additional notice.

15. Contact us

If you have questions about this Cookie Policy, our use of cookies, or your privacy rights, please contact us at:

TMN Société Anonyme
TVA CHE-256.320.417
Rue du Grand-Chêne 5
1003 Lausanne
Switzerland

Privacy contact: privacy@apexguard.com