New York City, New York

Welcome to Stepup Scaffold’s Cookie Policy. This policy will help you understand what cookies and tracking technologies we use, how we use them, and what your rights are regarding them.

Last updated: November 13, 2025

This document informs Users about the technologies that allow Stepup Scaffold to achieve the purposes described below. These technologies enable the Owner to access and store information (for example, by using a Cookie) or use resources (for example, by running a script) on a User’s device while interacting with Stepup Scaffold.

For simplicity, all such technologies are referred to as “Trackers” within this document, unless there is a reason to differentiate them.

For instance, while Cookies can be used on both web and mobile browsers, it would be incorrect to speak of Cookies in the context of mobile apps, as they rely on browser-based Trackers. For this reason, the term “Cookies” is used in this document only when specifically referring to that type of Tracker.

Some of the purposes for which Trackers are used may also require User consent, depending on applicable laws. Whenever consent is given, it can be freely withdrawn at any time by following the instructions provided in this document.

Stepup Scaffold uses Trackers managed directly by the Owner (so-called first-party Trackers) and Trackers that enable services provided by third parties (so-called third-party Trackers). Unless otherwise specified in this document, third-party providers may access the Trackers they manage.

The validity and expiration periods of Cookies and other similar Trackers may vary depending on the duration set by the Owner or the relevant provider. Some of them expire at the end of the User’s browsing session.

In addition to what is specified in the descriptions of each category below, Users can find more accurate and updated information regarding duration, as well as any other relevant information—such as the presence of other Trackers—in the linked privacy policies of the respective third-party providers or by contacting the Owner.

How to manage your preferences and give or withdraw your consent on Stepup Scaffold

Where the use of Trackers is based on consent, Users can grant or withdraw such consent by setting or updating their preferences through the relevant Privacy Options panel available on Stepup Scaffold.

Regarding third-party Trackers, Users can manage their preferences via the relevant opt-out link (where available), by using the means indicated in the third party’s privacy policy, or by contacting that third party directly.

How to control or delete Cookies and similar technologies through your device settings

Users can use their own browser settings to:

• See what Cookies or other similar technologies have been installed on the device.
• Block Cookies or similar technologies.
• Clear Cookies or similar technologies from the browser.

However, browser settings do not allow for granular consent management by category.

For example, Users can find information on how to manage Cookies in the most commonly used browsers at the following addresses:

• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Internet Explorer
• Microsoft Edge
• Brave
• Opera

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, such as mobile advertising settings or general tracking settings. To do so, users can open their device settings and look for the corresponding option.

How to opt out of interest-based advertising

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU and UK), the Network Advertising Initiative (US), the Digital Advertising Alliance (US), the DAAC (Canada), the DDAI (Japan), or other similar services.

These initiatives allow Users to select their tracking preferences for most advertising tools. Therefore, the Owner recommends using these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices, which helps Users control interest-based advertising on mobile apps.

Consequences of denying the use of Trackers

Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help Stepup Scaffold provide a better experience and advanced features to Users, in accordance with the purposes described in this document.

Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide certain related features.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Stepup Scaffold (or third-party services employed in Stepup Scaffold), which may include: the IP addresses or domain names of the computers utilized by the Users who use Stepup Scaffold; the URI addresses (Uniform Resource Identifier); the time of the request; the method utilized to submit the request to the server; the size of the file received in response; the numerical code indicating the status of the server’s answer (successful outcome, error, etc.); the country of origin; the features of the browser and operating system utilized by the User; the various time details per visit (e.g., the time spent on each page within the Application); the details about the path followed within the Application with special reference to the sequence of pages visited; and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using Stepup Scaffold who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Stepup Scaffold.

Unless otherwise specified, the Data Controller is the Owner of Stepup Scaffold.

Stepup Scaffold (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Stepup Scaffold, as described in the relative terms (if available) and on this site/application.

Unión Europea (o UE)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology—e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that enables the tracking of Users, for example by accessing or storing information on the User’s device.