Cookie Policy

1. What is a cookie?

A cookie is a small text file that the web server hosting https://profitroomshop.org places on the storage of your browsing device (computer, tablet, smartphone) when you visit the site. Cookies allow us, among other things, to recognise your device, analyse browsing behaviour and remember your preferences. Under European law, cookies are governed by Directive 2002/58/EC (the "ePrivacy Directive") and by the guidelines adopted by the European Data Protection Board (EDPB). Under Montenegrin law, they fall within the scope of the Zakon o zaštiti podataka o ličnosti (Personal Data Protection Act). Equivalent tracking technologies are treated in the same way as cookies: local storage, session storage, IndexedDB, browser fingerprinting, tracking pixels, and similar techniques.

2. Your preferences and consent

On your first visit to profitroomshop.org, a cookie banner is displayed at the bottom of the screen. This banner allows you, in a single click, to either Accept the placement of all non-essential cookies, or to Reject them. Rejection does not in any way degrade your browsing experience on the public pages or in the Client Area. You may change your choice at any time by clearing the cookies already stored in your browser settings, which will trigger the banner to appear again on your next visit. Your consent is stored for a maximum rolling period of six months, after which a new banner will be presented.

3. Strictly necessary cookies

These cookies are essential to the proper operation of the website and to the delivery of the services you expressly request (Client Area session, shopping cart, CSRF-protection of forms, storage of your cookie choice). They are exempt from prior consent, in line with the ePrivacy Directive.

Cookies active in this category:

• shop_cart_v1 — shopping cart (localStorage). Issuer: Profitroomshop. Duration: until manually cleared.
• px_session — authenticated user session. Issuer: Profitroomshop. Duration: browser session.
• px_csrf — anti-CSRF token used to protect forms. Issuer: Profitroomshop. Duration: 24 hours.
• px_cookie_consent — storage of your cookie choice. Issuer: Profitroomshop. Duration: six months.

4. Anonymised audience measurement cookies

These cookies allow us to compile visitor statistics, identify the most visited pages and understand navigation paths. In our configuration, they are fully anonymised (IP address truncated before recording, no cross-referencing with other data sets, cross-account sharing disabled) and are, on that basis, exempt from consent, in line with the guidance issued by the EDPB and by several national supervisory authorities.

Cookies active in this category:

• _pk_id.*, _pk_ses.* — Matomo Analytics self-hosted in Germany (Frankfurt). Issuer: Profitroomshop. Duration: 13 months maximum.

5. Cookies requiring consent

No third-party advertising cookies, social-media cookies or retargeting cookies are placed on profitroomshop.org without your prior express consent. At the date of publication of this policy, Profitroomshop uses no third-party cookies that require consent. Should this change, this policy will be updated and a fresh cookie banner will be presented before any new tracker is enabled on your device.

The consent mechanism used by Profitroomshop follows the two-layer model recommended by the European Data Protection Board: the first layer (banner) contains a short, plain-language description of the categories of cookies, together with clearly labelled "Accept" and "Reject" buttons of equivalent visual prominence; the second layer (preferences panel) provides a per-category breakdown with granular toggles and the full list of cookies actually placed. Consent is recorded, timestamped and versioned so that we can demonstrate its validity if a supervisory authority requests it.

Rejecting non-essential cookies never blocks access to any content on profitroomshop.org, never triggers repeated banners within a rolling six-month window and never activates alternative tracking mechanisms such as browser fingerprinting or link decoration. Accepting cookies never enables cross-site advertising and never causes your data to be shared with data brokers, ad networks or social platforms.

5-bis. Legal basis for each cookie category

In line with Article 82 of the ePrivacy Directive as interpreted by the EDPB and Article 6 GDPR, we rely on the following legal bases:

• Strictly necessary cookies — Article 82(2) of the ePrivacy Directive: legitimate exemption from consent as they are needed to deliver an information-society service expressly requested by the user.
• Anonymised audience-measurement cookies — regulator guidance: exemption from consent subject to strict configuration (IP truncation, no cross-referencing, no ad targeting, no cross-account sharing).
• Any future non-essential cookie — Article 6(1)(a) GDPR: prior, specific, informed and unambiguous consent, freely given and as easy to withdraw as to grant.

6. Cookies placed by third parties

Some pages, in particular guides and blog articles, may contain links to external resources (official Profitroom documentation, industry publications). Simply displaying these links does not place any third-party cookies; however, activating a link may trigger cookie placement by the destination website, over which Profitroomshop has no control. We recommend that you consult the cookie policy of the destination website before browsing.

7. Cookie retention

Cookies placed on your device are kept for a period that may not exceed thirteen rolling months from the date they are first placed, in line with EDPB and national supervisory-authority recommendations. Once this period has expired, they are automatically deleted and a fresh consent is requested where applicable. Aggregated statistical data derived from these cookies may be retained for up to twenty-five rolling months.

8. How to manage or reject cookies from your browser

You may at any time configure your browser to block, filter or delete cookies. Such configuration may affect the use of some features of profitroomshop.org (for example the shopping cart). Configuration procedures differ from one browser to another:

• Google Chrome: Settings → Privacy and security → Cookies and other site data.
• Mozilla Firefox: Settings → Privacy and Security → Cookies and Site Data.
• Safari (macOS): Preferences → Privacy → Manage Website Data.
• Safari (iOS): Settings → Safari → Privacy and Security.
• Microsoft Edge: Settings → Cookies and site permissions → Cookies and site data.

You may also opt out of Matomo audience-measurement cookies by enabling the "Do Not Track" option in your browser, or by installing the opt-out extension provided by Matomo at matomo.org/privacy.

9. Your rights and remedies

In accordance with the GDPR and the Montenegrin Personal Data Protection Act, you have, in respect of data collected via cookies, the same rights as those described in our Privacy Policy, including the right of access, rectification, erasure, objection, restriction and portability. These rights are exercised at privacy@profitroomshop.org.

You also have the right to lodge a complaint with the Agencija za zaštitu ličnih podataka (AZLP) in Montenegro or with the supervisory authority of your country of residence, if you believe that the processing of your data does not comply with the applicable legislation.

9-bis. What is not tracked on profitroomshop.org

For the sake of full transparency, we make the following commitments and consider them an integral part of this policy:

• No cookie or tracker enables profiling of your browsing across other websites.
• No cookie or tracker is used for automated advertising bidding, real-time bidding (RTB) or programmatic ad auctions.
• No cookie or tracker is placed by a social network, a chat widget or a video player embedded on our pages.
• No cookie or tracker is used to determine the price or availability of a Module based on your individual behaviour.
• Data collected through Matomo is retained only in aggregate form after the retention window and is never re-identified.
• Your Profitroom API credentials are never stored client-side and are never accessible from any tracker or third party.

9-ter. Interaction with browser-level privacy signals

Profitroomshop respects the Global Privacy Control (GPC) signal transmitted by compatible browsers and treats it as a valid opt-out request for any category that would otherwise require consent. The site also complies with the "Do Not Track" signal for statistical trackers. If both are enabled, no non-essential cookie is placed and the cookie banner is minimised to a discreet confirmation notice acknowledging that your preference has been recorded. This behaviour is applied by default, without you having to interact with the banner.

10. Changes to this policy

This Cookie Policy may be modified at any time to reflect technical, legal or operational developments. The date of the most recent update is shown at the top of this document. In the event of a substantial change, in particular the addition of a new cookie subject to consent, a fresh banner will be presented to obtain your consent.

11. Contact details

Profitroomshop d.o.o.
ul. Vasa Raičkovića 66, 81000 Podgorica, Crna Gora
PIB: 04567892 — CRPS: 4-0074615/3
Director: Nikola Popović
Email: privacy@profitroomshop.org — DPO: dpo@profitroomshop.org
Phone: +382 20 852 964
Supervisory authority: Agencija za zaštitu ličnih podataka (AZLP), Reg-No. 05-030/26-2148. Jurisdiction: Osnovni sud u Podgorici.

Version 1.0 — published 3 August 2026. Next scheduled review: 3 February 2027.