Last updated: April 26, 2026
1. Who we are and the applicable framework
This Cookie Policy explains how PHOTON SPARK S.R.L., a company established and operating under Romanian law, with its registered office at Aleea Arutela No. 2, Bl. M18, Sc. 1, Et. 4, Ap. 25, Sector 6, Bucharest, Romania, 061902, uses cookies and similar technologies on the website https://photonspark.com and in connection with our digital services (including hosting, VPS, game hosting, web hosting, cloud infrastructure, software solutions, OCR, transcription). This Policy is supplemented by PhotonSpark's Terms and Conditions of Use and Privacy Policy; the terminology used ("User", "Client", "Site", "Services", "Content", "Contributions", "PHOTON SPARK") is consistent with those documents.
The use of cookies is governed, as applicable, by Law No. 506/2004 (the ePrivacy transposition) and by the GDPR to the extent that processing involves personal data; consent is required for non-essential cookies, and the exception applies only to those strictly necessary for the provision of the requested service or the transmission of the communication, in accordance with relevant practice and case law (including CJEU, C-673/17, Planet49).
2. What cookies and similar technologies are
Cookies are small files that may be stored on the User's device and enable the proper functioning of the Site, session maintenance, the personalization of certain settings, traffic analysis or, if implemented, marketing communications. Comparable technologies (local/session storage, pixels, SDKs, online identifiers, tags, scripts, logs) can perform similar functions.
Cookies may be placed by PHOTON SPARK (first-party) or by third-party providers involved in the provision of the Services (e.g., payment processors, IT infrastructure, cloud, hosting, CDN, security, monitoring, analytics, ticketing, support, communication). The specific list and technologies may change over time.
3. Categories of cookies we may use
3.1. Strictly necessary (essential) cookies
Indispensable for the operation of the Site and Services: authentication, session maintenance, account security, saving essential preferences, shopping cart/order flow, payment processing, fraud prevention, infrastructure protection, traffic management, proper page loading, Service stability. These may include session cookies, authentication cookies, anti-fraud cookies, security cookies, traffic-balancing cookies, consent-storage cookies, technical cookies from payment processors, and cookies necessary for infrastructure (hosting/cloud/CDN).
3.2. Functional (non-essential) cookies
Allow us to remember certain options and preferences (e.g. language, region, interface, display settings) — they enhance the experience without being indispensable, and are used only based on consent where required.
3.3. Performance, analytics and monitoring cookies
Measure how the Site is used and the stability of the Services (pages visited, visit duration, actions, device, browser, traffic source, errors) to identify issues and improve the Services. Their non-essential use requires consent; obtaining prior consent is recommended in Romania for analytics/statistics.
3.4. Marketing, advertising or commercial-communication cookies
If implemented, they may measure campaign effectiveness, display relevant communications, cap display frequency or tailor messaging. They are used exclusively on the basis of the User's prior, informed consent.
3.5. Third-party cookies
May be set by providers of advertising, analytics, social media, communication platforms or measurement tools. Such third parties may act as independent or joint controllers for certain processing activities, and their practices are governed by their own policies.
4. Legal grounds for the use of cookies
Strictly necessary cookies are used without consent, to the extent that they are indispensable for the provision of an information-society service expressly requested by the User or for the transmission of a communication over a network. The legal bases for the related processing may be performance of the contract and PHOTON SPARK's legitimate interest in ensuring the operation and security of the Services.
Non-essential functional, analytical and marketing cookies are used only on the basis of the User's valid consent (free, specific, informed, unambiguous), expressed through a banner or preference-panel mechanism, without pre-checked boxes or consent implied by the mere continuation of browsing, in accordance with Planet49 and European best practice.
5. Correlation with accounts, payments, infrastructure and support
Accounts and authentication. PHOTON SPARK may use cookies to create/maintain the session, protect passwords, detect suspicious logins, retain security preferences and manage the account; these cookies are generally strictly necessary.
Online payments and recurring services. Payment processors (e.g. Stripe, PayPal) may use cookies/similar technologies to initiate, secure, validate and complete payments, prevent fraud, confirm transactions and manage subscriptions; some are strictly necessary for the transaction/security, others (analytics/marketing) require consent. PHOTON SPARK generally receives only the information strictly necessary to administer the transaction, with full card details processed by the processors in accordance with the Privacy Policy.
Infrastructure (hosting/VPS/game hosting/web hosting). Cookies/similar technologies may be used for DDoS protection, traffic balancing, security, firewall, monitoring, backup, technical administration, error detection and availability. Use is justified by technical necessity, performance of the contract, and the legitimate interest in infrastructure security.
Support (email, ticketing, Discord). Cookies/technologies used by contact forms, ticketing systems, chat or communication platforms may be used to transmit requests, maintain the conversation, identify the account or correlate a request with the Services; if necessary for the operation of requested support they may be strictly necessary; additional purposes (analytics/personalization/marketing) require consent.
6. Consent mechanism and preference management
On first access, a cookie banner may be displayed informing about the use of cookies and offering options to accept all, reject non-essential cookies, or configure preferences by category; strictly necessary cookies remain active because they are indispensable to the requested service.
Consent for non-essential cookies must be free, specific, informed and unambiguous; continued browsing, silence, pre-checked boxes or forced acceptance do not constitute valid consent. Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out beforehand.
You can change your preferences at any time via a "Cookie settings/preferences" panel available in accessible areas of the Site. PHOTON SPARK may store a strictly necessary cookie to retain your options so the banner is not shown repeatedly, except when preferences expire, are deleted, or significant changes occur in the technologies used.
Browser management. You may block/delete cookies via your browser settings. Disabling all cookies may affect the functioning of the Site, authentication, order completion, use of the Services, payment processing or session security; PHOTON SPARK cannot guarantee full functionality if strictly necessary cookies are blocked.
7. Storage duration
Duration varies according to the nature and purpose: session cookies are typically deleted when the browser is closed; persistent cookies remain for a set period or until manual deletion; consent-preference cookies may be kept for a reasonable period; security/authentication/payment/infrastructure cookies are retained for as long as necessary for their purpose; analytics/functional/marketing cookies (if used) have durations proportional to their purpose, in accordance with provider settings and expressed preferences.
8. Data processed via cookies and link to the Privacy Policy
Where the use of cookies involves the processing of personal data (e.g. IP, online identifiers, session ID, browser/device data, pages visited, actions on the Site, account preferences, authentication data, transaction data, security data, traffic), processing takes place under the conditions of the Privacy Policy (purposes, legal bases, recipients, transfers, retention periods, rights).
Further processing of data obtained through cookies (e.g. analytics, profiling) falls under the GDPR and requires an appropriate legal basis (consent for marketing/profiling; or, where applicable, legitimate interest with safeguards and right of objection for non-intrusive analytics).
9. Third-party cookies, responsibilities and limitation of liability
Third parties may use their own cookies/technologies as part of integrations (e.g. payment processors, support, communication, social media, analytics, cloud). PHOTON SPARK does not always control cookies placed directly by third parties, whose use is subject to their own policies; we recommend consulting third-party policies when interacting with them.
To the extent permitted by law, PHOTON SPARK acts as a technical intermediary for third-party cookies; the obligation to obtain consent and provide information about third-party cookies lies with the respective controllers, without excluding our transparency obligations regarding their integration on the Site.
10. International data transfers
The Services may be accessed globally, including from outside the EEA; certain solutions (payments, cloud, CDN, analytics, monitoring, support) may involve infrastructure outside the EEA, resulting in international data transfers. In the absence of an adequacy decision, we use appropriate safeguards (Standard Contractual Clauses approved by the European Commission), additional technical and organizational measures, transfer assessments, or other mechanisms permitted by law.
11. User rights
The rights provided for by the GDPR (access, rectification, erasure, restriction, portability, objection, withdrawal of consent, complaint to the competent authority) apply to the extent that cookies involve processing of personal data; they are exercised in accordance with the Privacy Policy.
12. Updates, technical and legislative changes
PHOTON SPARK may update this Policy to reflect legislative, technical, operational, commercial or security changes; the updated version will be published on the Site, indicating the date of the last update. If the changes are significant, we may inform Users by reasonable means; if the changes affect cookies that require consent, a new choice may be requested.
Without prejudice to transparency obligations, PHOTON SPARK may vary providers and technologies used without an obligation to constantly update the list in this Policy, provided such changes are reflected in the consent and information mechanism.
13. Express references to the Terms and the Privacy Policy
This Policy applies together with the Terms and Conditions (including provisions on data protection and limitations of liability) and the Privacy Policy; in case of processing of data through cookies, the provisions of the Privacy Policy regarding legal bases, recipients, transfers and rights apply accordingly.
Accounts, payments, recurring services and support are reflected consistently: cookies necessary for authentication and account security, payment processing, and infrastructure operation are generally strictly necessary; non-essential cookies (analytics/marketing) are based on consent, in accordance with Section 6.
14. Contact
For questions regarding this Policy, cookie preferences, withdrawal of consent or data protection rights:
PHOTON SPARK S.R.L.
Aleea Arutela No. 2, Bl. M18, Sc. 1, Et. 4, Ap. 25, Sector 6, Bucharest, Romania, 061902
Email: contact@photonspark.com