Cookie Policy

Cookie Policy — InternBoard.com

Issued by: Master Trading Class Private Limited

Designation: Owner and Operator of InternBoard.com

Global Office: InternBoard.com 12 Woodlands Square #13-79 Woods Square Tower One Singapore 737715

Corporate and Correspondence Address: Master Trading Class Private Limited #G-3, South West Avenue, Street No. 2 Lalamma Gardens, Puppalaguda, Hyderabad, Telangana, India — 500089

Support and Enquiries: support@internboard.com

Last Reviewed and Updated: April 22, 2026

Effective Date: April 22, 2026

This Cookie Policy is a legally binding document that forms part of the Agreement between InternBoard.com, operated by Master Trading Class Private Limited (“the Company”), and all persons who access or use the Platform. It explains in detail what cookies and similar tracking technologies are, how the Company uses them, the legal basis for their use, and the rights available to users in relation to cookie-based data processing. This Policy should be read in conjunction with the Company’s Privacy Policy, which governs the broader collection and use of personal data through the Platform. The Company is in the process of deploying a dedicated Cookie Consent Management Tool on the Platform and will update this Policy when that tool is operational. In the interim, users may manage non-essential cookies through their browser settings and may submit cookie-related requests by writing to support@internboard.com. By accessing or using the Platform in any manner, users acknowledge that they have read and understood this Cookie Policy and accept its terms to the extent permitted by applicable law.

1. Introduction and Scope

1.1 About InternBoard.com

InternBoard.com (“InternBoard,” “the Platform,” “we,” “us,” or “our”) is a global digital opportunity marketplace developed, owned, and operated by Master Trading Class Private Limited, a company incorporated in accordance with applicable law. The Company’s global office is located at 12 Woodlands Square, #13-79 Woods Square Tower One, Singapore 737715, and its corporate and correspondence address is at #G-3, South West Avenue, Street No. 2, Lalamma Gardens, PuppalGuda, Hyderabad, Telangana, India—500089.

The Platform serves as a technology-driven intermediary connecting Career Starters—comprising students, fresh graduates, and early-career professionals—with employers offering internships, apprenticeships, full-time positions, part-time roles, remote opportunities, freelance gigs, and career development resources. The terms “Career Starter” and “Candidate” are used interchangeably and carry identical legal meaning throughout this Policy.

1.2 Purpose of this Policy

This Cookie Policy sets out:

what cookies and similar tracking technologies are and how they function;
the categories of cookies the Company uses on the Platform and the purposes for which they are deployed;
the legal bases upon which the Company relies to place and process cookies;
how cookies collect, store, and process personal data;
the rights available to users in relation to cookies, including how to manage, withdraw, or restrict consent;
the Company’s approach to third-party cookies and cross-border data processing; and
how and when this Policy may be updated.

1.3 Scope of Application

This Policy applies to all users of the Platform—including Career Starters, Employers, and Visitors—regardless of geographic location and irrespective of the device or browser used to access the Platform. It applies to all cookies and similar tracking technologies placed by the Company or by authorized third-party providers in connection with the Platform.

2. Definitions and Interpretation

2.1 Browser Storage

“Browser Storage” means local storage, session storage, and IndexedDB—mechanisms built into web browsers that allow websites to store data locally on a user’s device, independently of cookies, and which may be used for similar purposes as session or persistent cookies.

2.2 Career Starter

“Career Starter” refers to any individual who registers on the Platform to discover and apply for Opportunities, including students, graduates, and early-career professionals. The terms “Career Starter” and “Candidate” are used interchangeably in this Policy and carry identical legal meaning.

2.3 Company

“Company” means Master Trading Class Private Limited, the owner and operator of InternBoard.com.

2.4 Consent

“Consent” means a freely given, specific, informed, and unambiguous indication of a user’s agreement to the placement and processing of cookies for a specified purpose, expressed through a clear affirmative act. Consent shall not be inferred from silence, inactivity, pre-ticked checkboxes, or continued browsing alone. Pending the deployment of the Company’s Cookie Consent Management Tool, consent for non-essential cookies is managed through browser-level controls and written requests to support@internboard.com.

2.5 Cookie

“Cookie” means a small text file that is placed on and stored in a user’s device—including desktop computers, laptops, tablets, and mobile phones—by a web server when the user accesses a website. Cookies enable the website to recognize the user’s device on subsequent visits and to store and retrieve information about the user’s interactions with the website.

2.6 Cookie Consent Management Tool

“Cookie Consent Management Tool” means a dedicated on-Platform interface through which users will be able to view, select, accept, reject, and manage their cookie preferences by category. The Company is in the process of developing and deploying this tool. Until it is operational, users may exercise control over nonessential cookies through their browser settings as described in Section 10 or by submitting a written request to support@internboard.com. This Policy will be updated to reflect the tool’s features and operation upon its deployment.

2.7 Device

“Device” means any internet-enabled hardware through which a user accesses the Platform, including without limitation desktop computers, laptop computers, tablet devices, smartphones, and smart televisions.

2.8 Do Not Track (DNT)

“Do Not Track” or “DNT” means a browser-level signal that a user may configure in certain web browsers to indicate a preference against online behavioral tracking across multiple websites.

2.9 Employer

“Employer” means any individual, organisation, company, or entity that registers on the Platform for the purpose of posting Opportunities or accessing Career Starter profiles.

2.10 First-Party Cookie

“First-Party Cookie” means a cookie placed directly by the Company on a user’s device when the user accesses the Platform.

2.11 Global Privacy Control (GPC)

“Global Privacy Control” or “GPC” means a browser-based or extension-level signal that communicates a user’s opt-out preference in respect of the sale or sharing of personal data, as recognized under applicable privacy laws, including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

2.12 Persistent Cookie

“Persistent Cookie” means a cookie that remains stored on a user’s device after the browser session has ended, until the cookie’s programmed expiry date is reached or until the user manually deletes the cookie.

2.13 Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person, as defined in the Company’s Privacy Policy and under applicable data protection law.

2.14 Pixel Tag

“Pixel Tag” means a small transparent image — also known as a “web beacon,” “clear GIF,” or “tracking pixel” — embedded in a webpage or email that, when loaded, signals to a server that the page or email has been accessed and may collect information such as the user’s IP address, browser type, and the time and date of access.

2.15 Platform

“Platform” refers collectively to the InternBoard.com website; any associated mobile applications; application programming interfaces (“APIs”); tools; widgets; and any other digital products or services operated by the Company under the InternBoard brand.

2.16 SDK Identifier

“SDK Identifier” means a software development kit-based tracking identifier embedded in a mobile application that enables the collection of device-level data and user behavior analytics on mobile platforms.

2.17 Session Cookie

“Session Cookie” means a temporary cookie that exists only for the duration of a single browser session and is automatically deleted when the user closes their browser.

2.18 Similar Tracking Technologies

“Similar Tracking Technologies” means technologies that function analogously to cookies, including but not limited to pixel tags, web beacons, browser storage mechanisms (local storage, session storage), SDK identifiers, device fingerprinting scripts, and cross-device tracking technologies.

2.19 Third-Party Cookie

“Third-Party Cookie” means a cookie placed on a user’s device by a domain other than InternBoard.com—typically a third-party service provider engaged by the Company—when the user accesses the Platform.

2.20 Visitor

“Visitor” means any individual who accesses or browses the Platform without creating a registered account.

3. What Are Cookies and How Do They Work

3.1 Technical Operation of Cookies

When a user accesses the Platform, the Platform’s web server may send a small data file—a cookie—to the user’s browser, which stores it on the user’s Device. On each subsequent request to the same domain, the browser transmits the stored cookie back to the server, enabling the server to recognize the returning user and retrieve relevant information about that user’s prior interactions.

Cookies operate at the domain level, meaning that cookies set by InternBoard.com can only be read by servers operating under the InternBoard.com domain (in the case of First-Party Cookies), or by the domain of the specific third party that placed the cookie (in the case of Third-Party Cookies). Cookies cannot access other files on a user’s device and, where properly configured, cannot execute software or install programs.

3.2 Similar Tracking Technologies

In addition to cookies, the Platform may employ Similar Tracking Technologies, which serve comparable functions through different technical mechanisms. These include:

Pixel Tags and Web Beacons: Tiny transparent images embedded in web pages or email communications that, when loaded, transmit technical information such as the user’s IP address, browser type, access time, and whether a particular page was viewed or email opened;
Browser Local Storage and Session Storage: Mechanisms that allow the Platform to store data directly in the user’s browser, outside the cookie framework, for the duration of a session (session storage) or until manually cleared by the user (local storage);
SDK Identifiers: Identifiers embedded within mobile application software that collect device-level and behavioural analytics on mobile platforms; and
Device Fingerprinting: The collection and combination of device-level attributes—such as screen resolution, installed fonts, browser plugins, and time zone—to create a probabilistic identifier that may be used to recognize a returning user even in the absence of stored cookies.

All references to “cookies” in this Policy extend to Similar Tracking Technologies where applicable and appropriate, unless the context otherwise requires.

4. Legal Basis for Cookie Usage

4.1 Applicable Legal Frameworks

The Company’s use of cookies and Similar Tracking Technologies is governed by the following legal frameworks, applied according to the jurisdiction in which the user is located:

European Union: The EU ePrivacy Directive (Directive 2002/58/EC, as amended by Directive 2009/136/EC), as implemented in the national laws of each EU Member State, and the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Following the formal withdrawal of the proposed ePrivacy Regulation by the European Commission in February 2025, the existing ePrivacy Directive and its national implementations remain in force and constitute the primary legal framework for cookie consent in the EU. Non-essential cookies may not be placed on the devices of EU users without prior, specific, informed, and freely given consent;
United Kingdom: The Privacy and Electronic Communications Regulations 2003 (as amended) (“PECR”) and the UK General Data Protection Regulation (“UK GDPR”), as supplemented by the Data Protection Act 2018 and the Data Use and Access Act 2025;
India: The Information Technology Act, 2000; the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; and the Digital Personal Data Protection Act, 2023 (“DPDP Act”) together with the Digital Personal Data Protection Rules, 2025 (notified on 13 November 2025), applicable in their phased implementation;
Singapore: The Personal Data Protection Act 2012 (“PDPA”) and the guidelines issued by the Personal Data Protection Commission (PDPC);
United States (California): The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), applicable to California residents; and
Other Jurisdictions: Applicable national or regional data protection and electronic privacy laws of any other jurisdiction in which users are located.

4.2 Consent

The Company relies on Consent as the legal basis for placing all non-essential cookies on the devices of users located in jurisdictions where prior consent is required by law, including the EU, UK, and other jurisdictions with equivalent requirements. The Company does not rely on pre-ticked boxes, continued scrolling, or inactivity as a substitute for valid consent.

The Company’s dedicated Cookie Consent Management Tool is currently under development and is not yet deployed on the Platform. During this interim period, the Company operates a limited-deployment cookie approach in which only Strictly Necessary Cookies are placed by default on all users’ Devices. Non-essential cookies—including Functional, Analytics, and Marketing Cookies—are not loaded without a valid consent mechanism. Users who wish to enable or disable specific categories of non-essential cookies may do so through their browser settings as described in Section 10 or by contacting the Company at support@internboard.com with a written statement of their preferences. Upon deployment of the Cookie Consent Management Tool, this Policy will be updated, and users will be informed accordingly.

4.3 Legitimate Interests

For certain security and fraud-prevention processing carried out in connection with cookie data—such as detecting bot activity, preventing credential stuffing, and identifying suspicious login patterns—the Company may rely on its legitimate interests and the legitimate interests of its users as a legal basis, where such interests are not overridden by the fundamental rights and freedoms of users.

4.4 Contractual Necessity

Strictly Necessary Cookies (described in Section 6.1) are placed on the basis of contractual necessity, as they are indispensable to the delivery of the Platform’s core services that users have requested. These cookies do not require consent under the applicable legal frameworks and cannot be disabled by users without impairing the fundamental functionality of the Platform.

4.5 Consent Records

The Company maintains records of all cookie consent interactions with users. During the interim period prior to the deployment of the Cookie Consent Management Tool, consent records are maintained through written correspondence logs (where users have submitted cookie preference requests by email) and through server-side records confirming that non-essential cookies are not loaded by default. Upon deployment of the Cookie Consent Management Tool, the Company will maintain timestamped, structured consent records including the date, time, version of the Cookie Policy in force at the time, the categories accepted or rejected, and, where technically feasible, a pseudonymized user identifier. Consent records will be retained for a minimum of five (5) years and will be available for regulatory audit upon request.

5. Purposes of Cookie Usage

The Company uses cookies and Similar Tracking Technologies for the following purposes:

5.1 Core Platform Operations

Cookies are used to maintain the technical infrastructure necessary for the Platform to function, including:

authenticating users who have logged in to the Platform and maintaining their logged-in status throughout a session;
managing and maintaining secure session states between the user’s browser and the Platform’s servers;
validating payment sessions and processing membership transactions securely;
maintaining platform stability and ensuring consistent delivery of content to the user’s browser;
preventing Cross-Site Request Forgery (CSRF) attacks by verifying that form submissions and state-changing requests originate from legitimate sessions on the Platform; and
enabling load balancing and server-side routing to distribute traffic efficiently across the Platform’s infrastructure.

5.2 User Experience and Personalisation

Cookies are used to personalize and enhance the user’s experience on the Platform, including:

storing user language and locale preferences so that the appropriate language version of the Platform is displayed on return visits;
remembering dashboard customisation settings, display preferences, and user interface configurations;
retaining Career Starter Opportunity search filters, saved searches, and application history for ease of navigation;
enabling the “Remember Me” or equivalent login convenience feature where elected by the user; and
personalizing opportunity recommendations to Career Starters based on browsing history, profile data, and stated preferences, subject to applicable consent requirements.

5.3 Analytics and Performance Monitoring

With the user’s consent where required, cookies are used to collect anonymized or pseudonymized data about how users interact with the Platform, in order to:

measure and analyse traffic volumes, user flows, and navigation patterns;
identify pages, features, and content that are most and least accessed;
monitor Platform loading times, error rates, and technical performance metrics;
detect and diagnose bugs, service disruptions, and technical failures;
evaluate the effectiveness of content, features, and interface updates; and
generate aggregate, non-identifiable insights that inform product development and Platform improvements.

5.4 Security, Fraud Prevention, and Abuse Detection

Cookies are used to protect the security and integrity of the Platform and its users, including:

detecting and blocking automated bot activity, web scraping, credential stuffing, and other unauthorised automated access;
identifying and flagging suspicious login attempts, unusual account activity, or anomalous usage patterns;
enforcing rate limits and access controls to prevent abuse of the Platform’s features;
implementing CSRF protections, clickjacking mitigations, and other standard web security measures; and
supporting real-time fraud detection in connection with Opportunity listings and Career Starter applications.

5.5 Marketing and Campaign Measurement

With the user’s prior consent where required by applicable law, cookies may be used to:

track the source channels through which users discover and access the Platform, such as search engines, referral links, or digital advertising campaigns;
measure the effectiveness of the Company’s marketing campaigns, including click-through rates, conversion rates, and cost-per-acquisition metrics;
prevent duplicate or fraudulent counting of campaign performance events; and
where applicable and consented to, assist in delivering relevant promotional content about the Platform’s services to users who have previously expressed interest.

The Company does not use cookies to display third-party advertisements on the Platform, nor does it sell or transfer cookie-derived personal data to third-party advertisers for their independent advertising purposes.

6. Categories of Cookies

The cookies used on the Platform are classified into the following categories:

6.1 Strictly Necessary Cookies

Strictly Necessary Cookies are essential to the operation of the Platform and cannot be disabled. They are placed on the basis of contractual necessity and do not require user consent under applicable law. Without these cookies, core features of the platform—including user authentication, session management, and payment processing—cannot function.

These cookies do not collect or store any information that could be used for marketing, profiling, or analytics purposes.

6.1.1 Examples of Strictly Necessary Cookies

The following are representative examples of Strictly Necessary Cookies deployed on the Platform. The Company’s full cookie inventory, including the names, providers, purposes, and expiry details of all active cookies, is maintained internally and will be made available through the Platform’s Cookie Consent Management Tool upon its deployment. Users may request a copy of the current cookie inventory by writing to support@internboard.com.

Cookie Name	Provider	Purpose	Duration
session_id	InternBoard	Maintains the authenticated user session throughout a visit	Session
auth_token	InternBoard	Authenticates and validates logged-in user status	Session
csrf_token	InternBoard	Prevents Cross-Site Request Forgery attacks on form submissions	Session
login_state	InternBoard	Tracks whether a user is authenticated and their access level	Session
load_balancer	InternBoard	Routes user requests to the appropriate server for performance	Session

6.2 Functional Cookies

Functional Cookies enable the Platform to provide enhanced features and personalization beyond its strictly necessary operations. These cookies are placed based on user consent where required by applicable law, and users may decline them without preventing access to the Platform’s core functions, though some features may be unavailable or less convenient as a result.

6.2.1 Examples of Functional Cookies

Cookie Name	Provider	Purpose	Duration
user_preferences	InternBoard	Stores UI and dashboard display preferences	90 days
saved_filters	InternBoard	Retains Opportunity search filters and parameters	60 days
membership_status	InternBoard	Identifies active Membership tier for feature access	30 days
language_pref	InternBoard	Remembers the user’s selected language and locale	12 months
remember_me	InternBoard	Maintains login state across sessions where the user opts in	30 days

6.3 Performance and Analytics Cookies

Performance and Analytics Cookies collect data about how users interact with the Platform in order to enable the Company to understand usage patterns, identify areas for improvement, and monitor Platform performance. Data collected through these cookies is aggregated and pseudonymized wherever possible and is not used to identify individual users for commercial or marketing purposes.

These cookies require the user’s prior consent where mandated by applicable law.

6.3.1 Examples of Performance and Analytics Cookies

Cookie Name	Provider	Purpose	Duration
analytics_id	Analytics Provider	Assigns a pseudonymous identifier to track session-level engagement	12 months
performance_log	InternBoard	Monitors page load times and server response metrics	30 days
error_log	InternBoard	Records client-side errors and browser compatibility issues	7 days
feature_usage	InternBoard	Tracks which Platform features are used and with what frequency	90 days

6.4 Security Cookies

Security Cookies are used specifically to protect the Platform and its users from fraudulent activity, automated abuse, and cybersecurity threats. Some Security Cookies are strictly necessary (and therefore do not require consent), while others—particularly those that involve processing personal data beyond the minimum necessary for security—are placed only with the user’s consent where required.

6.4.1 Examples of Security Cookies

Cookie Name	Provider	Purpose	Duration
anti_bot_token	InternBoard Security	Detects and blocks automated bot access and scraping attempts	Session
fraud_detection	InternBoard Security	Identifies and flags suspicious or anomalous account activity	30 days
rate_limit_id	InternBoard Security	Enforces rate limits to prevent abuse of API and form endpoints	Session

6.5 Marketing and Campaign Tracking Cookies

Marketing and Campaign Tracking Cookies are used, with the user’s prior consent, to measure the performance of the Company’s own marketing and promotional activities and to track the acquisition channels through which users discover the Platform. The Company does not place marketing cookies for the purpose of delivering third-party advertisements to users on the Platform or on third-party websites.

6.5.1 Examples of Marketing Cookies

Cookie Name	Provider	Purpose	Duration
marketing_source	Platform Analytics	Records the channel through which a user arrived at the Platform	90 days
conversion_tracking	Platform Analytics	Measures whether a user who accessed the Platform via a campaign completes a registration or application	180 days
campaign_id	Platform Analytics	Associates a user session with a specific marketing campaign identifier	30 days

6.6 Third-Party Cookies

Third-Party Cookies are placed by external service providers engaged by the Company in connection with the Platform’s operation, including but not limited to analytics providers, cloud infrastructure services, customer support tools, and payment gateway providers. Third-Party Cookies are governed by the privacy and cookie policies of the respective third-party providers, over which the Company has no direct control.

The Company takes reasonable steps to ensure that Third-Party Cookies deployed on the Platform are placed by reputable providers that comply with applicable data protection law. The Company requires that all Third-Party Cookies with access to personal data be placed only where appropriate legal authorization exists. However, the Company is not responsible for the independent data practices of third-party providers.

Users are encouraged to review the privacy and cookie policies of third-party providers whose cookies may appear on the Platform. Upon deployment of the Cookie Consent Management Tool, users will be able to view the categories of Third-Party Cookies in use at any given time directly through the Platform’s interface. In the interim, users may request this information by contacting support@internboard.com.

Note: The cookie tables above are representative and illustrative. Cookie names, providers, and durations may change as the Platform evolves. An up-to-date and comprehensive cookie inventory will be maintained within the Platform’s Cookie Consent Management Tool upon its deployment. Until that time, users may request a current list of cookies by writing to support@internboard.com.

7. Cookie Duration

7.1 Session Cookies

Session Cookies are temporary and exist only for the duration of a single browser session. They are automatically and permanently deleted from the user’s Device when the user closes their browser tab or browser window. Session Cookies are primarily used for authentication, CSRF protection, and load-balancing functions that need not persist between visits.

7.2 Persistent Cookies

Persistent Cookies remain stored on the user’s Device after the browser session has ended, either until:

the cookie’s programmed expiry date and time is reached, upon which it is automatically deleted by the browser; or
the user manually deletes the cookie through their browser settings, whichever occurs first.

Persistent Cookies are used for purposes that benefit from continuity between sessions, such as remembering user preferences, maintaining functional settings, and tracking analytics over time. The Company applies the principle of data minimization to cookie duration—cookies are set with the shortest expiry period necessary to fulfill their stated purpose, and no persistent cookie is set with a duration exceeding the maximum period specified for its category without a documented and proportionate justification.

8. First-Party and Third-Party Cookies — Distinction and Responsibilities

8.1 First-Party Cookies

First-Party Cookies are set directly by InternBoard.com and are only readable by the Company’s own servers. The Company is solely responsible for the purposes, duration, and data handling practices associated with all First-Party Cookies. First-Party Cookies are governed entirely by this Policy and by the Company’s Privacy Policy.

8.2 Third-Party Cookies

Third-Party Cookies are set by third-party domains—such as analytics platforms, cloud security providers, or payment processing services—when those third-party components are loaded as part of the Platform. Third-Party Cookies are independently governed by the privacy and cookie policies of the third parties that set them.

The Company:

exercises reasonable due diligence in selecting third-party providers and reviewing their data handling practices prior to integration;
requires all third-party providers with access to user personal data to enter into appropriate data processing agreements;
restricts, to the extent technically feasible in its current implementation, Third-Party Cookies that are non-essential from loading prior to a valid consent mechanism being in place, and will enforce this restriction through the Cookie Consent Management Tool upon its deployment; and
accepts no liability for the independent data practices of third-party providers that are beyond the Company’s reasonable control.

9. Cookie Consent Management

9.1 Current Consent Framework — Interim Period

The Company’s dedicated Cookie Consent Management Tool is currently under development and has not yet been deployed on the Platform. During this interim period, the Company operates under the following consent framework, which is designed to protect user rights and comply with applicable law:

Default-Off for Non-Essential Cookies: Only Strictly Necessary Cookies—those indispensable to the core operation of the Platform including authentication, session management, and security—are placed on users’ Devices by default. No Functional, Analytics, Security, or Marketing Cookies that require consent are loaded without a separately obtained consent mechanism being in place;
Browser-Based Consent Control: Users may exercise granular control over the placement of cookies on their Devices through their browser settings, as described in detail in Section 10 of this Policy. Browser-level controls enable users to accept, reject, restrict, or delete cookies by category or by provider;
Written Consent and Preference Requests: Users who wish to express a specific cookie preference—including opting in to certain categories of non-essential cookies or withdrawing previously given consent—may do so by submitting a written request to support@internboard.com. The Company will acknowledge all such requests within forty-eight (48) hours and will implement the requested change to the extent technically feasible; and
Regulatory Compliance Commitment: The Company is committed to full compliance with the requirements of the EU ePrivacy Directive, the GDPR, the UK PECR and UK GDPR, India’s DPDP Act and DPDP Rules 2025, the Singapore PDPA, and other applicable data protection laws in all jurisdictions in which the Platform operates. The Cookie Consent Management Tool is being developed specifically to satisfy and exceed the consent management requirements of these frameworks.

9.2 Deployment of the Cookie Consent Management Tool

The Company intends to deploy its Cookie Consent Management Tool on the Platform in due course. Upon deployment, the Tool will:

be presented to all users upon their first access to the Platform from a jurisdiction where prior consent is required by applicable law;
clearly identify the categories of cookies proposed to be deployed and their respective purposes;
provide equally prominent and easily accessible options to accept all, reject all non-essential, or manage preferences by category;
include a direct link to this Cookie Policy for users who wish to obtain further information before making a choice;
require a clear affirmative act—such as clicking an “Accept” or category-specific toggle—before any non-essential cookies are placed, and will not treat continued use of the Platform, scrolling, or any passive conduct as consent; and
maintain a structured, timestamped record of each user’s consent choices for regulatory compliance purposes.

Users will be notified by email and by a prominent notice on the Platform when the Cookie Consent Management Tool is deployed, and this Policy will be updated accordingly at that time.

9.3 Withdrawal of Consent

Users who have given consent to the placement of non-essential cookies — whether through browser settings, written request, or (when deployed) through the Cookie Consent Management Tool — may withdraw that consent at any time, without prejudice to the lawfulness of any processing that took place prior to the withdrawal. Withdrawal may be effected through:

adjusting browser settings to block or delete the relevant cookies, as described in Section 10; or
submitting a written withdrawal request to support@internboard.com, specifying the categories of cookies in respect of which consent is being withdrawn. The Company will implement such withdrawal within forty-eight (48) hours of receipt.

Withdrawal of consent does not affect Strictly Necessary Cookies, which will continue to function regardless of the user’s stated preferences, as they are placed on the basis of contractual necessity rather than consent.

9.4 Policy Updates and Re-Consent

Where the Company materially updates this Cookie Policy in a manner that affects the nature, category, or purpose of cookies previously consented to, the Company will:

notify registered users by email to the address held on their account prior to the amendment taking effect;
display a prominent notice on the Platform for at least thirty (30) calendar days following publication of the amended Policy; and
upon deployment of the Cookie Consent Management Tool, present a renewed consent interface to existing users, requiring fresh consent for any materially new or different processing purpose before such processing commences.

The Company will not rely on prior consent for any materially changed processing purpose until fresh consent has been obtained or, where applicable law does not require prior consent, until the user has been duly notified.

10. Managing Cookies Through Browser Settings

10.1 Browser-Level Controls

Users may manage cookies through the settings of their web browser. This is the primary mechanism available to users during the interim period prior to the deployment of the Platform’s Cookie Consent Management Tool. Most modern browsers allow users to:

view and delete cookies that have already been stored on their Device;
block the placement of new cookies, either from all websites or from specific websites;
receive a notification before each cookie is placed, giving the user the opportunity to accept or decline it;
block Third-Party Cookies specifically, while permitting First-Party Cookies; and
clear all stored cookies and browsing data at the end of each session.

Instructions for managing cookies in the most commonly used browsers are accessible through the following reference links:

Google Chrome: Settings > Privacy and Security > Cookies and other site data;
Mozilla Firefox: Options > Privacy and Security > Cookies and Site Data;
Apple Safari: Preferences > Privacy > Manage Website Data;
Microsoft Edge: Settings > Privacy, Search, and Services > Cookies and Site Permissions; and
Opera: Settings > Advanced > Privacy and Security > Cookies.

For browsers not listed above, users are directed to the browser developer’s official documentation. Browser-level cookie controls are applied globally across all websites accessed through that browser and are not specific to the Platform.

10.2 Impact of Disabling Cookies

Users who disable or restrict cookies through their browser settings should be aware that:

disabling Strictly Necessary Cookies at the browser level may prevent the user from logging in, maintaining a session, or using core Platform features, as these cookies are placed on the basis of contractual necessity and cannot be disabled without impairing fundamental Platform functionality;
disabling Functional Cookies may result in the loss of personalised settings, saved search filters, and dashboard preferences, which will not be retained between sessions;
disabling Analytics Cookies will prevent the Company from gathering usage data about that user’s session, though this will not materially affect the user’s experience of the Platform; and
disabling Marketing Cookies will prevent the Company from measuring the effectiveness of its promotional campaigns, though this will not affect the user’s ability to use any Platform feature.

10.3 Mobile Device Controls

On mobile devices, users may additionally manage tracking through:

the privacy or tracking settings offered by the mobile device’s operating system (such as “Limit Ad Tracking” on Apple iOS or “Opt out of Ads Personalisation” on Android); and
the settings within any mobile application version of the Platform, where applicable.

11. Do Not Track (DNT) Signals

11.1 Company’s Position on DNT

The Do Not Track (“DNT”) signal is a browser-level preference that a user may enable to indicate to websites a preference against cross-site behavioral tracking. At present, there is no legally binding requirement or universally accepted technical standard under which websites are obligated to honour DNT signals, and the signal’s interpretation varies across jurisdictions and browsers.

The Company’s Platform does not currently alter its cookie practices in response to DNT signals because the absence of a standardized and legally binding protocol makes it impossible for the Company to reliably confirm the meaning and intended scope of such signals. Users who do not wish to be tracked through nonessential cookies are encouraged to use their browser’s cookie settings as described in Section 10 or to submit a written preference request to support@internboard.com, both of which provide a more reliable and enforceable mechanism for expressing and giving effect to such preferences. Upon deployment of the Platform’s Cookie Consent Management Tool, users will have an additional on-Platform option for managing their cookie preferences.

The Company will keep its position on DNT under review and will update this Policy if it adopts a different approach in the future.

12. Global Privacy Control (GPC)

12.1 GPC Recognition

The Global Privacy Control (“GPC”) is a browser-level or extension-level signal that communicates a user’s preference to opt out of the sale or sharing of their personal data for cross-context behavioral advertising. The GPC signal is recognized under the California Consumer Privacy Act (CCPA) as amended by the CPRA and under certain other applicable US state privacy laws as a legally valid opt-out mechanism.

Where the Company receives a GPC signal from a user whose rights are protected under applicable law—including California residents—the Company will treat the GPC signal as a valid opt-out of any processing of that user’s personal data that constitutes a “sale” or “sharing” for purposes of targeted advertising under the CCPA/CPRA. The Company does not currently sell or share users’ personal data with third parties for targeted advertising purposes; accordingly, GPC signals will be acknowledged but will not materially alter the Company’s cookie practices at this time.

The Company will review its GPC response obligations as additional US state privacy laws are enacted or amended to recognize GPC as a mandatory opt-out mechanism.

13. Cross-Border Processing of Cookie Data

13.1 International Data Flows

In view of the global nature of the Platform and the Company’s reliance on third-party service providers operating in multiple jurisdictions, personal data collected through cookies and Similar Tracking Technologies may be transferred to, stored in, and processed in countries other than the user’s country of residence. Such countries may include India, Singapore, member states of the European Economic Area, the United Kingdom, the United States of America, and other jurisdictions in which the Company or its authorized service providers maintain operations.

13.2 Safeguards for International Transfers

The Company implements the following safeguards to ensure that cross-border transfers of cookie data are conducted lawfully and with appropriate protection:

Standard Contractual Clauses (SCCs): For transfers of cookie-derived personal data from the EU or EEA to third countries without an EU adequacy decision, the Company employs the Standard Contractual Clauses approved by the European Commission under Article 46 of the GDPR or such equivalent mechanisms as are available under UK law;
Adequacy Decisions: Where an adequacy decision has been issued by the European Commission or a competent UK authority in respect of the destination country, the Company relies upon such decision as the applicable transfer mechanism;
DPDP Act Compliance: For transfers from India, the Company complies with the cross-border transfer obligations under the DPDP Act 2023 and the DPDP Rules 2025, in accordance with their phased implementation;
Singapore PDPA Transfer Obligations: For data relating to individuals in Singapore, the Company complies with the transfer limitation obligations under the PDPA 2012, including by ensuring that recipient organisations provide a comparable standard of protection; and
Contractual Data Processing Agreements: All third-party service providers that receive cookie data are engaged under written data processing agreements requiring them to implement appropriate technical and organizational security measures and to comply with applicable data protection law.

14. Security Measures for Cookie Data

14.1 Technical Security Attributes

The Company applies the following technical security attributes to cookies where supported by the browser and server environment:

Secure Flag: Cookies marked with the “Secure” attribute are transmitted only over encrypted HTTPS connections, preventing them from being intercepted in transit;
HttpOnly Flag: Cookies marked with the “HttpOnly” attribute are inaccessible to client-side JavaScript, substantially reducing the risk of cookie theft through Cross-Site Scripting (XSS) attacks;
SameSite Attribute: Cookies are configured with an appropriate “SameSite” value (“Strict” or “Lax” where appropriate) to mitigate Cross-Site Request Forgery (CSRF) risks by controlling when cookies are transmitted with cross-site requests; and
Short Expiry Periods: Cookies are assigned the minimum expiry period necessary for their stated purpose, reducing the window of exposure in the event of compromise.

14.2 Organisational Security Measures

In addition to technical cookie attributes, the Company implements the following organizational measures:

access to cookie-related personal data is restricted to authorised personnel on a need-to-know basis;
the Platform is protected by HTTPS/TLS encryption across all pages and endpoints;
real-time monitoring systems detect anomalous cookie usage patterns consistent with session hijacking, cookie theft, or automated abuse; and
the Company conducts periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate security weaknesses affecting cookie-based authentication and session management.

14.3 Limitation of Security Guarantees

Notwithstanding the security measures described in this Section, no electronic system or data transmission over the internet can be guaranteed to be entirely impervious to compromise. The Company cannot, therefore, warrant absolute security in relation to cookie data. Users are advised to keep their browser software updated, to use trusted and secure devices when accessing the Platform, and to log out of their account after each session, particularly when using shared or public devices.

15. Platform Integrity and Prohibited Conduct

15.1 Prohibited Manipulation of Tracking Systems

Users are strictly prohibited from:

manipulating, spoofing, interfering with, or circumventing the Company’s cookie-based authentication, session management, or fraud detection systems;
using scripts, browser extensions, or other tools to replay, forge, or inject cookie values in a manner designed to impersonate another user, bypass access controls, or circumvent security measures;
reverse-engineering the Company’s tracking technologies or using information derived from cookies to gain unauthorised access to any part of the Platform or its underlying systems;
using bots, scrapers, or automated tools to access the Platform in a manner that bypasses or disrupts cookie-based rate limiting or anti-bot protections; or
intercepting, reading, or modifying cookies transmitted between other users’ browsers and the Platform’s servers.

15.2 Consequences of Violation

Any user found to be engaged in conduct prohibited under Section 15.1 may be subject to:

immediate suspension or permanent termination of their account without prior notice;
reporting to relevant law enforcement, cybersecurity, or regulatory authorities; and
civil or criminal legal proceedings as appropriate under applicable law.

16. Third-Party Services and Links

16.1 Third-Party Services

The Platform may integrate third-party services—including but not limited to analytics platforms, cloud infrastructure providers, payment gateways, and customer support tools—that place their own cookies on users’ Devices. The Company exercises reasonable due diligence in selecting and contracting with such providers but is not responsible for the content, accuracy, or data practices of any third-party service.

16.2 Third-Party Websites

The Platform may contain links to third-party websites that are not owned or operated by the Company. Such websites may use their own cookies in a manner entirely independent of this Policy. The Company is not responsible for the cookie practices of third-party websites, and users who navigate to third-party websites are advised to review the cookie and privacy policies of those websites independently.

16.3 Social Media Plugins

Where the Platform incorporates social media sharing buttons or plugins, those features may cause third-party social media platforms to place cookies on the user’s Device, even if the user does not interact with the button or plugin. Users who do not wish social media platforms to place cookies through the Platform are advised to log out of those platforms before visiting the Platform or to manage their browser’s cookie settings accordingly.

17. Limitation of Liability

17.1 Scope of Exclusion

To the fullest extent permitted by applicable law, the Company, Master Trading Class Private Limited, and its respective directors, officers, shareholders, employees, and agents shall not be liable for:

any failure, malfunction, or inaccuracy of Third-Party Cookies or Similar Tracking Technologies deployed by third-party providers, including where such failure results in data loss, incorrect personalisation, or failed session authentication;
browser-level security vulnerabilities—such as cross-site scripting attacks or man-in-the-middle interceptions—that are not attributable to the Company’s failure to implement reasonable technical safeguards;
the independent data practices of third-party service providers whose cookies are integrated into the Platform, where such practices are beyond the Company’s reasonable control;
any loss or damage arising from a user’s failure to properly manage their cookie settings or to log out of the Platform after a session on a shared or public device; or
indirect, incidental, consequential, or punitive damages of any kind arising from or in connection with the placement, processing, or deletion of cookies.

17.2 Cap on Liability

Where the Company’s liability cannot be excluded by applicable law, the Company’s total aggregate liability to any user in connection with matters arising under this Cookie Policy shall not exceed the total Membership fees actually paid by that user to the Company in the twelve (12) calendar months immediately preceding the event giving rise to the claim.

18. Indemnification

Each user of the Platform agrees to defend, indemnify, and hold harmless the Company, Master Trading Class Private Limited, and its directors, officers, shareholders, employees, agents, and assigns from and against any and all third-party claims, liabilities, damages, losses, costs, and expenses—including reasonable legal fees—arising out of or in connection with:

the user’s manipulation, interference with, or circumvention of the Platform’s cookie-based security, authentication, or fraud detection systems;
the user’s violation of this Cookie Policy or any applicable law in connection with the use of cookies or tracking technologies; or
any misrepresentation made by the user regarding their cookie preferences or consent status.

19. Governing Law

This Cookie Policy, and all matters arising out of or relating to it, shall be governed by and construed in accordance with the laws of the Republic of India, without reference to its conflict of laws principles. The Company acknowledges that users located in other jurisdictions may also be entitled to the protections of applicable local law — including the GDPR (EU/UK), PDPA (Singapore), CCPA/CPRA (California, USA), and equivalent instruments — which shall apply to cookie processing in respect of such users to the extent required by mandatory applicable law.

20. Jurisdiction and Dispute Resolution

20.1 Good-Faith Resolution

Before initiating any formal legal proceedings in relation to this Cookie Policy, users are requested to notify the Company in writing at support@internboard.com, describing the nature of the dispute and the remedy sought. The parties agree to attempt resolution in good faith within thirty (30) calendar days of such notification.

20.2 Exclusive Jurisdiction

Subject to Section 20.1 and to any mandatory consumer forum jurisdiction available under applicable law, all disputes arising from or in connection with this Cookie Policy shall be subject to the exclusive jurisdiction of the courts located in Hyderabad, Telangana, India.

21. Amendments to this Policy

21.1 Right to Amend

The Company reserves the right to amend, update, or replace this Cookie Policy at any time to reflect changes in applicable law, regulatory guidance, judicial decisions, or changes in the cookies and Similar Tracking Technologies deployed on the Platform. The date of the most recent revision will be reflected in the “Last Reviewed and Updated” date and version number set out at the head of this Policy.

21.2 Notice of Material Changes

Where any amendment is material—including the introduction of a new category of cookie, a new third-party provider, or a change in the purpose for which cookie data is processed—the Company will:

notify registered users by email to the address held on their account prior to the amended Policy taking effect; and
display a prominent notice on the Platform for at least thirty (30) calendar days following publication of the amended Policy and—upon deployment of the Cookie Consent Management Tool—present a renewed consent interface to existing users requiring fresh consent for any materially new or different processing purpose.

21.3 Continued Use as Acceptance

Continued use of the Platform following the publication or notification of an amended Cookie Policy shall constitute the user’s acceptance of the amended terms, to the extent that continued use constitutes a valid form of acceptance under applicable law. Where applicable law requires fresh consent, the Company will obtain such consent before proceeding with any changed processing.

22. Contact Information

For all enquiries, consent withdrawal requests, complaints, or other communications relating to this Cookie Policy, users may contact the Company through the following channels:

Company Name: Master Trading Class Private Limited

Platform: InternBoard.com

Email: support@internboard.com