Schedule 2

Cookie Policy

This Cookie Policy explains how SPY Genesis Corp. (trading as “SpacePay”) uses cookies and similar tracking technologies on spacepay.com (the “Website”).

1. What Are Cookies

1.1Cookies are small text files placed on your device when you visit a website. They serve various purposes, including enabling the website to function, improving performance, and providing information to the operators of the site.

1.2Similar technologies include pixel tags, web beacons, local storage objects, and browser fingerprinting techniques. References to “cookies” in this Policy include all such technologies unless otherwise specified.

2. Categories of Cookies

2.1Strictly Necessary Cookies: These cookies are essential for the Website to function and cannot be switched off in our systems. They are set in response to actions made by you, such as setting your privacy preferences, logging in, or completing forms. These cookies do not require consent under the ePrivacy Directive.

2.2Performance and Analytics Cookies: These cookies collect information about how visitors use the Website, including which pages are visited most frequently and whether users receive error messages. All information collected by these cookies is aggregated and anonymised. These cookies require your prior consent.

2.3Functional Cookies: These cookies enable the Website to provide enhanced functionality and personalisation, such as remembering language preferences. They may be set by us or by third-party providers whose services we have added to our pages. These cookies require your prior consent.

2.4Targeting and Marketing Cookies: These cookies track browsing habits to deliver personalised advertisements and measure the effectiveness of marketing campaigns. They may be set by the Company or by advertising partners. These cookies require your prior consent.

3. Consent Mechanism

3.1Upon your first visit to the Website, a cookie consent banner will be presented. You may accept or reject each category of non-essential cookies individually. No non-essential cookies will be placed until you have made an affirmative choice. Pre-ticked boxes are not used.

3.2You may change your cookie preferences at any time by accessing the cookie settings panel available via the “Cookie Settings” link in the Website footer or by clearing cookies from your browser.

3.3Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

3.4Consent records are stored and maintained as evidence of valid consent for a minimum of twelve (12) months.

4. Third-Party Cookies

4.1Certain cookies on the Website are placed by third-party service providers, including Chainalysis for compliance screening purposes. The Company does not control the use of third-party cookies and you should refer to the relevant third party's privacy policy for further information.

5. Cookie Inventory

5.1A detailed inventory of all cookies used on the Website, including the name, provider, purpose, type, and expiry of each cookie, is available at spacepay.com/legal/cookie-inventory. This inventory is updated no less than quarterly.

Last updated: 16 February 2026