Cookie Policy
# TRUOPTIM SOLUTIONS LTD
# COOKIE POLICY
Copyright © 2025-present TruOptim Solutions Ltd. All rights reserved.
**Version:** 1.0
**Effective Date:** December 2025
**Last Updated:** December 2025
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## 1. INTRODUCTION
**1.1** This Cookie Policy explains how TruOptim Solutions Ltd ("**TruOptim**," "**we**," "**us**," or "**our**") uses cookies and similar technologies on our website at **truoptim.com** and any associated subdomains (the "**Website**").
**1.2** TruOptim Solutions Ltd is a company incorporated in England and Wales (Company Registration No. 16742261), with its registered office at 205 Regent Street, 4th Floor, London, England, W1B 4HB.
**1.3** This Cookie Policy should be read together with our [Privacy Policy](/privacy-policy) and [Website Terms of Service](/terms-of-service).
**1.4** By continuing to browse or use our Website, you acknowledge that you have read and understood this Cookie Policy.
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## 2. WHAT ARE COOKIES?
**2.1** Cookies are small text files that are placed on your computer, smartphone, or other device when you visit a website. They are widely used to make websites work more efficiently, provide information to website owners, and enhance your browsing experience.
**2.2** Cookies can be:
| Type | Description |
|------|-------------|
| **Session Cookies** | Temporary cookies deleted when you close your browser |
| **Persistent Cookies** | Remain on your device for a set period or until manually deleted |
| **First-Party Cookies** | Set by the website you are visiting |
| **Third-Party Cookies** | Set by a domain different from the one you are visiting |
**2.3** Similar technologies include:
- **Web beacons/pixels**: Small graphic images that track user behaviour
- **Local storage**: Browser storage mechanisms for data persistence
- **Fingerprinting**: Techniques that identify devices based on configuration
---
## 3. HOW WE USE COOKIES
### 3.1 Categories of Cookies We Use
We categorise cookies based on their purpose:
| Category | Purpose | Consent Required? |
|----------|---------|-------------------|
| **Strictly Necessary** | Essential for website functionality | No (legitimate interest) |
| **Functional** | Remember preferences and enhance experience | Yes |
| **Analytics** | Understand how visitors use the Website | Yes |
| **Marketing** | Deliver relevant advertisements | Yes |
### 3.2 Strictly Necessary Cookies
These cookies are essential for the Website to function and cannot be switched off. They are usually set in response to actions you take, such as setting privacy preferences, logging in, or filling in forms.
| Cookie Name | Provider | Purpose | Duration | Type |
|-------------|----------|---------|----------|------|
| `session_id` | TruOptim | Maintain user session state | Session | First-party |
| `csrf_token` | TruOptim | Protect against cross-site request forgery attacks | Session | First-party |
| `cookie_consent` | TruOptim | Store your cookie consent preferences | 1 year | First-party |
| `__cf_bm` | Cloudflare | Bot management and security | 30 minutes | Third-party |
**Legal Basis:** Legitimate interest (necessary for website operation and security).
### 3.3 Functional Cookies
These cookies enable enhanced functionality and personalisation, such as remembering your preferences or choices.
| Cookie Name | Provider | Purpose | Duration | Type |
|-------------|----------|---------|----------|------|
| `language` | TruOptim | Remember language preference | 1 year | First-party |
| `theme` | TruOptim | Remember display preferences | 1 year | First-party |
| `calculator_state` | TruOptim | Preserve ROI/Pricing Calculator inputs | Session | First-party |
| `assessment_progress` | TruOptim | Save Readiness Assessment progress | 7 days | First-party |
**Legal Basis:** Consent (you can choose to accept or reject these cookies).
### 3.4 Analytics Cookies
**NOT CURRENTLY USED**
We do not currently use third-party analytics cookies (such as Google Analytics) on our Website or in the Software. We rely on aggregate, anonymized usage metrics collected through our Control Plane for product improvement purposes.
If we introduce analytics cookies in the future, this policy will be updated and you will be asked for consent before any such cookies are placed.
### 3.5 Marketing Cookies
**NOT CURRENTLY USED**
We do not use marketing, advertising, or social media tracking cookies. We do not:
- Track visitors across websites for advertising purposes
- Use retargeting or remarketing cookies
- Share browsing data with advertising networks
- Use social media pixels for ad targeting
If we introduce marketing cookies in the future, this policy will be updated and you will be asked for explicit consent before any such cookies are placed.
---
## 4. COOKIES ON AZURE-HOSTED SERVICES
**4.1** When you access tools hosted on our Azure infrastructure (such as the ROI Calculator, Pricing Calculator, or Readiness Assessment), additional cookies may be set:
| Cookie Name | Provider | Purpose | Duration | Type |
|-------------|----------|---------|----------|------|
| `ARRAffinity` | Microsoft Azure | Route requests to same server instance | Session | Third-party |
| `ARRAffinitySameSite` | Microsoft Azure | Route requests (SameSite variant) | Session | Third-party |
| `ai_user` | Azure Application Insights | Anonymous user tracking | 1 year | Third-party |
| `ai_session` | Azure Application Insights | Session tracking | 30 minutes | Third-party |
**4.2** These cookies are necessary for the proper functioning of Azure-hosted services and fall under "Strictly Necessary" or "Analytics" depending on their specific function.
**4.3** For more information about Microsoft's use of cookies, see the [Microsoft Privacy Statement](https://privacy.microsoft.com/privacystatement).
---
## 5. COOKIES ON EMBEDDED CONTENT
**5.1** Our Website may include embedded content from third-party platforms (such as YouTube videos or LinkedIn feeds). When you interact with this content, those platforms may set their own cookies.
**5.2** We use a "click-to-load" approach for embedded content where possible, meaning third-party cookies are only loaded after you choose to interact with the content.
**5.3** Third-party cookies set by embedded content are governed by those third parties' cookie policies:
| Provider | Cookie Policy |
|----------|---------------|
| YouTube (Google) | [Google Privacy & Terms](https://policies.google.com/technologies/cookies) |
| LinkedIn | [LinkedIn Cookie Policy](https://www.linkedin.com/legal/cookie-policy) |
| Spotify | [Spotify Privacy Policy](https://www.spotify.com/legal/privacy-policy/) |
---
## 6. YOUR COOKIE CHOICES
### 6.1 Cookie Consent Banner
**6.1.1** When you first visit our Website, you will see a cookie consent banner that allows you to:
(a) **Accept All Cookies**: Enable all cookie categories;
(b) **Reject Non-Essential Cookies**: Enable only strictly necessary cookies;
(c) **Customise Preferences**: Choose which categories of cookies to accept.
**6.1.2** You can change your cookie preferences at any time by clicking the "Cookie Settings" link in the Website footer or by clearing your browser cookies and revisiting the Website.
### 6.2 Browser Settings
**6.2.1** Most web browsers allow you to control cookies through their settings. You can:
- Block all cookies
- Block third-party cookies only
- Delete cookies when you close your browser
- Set preferences for specific websites
**6.2.2** Instructions for managing cookies in common browsers:
| Browser | Instructions |
|---------|--------------|
| **Chrome** | Settings > Privacy and Security > Cookies |
| **Firefox** | Settings > Privacy & Security > Cookies |
| **Safari** | Preferences > Privacy > Cookies |
| **Edge** | Settings > Cookies and Site Permissions |
**6.2.3** Please note that blocking all cookies may impact the functionality of our Website and your ability to use certain features.
### 6.3 Opt-Out Links
**6.3.1** Since we do not currently use analytics or marketing cookies, there are no third-party tracking cookies to opt out of.
**6.3.2** If you wish to manage cookies from other websites you visit, you can use these general opt-out resources:
- [Your Online Choices (EU/UK)](https://www.youronlinechoices.com)
- [Network Advertising Initiative (US)](https://optout.networkadvertising.org)
- [Digital Advertising Alliance (US)](https://optout.aboutads.info)
### 6.4 Do Not Track
**6.4.1** Some browsers have a "Do Not Track" (DNT) feature that signals to websites that you do not want to be tracked.
**6.4.2** Currently, there is no industry standard for responding to DNT signals. Our Website does not currently respond to DNT signals, but you can manage cookies as described above.
---
## 7. LEGAL FRAMEWORK
### 7.1 UK/EU Compliance
**7.1.1** Our use of cookies complies with:
- **UK GDPR** (UK General Data Protection Regulation)
- **PECR** (Privacy and Electronic Communications Regulations 2003)
- **EU GDPR** (General Data Protection Regulation) where applicable
**7.1.2** Under these regulations:
(a) **Strictly necessary cookies** can be used without consent as they are essential for the service you have requested;
(b) **All other cookies** require your informed consent before they are placed on your device.
### 7.2 Lawful Bases
| Cookie Category | Lawful Basis | GDPR Article |
|-----------------|--------------|--------------|
| Strictly Necessary | Legitimate Interest | 6(1)(f) |
| Functional | Consent | 6(1)(a) |
| Analytics | Consent | 6(1)(a) |
| Marketing | Consent | 6(1)(a) |
### 7.3 Your Rights
Under data protection law, you have rights including:
- **Right to access**: Request copies of your personal data
- **Right to rectification**: Request correction of inaccurate data
- **Right to erasure**: Request deletion of your data
- **Right to restrict processing**: Request limitation of processing
- **Right to object**: Object to processing based on legitimate interests
- **Right to withdraw consent**: Withdraw consent at any time
To exercise these rights, contact us at privacy@truoptim.com.
---
## 8. DATA RETENTION
**8.1** Cookie data is retained for the duration specified in the tables above.
**8.2** Analytics data collected via cookies is:
- Aggregated and anonymised where possible
- Retained for a maximum of 26 months
- Deleted or anonymised after the retention period
**8.3** When you withdraw consent or opt out of cookies, we will:
- Stop setting non-essential cookies immediately
- Delete any personal data collected via those cookies within 30 days
- Note that cached or stored data may persist on your device until cookies expire or are cleared
---
## 9. INTERNATIONAL TRANSFERS
**9.1** Some cookies are provided by third parties located outside the United Kingdom. When personal data is transferred outside the UK:
- We ensure appropriate safeguards are in place (such as Standard Contractual Clauses)
- We verify that the recipient provides adequate data protection
**9.2** Third-party providers' data transfer mechanisms:
| Provider | Transfer Mechanism |
|----------|-------------------|
| Google | EU-US Data Privacy Framework, SCCs |
| Microsoft | EU-US Data Privacy Framework, SCCs |
| Meta | EU-US Data Privacy Framework, SCCs |
| LinkedIn | EU-US Data Privacy Framework, SCCs |
---
## 10. CHILDREN'S PRIVACY
**10.1** Our Website is not directed at children under 18 years of age.
**10.2** We do not knowingly collect personal data from children through cookies or otherwise.
**10.3** If we become aware that we have collected personal data from a child, we will take steps to delete that information.
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## 11. CHANGES TO THIS POLICY
**11.1** We may update this Cookie Policy from time to time to reflect changes in:
- The cookies we use
- Legal or regulatory requirements
- Our business practices
**11.2** We will indicate the date of the last update at the top of this policy.
**11.3** For material changes, we will provide notice through:
- A banner on the Website
- Resetting your cookie consent preferences where appropriate
- Email notification (for registered users)
**11.4** We encourage you to review this Cookie Policy periodically.
---
## 12. CONTACT US
**12.1** If you have questions about this Cookie Policy or our use of cookies, please contact us:
**TruOptim Solutions Ltd**
Company Registration No. 16742261
**Address:**
205 Regent Street, 4th Floor
London, England, W1B 4HB
United Kingdom
**Email:** privacy@truoptim.com
**Data Protection Officer:** dpo@truoptim.com
**General Enquiries:** info@truoptim.com
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## 13. SUPERVISORY AUTHORITY
**13.1** If you are not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner's Office (ICO):
**Information Commissioner's Office**
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
United Kingdom
**Website:** [https://ico.org.uk](https://ico.org.uk)
**Helpline:** 0303 123 1113
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**Copyright © 2025-present TruOptim Solutions Ltd. All rights reserved.**
*This Cookie Policy is effective as of the Effective Date stated above.*