Cookie Policy


TRUOPTIM SOLUTIONS LTD
COOKIE POLICY
Copyright © 2025-present TruOptim Solutions Ltd. All rights reserved.

Version: 1.3 Effective Date: 19 August 2026 Last Updated: 19 August 2026

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 and Website Terms of Service.

1.4 By continuing to browse or use our Website, you acknowledge that you have read and understood this Cookie Policy.

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
access_token	TruOptim Cloud Gateway	Maintain authenticated Cloud Gateway state	Session/configured token lifetime	First-party
csrf_token	TruOptim	Protect against cross-site request forgery attacks	Session	First-party
cp_session	TruOptim Control Plane	Maintain an authenticated Control Plane administrator session	Session/configured session lifetime	First-party
Legal Basis: Legitimate interest (necessary for website operation and security).

3.3 Functional Cookies
The pilot application does not claim to set separate language, theme, calculator-state, assessment-progress, consent-preference, Cloudflare, analytics or advertising cookies. Browser sessionStorage or localStorage, where used, is not a cookie and is described according to its actual feature context.

3.4 Analytics Cookies
TruOptim application code does not deliberately set third-party analytics cookies such as Google Analytics. The Azure hosting configuration selected for a particular service may nevertheless set infrastructure or Application Insights identifiers. Those cookies must be verified in the deployed service and, where they are analytics rather than strictly necessary, withheld until the required consent has been obtained. The Control Plane also receives limited service and usage metadata independently of cookies. That metadata can contain tenant, subscription, gateway, account or usage identifiers and is not represented as anonymous; see the Privacy Policy.

Where deployment verification confirms that no Azure analytics identifiers are enabled, no analytics cookies are used. If analytics cookies are enabled now or introduced later, the deployment must provide a consent banner or equivalent pre-consent mechanism and withhold them until the required consent is obtained; this policy and the deployed cookie inventory must be updated before access.

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 Azure infrastructure (such as the ROI Calculator, Pricing Calculator, or Readiness Assessment), Azure may set the following cookies if the corresponding routing or monitoring feature is enabled. This table is a deployment inventory to verify, not a statement that every pilot sets every cookie:

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 Affinity cookies may be strictly necessary where session affinity is enabled. Application Insights identifiers are analytics cookies and require the applicable consent unless counsel confirms another lawful exemption. The pilot owner must record the cookies actually observed, their duration and consent state before customer access.

4.3 For more information about Microsoft's use of cookies, see the Microsoft Privacy Statement.

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
LinkedIn	LinkedIn Cookie Policy
Spotify	Spotify Privacy Policy
6. YOUR COOKIE CHOICES
6.1 Essential application cookies
When deployment verification confirms that Azure analytics identifiers and all other non-essential cookies are disabled, the pilot sets only the essential cookies listed in Section 3.2 and does not need a non-essential-cookie consent banner or preference centre. A deployment that enables Application Insights cookies or any other non-essential cookie must instead provide a banner or equivalent preference mechanism and prevent those cookies before consent.

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 If the deployed-cookie verification confirms analytics and marketing cookies are disabled, there are no third-party tracking cookies to opt out of. If Azure analytics identifiers are enabled, use the deployment's consent or preference mechanism to reject or withdraw consent; the pilot owner must test that rejection prevents or removes the identifiers as applicable.

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)
Network Advertising Initiative (US)
Digital Advertising Alliance (US)
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.

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

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 Helpline: 0303 123 1113

Copyright © 2025-present TruOptim Solutions Ltd. All rights reserved.

This Cookie Policy is effective as of the Effective Date stated above.