Cookie Policy
Cookie Policy explaining how Finerty uses cookies and similar technologies
Cookie Policy
Effective Date: 15 January 2025 Version: 1.0.0
1. Introduction
This Cookie Policy explains how Finerty Data Solutions Limited (“Finerty,” “we,” “us,” or “our”) uses cookies and similar tracking technologies on our website (https://finerty.com) and our Letter of Authority (LOA) platform.
By using our website, you consent to the use of cookies in accordance with this policy. You can manage your cookie preferences at any time through our cookie consent tool or your browser settings.
2. What Are Cookies?
Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. They help websites recognise your device and remember information about your visit, such as your preferences, login status, and browsing behaviour.
2.1 Types of Cookies by Duration
Session Cookies Temporary cookies that are deleted when you close your browser. They are used to maintain your session as you navigate between pages.
Persistent Cookies Cookies that remain on your device for a set period or until you delete them. They remember your preferences and actions across multiple visits.
2.2 Types of Cookies by Source
First-Party Cookies Set by the website you are visiting (finerty.com). We control these cookies directly.
Third-Party Cookies Set by external services we use (e.g., analytics providers). These cookies are controlled by the respective third parties.
3. Cookies We Use
3.1 Strictly Necessary Cookies
These cookies are essential for our website to function properly. They cannot be disabled without affecting core functionality. No consent is required for these cookies under the ePrivacy Directive.
| Cookie Name | Purpose | Duration | Provider |
|---|---|---|---|
cc_cookie | Stores your cookie consent preferences | 12 months | First-party |
session_id | Maintains your authenticated session (platform only) | Session | First-party |
csrf_token | Protects against Cross-Site Request Forgery attacks | Session | First-party |
__cf_bm | Cloudflare bot management (if used) | 30 minutes | Cloudflare |
Legal Basis: These cookies are strictly necessary for service delivery (GDPR Article 6(1)(b)) and security (GDPR Article 6(1)(f)). Consent is not required under ePrivacy Directive Article 5(3).
3.2 Analytics Cookies
These cookies help us understand how visitors interact with our website, which pages are most popular, and how we can improve user experience. Consent is required before these cookies are set.
| Cookie Name | Purpose | Duration | Provider |
|---|---|---|---|
| (Currently none) | We do not currently use analytics cookies | - | - |
Future Implementation: If we implement analytics (e.g., Plausible Analytics), we will update this table and request your consent before setting any analytics cookies.
Note: We are considering privacy-focused analytics solutions that do not require cookies. If implemented, this policy will be updated accordingly.
3.3 Marketing Cookies
These cookies are used to deliver personalised advertisements and track marketing campaign effectiveness. Consent is required before these cookies are set.
| Cookie Name | Purpose | Duration | Provider |
|---|---|---|---|
| (Currently none) | We do not currently use marketing cookies | - | - |
Future Implementation: If we add marketing cookies (e.g., Google Ads, LinkedIn), we will update this table and request explicit consent.
3.4 Third-Party Cookies (Platform Only)
When using our LOA platform, you may encounter cookies from integrated services:
DocuSign (Electronic Signature Provider)
During the LOA signing process, DocuSign may set cookies to:
- Maintain your signing session
- Prevent fraud and ensure security
- Remember signing preferences
These cookies are set only when you actively engage in a signing workflow. See DocuSign’s privacy policy at https://www.docusign.com/privacy for more information.
4. Cookie Consent Management
4.1 First Visit
When you first visit our website, you will see a cookie consent banner. This banner allows you to:
- Accept All: Enable all optional cookies (analytics, marketing)
- Reject All: Disable all optional cookies (only necessary cookies used)
- Manage Preferences: Choose which cookie categories to enable
No optional cookies are set until you make a choice. We do not use “implied consent” or pre-checked boxes.
4.2 Changing Your Preferences
You can change your cookie preferences at any time:
- Via Our Website: Click “Cookie Preferences” in the website footer
- Via Browser Settings: See Section 5 below
- Via Email: Contact [email protected]
When you change preferences:
- Newly rejected cookies will be deleted immediately
- Existing tracking will stop for rejected categories
- Your new preferences will be saved for 12 months
4.3 Consent Withdrawal
You have the right to withdraw consent at any time. Withdrawal is as easy as giving consent:
- Click “Cookie Preferences” in the footer
- Deselect the categories you wish to withdraw consent for
- Click “Save Preferences”
Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
5. Managing Cookies via Browser Settings
You can also control cookies through your browser settings. Please note that disabling strictly necessary cookies may impair website functionality.
5.1 Browser-Specific Instructions
Google Chrome
- Click the three-dot menu > Settings
- Click “Privacy and security” > “Cookies and other site data”
- Choose your preferred cookie settings
Mozilla Firefox
- Click the menu button > Settings
- Click “Privacy & Security”
- Under “Cookies and Site Data,” choose your settings
Apple Safari
- Click Safari > Preferences
- Click “Privacy”
- Under “Cookies and website data,” choose your settings
Microsoft Edge
- Click the three-dot menu > Settings
- Click “Cookies and site permissions” > “Cookies and site data”
- Choose your preferred settings
5.2 Do Not Track (DNT)
Some browsers offer a “Do Not Track” (DNT) signal that indicates you do not wish to be tracked.
Our Response to DNT: We honour Do Not Track signals. If your browser sends a DNT signal, we will:
- Not set optional cookies (analytics, marketing)
- Treat your visit as if you selected “Reject All” on our consent banner
6. Local Storage and Similar Technologies
In addition to cookies, we use other client-side storage technologies:
6.1 Local Storage
- Purpose: Store non-sensitive user preferences (e.g., theme preferences, UI state)
- Data: JSON objects containing preference settings
- Duration: Persistent until cleared
- Clearing: Browser settings > Clear browsing data > Local storage
6.2 Session Storage
- Purpose: Temporary data for current session (e.g., form state, navigation)
- Data: Non-sensitive application state
- Duration: Until browser tab/window is closed
- Clearing: Automatic when tab is closed
6.3 IndexedDB
- Purpose: Currently not used on marketing website
- Platform Use: May be used on LOA platform for offline capability caching
7. Cookie Duration
| Category | Typical Duration | Purpose |
|---|---|---|
| Session Cookies | Until browser closes | Maintain state during visit |
| Consent Cookies | 12 months | Remember your consent choice |
| Authentication | Session or up to 30 days (remember me) | Keep you logged in |
| Analytics | Not currently used | - |
| Marketing | Not currently used | - |
8. Updates to This Cookie Policy
We may update this Cookie Policy to reflect:
- Changes in our cookie usage
- New regulatory requirements
- Implementation of new technologies
Notification Process:
- Material changes will be highlighted in a banner on our website
- We will update the “Last Updated” date
- For significant changes, we may request consent renewal
We recommend reviewing this policy periodically to stay informed about our use of cookies.
9. Contact Us
If you have questions about our use of cookies or this policy, please contact:
Email: [email protected]
Data Protection Officer: [email protected]
Postal Address: Data Protection Officer Finerty Data Solutions Limited The CHQ Building North Wall Quay Dublin 1, D01 Y6H7 Ireland
10. Regulatory Compliance
This Cookie Policy is designed to comply with:
| Regulation | Jurisdiction | Key Requirements |
|---|---|---|
| ePrivacy Directive (2002/58/EC as amended) | European Union | Prior consent for non-essential cookies |
| GDPR (Regulation EU 2016/679) | European Union | Lawful basis, data subject rights |
| Irish Data Protection Act 2018 | Ireland | GDPR implementation |
| UK GDPR | United Kingdom | Post-Brexit GDPR equivalent |
| PECR (Privacy and Electronic Communications Regulations 2003) | United Kingdom | Cookie consent requirements |
10.1 Key Compliance Measures
- Consent Before Cookies: We do not set optional cookies until you provide consent
- Granular Consent: You can choose which categories of cookies to accept
- Easy Withdrawal: Consent can be withdrawn as easily as it was given
- Clear Information: This policy provides transparent information about our cookies
- No Cookie Walls: Website content is accessible without accepting optional cookies
Appendix: Cookie Audit Summary
Last Audit Date: 15 January 2025 Audit Method: Manual review
| Category | Count | Consent Required |
|---|---|---|
| Strictly Necessary | 3-4 | No |
| Analytics | 0 | Yes (if added) |
| Marketing | 0 | Yes (if added) |
| Total | 3-4 | - |
Notes:
- Current cookie usage is minimal, focused on essential functionality
- No third-party tracking cookies in use on marketing website
- DocuSign cookies may appear during LOA signing workflows (platform only)
We will update this audit summary whenever cookies are added or removed.
Last Updated: 15 January 2025