COOKIE POLICY

COOKIE POLICY

COOKIE POLICY

Digital Capital Ltd

This policy covers cookies and similar technologies on the Digital Capital website.

1. INTRODUCTION

1. INTRODUCTION

1.1 This Cookie Policy explains how Digital Capital Ltd (“we”, “us”, “our”) uses cookies and similar technologies when you visit our Website.

1.2 This Policy should be read together with our Privacy Notice.

1.3 Digital Capital Ltd is incorporated in England and Wales (Company No. 10222334) and authorised by the Financial Conduct Authority (FRN 900710).

2. PURPOSE OF THIS POLICY

2. PURPOSE OF THIS POLICY

2.1 This Cookie Policy aims to:

  • provide clear and comprehensive information about cookies

  • explain how and why cookies are used

  • explain your rights and choices

  • ensure compliance with applicable laws

3. LEGAL FRAMEWORK

3. LEGAL FRAMEWORK

3.1 The use of cookies is governed by:

  • Privacy and Electronic Communications Regulations (PECR)

  • UK General Data Protection Regulation (UK GDPR)

3.2 PECR applies to storing information on, or accessing information from, a device, even if it is not personal data. Consent is required unless all conditions of a specific exception are met. Current exceptions cover communication, strictly necessary use, statistical purposes, appearance and emergency assistance, each with its own conditions. Where personal data is processed, an appropriate UK GDPR lawful basis and transparency are also required.

3.3 Our selected website approach is to rely on the communication or strictly necessary exception only where applicable and to ask for prior consent for optional functionality and marketing tracking, and for any analytics that uses cookies or stores information on your device. The Website’s built-in statistics, described in section 19, do not use cookies or persistent identifiers. We do not rely on the additional statutory exceptions unless a verified update explains the actual use and fulfils their conditions. This is the site’s chosen approach, not a claim that every optional technology always requires consent under the law.

4. WHAT ARE COOKIES

4. WHAT ARE COOKIES

4.1 Cookies are small text files stored on your device when you visit a website.

4.2 Cookies may:

  • enable functionality

  • recognise users

  • track activity

5. TYPES OF TRACKING TECHNOLOGIES

5. TYPES OF TRACKING TECHNOLOGIES

5.1 In addition to cookies, we may use:

  • pixels

  • local storage

  • similar technologies

5.2 These are treated in the same way as cookies for regulatory purposes.

5.3 The actual inventory must include browser local or session storage, tracking pixels, device identifiers and embedded third-party access as well as HTTP cookies. A label such as “security” does not itself establish an exemption.

6. HOW COOKIES ARE USED

6. HOW COOKIES ARE USED

We may use cookies to:

  • operate and secure the Website

  • improve functionality

  • analyse performance

  • support fraud prevention

  • enhance user experience

6.1 Only purposes supported by the verified inventory apply in practice. Describing analytics, marketing or fraud prevention here does not mean those technologies are currently deployed. The website must not set optional tracking until the corresponding choice has been implemented.

7. COOKIE CLASSIFICATION

7. COOKIE CLASSIFICATION

Cookies are categorised as follows:

7.1 Strictly Necessary Cookies

These cookies are required for:

  • Website operation

  • security

  • core functionality

These cookies do not require consent.

7.2 Performance / Analytics Cookies

These cookies:

  • analyse how users interact with the Website

  • help improve performance

These require consent.

7.3 Functional Cookies

These cookies:

  • remember user preferences

  • enhance usability

These require consent.

7.4 Marketing / Targeting Cookies

These cookies:

  • track behaviour

  • support advertising

These require consent.

7.5 Classification depends on the real function and context, not the provider’s category name. A technology is treated as strictly necessary only where the applicable exception is satisfied. For optional functions, this website uses the consent approach described in section 3.

8. FIRST-PARTY VS THIRD-PARTY COOKIES

8. FIRST-PARTY VS THIRD-PARTY COOKIES

8.1 First-party cookies are set by Digital Capital.

8.2 Third-party cookies are set by:

  • analytics providers

  • service providers

  • advertising partners

9. COOKIE LIFESPAN

9. COOKIE LIFESPAN

Cookies may be:

  • session cookies (deleted when browser closes)

  • persistent cookies (stored for a defined period)

10. CONSENT PRINCIPLES

10. CONSENT PRINCIPLES

10.1 Non-essential cookies:

  • are not set without consent

  • require an active user action

10.2 Consent must be:

  • explicit

  • informed

  • revocable

10.3 Consent is an active, specific and informed choice. Optional categories are off by default, with no pre-ticked boxes. Continuing to browse or closing the banner is not consent. Refusal must be as straightforward as acceptance, and essential access must not be made conditional on unnecessary tracking.

11. CONSENT MECHANISM

11. CONSENT MECHANISM

11.1 If we use optional cookies or similar technologies, users are first presented with a cookie banner.

11.2 The banner lets users:

  • accept cookies

  • reject cookies

  • customise preferences

11.3 Our website uses Framer’s built-in aggregate website statistics, described in section 19. Framer states that this service uses no cookies or persistent identifiers. Our published inventory describes the additional technologies used on this website. We do not display a consent banner where the technologies in use do not require consent under our selected approach in section 3. If we introduce non-exempt optional storage or access, we will provide the required choice before it occurs.

12. REJECTION OF COOKIES

12. REJECTION OF COOKIES

12.1 Rejecting cookies must be:

  • as easy as accepting them

13. WITHDRAWAL OF CONSENT

13. WITHDRAWAL OF CONSENT

13.1 Users may withdraw consent at any time.

13.2 This may be done via:

  • cookie settings

  • browser controls

13.3 Withdrawing consent through the website tool must stop future optional access and remove or disable relevant technologies where technically within our control. Browser deletion alone does not reliably notify every provider of withdrawal and is not a substitute for our own working withdrawal mechanism. We explain any independent provider steps.

14. RECORD OF CONSENT

14. RECORD OF CONSENT

14.1 We may record:

  • consent decisions

  • timestamps

14.2 Consent evidence must record the choices and applicable notice version without collecting unnecessary data. We disclose the retention period and any technical preference identifier in the verified inventory.

15. CHANGES TO COOKIES

15. CHANGES TO COOKIES

15.1 We may update cookies from time to time.

15.2 Changes will be reflected in this Policy.

16. CONTACT

16. CONTACT

16.1 For questions, contact:

info@digi-capital.co.uk

17. OVERVIEW

17. OVERVIEW

17.1 Sections 18 to 21 list, by category, the cookies and similar technologies on the Website.

17.2 Each cookie is described by:

  • name

  • purpose

  • provider

  • duration

17.3 For each technology we state its name and domain, the provider, whether it is first- or third-party, its purpose and the information it accesses, its duration, and the consent category or exception that applies.

18. STRICTLY NECESSARY COOKIES

18. STRICTLY NECESSARY COOKIES

No strictly necessary cookies are currently used. The table below lists the technologies the Website uses and whether any of them sets cookies or uses device storage.

Technology

Domain

Provider

Purpose

Cookies or device storage

Website hosting and delivery

www.digi-capital.co.uk, framerusercontent.com, app.framerstatic.com, framer.com

Framer B.V. (third party, our website provider)

Delivers the pages, images and code that make up the Website

None

Website statistics

events.framer.com

Framer B.V. (third party, our website provider)

Counts visits and page views for our aggregate website statistics (see section 19)

None

Fonts

fonts.gstatic.com

Google (third party)

Font files used to display text

None

Map data

raw.githubusercontent.com

GitHub (third party)

Map outline for the globe graphic on the homepage

None

18.1 None of these technologies sets a cookie or uses local or session storage on your device. As with any website, your browser sends these providers your IP address and browser details when it fetches the files, and it may keep copies of files in its cache, which you can clear in your browser settings.

19. PERFORMANCE / ANALYTICS COOKIES

19. PERFORMANCE / ANALYTICS COOKIES

These cookies help us understand how users interact with the Website.

19.1 The Website uses Framer’s built-in website statistics. When you open a page, a script from events.framer.com tells Framer about the visit, so that we can see aggregate figures such as the number of visitors and page views, the most visited pages, referring websites and approximate country. Framer states that these statistics use no cookies or persistent identifiers: it counts unique visitors with a hash of the IP address and browser details using a salt that changes daily, estimates country from the IP address and does not store the IP address. We see only aggregate figures and do not use them to identify you or for advertising.

20. FUNCTIONAL COOKIES

20. FUNCTIONAL COOKIES

These cookies enhance usability and user experience.

20.1 None. The Website does not store your preferences.

21. MARKETING / TARGETING COOKIES

21. MARKETING / TARGETING COOKIES

These cookies are used for marketing and tracking behaviour.

21.1 None. The Website uses no marketing, advertising or targeting cookies, pixels or similar technologies.

22. THIRD-PARTY COOKIES

22. THIRD-PARTY COOKIES

22.1 No third-party cookies are set through the Website at present.

22.2 If they are used in future, they may include:

· analytics providers

· payment-related tools

· embedded services

22.3 Third-party scripts and embedded services must also respect your choice before loading any non-exempt storage or access. Consent must not be bypassed by a tag manager, embedded video, form integration or server-triggered tracker that accesses your device.

22.4 Framer may load an editing interface for authorised website editors. The privacy and cookie information for this public website must reflect any storage or access that interface causes for ordinary visitors as well as other embedded services. Any non-exempt optional access is subject to the controls described above.

23. THIRD-PARTY RESPONSIBILITY

23. THIRD-PARTY RESPONSIBILITY

23.1 Third parties may process data independently.

23.2 Their own privacy policies apply.

23.3 A third party’s own notice does not remove Digital Capital’s obligations for technologies it deploys or causes to access a device. We identify roles and relevant sharing in the Privacy Notice.

24. COOKIE CHANGES

24. COOKIE CHANGES

24.1 Cookies may change over time.

24.2 This table will be updated accordingly.

25. ACCURACY OF COOKIE INFORMATION

25. ACCURACY OF COOKIE INFORMATION

25.1 We aim to keep this information accurate.

25.2 We test relevant devices, configurations and user interactions, including rejection, acceptance, reopening settings and withdrawal. Variations must be reflected in the inventory and controls; they do not excuse a misleading list or undisclosed tracking.

26. MANAGING COOKIES

26. MANAGING COOKIES

26.1 You can control how cookies are used through:

· our cookie preference tool, once optional cookies are used

· your browser settings

26.2 Where the preference tool is available, you may choose to:

· accept all cookies

· reject non-essential cookies

· customise your preferences

27. COOKIE PREFERENCE TOOL

27. COOKIE PREFERENCE TOOL

27.1 Our Website does not currently need a cookie management tool, because it uses no optional cookies or similar technologies. If that changes, we will provide one before any optional technology is used.

27.2 The tool will allow you to:

· view cookie categories

· enable or disable non-essential cookies

· change your preferences at any time

27.3 The tool will be available through a “Cookie settings” link in the footer of every page. The control must remain accessible after the initial banner is closed and apply category choices to every relevant script and embed.

28. WITHDRAWING CONSENT

28. WITHDRAWING CONSENT

28.1 You may withdraw consent at any time.

28.2 Withdrawal does not affect the lawfulness of processing before withdrawal.

29. EFFECT OF DISABLING COOKIES

29. EFFECT OF DISABLING COOKIES

29.1 Declining optional analytics or marketing does not prevent the core website from working. Disabling a technology necessary for a function you request can affect that function; we explain the particular effect accurately and do not use a generic warning to pressure you into optional consent.

29.2 We do not currently use strictly necessary cookies. If this changes, we will update this policy to explain their purpose and use.

30. BROWSER CONTROLS

30. BROWSER CONTROLS

30.1 You can manage cookies through your browser.

30.2 Common browser controls include:

· blocking cookies

· deleting cookies

· setting preferences

31. DEVICE SETTINGS

31. DEVICE SETTINGS

31.1 Some devices allow control of tracking technologies through system settings.

32. THIRD-PARTY CONTROLS

32. THIRD-PARTY CONTROLS

32.1 Third-party providers may offer their own cookie controls.

32.2 You should refer to their policies for more information.

33. DATA PROTECTION RIGHTS

33. DATA PROTECTION RIGHTS

33.1 Where cookies involve personal data, you have rights under data protection law.

33.2 These include:

· access

· rectification

· erasure

· restriction

34. COOKIE CONSENT RECORDS

34. COOKIE CONSENT RECORDS

34.1 We may retain records of:

· consent preferences

· timestamps

· user choices

34.2 This is to demonstrate compliance.

35. CHANGES TO THIS POLICY

35. CHANGES TO THIS POLICY

35.1 We may update this Cookie Policy.

35.2 Updates may reflect:

· changes in cookies

· regulatory updates

· operational changes

36. VERSION CONTROL

36. VERSION CONTROL

36.1 The latest version of this Policy will always be available on the Website.

37. LEGAL DISCLAIMER

37. LEGAL DISCLAIMER

37.1 We are responsible for maintaining clear and accurate information about technologies used through our website and for correcting errors promptly. A change in third-party behaviour does not waive our transparency or consent obligations.

38. LIMITATION OF LIABILITY

38. LIMITATION OF LIABILITY

38.1 You control your browser settings and third parties may have independent responsibilities, but nothing in this Policy limits Digital Capital’s own data protection, PECR or other mandatory legal duties or your rights and remedies.

39. CONTACT AND ENQUIRIES

39. CONTACT AND ENQUIRIES

39.1 For questions about this Cookie Policy or our use of cookies, contact:

Digital Capital Ltd

Email: info@digi-capital.co.uk

40. FINAL PROVISION

40. FINAL PROVISION

40.1 This Cookie Policy forms part of the Website legal framework.