COOKIE POLICY

1. WHAT ARE COOKIES

Cookies are small text files that are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.

Cookies perform various functions, such as enabling you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help ensure that advertisements you see online are more relevant to you and your interests.

2. TYPES OF COOKIES WE USE

We use the following category of cookies on our Site:

2.1 Strictly Necessary Cookies

These cookies are essential for you to browse the Site and use its features. Without these cookies, services you have requested cannot be provided. These cookies:

• Enable core functionality such as security, network management, and accessibility
• Do not collect information for marketing purposes
• Do not track your browsing activity across other websites
• Are automatically set when you visit the Site (no consent required under PECR)
• Cannot be disabled through our Site, but you can set your browser to block them (this may affect Site functionality)

Examples of strictly necessary functions our cookies provide:

• Maintaining your session as you navigate between pages
• Enabling the registration and login process
• Remembering information you've entered in forms during your session
• Ensuring security and preventing fraudulent activity
• Load balancing to ensure the Site remains available

3. COOKIES WE SET

3.1 Session Cookies

We use session cookies that are strictly necessary to maintain your session state and ensure functionality during your visit to our Site. These cookies:

• Are essential for the Site to function properly
• Do not require your consent under UK data protection law (PECR Regulation 6)
• Are automatically deleted when you close your browser
• Do not track or collect personal data for marketing purposes
• Are first-party cookies (set by Emcomit, not third parties)

These strictly necessary session cookies enable core website functionality such as:

• Maintaining your logged-in state during your visit
• Remembering your form inputs as you navigate between pages
• Ensuring security and preventing fraud
• Enabling the registration and authentication process

Cookie details:

• Type: HTTP Session Cookie
• Duration: Session only (deleted when browser closes)
• Purpose: Essential site functionality
• Legal basis: Legitimate interest (no consent required under PECR)

4. THIRD-PARTY COOKIES

We do not use:

• Analytics or tracking cookies (e.g., Google Analytics)
• Advertising or marketing cookies
• Social media cookies
• Any other non-essential third-party cookies

Note: We use Google Tag Manager solely to manage technical scripts, including the cookie consent banner. GTM does not collect or store any personal data nor deploy non-essential cookies.

If we introduce third-party cookies in the future, we will:

• Update this Cookie Policy with full details
• Clearly inform you about the third parties involved and their purposes
• Implement a cookie consent banner
• Obtain your explicit consent before setting any non-essential third-party cookies
• Provide you with easy ways to manage your cookie preferences

5. HOW TO MANAGE AND DELETE COOKIES

You have the right to decide whether to accept or reject cookies.

5.1 Browser Controls

Most web browsers allow you to manage your cookie preferences through the browser settings. You can set your browser to refuse cookies or delete certain cookies. Generally, you can access these controls through your browser's "Settings" or "Preferences" menu.

Please note that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this Site. Therefore, it is recommended that you do not disable cookies unless necessary.

5.2 Browser Help Resources

For information on how to manage cookies on different browsers, please consult your browser's Help function or visit:

• Chrome: https://support.google.com/chrome/answer/95647
• Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
• Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
• Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

5.3 Opt-Out Tools

For more information about online advertising and your choices, you can visit:

• Your Online Choices: https://www.youronlinechoices.com/uk/
• Network Advertising Initiative: https://www.networkadvertising.org/choices/
• Digital Advertising Alliance: https://www.aboutads.info/choices/

6. CONSENT

Under PECR Regulation 6, consent is not required for cookies that are:

• Strictly necessary for providing a service explicitly requested by the user, or
• Strictly necessary for the sole purpose of carrying out the transmission of a communication

Our session cookies fall under this exemption as they are essential for:

• Enabling you to navigate the Site
• Processing your registration
• Maintaining security during your session
• Providing the core functionality you expect

No Cookie Consent Banner Required:

Future Changes:

If we introduce non-essential cookies in the future (such as analytics, marketing, or functional cookies that are not strictly necessary), we will:

• Implement a cookie consent banner
• Clearly explain what cookies we use and why
• Only set non-essential cookies after you have given explicit consent
• Provide easy ways to withdraw or modify your consent
• Update this Cookie Policy with full details

You can still manage strictly necessary cookies through your browser settings (see section 5), although this may affect your ability to use the Site.

7. LEGAL BASIS FOR PROCESSING

Under UK data protection law (UK GDPR and Data Protection Act 2018) and the Privacy and Electronic Communications Regulations (PECR), we process personal data collected through cookies on the following legal basis:

Strictly Necessary Session Cookies:

• Legal basis: Legitimate interests (Article 6(1)(f) UK GDPR)
• Legitimate interest: To enable core Site functionality, maintain security, and provide the service explicitly requested by users (access to offers and coupons)
• No consent required under PECR Regulation 6(1), which exempts cookies that are strictly necessary for providing a service explicitly requested by the user

For more information about how we process your personal data more generally, please see our Privacy Policy.

8. YOUR RIGHTS

Under UK data protection law, you have rights including:

• The right to access personal data we hold about you
• The right to require us to rectify any inaccurate personal data
• The right to require us to erase personal data in certain circumstances
• The right to object to processing
• The right to data portability
• The right to withdraw consent at any time

To exercise any of these rights, please contact us using the details in section 10 below.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/).

9. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Cookie Policy on this page and updating the "Last updated" date at the top of this policy.

We encourage you to review this Cookie Policy periodically to stay informed about our use of cookies.

10. CONTACT US

If you have any questions about this Cookie Policy or our use of cookies, please contact us:

11. ADDITIONAL INFORMATION

For more general information on cookies and how they work, you can visit:

• All About Cookies: https://www.allaboutcookies.org/
• Information Commissioner's Office: https://ico.org.uk/for-the-public/online/cookies/