# COOKIE POLICY **Last Updated:** 6 May 2026 This Cookie Policy explains how Barkley ("**Barkley**", "**we**", "**us**", or "**our**") uses cookies and similar tracking technologies on our website and related services (together, the "**Services**"). This Policy should be read together with our **Privacy Statement**, which explains how we handle personal data more generally. We use cookies in accordance with the **Privacy and Electronic Communications Regulations 2003 (PECR)** and the **UK General Data Protection Regulation (UK GDPR)**. --- ## 1. WHAT ARE COOKIES? Cookies are small text files placed on your device (computer, tablet, or mobile phone) when you visit a website. They are widely used to make websites work, to make them work more efficiently, and to provide information to website operators. We also use **similar technologies** that work in comparable ways, including: - **pixels** (small images embedded in pages or emails that record activity); - **local storage** and **session storage** (data stored in your browser); - **device fingerprinting** (techniques that identify your device based on its configuration); and - **software development kits (SDKs)** in mobile applications. In this Policy, we use "**cookies**" to refer to all of these technologies unless we specify otherwise. --- ## 2. FIRST-PARTY AND THIRD-PARTY COOKIES - **First-party cookies** are set by Barkley directly. - **Third-party cookies** are set by other organisations whose services we use (for example, analytics providers, advertising partners, and social media platforms). These third parties may also process your personal data for their own purposes; we recommend reviewing their privacy policies, which are linked below. --- ## 3. SESSION AND PERSISTENT COOKIES - **Session cookies** are temporary and are deleted when you close your browser. - **Persistent cookies** remain on your device for a set period or until you delete them manually. --- ## 4. CATEGORIES OF COOKIES WE USE We use the following categories of cookies: ### 4.1 Strictly necessary cookies These cookies are essential for the Services to function. They allow you to navigate the Services and use core features such as logging in, maintaining a session, and remembering items you have selected. Without these cookies, the Services cannot work properly. **Legal basis:** these cookies are exempt from the consent requirement under PECR because they are strictly necessary for the service you have requested. ### 4.2 Functional cookies These cookies allow the Services to remember choices you make (such as your language, region, or display preferences) and provide enhanced features. **Legal basis:** consent. ### 4.3 Analytics and performance cookies These cookies help us understand how visitors interact with the Services by collecting information about pages visited, time spent, navigation paths, and any error messages encountered. We use this information to improve the performance and content of the Services. **Legal basis:** consent. ### 4.4 Advertising and targeting cookies These cookies are used to deliver advertising that is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement, to measure the effectiveness of advertising campaigns, and to build profiles about your interests across websites and over time. They may be set by us or by third-party advertising partners. **Legal basis:** consent. ### 4.5 Social media cookies These cookies are set by social media services that we have added to the Services to allow you to share our content with your networks. They may track your activity across other websites and build a profile of your interests. **Legal basis:** consent. --- ## 5. SPECIFIC COOKIES WE USE The table below sets out the specific cookies and similar technologies we use, what they do, and how long they last. We may update this list from time to time as our use of cookies evolves. | Cookie / Technology | Provider | Category | Purpose | Duration | |---|---|---|---|---| | `session_id` | Barkley (first-party) | Strictly necessary | Maintains your session and keeps you logged in | Session | | `csrf_token` | Barkley (first-party) | Strictly necessary | Protects against cross-site request forgery attacks | Session | | `cookie_consent` | Barkley (first-party) | Strictly necessary | Records your cookie preferences | 12 months | | `auth_token` | Barkley (first-party) | Strictly necessary | Authenticates logged-in users | 30 days | | `preferences` | Barkley (first-party) | Functional | Remembers your display and language preferences | 12 months | | `_ga`, `_ga_*` | Google Analytics | Analytics | Distinguishes unique users and sessions | Up to 24 months | | `_gid` | Google Analytics | Analytics | Distinguishes unique users | 24 hours | | `_gcl_au` | Google | Advertising | Used by Google AdSense for experimenting with advertising efficiency | 3 months | | `_fbp` | Meta (Facebook) | Advertising | Tracks visits across websites for advertising purposes | 3 months | | `fr` | Meta (Facebook) | Advertising | Delivers, measures, and improves the relevance of ads | 3 months | | `IDE` | Google DoubleClick | Advertising | Used to display targeted ads based on user profile | 13 months | | `MUID` | Microsoft (Bing) | Advertising | Identifies unique browsers for advertising and analytics | 13 months | | `personalization_id` | X (Twitter) | Social media / advertising | Tracks integration with X for sharing and advertising | 24 months | | `li_sugr` | LinkedIn | Advertising | Used for targeted advertising based on LinkedIn data | 3 months | | `lidc` | LinkedIn | Social media | Facilitates data centre selection for LinkedIn integration | 24 hours | If you would like more information about any specific cookie, please contact us at **privacy@barkley-example.com**. --- ## 6. THIRD-PARTY PROVIDERS The following third-party providers may set cookies through the Services. Their use of your personal data is governed by their own privacy policies: - **Google (Analytics, Ads, DoubleClick)** — policies.google.com/privacy - **Meta (Facebook, Instagram)** — facebook.com/privacy/policy - **Microsoft (Bing Ads)** — privacy.microsoft.com - **X (formerly Twitter)** — x.com/en/privacy - **LinkedIn** — linkedin.com/legal/privacy-policy Some of these providers are based outside the United Kingdom. Where personal data is transferred internationally, appropriate safeguards (such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses) are in place. See our **Privacy Statement** for more detail on international transfers. --- ## 7. YOUR CHOICES ### 7.1 Cookie banner When you first visit the Services, you will be presented with a cookie banner that allows you to: - **accept all** non-essential cookies; - **reject all** non-essential cookies (with equal prominence to "accept all"); or - **manage your preferences** by category. Strictly necessary cookies will be set regardless of your choice, because they are required for the Services to function. All other cookies will only be set after you have given consent. ### 7.2 Changing your preferences You can change your cookie preferences at any time by clicking the **"Cookie preferences"** link in the footer of the Services. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal. ### 7.3 Browser controls Most browsers allow you to view, manage, delete, and block cookies. You can usually find these settings in the "options", "preferences", or "privacy" section of your browser. Useful guides include: - **Google Chrome:** support.google.com/chrome/answer/95647 - **Mozilla Firefox:** support.mozilla.org/kb/cookies-information-websites-store-on-your-computer - **Apple Safari:** support.apple.com/en-gb/guide/safari/sfri11471/mac - **Microsoft Edge:** support.microsoft.com/microsoft-edge Please note that blocking strictly necessary cookies may prevent parts of the Services from working properly. ### 7.4 Opting out of advertising cookies You can opt out of personalised advertising from many providers using the following industry tools: - **Your Online Choices (UK/EU):** youronlinechoices.com - **Network Advertising Initiative:** optout.networkadvertising.org - **Digital Advertising Alliance:** optout.aboutads.info ### 7.5 "Do Not Track" Some browsers offer a "Do Not Track" (DNT) signal. Because there is no industry consensus on how to interpret DNT, the Services do not currently respond to DNT signals. You can manage your preferences using the cookie banner and your browser settings. --- ## 8. CHANGES TO THIS POLICY We may update this Cookie Policy from time to time to reflect changes in the cookies we use, in technology, or in legal requirements. The "Last Updated" date at the top shows when it was last revised. Where changes are material, we will take reasonable steps to notify you, for example by re-presenting the cookie banner. --- ## 9. CONTACT US If you have any questions about this Cookie Policy or our use of cookies, please contact: **Email:** privacy@barkley-example.com You also have the right to lodge a complaint with the **Information Commissioner's Office (ICO)**, the UK's supervisory authority for data protection and PECR: - **Website:** ico.org.uk - **Helpline:** 0303 123 1113 --- **Barkley** — Company number 11791358 (registered in England and Wales)