Last Updated: 29 May 2026

1. INTRODUCTION

This Cookie Policy ("Policy") explains how CIRCLE GREEN LIMITED ("Circle Green", "we", "us", or "our") uses cookies and similar tracking technologies when you access or use our website https://circen.net/ (the "Website") and any services made available through it (the "Services").

Please read this Policy carefully to understand how cookies help optimize your user experience and how you can manage your preferences. By continuing to use our Website or Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy, alongside our core Terms and Conditions and our Privacy Policy.

We are committed to protecting your personal data. To the extent that information collected through cookies constitutes personal data under the UK General Data Protection Regulation (UK GDPR), we process it in accordance with our Privacy Policy.

Our use of cookies and tracking technologies complies with the following data protection frameworks:

• UK General Data Protection Regulation (UK GDPR);

• Data Protection Act 2018;

• Privacy and Electronic Communications Regulations (PECR);

• EU ePrivacy Directive.

2. WHAT ARE COOKIES

2.1 Cookies

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device on future visits, maintain session state, and store information about your preferences or browsing activity.

Where cookies collect data that identifies or can identify an individual (directly or indirectly), that data constitutes personal data under UK GDPR, Article 4(1), and is processed in accordance with our Privacy Policy.

2.2 Similar Technologies

In addition to cookies, we may use the following similar technologies:

• Local storage: a browser-based mechanism persisting beyond the session and not transmitted to the server with each request. Used for functional preferences.

• Session storage: similar to local storage but cleared automatically when the browser session ends.

• Tracking pixels (web beacons): small invisible image files embedded in web pages, used to detect whether a page has been accessed or an email has been opened.

• Device fingerprinting: Circle Green does not currently use device fingerprinting. If this practice is introduced in future, this Policy will be updated and, where required, prior consent will be obtained. The ICO has confirmed that device fingerprinting requires the same standard of consent as cookies under PECR.

3. TYPES OF COOKIES USED

The Website may use the following categories of cookies:

3.1 Strictly Necessary Cookies

Strictly necessary cookies are essential for the Website and Services to operate. They enable core functions including session management, security, authentication, and document processing. They cannot be disabled without breaking core functionality.

Under PECR Regulation 6(4) and the ICO’s guidance on strictly necessary cookies, these do not require user consent. They are set automatically when you access the Website.

These cookies are used to:

• maintain authenticated session state;

• provide protection against cross-site request forgery (CSRF);

• support server-side load balancing and routing;

• enable document upload, processing, and retrieval operations; and

• maintain platform security integrity.

3.2 Analytics and Performance Cookies

These cookies help us understand how users interact with the Website. They may be used to:

• analyse traffic and usage patterns;

• monitor performance;

• improve functionality and user experience.

Analytics cookies are not strictly necessary and require user consent.

3.3 Functional Cookies

These cookies enable enhanced functionality and personalisation.

They may be used to:

• remember user preferences;

• improve usability;

• customise user experience.

They are not strictly necessary; disabling them may reduce personalisation but will not prevent use of the core Services.

Functional cookies require your prior consent under PECR.

3.4 Marketing and Advertising Cookies

Circle Green does not currently deploy marketing or advertising cookies on the Website. No third-party advertising networks, retargeting scripts, or cross-site tracking technologies are used for marketing purposes.

If Circle Green deploys marketing cookies in future, this Policy will be updated before those cookies are placed. Your explicit prior consent will be sought before any marketing cookie is set. You will be given the ability to accept or reject marketing cookies separately from other cookie categories.

4. LEGAL BASIS FOR COOKIE USE

Under PECR and the ePrivacy Directive:

• strictly necessary cookies may be used without consent;

• all other cookies require prior user consent.

Users must be provided with clear and comprehensive information about cookie usage and given the opportunity to accept or refuse them.

Consent must be:

• freely given

• specific

• informed

• unambiguous

5. COOKIE CONSENT PERIOD

Upon first access to the Website, users are presented with a cookie consent banner.

Users can:

• accept all cookies

• reject non-essential cookies

• manage preferences

Non-essential cookies are not placed until valid consent is obtained.

You may withdraw or modify this consent at any time through our interactive cookie settings tool on the Website.

6. FIRST-PARTY AND THIRD-PARTY COOKIES

Cookies may be:

6.1 First-Party Cookies

Set directly by Circle Green to support platform functionality. We have full control over these cookies and the data they collect.

6.2 Third-Party Cookies

Third-party cookies are set by external service providers whose code is loaded by the Website. Circle Green does not control how third-party providers set, access, or use their cookies beyond the agreements in place with them. Examples of external providers:

• cloud hosting providers

• analytics services

• infrastructure providers

• security providers

We do not control third-party cookies and recommend reviewing their respective privacy policies.

7. COOKIE RETENTION PERIOD

Cookies may be stored for varying periods depending on their function:

• session cookies: deleted when the browser is closed

• persistent cookies: stored for a defined duration or until manually deleted

Retention periods are determined based on operational and legal requirements.

8. MANAGING YOUR COOKIES PREFERENCES

Users can control cookies through:

• browser settings;

• cookie consent tools on the Website.

Most browsers allow you to manage cookies through their settings. Depending on your browser you can typically:

• delete all existing cookies or cookies from specific websites;

• block all cookies or cookies from specific domains;

• receive a notification before a cookie is stored; and

• browse in a private or incognito mode (which generally prevents persistent cookies from being stored).

Disabling cookies at browser level will affect the functionality of many websites, including potentially the ability to use certain features of the Services.

9. DATA PROTECTION AND PRIVACY

Where cookies process personal data:

• processing is governed by UK GDPR and Data Protection Act 2018

• appropriate safeguards are applied

Cookies may be used in conjunction with other data sources to improve services, subject to applicable legal requirements.

10. INTERNATIONAL USERS

10.1 EU / EEA Users

If you access the Website from the EU or EEA, cookie use is also subject to the EU ePrivacy Directive (2002/58/EC, Article 5(3)) as transposed into your country’s national law. Circle Green applies the ePrivacy Directive consent standard for all EU/EEA users as a matter of policy, which is substantively equivalent to or stricter than PECR.

EU/EEA users have rights under EU GDPR (Regulation (EU) 2016/679), including the right to lodge a complaint with your national data protection supervisory authority.

For users located in the EU or other jurisdictions:

• cookie use complies with applicable local laws, including the ePrivacy Directive

• consent requirements may vary depending on jurisdiction

Where multiple legal frameworks apply, we implement the stricter standard.

11. CHANGES TO THIS POLICY

We review and update this Cookie Policy at a minimum on an annual basis, and additionally whenever we materially change our cookie practices, introduce new third-party sub-processors, or receive updated regulatory guidance from the Information Commissioner’s Office (ICO) or other data protection authorities.

Material changes, particularly the introduction of new cookie categories or alternative tracking technologies, will be communicated via a prominent notice on the Website no less than 30 days before the change takes effect. This notice period will trigger a refresh of the cookie consent banner, ensuring you are given a fair opportunity to review and modify your tracking preferences before non-essential cookies are deployed.

12. CONTACT

For any questions, concerns, or complaints regarding this Cookie Policy, or to exercise your data protection rights:

• Email: [email protected] (subject line: “Cookie Policy Enquiry”)

• Postal Address: Office 2 Little Winters Farm, Roundbush Road, Layer Marney, Colchester, Essex, CO5 9UR, United Kingdom

• For data subject rights requests, please refer to Section 13 of our Privacy Policy.

• If you are dissatisfied with our response, you may complain to:

• The Information Commissioner’s Office (UK): https://ico.org.uk, telephone: 0303 123 1113

• Your national data protection authority (EU/EEA users): see Privacy Policy, Section 16.2 for a full list

• We aim to respond to all cookie-related enquiries within 5 business days.

COOKIE POLICY