Cookie Policy

This Cookie Policy explains how The C-MORE Company ("C-MORE", "we", "us" or "our") uses cookies and similar technologies when you visit or use the C-MORE website, the C-MORE platform and any related services, applications and communications that link to this policy (together, the "Services"). It explains what these technologies are, why we use them, the choices available to you, and how you can exercise those choices.

Please read this Cookie Policy carefully and in full. It should be read together with the Terms & Conditions set out in Part 1 above and with our Privacy Policy, which describe the terms on which the Services are provided and, in more detail, how we process personal data. Where this Cookie Policy uses a term defined in those documents, that term has the same meaning here unless stated otherwise. If there is any conflict between this Cookie Policy and our Privacy Policy as regards the use of cookies, this Cookie Policy prevails.

By selecting "Accept all" in the cookie notice, you consent to the placement and use of all the cookies and similar technologies described in this policy. By selecting "No cookies", you refuse all cookies, including those that are strictly necessary for parts of the Services to work, with the consequences described in section 7. You may change your choice at any time, as explained in section 8.

1. Who we are

The Services are operated by The C-MORE Company, a company registered under number [company registration number], whose registered office is at [registered address]. For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK General Data Protection Regulation, the Data Protection Act 2018 and any other applicable data protection law (together, "Data Protection Law"), C-MORE is the controller of the personal data collected through the cookies and similar technologies described in this policy, except where we state otherwise.

If you have any question about this Cookie Policy or about how we use cookies, you can contact us at [privacy contact email] or by post at the address above, marked for the attention of our Data Protection Officer.

2. What cookies and similar technologies are

A cookie is a small text file that a website stores on your computer, tablet, phone or other device when you visit it. Cookies allow a website to recognise your device on later requests, to remember information about your visit, such as your preferred language or whether you are signed in, and to collect information about how the website is used. Cookies set by the website you are visiting are called "first-party cookies". Cookies set by a different domain are called "third-party cookies".

Cookies may be "session cookies", which are deleted automatically when you close your browser, or "persistent cookies", which remain on your device for a set period or until you delete them.

In this policy we use the word "cookies" to include similar technologies that store or read information on your device, such as local storage, session storage, pixels, tags and software development kits. These technologies work in a similar way to cookies and are subject to the same choices.

3. The law that applies to cookies

The use of cookies is governed by Article 5(3) of the ePrivacy Directive 2002/58/EC, as implemented in each Member State of the European Union, by the Privacy and Electronic Communications Regulations 2003 in the United Kingdom, and by Data Protection Law where cookies are used to process personal data.

Under these rules, we may store or read information on your device without your consent only where this is strictly necessary to provide a service that you have explicitly requested. For all other cookies we must obtain your prior consent, which must be freely given, specific, informed and unambiguous, and which you may withdraw at any time as easily as you gave it.

Where cookies process personal data, our legal basis is your consent under Article 6(1)(a) GDPR for analytics cookies, and, for strictly necessary cookies, our legitimate interest under Article 6(1)(f) GDPR in providing Services that are secure and work as you would expect, or the performance of our contract with you under Article 6(1)(b) GDPR where you hold a C-MORE account.

4. The cookies we use

We use two categories of cookies. We do not use advertising or marketing cookies, we do not use cookies to build profiles of you across other websites, and we do not sell or rent any information collected through cookies.

Strictly necessary cookies. These cookies are essential for the Services to work and for you to move around them and use their features securely. Without them, services you have asked for, such as signing in to your account, cannot be provided. They include:

• cm_session, which keeps you signed in as you move between pages of the C-MORE platform. It is a session cookie and is deleted when you close your browser.
• cm_csrf, which protects the forms you submit against cross-site request forgery, by proving that a request was sent from the Services and not from another website acting on your behalf. It is a session cookie.
• cm_consent, which records the choice you make in our cookie notice, so that we respect it and do not ask you again on every visit. It lasts for 12 months.
• cm_lang, which remembers the language you have selected for the Services. It lasts for 12 months.

Analytics cookies. With your consent, these cookies collect information about how visitors use the Services, such as which pages are visited most often, how visitors arrive at a page, how long they stay and whether they encounter errors. We use this information only in aggregate, to understand which parts of the Services are useful and to improve them. They include:

• cm_analytics_id, which distinguishes one visitor from another by means of a randomly generated identifier, without identifying you by name. It lasts for 13 months.
• cm_analytics_visit, which groups together the pages viewed during a single visit. It lasts for 30 minutes from your last activity.

Analytics cookies are placed only if you select "Accept all". They are never placed if you select "No cookies".

5. Information collected through cookies

Depending on the cookies you accept, the information collected may include: the identifier stored in the cookie; your IP address, which we truncate before storing so that it cannot be used to identify you; the type and version of your browser and operating system; the pages you visit and the links you follow on the Services; the date, time and duration of your visit; the website or page that referred you; and technical information about errors and the performance of the Services.

We do not use cookies to collect the content of the documents you upload to the Services, the answers you give in questionnaires, or any special category of personal data within the meaning of Article 9 GDPR.

6. Third parties and international transfers

All the cookies described in this policy are first-party cookies set by C-MORE. Where we use service providers to host the Services or to process analytics information on our behalf, they act as our processors under written agreements that meet the requirements of Article 28 GDPR, may use the information only on our instructions, and are not permitted to use it for their own purposes.

Where information collected through cookies is transferred to a country outside the European Economic Area or the United Kingdom that has not been recognised as providing an adequate level of protection, we put in place appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission and the UK International Data Transfer Addendum, together with any supplementary measures required. You may request a copy of these safeguards using the contact details in section 1.

7. Your choices in the cookie notice

When you first visit the Services, we show a cookie notice that asks for your choice before any cookie other than those needed to display the notice itself is placed on your device. You may choose:

• "Accept all": you consent to all the cookies described in this policy, strictly necessary and analytics.
• "No cookies": you refuse all cookies, including strictly necessary ones. You will still be able to read the public pages of the website. However, because strictly necessary cookies are required to sign in and to submit forms securely, you will not be able to create an account, sign in or use the C-MORE platform while this choice is in effect. Because we cannot store your choice without a cookie, it applies only for your current visit, and we will ask you again the next time you visit.

Refusing cookies has no consequence other than those described above. In particular, it does not affect the price, availability or quality of any part of the Services that can be provided without cookies.

8. Changing your mind

You can change your choice or withdraw your consent at any time by selecting "Cookies" in the footer of the website, which reopens this policy and the choices described in section 7. Withdrawing consent does not affect the lawfulness of any processing carried out on the basis of your consent before you withdrew it.

When you withdraw consent to analytics cookies, we stop placing them and stop collecting information through them. Analytics cookies already on your device will be deleted the next time you visit, or you can delete them yourself as described in section 9.

9. Managing cookies in your browser

Most web browsers allow you to see which cookies are stored on your device, to delete them individually or all at once, and to block cookies from particular websites or from all websites. Instructions are usually found in the "Settings", "Preferences" or "Help" menu of your browser.

If you block or delete strictly necessary cookies through your browser, parts of the Services will not work, as described in section 7. If you delete the cm_consent cookie, we will ask for your choice again on your next visit. Settings in your browser apply only to that browser on that device: if you use several browsers or devices, you will need to set your preferences in each of them.

10. Do Not Track and Global Privacy Control

Some browsers send a "Do Not Track" or "Global Privacy Control" signal. Where we receive a Global Privacy Control signal, we treat it as a refusal of analytics cookies for that browser. There is no common standard for responding to Do Not Track signals, and we do not currently respond to them separately; your choice in our cookie notice applies instead.

11. How long we keep information

Each cookie remains on your device for the period stated in section 4, unless you delete it sooner. Information collected through analytics cookies is kept in identifiable form for no longer than 14 months from collection, after which it is deleted or aggregated so that it no longer relates to an identifiable device. Records of your cookie choices are kept for as long as necessary to demonstrate that we obtained valid consent, and for no longer than three years after the choice was made.

12. Your rights

Where cookies are used to process your personal data, you have the following rights under Data Protection Law, subject to the conditions and exceptions it sets out:

• the right of access, to obtain confirmation of whether we process personal data about you and a copy of it;
• the right to rectification, to have inaccurate personal data corrected;
• the right to erasure, to have personal data deleted in certain circumstances;
• the right to restriction of processing, to have the processing of personal data limited in certain circumstances;
• the right to object to processing based on our legitimate interests;
• the right to data portability, to receive personal data you have provided to us in a structured, commonly used and machine-readable format;
• the right to withdraw your consent at any time, as described in section 8.

To exercise any of these rights, contact us using the details in section 1. We will respond within one month of receiving your request, which may be extended by two further months where necessary, taking into account the complexity and number of requests. We may need to ask you for information to confirm your identity before we act on a request.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, or, in the United Kingdom, with the Information Commissioner's Office. We would, however, appreciate the chance to address your concerns first.

13. Children

The Services are intended for businesses and their representatives and are not directed at children under the age of 16. We do not knowingly place cookies on the devices of children or collect information about them through cookies.

14. Changes to this Cookie Policy

We may update this Cookie Policy from time to time, for example when we introduce new cookies, change the purposes for which we use them, or when the law changes. The date at the top of this policy shows when it was last updated. Where a change materially affects the cookies we use or the way we use them, we will ask for your choice again through the cookie notice before any new cookie that requires consent is placed.

15. Contact

If you have any question, comment or request about this Cookie Policy or our use of cookies, please contact our Data Protection Officer at [privacy contact email], or write to The C-MORE Company, [registered address].