Cookie Policy

What cookies and local storage are

A "cookie" is a small text file that a website asks your browser to save on your device. When you return to the site, the browser can send the cookie back, which lets the site remember something about your visit. Cookies are widely used for essential functions (such as keeping you signed in) and, on many sites, for analytics and advertising.

"Local storage" (more precisely, the browser's localStorage feature) is a related technology built into modern browsers. Like a cookie, it lets a website save a small piece of information in your browser so it can be read again later. Unlike a cookie, information in local storage is not automatically sent to a server with every request; it simply stays in your browser until it is cleared.

Both technologies, along with things like session storage and tracking pixels, are commonly grouped together under the general heading of "cookies" in law and in everyday language. This policy covers all such storage that our site uses.

What this site stores, and why

This site uses a single strictly-necessary item, stored in your browser's local storage, whose only purpose is to remember the choice you make on our cookie-consent banner (for example, that you have seen and acknowledged it). Keeping a record of your choice is what stops the banner from reappearing on every page and every visit.

• What it is: one small local-storage entry [TODO(client): confirm the exact key name, e.g. "hca-cookie-consent"].
• What it holds: a short value recording your consent choice and, optionally, when it was made. It does not contain your name, email address or any other information that identifies you.
• Why we use it: to honour your choice and to keep a simple record that we asked for and obtained (or did not obtain) consent. This is a strictly-necessary function of the consent mechanism itself.
• How long it lasts: it remains in your browser until you clear it, or until [TODO(client): confirm any expiry/refresh period, if one is set].

Because this item is strictly necessary to provide the consent feature you have asked for, it does not itself require consent under UK and EU rules (see "The law we follow" below). We do not use it to track you across pages, across sessions or across other websites.

Third-party cookies we use

Google Analytics. If you accept analytics cookies through our banner, we use Google Analytics (provided by Google) to understand how our site is used. It sets a small number of analytics cookies — typically _ga and _ga_<id> — which distinguish visitors and remember session state, with expiries of up to about two years. These cookies are not strictly necessary, so they load only after you consent, and you can withdraw consent at any time. Google may process this data outside the UK and EEA, including in the United States, under appropriate safeguards (the EU-US Data Privacy Framework and/or standard contractual clauses). [TODO(client): confirm GA retention and whether Google Signals / advertising features are enabled.]

When you open our content-download form, and on any page where we run HubSpot's analytics, we use HubSpot (provided by HubSpot, Inc. in the United States) to host the form, to record your submission in our CRM, and to email you the file you request. HubSpot sets a small number of non-essential cookies for these purposes: to recognise your browser between the form and the follow-up, and, where analytics is enabled, to understand which content is used. The cookies HubSpot typically sets are hubspotutk, __hstc, __hssc and __hssrc, with expiries ranging from the end of your browser session to several months.

These HubSpot cookies are not strictly necessary, so they load only after you consent through our cookie banner, and you can withdraw consent at any time. HubSpot is based in the United States; where it processes personal data on our behalf, that transfer is covered by appropriate safeguards (the EU-US Data Privacy Framework and, where relevant, standard contractual clauses). How we handle the personal data you submit through the form is explained in our Privacy Policy.

What this site does not do

We are still clear about what is not happening on this site:

• No advertising cookies or pixels. We do not run ad networks or retargeting tags.
• No social-media trackers. We do not embed social "like" or share trackers.
• No third-party fonts or CDN calls. Our web fonts are self-hosted, so displaying the site does not send a request, or your IP address, to an outside font provider or CDN.

The law we follow

We operate under UK GDPR and the Data Protection Act 2018, together with the UK Privacy and Electronic Communications Regulations (PECR), for our London activities; and under the EU GDPR and the EU ePrivacy rules for our Warsaw activities.

Under these rules, cookies and similar storage that are "strictly necessary" to provide a service the user has asked for do not require prior consent. Recording your consent choice, so that we can respect it and not ask again, falls within this strictly-necessary category. Any storage used for analytics, marketing or other non-essential purposes requires your prior, opt-in consent. The HubSpot cookies described above fall into this category, so they are set only after you consent through our banner.

Governing law for this website and its policies is the law of England and Wales, save that engagements with our Warsaw entity may be subject to Polish law.

Managing and clearing what we store

You are in full control of what your browser keeps. If you have consented to the HubSpot cookies, you can withdraw that consent through our cookie banner, and you can clear all cookies and browser storage through your browser at any time.

• Clearing site data. You can delete the consent record (and any cookies) at any time through your browser settings, usually under a heading such as "Privacy", "Cookies and site data", or "Clear browsing data". Guidance for the most common browsers (Chrome, Edge, Safari, Firefox) is available in each browser's own help pages.
• What happens if you clear it. Removing the consent record simply means our cookie-consent banner will treat you as a new visitor and appear again on your next visit, so you can make your choice afresh.
• Reopening your consent settings. You can change your choice at any time by [TODO(client): confirm the mechanism, e.g. clicking the "Cookie settings" link in the website footer], which re-opens the consent banner.

You can also configure your browser to block or limit local storage and cookies generally. Doing so is unlikely to affect this site meaningfully, given how little we store, but it may affect other websites you use.

Optional cookies and your consent

The Google Analytics and HubSpot cookies described above are optional. They do not run unless and until you actively agree through the consent banner, and you can withdraw that agreement just as easily. If we add further non-essential cookies or tools in the future, we will update this policy first, and they too will be strictly opt-in.

Changes to this policy

We may update this Cookie Policy from time to time to reflect changes to our website, technology or the law. When we do, we will revise the "Last updated" date at the top. Material changes affecting how we use cookies or storage will be reflected in the policy before those changes take effect.

Contact us

If you have any questions about this Cookie Policy or how we use cookies and browser storage, please contact us:

• Email: contact@horizoncreditadvisory.com
• Offices: London (UK) and Warsaw (Poland)
• Company details and registered address: [TODO(client): insert registered company name, number and address]
• Data protection / rights contact: privacy@horizoncreditadvisory.com