Cookie policy

1. About this Cookie Policy

This Cookie Policy explains how GRAHAMSTOWN LIMITED, a company incorporated in Cyprus, operating under the brand Gate (“Gate”, “we”, “us” or “our”), uses cookies and similar technologies on hrgate.io (the “Website”).

It explains the purposes of these technologies, the service providers involved and how you can manage your preferences.

This Cookie Policy supplements our Privacy Policy. Please read both documents together. Our Privacy Policy explains our processing of personal data, including the applicable legal bases, recipients, international transfers, retention periods and your rights.

2. What are cookies?

Cookies are small files that a website places on your device to retain information between interactions or visits, such as your selected preferences.

First-party cookies are associated with the domain of the website you visit. Third-party cookies are associated with another domain, such as a service provider’s domain.

Session cookies generally last for a browsing session. Persistent cookies remain for a specified period unless they are deleted earlier.

In this Policy, “cookies” also refers, where applicable, to similar technologies that store information on or access information from your device. These may include browser storage and technologies used alongside tracking tags or pixels.

3. How do we use cookies?

3.1 Consent preferences

We use CookieYes, provided by CookieYes Limited, to display our cookie consent interface and manage your cookie choices. CookieYes acts as a processor under its applicable data processing agreement.

Cookies used solely to remember and apply your consent choices are treated as strictly necessary.

Other cookies qualify as strictly necessary only where their sole purpose is transmitting a communication over an electronic communications network, or where they are strictly necessary to provide a service you have expressly requested. Consent is not required for operations meeting this exemption under section 99(5) of Cyprus Law 112(I)/2004, as amended.

Strictly necessary cookies cannot be disabled through our optional-cookie controls. You may block them in your browser, although this may prevent the corresponding functions from working.

3.2 Website analytics

We use Google Analytics 4 (“GA4”) to understand how visitors find and interact with the Website and to improve its content and usability.

Depending on the measurements enabled, the information collected may include page views, referring pages, engagement and interaction events, language, screen resolution, and browser or session identifiers. The final configuration and information collected are described in our Privacy Policy and the inventory in Section 5.

GA4 cookies are optional and are set or read only after you consent to analytics. Analytics cookies are not treated as strictly necessary under the Cyprus Commissioner’s guidance. Any transmission of information without cookies through Google Consent Mode is addressed separately in Section 4.

Your analytics choice is separate from your decision to contact Gate or request a demo.

3.3 Advertising and campaign measurement

The LinkedIn Insight Tag may transmit information to LinkedIn, including the page URL, referring page, IP address, device and browser characteristics, timestamp and configured interaction or conversion information. LinkedIn may associate website visits with LinkedIn member accounts. We will activate the LinkedIn Insight Tag only after you consent to the relevant advertising or marketing purposes.

4. Google Consent Mode

We use Google Consent Mode to adjust the behaviour of Google tags according to your choices. We use Google Consent Mode in its advanced implementation. When analytics consent is denied, GA4 does not set or read analytics cookies. However, Google may still receive consent-status signals and measurements sent without cookies.

5. Which cookies and similar technologies do we use?

The following inventory identifies the technologies used on the Website, their providers, purposes, categories and duration.

6. Third-party technologies

We use external service providers, including CookieYes, Google, LinkedIn, for the purposes described above. A cookie associated with the Website’s domain may still be used by an external service provider. The distinction between first-party and third-party cookies does not, by itself, determine who receives the information.

The providers and third parties with access to information are identified in Section 5. Further details are provided in our Privacy Policy.

7. How can you manage cookies?

7.1 Making your choice

Our CookieYes interface allows you to “Accept all”, “Reject all” or “Customise” your choices.

Accepting and rejecting optional cookies are available at the same level and require the same number of actions. Optional cookies remain disabled unless you actively consent. Closing the banner, scrolling or continuing to browse does not constitute consent.

You can refuse analytics and marketing cookies without losing access to the public Website or the ability to request a demo. Consent is specific to the purposes presented to you. We do not treat acceptance of analytics as acceptance of advertising, or acceptance of one disclosed purpose as permission for an unrelated future purpose.

7.2 Changing your choices and withdrawing consent

You can review your preferences or withdraw consent at any time by selecting “Cookie settings”, available via the cookie icon in the bottom corner of our Website.

Withdrawal is as easy as giving consent. It does not affect the lawfulness of processing carried out on the basis of consent before withdrawal. After withdrawal, we stop setting or reading the optional cookies for the withdrawn purposes and stop the processing that relies on that consent. Withdrawal may not automatically remove every cookie already stored on your device. You can remove stored cookies through your browser settings.

7.3 Remembering your preferences

We retain your cookie choice for 1 year. The same period applies whether you accept or reject optional cookies. You may be asked to choose again when that period expires, when your saved preferences are deleted, when you use another browser or device, or when a change requires fresh consent. The duration of your saved cookie choice is distinct from the retention period for any consent records maintained to demonstrate compliance.

7.4 Browser controls

Your browser may allow you to delete cookies, block new cookies or set preferences for individual websites. Instructions are available in your browser’s help or privacy settings.

Deleting or blocking cookies may remove saved preferences or affect website functionality. Browser controls are an additional option and do not replace the consent controls available on the Website.

8. Personal data, retention and your rights

Where we determine the purposes and means of processing personal data through the Website’s cookies and similar technologies, we act as a controller.

For our consent-based analytics and marketing processing, the legal basis is consent under Article 6(1)(a) GDPR. The legal bases for other processing, including the management of consent records, are explained in our Privacy Policy.

Please refer to our Privacy Policy for information about the personal data involved, recipients, international transfers and safeguards, retention, and the exercise of your applicable data protection rights.

You may also lodge a complaint with a competent supervisory authority, including the Office of the Commissioner for Personal Data Protection in Cyprus, where applicable.

9. Changes to this Policy

We may update this Policy to reflect changes to the Website, the technologies we use or applicable requirements. We will update the relevant disclosures and consent controls before introducing a new purpose or technology requiring consent. Where fresh consent is required, we will obtain it before the relevant processing begins.

10. Contact us

For questions about cookies or your privacy choices, please contact:

• Company: GRAHAMSTOWN LIMITED
• Email: privacy@hrgate.io