Cookies policy

This policy describes our use of cookies. For information on how we handle your personal data, please read our Privacy Policy.
We (“Altery”) use cookies and similar technologies as outlined in this section. By consenting to this cookie notice, you agree that we can distinguish you from other users of our website and apps for the purposes set out below. This helps us provide you with the services you have requested, good user experience, tailored content and interest-based adverts. For example, we can recognise and remember important information, such as your preferred settings, making it more comfortable for you to browse our website. You can update or withdraw your consent to cookie usage at any time by following the steps outlined in the ‘Refusing or deleting cookies’ section of this policy. 

What are Cookies and similar technologies?

A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device.
There are three main types of cookies:

• Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

• Persistent cookies: record information about your preferences and are stored in your browser cache or mobile; and

• Third party cookies: placed by someone other than us, which may gather data across multiple websites or sessions.

We may also automatically collect and store certain information about your interaction with our website or app including IP address, browser type, internet service provider, referring and exit pages, operating system, date and time stamps and related data.

Other technologies

In addition to cookies, we may use some other similar technologies as follows:

• Web Beacons: small graphic images included on our website or emails or those of third parties to provide analytics information

• Social widgets: buttons or icons provided by third party social media networks which may collect browsing data and will be received by the third party and are controlled by the third party

• Software Development Kits (SDKs): these are mobile application third party software development kits used in our apps. They enable us to collect information about app activity and the device it runs on.

• Local shared objects: these are sometimes called flash cookies and can be stored on your browser. They are used to maintaining preferences and usage records.

Cookies we use

Third party cookies

Third-party cookies are classified by purpose (e.g., analytics or advertising) and may involve cross-site tracking. Users should consult each third party's privacy policy. We do not control or accept liability for third-party cookie usage.

Other similar technologies used in our apps

Some mobile applications use embedded Software Development Kits (SDKs) to enable services such as analytics, identification, or secure user onboarding. 

You acknowledge that where we allow the third parties identified above to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party's privacy policy for information on what information they collect and how they use it.

Refusing or deleting cookies

Please click on the following links to adjust your browser settings:

• Internet Explorer

• Google Chrome

• Mozilla

• Firefox

• Safari

Please note that you may not be able to take advantage of all features of our Website or apps if you delete or refuse cookies. In addition to using browser-level controls, cookie preferences relating to visits to our website may, where available, be managed through a settings mechanism provided on the site itself.

Mobile Opt-out

If you access our services through our Apps, you can enable a "do not track" feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Ad Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements, but will mean that they will no longer be personalised to your interests.
To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.
For more information on managing cookies, please go to www.allaboutcookies.org.

If you are a resident in the EU:

For more information on managing cookies, please visit www.youronlinechoices.eu which has further information about behavioural advertising and online privacy.

1. Monitoring and Reporting Requirements

Altery is committed to regular monitoring and auditing of its cookie practices on www.altery.com  to ensure compliance with this Cookie Policy, the General Data Protection Regulation (GDPR), and the Privacy and Electronic Communications Regulations (PECR). Internal reporting channels are established for employees to report concerns, and users are encouraged to provide feedback on cookie usage. In the event of a data breach or significant incident, Altery will promptly notify the Data Protection Officer (DPO) and relevant teams, adhering to legal obligations. Accurate documentation of cookie-related activities, incident assessments, and continuous improvement efforts will be maintained to align with best practices and legal requirements.

In line with the DUAA 2025, Altery must maintain audit-ready logs of cookie consent and withdrawal actions, and be able to demonstrate compliance with enhanced PECR enforcement standards. The DPO will review these records as part of quarterly monitoring activities, and report outcomes to Senior Management and the ARCC.

2. Training

Altery will provide training to all applicable employees  on their obligations with respect to this policy and any accompanying procedures to them.

Some training will involve a short assessment to confirm the employee's understanding.

3. Record Keeping

Altery must keep clear, accessible and up-to-date records in applicable stored folders of the steps taken to implement this policy including:

• Approval from the ARCC Committee recorded in the applicable minutes (PDF version)

• Training conducted business wide or to specific business departments

• Attestation from employees, confirming they have read and understood the contents of the policy

Altery must maintain logs of cookie consent given or withdrawn by users, to be stored securely and retained for the period specified within the Data Retention Policy, along with any other associated records related to the implementation of this policy. 

4. Policy Review and Change

This Policy will be reviewed on an annual basis, and must be approved by the Audit Risk & Compliance Committee (ARCC). There are no exceptions and/or changes to this Policy without written approval from ARCC, and is effective on the date of approval by the ARCC as noted within the version control section of this Policy and supersedes any previous Policy.

The DPO must regularly review and assess the effectiveness of this policy and the procedures in place to implement it.

This Policy will also be reviewed on an ad-hoc basis when:

●        There is a change in Altery’s risk appetite

●        There is a significant change in Altery’s business plan, strategy or objectives

●        Altery introduces new products or services

●        New jurisdictions and markets are introduced

●        There are any significant emerging risks

●        A major or critical risk event has occurred

●        New legal and / or regulatory requirements arise

●        There are significant changes in current legal and / or regulatory requirements

This policy will also be reviewed if material changes are made to website tracking, consent mechanisms, or the introduction of new third-party integrations affecting cookies.