This is a draft prepared for the international market. It should be reviewed by qualified legal counsel before publication.
1. What cookies are
Cookies are small text files stored on your device while you browse. They let us recognise your browser, keep your login session active, remember preferences and measure how the site performs. Similar technologies (such as localStorage, pixels and SDKs) may also be used and are covered by this policy.
2. Categories of cookies we use
2.1. Essential cookies (always on)
These are necessary for the site to work and do not require consent.
- Keeping your login session active.
- Remembering the plan you selected during checkout.
- Local cache of translations (EN/PT) and the language detected by your browser.
- Protection against fraud and automated attacks (CSRF, rate limiting, App Check, Cloudflare CDN protection).
2.2. Analytics cookies (optional)
Used to understand, in aggregate, how visitors interact with the site (most-visited pages, time on page, traffic source). These are only activated after your prior consent through the cookie banner.
When enabled, this policy will be updated to list the specific providers (for example, Google Analytics 4 or Plausible Analytics) and their retention periods.
2.3. Marketing cookies (optional)
Used to measure the effectiveness of advertising campaigns and to present relevant content on other platforms. These are only activated after prior consent.
When enabled, this policy will be updated to list the specific providers (for example, Meta Pixel, Google Ads, TikTok Pixel) and their purposes.
3. Other automatic collection technologies (beyond cookies)
For completeness, the site also collects some data automatically by means that do not rely on cookies:
- IP address for country detection: used on our servers to display prices in the correct currency and to help prevent payment fraud. The lookup is done by a local library on our servers (geoip-lite), without sending your IP to external services for this purpose.
- Cloudflare CDN technical headers: Cloudflare, acting as a content delivery network and abuse-protection layer, may inject and process headers containing the country of origin, a request identifier and similar data. More information in our Website Privacy Policy.
- Browser localStorage: used to store preferences such as the detected language and translation cache, avoiding repeated requests and improving performance.
4. How to manage cookies
On your first visit, you see a banner that lets you accept all cookies, reject optional cookies or customise your preferences by category. You can change your choice at any time through the "Cookie preferences" link in the site footer.
Your browser also offers its own controls to block or delete cookies. Note that disabling essential cookies may affect the functioning of authenticated areas, such as the device management page.
5. Third-party cookies
Analytics and marketing cookies, when enabled, are set by third parties (for example, Google, Meta) acting as controllers or processors of that data, as the case may be. We recommend reviewing those providers' policies for details of their own processing.
6. Legal basis
Under the UK GDPR, the EU GDPR and the ePrivacy rules (the "cookie law"):
- Essential cookies — necessary for a service you request, and our legitimate interest in the security of the site.
- Analytics and marketing cookies — your consent, given freely and on an informed basis through the cookie banner, and withdrawable at any time.
7. Your rights
You can withdraw consent and request deletion of data processed via cookies at any time. Requests can be sent to privacy@giramilleapp.com.
8. Changes to this Policy
This Cookie Policy may be updated to reflect changes in the technologies used, the providers integrated or the law. The new version takes effect on the date shown at the top of the document.
9. Contact
Questions about cookies can be sent to privacy@giramilleapp.com.