Last updated: 1 April 2026. This policy explains how we use cookies and similar tracking technologies on our website and platform.
This Cookie Policy ("Policy") applies to all digital properties operated by Proxera Ltd ("Proxera", "we", "us", "our"), including our public-facing website and the Proxera platform accessible to registered users. It should be read alongside our Privacy Policy, which sets out the broader framework under which personal data is processed in connection with our services.
This Policy addresses our use of cookies and functionally equivalent client-side storage mechanisms, including but not limited to session storage, persistent local storage, pixel tags, web beacons and device fingerprinting identifiers (collectively, "Cookies"). References to "Cookies" throughout this document encompass all such technologies unless otherwise specified.
Our use of Cookies is governed by the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) ("PECR"), the UK General Data Protection Regulation ("UK GDPR"), and the Data Protection Act 2018 ("DPA 2018"). Where Cookies involve the processing of personal data, such processing is conducted under a lawful basis as defined in Article 6 UK GDPR, as further described in Section 4 below.
Strictly necessary Cookies are deployed pursuant to our legitimate interest in providing the services you have requested and do not require your consent. All other Cookie categories are deployed only upon receipt of your freely given, specific, informed and unambiguous consent, obtained prior to the placement of such Cookies on your device.
These Cookies are technically required for the secure and functional operation of the platform. They facilitate core authentication processes, maintain session integrity, enforce access control, and support infrastructure load distribution. Disabling or blocking these Cookies will impair the delivery of the service and may render certain features entirely inaccessible.
The legal basis for processing personal data via these Cookies is Article 6(1)(b) UK GDPR (performance of a contract to which the data subject is party) and Article 6(1)(f) UK GDPR (legitimate interests of the data controller in maintaining platform security and service continuity).
Functional Cookies enable the platform to retain user-configured preferences and interface customisations across sessions. These may include personalisation settings, notification state, and operationally relevant configuration parameters selected by the user during their interaction with the platform.
The legal basis for processing personal data via these Cookies is Article 6(1)(a) UK GDPR (consent) or, where directly linked to service delivery, Article 6(1)(b) UK GDPR.
We deploy analytical Cookies to collect aggregate and pseudonymised data relating to user interaction patterns, navigation pathways, feature engagement and performance diagnostics across our digital properties. This data is used to evaluate platform efficacy, identify technical deficiencies, and inform iterative product development. Where feasible, analytical data is processed in a de-identified or pseudonymised form such that it does not permit direct identification of individual data subjects.
The legal basis for processing via analytical Cookies is Article 6(1)(a) UK GDPR (consent). Where analytical processing is conducted entirely on an anonymised basis, no personal data processing lawful basis is required.
Marketing Cookies may be used, subject to your consent, to assess the reach and performance of promotional communications, to facilitate audience segmentation, and to enable interest-based advertising across third-party platforms and networks. These Cookies may involve the processing of pseudonymous identifiers across multiple digital environments.
The legal basis for processing via marketing Cookies is Article 6(1)(a) UK GDPR (explicit consent). Consent may be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Certain Cookies deployed on our platform are placed by third-party service providers acting as data processors or independent data controllers in accordance with their own privacy and cookie documentation. These providers supply functionality including but not limited to: web analytics and behavioural measurement; customer relationship management and marketing automation; scheduling and communications infrastructure; and regulated payment and financial data connectivity services.
Where such providers process personal data as independent controllers, their processing is governed by their own applicable privacy documentation and regulatory obligations. We conduct appropriate due diligence in the selection of third-party providers to ensure standards of data protection commensurate with our own obligations under applicable law.
Details of third-party providers and links to their current privacy documentation are available upon request by contacting us at the address set out in Section 7.
Upon your first visit to our website, a consent management interface will be presented enabling you to provide granular consent in respect of non-essential Cookie categories. Your selections are recorded and applied throughout your interaction with our platform. You may review and modify your consent preferences at any time by clearing your browser's stored Cookie data and revisiting the platform, at which point the consent interface will be re-presented.
All major browsers provide user-accessible controls for managing Cookie acceptance, deletion and blocking, typically accessible via the browser's privacy or security settings. Restricting or disabling Cookies at the browser level may affect the availability and performance of certain platform features, including those governed by strictly necessary Cookies. We recommend consulting your browser's support documentation for guidance specific to your browser version and configuration.
Where Cookies are used for interest-based advertising or cross-context behavioural tracking, you may exercise opt-out rights via applicable industry self-regulatory frameworks, including the Digital Advertising Alliance (DAA), the Network Advertising Initiative (NAI), and the European Interactive Digital Advertising Alliance (EDAA). Further information and opt-out tools are available at youronlinechoices.com.
Cookies are retained for periods commensurate with their functional purpose:
This Policy is subject to periodic review and revision to reflect changes in our operational practices, applicable law, regulatory guidance issued by the ICO or other competent supervisory authority, or developments in industry standards. The current version and effective date are indicated at the head of this document. Where amendments are material in nature, we will notify affected users via the platform or by direct communication prior to the changes taking effect.
Enquiries regarding this Policy, including requests to understand the specific Cookies in use at any given time, may be directed to our data protection contact at [email protected] or in writing to Proxera Ltd, 39th Floor, One Canada Square, Canary Wharf, London E14 5AB.
Where Cookie-related processing involves personal data, you retain the rights afforded to data subjects under Chapter III UK GDPR and Part 3 DPA 2018, including the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18) and the right to withdraw consent (Article 7(3)). Complaints may be referred to the Information Commissioner's Office at ico.org.uk or by telephoning 0303 123 1113.
This Cookie Policy was prepared in accordance with the requirements of the UK General Data Protection Regulation (as retained in UK law by the European Union (Withdrawal) Act 2018), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.