Purpose and Function: Essential cookies are strictly necessary for our website to function properly and securely. These cookies enable core functionality that you expect from any modern website.

Specific Functions:

• Session Management: Maintaining secure connections during your visit and ensuring proper page-to-page navigation
• Security Protection: Protecting against cross-site request forgery (CSRF) attacks and other security threats
• Basic Functionality: Enabling form submissions, search functionality, and other interactive website features
• Error Prevention: Preventing duplicate form submissions and ensuring data integrity during website interactions

Technical Details:

• Duration: Session-based cookies that are automatically deleted when you close your browser
• Storage Location: Temporarily stored in your device's memory only
• Data Content: Security tokens, session identifiers, and basic functionality indicators
• Privacy Impact: Minimal privacy impact as they contain no personal information

Legal Basis: These cookies are processed under legitimate interest as they are strictly necessary for website operation. Under GDPR Article 6(1)(f) and similar provisions in other privacy laws, no separate consent is required for essential cookies.

Your Control: Essential cookies cannot be disabled through our cookie settings as they are required for basic website functionality. Disabling these cookies through browser settings may result in website malfunctions or security vulnerabilities.

Purpose and Function: Analytics cookies help us understand how visitors interact with our website so we can improve performance, identify popular content, and enhance the overall user experience.

Specific Data Collection:

• Page Views: Which pages are visited and in what sequence to understand user navigation patterns
• Session Duration: How long visitors spend on our website and individual pages to measure engagement
• Bounce Rate Analysis: Whether visitors leave after viewing only one page, helping us identify content effectiveness
• Technical Compatibility: General device and browser information to ensure optimal website performance across different platforms
• Geographic Analysis: General location information at country/region level for demographic insights
• Performance Metrics: Page load times, error occurrences, and system performance indicators

Privacy Safeguards:

• Anonymous Tracking: Visitor identification using secure, cryptographic hashes that cannot be reversed to identify individuals
• Short Retention: All visitor identifiers automatically expire and are deleted within 24 hours
• No Personal Data: No collection of names, email addresses, phone numbers, or other personal identifiers
• No Cross-Site Tracking: Analytics limited exclusively to our website with no tracking across other sites
• Aggregated Analysis: All reporting conducted at aggregate level preventing individual identification

Technical Implementation:

• Hash-Based Identification: Secure algorithmic generation of anonymous visitor identifiers
• Automatic Expiration: Technical systems configured to automatically delete identifying information
• Internal Processing: All analytics processing conducted on SureFlow servers without third-party involvement
• Data Minimization: Collection limited to minimum information necessary for stated purposes

Legal Basis: Analytics cookies are processed under legitimate interest (GDPR Article 6(1)(f)) with comprehensive balancing test demonstrating minimal privacy impact and significant benefits for website improvement.

Your Control Options:

• Browser Settings: Disable analytics cookies through standard browser cookie controls
• Do Not Track: We honor browser "Do Not Track" signals for analytics cookies
• Incognito/Private Browsing: Use private browsing mode to limit cookie storage
• Ad Blockers: Many ad blocking extensions also block analytics scripts
• Direct Contact: Contact privacy@sureflow.com to manually opt out of analytics

Essential Cookies:

• Session Cookies: Automatically deleted when you close your browser
• Temporary Security Tokens: Expire within 1 hour of creation for maximum security
• Functionality Cookies: Retain basic preferences for current session only
• Error Prevention Cookies: Automatically cleared after successful operation completion

Analytics Cookies:

• Visitor Identification Hashes: Maximum 24-hour lifespan with automatic deletion
• Session Analytics: Cleared at end of each browsing session
• Performance Metrics: Aggregated immediately and individual identifiers removed
• Technical Compatibility Data: Processed immediately and individual associations removed

Aggregated Data Retention:

• Statistical Summaries: Retained for maximum 25 months in fully anonymized form
• Trend Analysis: Long-term performance data with all individual identifiers removed
• Technical Reports: System performance metrics retained for operational purposes only

Automatic Deletion Systems:

• Scheduled Cleanup: Automated systems run regularly to delete expired cookies and data
• Technical Verification: Regular audits to ensure deletion procedures are functioning correctly
• Redundancy Removal: Deletion from all system locations including backups and temporary files

Data Anonymization Process:

• Hash Expiration: Cryptographic hashes rendered permanently unusable after expiration
• Individual De-identification: Removal of any remaining individual associations from aggregate data
• Statistical Preservation: Maintenance of useful aggregate statistics without individual linkability

Google Chrome:

• Click three dots menu → Settings
• Navigate to Privacy and Security → Cookies and other site data
• Choose from "Allow all cookies," "Block third-party cookies," or "Block all cookies"
• Add specific site exceptions for custom control
• Clear existing cookies through "See all cookies and site data"

Mozilla Firefox:

• Click menu button → Options
• Select Privacy & Security from left sidebar
• Under Cookies and Site Data, adjust settings as preferred
• Use "Manage Data" to view and delete specific cookies
• Enable "Delete cookies and site data when Firefox is closed" for automatic cleanup

Apple Safari:

• Open Safari → Preferences
• Click Privacy tab
• Choose cookie blocking preferences from available options
• Use "Manage Website Data" to view and remove specific cookies
• Select "Prevent cross-site tracking" for enhanced privacy protection

Microsoft Edge:

• Click three dots menu → Settings
• Select Privacy, search, and services
• Under Cookies and site permissions, adjust cookie settings
• Choose from "Allow all cookies," "Block only third-party cookies," or "Block all cookies"
• Manage exceptions and view stored cookies through advanced settings

Advanced Browser Options:

• Do Not Track: Enable Do Not Track headers in browser settings (we honor these signals)
• Private Browsing: Use incognito/private mode to prevent cookie storage
• Cookie Auto-Delete: Configure browsers to automatically delete cookies on exit
• Site-Specific Settings: Set different cookie preferences for different websites

Browser Extensions and Add-ons:

• Privacy Badger: Blocks tracking cookies while allowing functional cookies
• uBlock Origin: Comprehensive blocking of advertising and analytics cookies
• Ghostery: Detailed control over tracking scripts and cookies
• DuckDuckGo Privacy Essentials: Privacy-focused browsing with tracking protection

Operating System Controls:

• iOS Safari: Settings → Safari → Privacy & Security options
• Android Chrome: Chrome app → Settings → Site settings → Cookies
• Windows Privacy: Windows Settings → Privacy → Activity history and cookie controls
• macOS Safari: Safari → Preferences → Privacy settings

Network-Level Blocking:

• Router Configuration: Configure home router to block advertising and tracking domains
• DNS Filtering: Use privacy-focused DNS services that block tracking domains
• VPN Privacy Features: Some VPN services include cookie and tracking protection

Legal Framework:

• GDPR Articles 6 and 7: Lawful basis for processing and consent requirements
• ePrivacy Directive: Specific rules for cookies and electronic communications
• UK PECR: Privacy and Electronic Communications Regulations (post-Brexit)
• National Implementations: Country-specific variations of EU ePrivacy rules

Compliance Approach:

• Essential Cookies: No consent required under ePrivacy Article 5(3) exception for strictly necessary cookies
• Analytics Cookies: Legitimate interest legal basis under GDPR Article 6(1)(f) with comprehensive balancing test
• Transparency: Full disclosure of cookie practices through this policy and privacy notices
• User Control: Clear opt-out mechanisms and respect for Do Not Track signals

Your GDPR Rights Applied to Cookies:

• Right to Object: Object to analytics cookie processing based on legitimate interests
• Right of Access: Request information about cookie data processing activities
• Right to Erasure: Request deletion of cookie-related personal data (limited applicability due to anonymization)
• Right to Restriction: Request limitation of cookie processing in specific circumstances

CCPA Compliance Framework:

• Personal Information Definition: Technical cookie data may qualify as personal information under broad CCPA definition
• No Sale Activity: Our analytics cookies do not constitute "sale" of personal information as no monetary exchange occurs
• Consumer Rights: California residents have rights regarding cookie-collected information under CCPA
• Disclosure Requirements: Transparent disclosure of cookie practices and data collection purposes

State Privacy Law Compliance:

• Virginia CDPA: Compliance with Virginia Consumer Data Protection Act for Virginia residents
• Colorado CPA: Adherence to Colorado Privacy Act requirements for Colorado residents
• Connecticut CTDPA: Compliance with Connecticut Data Privacy Act for Connecticut residents
• Emerging Laws: Ongoing monitoring and compliance with new state privacy legislation

Your US Privacy Rights:

• Right to Know: Detailed information about cookie data collection and processing
• Right to Delete: Request deletion of cookie-collected personal information
• Right to Opt-Out: Direct us not to sell personal information (not applicable as we don't sell data)
• Non-Discrimination: Exercise rights without facing different treatment or pricing

Multi-Jurisdictional Approach:

• Highest Standard Application: Application of strictest applicable privacy standards across all visitors
• Regional Customization: Specific compliance measures for different regulatory environments
• Ongoing Monitoring: Regular review of evolving international privacy laws and requirements
• Compliance Documentation: Maintenance of detailed compliance records and impact assessments

Transmission Security:

• HTTPS Encryption: All cookie data transmitted using TLS 1.3 encryption protocols
• Secure Cookie Flags: Implementation of Secure flag requiring encrypted transmission
• SameSite Attributes: Protection against cross-site request forgery attacks
• HttpOnly Flags: Prevention of client-side JavaScript access to sensitive cookies

Storage Security:

• Encrypted Storage: Server-side cookie data encrypted using AES-256 standards
• Access Controls: Strict permission controls limiting cookie data access to authorized personnel
• Secure Deletion: Cryptographic deletion ensuring cookie data cannot be recovered
• Backup Protection: Encrypted backup systems with restricted access controls

System Security:

• Regular Security Audits: Comprehensive security assessments of cookie handling systems
• Vulnerability Monitoring: Continuous monitoring for security threats and vulnerabilities
• Incident Response: Documented procedures for cookie-related security incidents
• Staff Training: Regular training on secure cookie handling procedures

Privacy by Design:

• Default Privacy Settings: Cookie systems configured for maximum privacy by default
• Data Minimization: Technical limitations preventing excessive cookie data collection
• Purpose Limitation: System design ensuring cookies used only for stated purposes
• Regular Assessment: Ongoing evaluation of cookie necessity and privacy impact

Access Management:

• Role-Based Access: Cookie data access limited to specific job functions and responsibilities
• Authentication Requirements: Multi-factor authentication for systems handling cookie data
• Activity Logging: Comprehensive logging of all cookie data access and modifications
• Regular Reviews: Periodic review of access rights and activity logs

Technical Improvements:

• Enhanced Privacy Technologies: Implementation of emerging privacy-preserving technologies
• Reduced Data Collection: Ongoing efforts to minimize cookie data collection while maintaining functionality
• Improved User Controls: Development of more granular cookie control options
• Performance Optimization: Continued optimization of cookie systems for better user experience

Compliance Evolution:

• Regulatory Monitoring: Continuous tracking of evolving privacy laws and cookie regulations
• Best Practice Adoption: Implementation of emerging industry best practices for cookie management
• International Standards: Alignment with developing international privacy and cookie standards
• Proactive Compliance: Anticipatory compliance with expected future regulatory requirements

Policy Updates:

• Minor Changes: Administrative updates posted immediately with revised "Last Updated" date
• Material Changes: Significant changes to cookie practices will receive 30 days advance notice
• Notification Methods: Website banners, email notifications where available, and prominent policy updates
• User Choice: Continued use after material changes constitutes acceptance, with clear opt-out options

New Cookie Categories:

• Advance Notice: Minimum 30 days notice before implementing new types of cookies
• Consent Collection: Implementation of appropriate consent mechanisms for new non-essential cookies
• Clear Disclosure: Detailed explanation of new cookie purposes and privacy implications
• User Control: Immediate availability of control options for new cookie categories

Primary Contact:

• Email: privacy@sureflow.com
• Subject Line: "Cookie Policy Inquiry" for priority handling
• Response Time: Acknowledgment within 2 business days, substantive response within 5 business days

Technical Support:

• Cookie Issues: Assistance with cookie-related technical problems or questions
• Privacy Settings: Help configuring browser settings for optimal privacy
• Opt-Out Assistance: Support with implementing opt-out preferences
• Compliance Questions: Information about our cookie compliance practices

SureFlow Ltd

• Address: SureFlow Ltd, 1 Old Street Yard, London EC1Y 8AF, United Kingdom
• Telephone: +447449457293
• Business Hours: 09:00–17:00 (GMT), Monday to Friday GMT
• General Email: privacy@sureflow.com

Specialized Support:

• Privacy Rights: privacy@sureflow.com with "Privacy Rights" in subject line
• Security Concerns: privacy@sureflow.com with "Security Issue" in subject line
• Compliance Questions: privacy@sureflow.com with "Compliance Inquiry" in subject line

This Cookies Policy complies with UK PECR, EU ePrivacy Directive, GDPR, and relevant US privacy laws including CCPA.