[Example] Cookie Policy

NOTE: This template is provided for general guidance only and does not constitute legal advice. Each marketplace is responsible for ensuring that its published policy accurately reflects its operations and complies with applicable law. You should obtain independent legal advice before publication.

[Marketplace Name] Cookie Policy

Last updated [Date]

We use certain technologies on our websites (including mobile-optimised versions) and applications (each a "Site" and collectively, our "Sites") to collect information that helps us improve your online experience. In this Cookie Policy, we refer to these technologies, which include cookies, collectively as "cookies." This policy explains the different types of cookies used and how you can control them. We may update this Cookie Policy from time to time. Any update is effective as of the date it is posted, which will be indicated at the top of this Cookie Policy.

If you have any questions about how we use cookies or handle your personal information, please refer to our Privacy Policy or contact us on [Marketplace Email] with the subject line: COOKIES.

Table of Contents

1. What is a Cookie?

2. Before you respond to our cookie banner

3. What cookies do we use?

4. How do third parties use cookies on the site?

5. How do I control cookies?

What is a Cookie?

A cookie is a small file containing a string of characters that is sent to your device when you first use our Sites. When you use our Sites a second time, the cookie allows our Sites to recognise your device or browser. Some cookies may collect or store information that can be used to identify you as an individual ("Personally Identifiable Information").

Some cookies may collect information that is considered personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, such as your IP address, device ID, or location. We treat any such information in accordance with the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

Most cookies collect aggregated or anonymised usage information to help us understand how users interact with our Sites and to improve the services we offer. Some features of the Sites may not function properly without cookies.

Some cookies contain a persistent identifier - a unique code stored on your device that allows us to recognise the same browser or device across multiple visits, rather than treating each visit as new. This is different from the temporary identifiers described below, which are not stored and cannot be linked back to you over time.

Before you respond to our cookie banner

Before you accept or decline cookies, some essential data is still stored on your device so the Site works, for example to;

• keep you logged in.

• remember your basket.

• remember your chosen outlet and delivery or collection preference.

• remember your cookie choice itself.

See Essential Cookies below for the full list. No analytics, session recording or advertising cookies are set in this state, and no profile is built about you from this essential data.

For analytics, we measure visits from the moment you arrive using a temporary identifier that changes regularly and cannot be linked back to you, without setting an analytics cookie or storing anything else on your device.

Whether you accept or decline, this specific anonymous visit count continues - it doesn't involve cookies or anything stored on your device, so it sits outside your cookie choice. Everything else does depend on your choice: if you decline, no analytics cookies, session recording, or persistent identifiers are used (see Performance Cookies below). We store a record of your decision (see Essential Cookies below) so we don't ask you again on every visit.

One exception: if you place an order, we send the order details, including the transaction value and items purchased, to Google Analytics regardless of your cookie choice, so that we can measure completed sales. This is necessary to process and analyse orders and is separate from browsing measurement.

What cookies do we use?

Below we list the different types of cookies we may use, including where a persistent identifier is involved.

Essential Cookies

These cookies and similar storage are essential to the operation of our Sites - used to;

• keep you logged in.

• remember your basket and its contents.

• remember your chosen outlet and delivery/collection preference.

• remember an applied discount or voucher.

• remember whether you've dismissed an app prompt.

• remember your cookie choice.

Without these, features you've asked for - such as your basket or checkout - cannot be provided. These are not affected by your cookie choice and are set regardless of whether you accept or decline.

Performance Cookies

Performance/analytical cookies allow us to recognise and count the number of visitors to our Sites and to collect information about how visitors navigate within the Sites. We currently use PostHog and Google Analytics (GA4) for this.

Before you accept cookies, PostHog and GA4 do not set cookies or store anything on your device for this purpose, see "Before you respond to our cookie banner" above.

Once you accept, PostHog and GA4 set cookies, containing a persistent identifier so we can recognise you as a returning visitor, and record your session on the Site, including page views, clicks and mouse movements, to help us understand and fix problems. Anything you type into a form during a session recording is masked and never visible to us. PostHog is hosted in the EU.

PostHog specifically works differently to our other analytics: Redbox, the company that powers this Site, uses PostHog for its own analytics across all the marketplaces it powers, not just this one, to understand and improve its platform. For that specific use, Redbox is a data controller in its own right rather than acting on our behalf. Accepting cookies here also covers that processing. See our Privacy Policy for full details, including how to exercise your rights over that data.

Functionality Cookies

We use functionality cookies to recognise your device when you return to our Sites and to remember the choices you make on our Sites, in order to provide enhanced and more personalised features, such as customising the Sites to your personal preferences.

Targeting or Advertising Cookies

We may use targeting or advertising cookies to deliver ads that we believe are more relevant to you and your interests. We currently use the Meta pixel and Google Ads Enhanced Conversions for this.

Unlike our analytics cookies, neither the Meta pixel nor Enhanced Conversions has an anonymous or cookieless mode, so neither runs in any form until you accept cookies. Once active, the Meta pixel may automatically collect some information about your interactions with page elements such as buttons and forms, and, where you're logged in, may link a persistent identifier for your account to help match you to your Meta advertising profile. Enhanced Conversions shares a securely hashed (not readable) version of your name, email address and phone number with Google when you complete an order, to help measure the performance of our advertising.

We may also use targeting or advertising cookies to limit the number of times you see the same ad on our Sites and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on the Sites and we may share this information with third parties such as our advertisers.

How do third parties use cookies on the site?

We may allow third-party service providers, such as PostHog, Google Analytics (GA4), Google Ads, Meta, other advertisers, analytics services, or payment providers to use cookies and similar technologies on our Sites. These third parties may collect data about your use of the Sites or ads you've interacted with.

If you later withdraw your consent, we will stop sending new information to these third parties, but any cookies they have already set on your device (such as Meta's cookies) may remain until you clear them yourself via your browser settings.

Some of this data may be transferred overseas. If this includes your personal information, we ensure such transfers comply with UK GDPR, including the use of adequacy decisions or appropriate safeguards such as standard contractual clauses.

We encourage you to review the cookie and privacy policies of any third parties via the links we provide, or visit their websites for more information.

How do I control cookies?

You may refuse to accept cookies from our Sites at any time by changing the setting on your browser to refuse cookies, which you can learn more about by going to the browser's Help feature.

In the UK, you can manage your cookie preferences through your browser settings, or via our on-site Cookie Consent Tool, which allows you to accept or reject non-essential cookies in line with PECR requirements.

Please be aware that if cookies are disabled, not all features of the Sites may operate as intended. Blocking cookies won't stop the temporary, non-identifying measurement described above, since that doesn't involve storing anything on your device.