Cookie Policy

1. Introduction

This Cookie Policy ("Policy") explains how Forlais Group LTD (trading as Forlais AI, "we", "us", "our", "Company") uses cookies and similar tracking technologies on our website located at www.allnudge.com (the "Website").

We are committed to transparency about our use of cookies and your privacy. This policy details what cookies are used, why they are used, how long they persist, and how you can manage your preferences.

Please read this Cookie Policy in conjunction with our Privacy Policy and Terms of Service, which form part of our complete legal framework.

2. What Are Cookies?

A cookie is a small text file that is stored on your device (computer, tablet, or mobile phone) when you visit a website. Cookies can be stored temporarily (session cookies) or for an extended period (persistent cookies).

Cookies serve various functions:

• Remembering your preferences and settings
• Tracking your activity for analytics and improvement
• Enabling functionality required for the website to operate
• Delivering targeted advertising and marketing content
• Preventing fraud and enhancing security

Cookies contain information that is typically linked to your device but may also be linked to you personally if you have logged into an account.

3. Types of Cookies We Use

We use the following categories of cookies on our Website:

3.1 Essential/Strictly Necessary Cookies

What they are: Cookies essential for the Website to function properly and for you to access our core services.

Examples include:

• Session management and authentication
• Security tokens and fraud prevention
• User preferences (language selection, accessibility settings)
• Load balancing and server performance
• Cookie consent preferences
• CSRF (Cross-Site Request Forgery) protection

Legal basis: These cookies do not require your consent as they are strictly necessary to provide the service you have requested.

Retention: Session cookies (deleted when you close your browser) or up to 12 months for persistent cookies.

Cookie names (examples): session_id, auth_token, csrf_token, user_preferences

3.2 Performance and Analytics Cookies

What they are: Cookies that collect information about how you use the Website to help us improve functionality, performance, and user experience.

Purpose:

• Understanding which pages are most frequently visited
• Identifying how users navigate the Website
• Measuring loading times and technical performance
• Identifying technical errors and issues
• Aggregating anonymous usage data for statistical analysis

Third-party providers:

• Google Analytics 4 – Collects data on user behaviour, traffic sources, and engagement metrics
• Other analytics tools as listed below

Legal basis: Consent (via cookie banner)

Data shared: Anonymised and aggregated data; individual user tracking data is not shared with third parties without additional consent

Retention: Typically 13-24 months from last user activity, after which data is automatically deleted or anonymised

Cookie names (examples): _ga, _gid, _gat, _dc_gtm_*

Opt-out options:

• Disable through browser settings
• Google Analytics opt-out browser extension
• Within our cookie preference centre

3.3 Functional Cookies

What they are: Cookies that enable enhanced functionality and personalisation of the Website.

Purpose:

• Remembering your login status and account information
• Storing your preferences and settings
• Personalising content and recommendations based on your interaction history
• Enabling live chat and customer support features
• Managing form data and input history
• Enabling third-party integrations and plugins

Legal basis: Consent (via cookie banner) or legitimate interest (where cookies provide functionality you have explicitly requested)

Retention: Up to 12 months, unless you clear your cookies or change your preferences

Cookie names (examples): user_pref, language_setting, theme_selection, form_data

3.4 Marketing and Advertising Cookies

What they are: Cookies used to deliver targeted advertising and marketing content, and to measure campaign effectiveness.

Purpose:

• Displaying personalised advertisements based on your browsing history
• Measuring advertising campaign performance
• Retargeting you with relevant ads across other websites
• Creating audience segments for advertising purposes
• A/B testing of marketing messages and landing pages
• Tracking conversion rates and ROI of marketing campaigns

Third-party partners include:

• Google Ads – Retargeting and conversion tracking
• Meta (Facebook) – Custom audience targeting and pixel tracking
• LinkedIn – B2B advertising and audience insights
• Display advertising networks – Programmatic advertising
• Other advertising partners as deployed

Legal basis: Explicit consent (via cookie banner). These cookies will not be set until you actively consent.

Data collection: Browsing history, pages visited, time spent on site, click behaviour, device information, IP address (anonymised)

Data sharing: With advertising partners and platforms for targeting and measurement purposes

Retention: Typically 30-365 days from consent, but may persist until consent is withdrawn

Cookie names (examples): fbp, fr, _fbp, gclid, utm_*

Opt-out options:

• Withdraw consent in cookie preference centre
• Use browser "Do Not Track" signals
• Opt out of third-party tracking through advertising industry opt-out mechanisms:
  • Digital Advertising Alliance (DAA)
  • Network Advertising Initiative (NAI)
  • Your Online Choices (www.youronlinechoices.com)

3.5 Social Media Cookies

What they are: Cookies placed by social media platforms to track your activity and enable social sharing features.

Purpose:

• Enabling social sharing buttons (Twitter, Facebook, LinkedIn, etc.)
• Allowing integration with social media login
• Tracking your activity for social media analytics
• Creating social media audiences and retargeting

Third-party platforms:

• Meta (Facebook) – Social sharing and login integration
• Twitter/X – Tweet buttons and engagement tracking
• LinkedIn – Professional network integration
• YouTube – Video embedding and viewing analytics
• Other social platforms as integrated

Legal basis: Consent (via cookie banner) or where placed by social media platforms based on their own legitimate interest

Data shared: With the respective social media platform; these platforms have their own privacy policies and cookie usage terms

Retention: Varies by platform (typically 30-365 days or longer)

Opt-out options:

• Withdraw consent in our cookie preference centre
• Disable cookies in individual social media platform settings
• Review social media platform privacy policies for opt-out options

3.6 Third-Party Cookies Summary

Third-party cookies are placed by: External companies, advertisers, analytics providers, and social media platforms that have services embedded or linked on our Website.

Common third-party cookie providers:

• Google (Analytics, Ads, reCAPTCHA)
• Meta/Facebook (Pixel, Login, Ads)
• LinkedIn
• Twitter/X
• Advertising networks and exchanges
• Consent management platforms (CMP)

Important: We do not control third-party cookies directly. These are governed by each third party's privacy policy and cookie usage terms. You should review third-party privacy policies to understand their practices.

Right to object: You can object to third-party cookie usage through:

• Our cookie preference centre
• Third-party opt-out mechanisms (e.g., www.youronlinechoices.com)
• Your browser privacy settings
• Tools like Global Privacy Control (GPC)

4. Cookie Consent and Your Preferences

4.1 How We Obtain Consent

When you first visit the Website, you will see a cookie consent banner that:

• Explains the purpose of cookies
• Distinguishes between essential and non-essential cookies
• Provides clear options to accept or reject non-essential cookies
• Includes a link to this Cookie Policy

Important: We will not set non-essential cookies until you have given explicit consent. Inaction or continuing to use the Website does not constitute consent.

4.2 Your Consent Choices

You have the following options:

• "Accept All" – Accepts all cookies, including analytics, functional, marketing, and social media cookies
• "Reject All" – Rejects all non-essential cookies. Only essential cookies will be set
• "Manage Preferences" – Allows you to customise which non-essential cookies to accept on a category-by-category basis

4.3 Granular Control

Our cookie preference centre allows you to:

• Accept or reject each cookie category individually
• View a detailed list of cookies used and their purposes
• Withdraw consent at any time
• Review the privacy policies of third-party cookie providers

You can access the preference centre at any time by:

• Clicking the cookie banner (re-displayed after consent is given)
• Looking for a "Cookie Preferences" or "Cookie Settings" link in the website footer
• Contacting us for assistance

4.4 Withdrawing Consent

You can withdraw your consent to non-essential cookies at any time:

1. Return to our Website
2. Access the cookie preference centre
3. Toggle off the categories you wish to withdraw consent from
4. Click "Save Preferences"

Once you withdraw consent, we will stop setting new cookies in that category. However, cookies already set will remain on your device until they naturally expire or you manually delete them.

5. Essential Cookies (No Consent Required)

The following essential cookies are set automatically and do not require your consent:

6. Non-Essential Cookies (Consent Required)

Non-essential cookies are only set after you have explicitly consented through our cookie banner. These include:

Analytics Cookies (Consent Required)

• Google Analytics (_ga, _gid, _gat)
• Custom analytics tracking pixels

Marketing Cookies (Consent Required)

• Google Ads conversion tracking
• Meta Pixel for retargeting
• LinkedIn Insight Tag
• Third-party advertising network cookies

Functional Cookies (Consent Required)

• Personalisation and preference cookies
• Third-party integration cookies
• Form data persistence

Social Media Cookies (Consent Required)

• Meta (Facebook) social pixel and login cookies
• Twitter/X engagement cookies
• LinkedIn cookies
• YouTube integration cookies

7. How Long Cookies Are Stored

You can manually delete cookies at any time through your browser settings.

8. Managing Cookies Through Your Browser

8.1 Browser Settings

Most web browsers allow you to control cookies through settings. You can typically:

• Block all cookies
• Block only third-party cookies
• Allow cookies but delete them when you close your browser
• View, delete, or manage specific cookies

Instructions for popular browsers:

Google Chrome:

• Go to Settings > Privacy and security > Cookies and other site data
• Choose your preferred cookie settings
• Manage exceptions for specific sites

Mozilla Firefox:

• Go to Preferences > Privacy & Security > Cookies and Site Data
• Choose your preferred cookie settings
• Clear cookies manually as needed

Apple Safari:

• Go to Preferences > Privacy > Cookies and website data
• Choose your preferred settings
• Manage exceptions for specific sites

Microsoft Edge:

• Go to Settings > Privacy, search, and services > Cookies and other site data
• Choose your preferred cookie settings
• Manage exceptions

Note: Blocking or deleting cookies may affect Website functionality and your user experience.

8.2 Third-Party Opt-Out Tools

You can opt out of third-party advertising cookies using:

• Your Online Choices: www.youronlinechoices.com
• Digital Advertising Alliance (DAA): www.aboutads.info
• Network Advertising Initiative (NAI): www.networkadvertising.org
• Google's Ad Settings: myaccount.google.com/ads
• Meta's Ad Preferences: facebook.com/ads/preferences

8.3 Global Privacy Control (GPC)

If your browser supports Global Privacy Control (GPC), you can enable this feature to signal your privacy preference. We honour GPC signals in accordance with UK regulations.

9. Specific Third-Party Cookie Providers

9.1 Google Analytics 4

• Provider: Google Ireland Limited
• Purpose: Tracking user behaviour, traffic sources, user engagement, and providing website analytics reports
• Data collected: Pages visited, time on site, device information, location data (country/city level), referral source, user interactions
• Legal basis: Consent
• Your rights: Opt out via Google Analytics Opt-Out Browser Extension or view Google's Privacy Policy at privacy.google.com
• Retention: 14-26 months from date of last activity

9.2 Google Ads (Conversion Tracking)

• Provider: Google Ireland Limited
• Purpose: Measuring conversions, retargeting, and campaign performance
• Data collected: Click data, conversion data, device information, browsing behaviour
• Legal basis: Consent
• Retention: Up to 540 days

9.3 Meta Pixel (Facebook)

• Provider: Meta Platforms, Inc. (USA) / Meta Ireland Limited (EU/UK)
• Purpose: Tracking user actions, conversion tracking, audience creation, and retargeting
• Data collected: Pages visited, actions taken, device information, IP address, browsing behaviour
• Legal basis: Consent
• Your rights: Opt out through Meta's Ad Preferences or view Meta's Data Policy at facebook.com/about/privacy
• Retention: Up to 365 days or longer depending on Meta's policy
• Data transfers: Meta may transfer data to the USA under appropriate safeguards (Standard Contractual Clauses)

9.4 LinkedIn

• Provider: LinkedIn Ireland Unlimited Company
• Purpose: B2B advertising, audience insights, conversion tracking
• Data collected: Professional profile information (if linked), browsing behaviour, device information
• Legal basis: Consent
• Your rights: Manage LinkedIn advertising preferences at linkedin.com/psettings

9.5 YouTube (Video Embedding)

• Provider: Google / Alphabet Inc.
• Purpose: Embedding and tracking video content
• Data collected: Video viewing behaviour, playback data
• Legal basis: Consent or legitimate interest (embedded content functionality)
• Your rights: Manage YouTube privacy settings or view Google's Privacy Policy at privacy.google.com

10. Cookie Consent Banner Specifications

10.1 Banner Design and Placement

Our cookie consent banner:

• Appears on first visit before any non-essential cookies are set
• Is clearly visible on the Website and not hidden or minimised
• Provides equal prominence to accept and reject options
• Does not use pre-ticked boxes – you must actively consent
• Contains links to this Cookie Policy and our Privacy Policy
• Remains accessible after consent is given

10.2 Banner Buttons and Options

The banner provides the following buttons with equal visual prominence:

• "Reject All" – Rejects all non-essential cookies immediately
• "Accept All" – Accepts all cookie categories
• "Manage Preferences" – Opens detailed cookie settings where you can customise by category

10.3 Accessibility

Our cookie banner:

• Meets WCAG 2.1 AA accessibility standards
• Is keyboard navigable
• Has appropriate colour contrast
• Supports screen reader technology

11. Legal Basis for Cookies

Our cookie usage complies with the following UK legislation:

11.1 Privacy and Electronic Communications Regulations (PECR) 2003

Regulation 6 PECR requires that:

• We inform you about cookies before setting them
• We clearly explain what cookies do
• We obtain your consent before setting non-essential cookies (with the "strictly necessary" exemption)

We comply by:

• Displaying a clear cookie banner before setting non-essential cookies
• Providing detailed information about each cookie category
• Only setting non-essential cookies after explicit consent
• Allowing you to withdraw consent at any time

11.2 UK General Data Protection Regulation (UK GDPR)

Articles 4(11) and 7 (Consent) require that consent be:

• Freely given – You can refuse without detriment
• Specific – Distinct for each cookie purpose
• Informed – You must understand what you're consenting to
• Unambiguous – Clear affirmative action is required (no pre-ticked boxes)

We comply by:

• Using clear language about cookie purposes
• Providing granular cookie category controls
• Not using pre-ticked consent boxes
• Allowing easy withdrawal of consent

11.3 Data Protection Act 2018 (DPA 2018)

We comply with DPA 2018 principles by:

• Processing cookie data lawfully, fairly, and transparently
• Collecting data for specified, legitimate purposes
• Using data security measures to protect your information
• Being accountable for our processing practices

12. Contact and Queries

If you have questions about this Cookie Policy, our cookie usage, or wish to exercise your rights regarding cookies, please contact:

13. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our cookie usage, technology, or legal requirements.

Material changes will be notified to you by:

• Prominent notice on the Website
• Email notification (if we have your contact details)
• Re-displaying the cookie consent banner

Your continued use of the Website following updates constitutes acceptance of the updated policy.

14. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature. We recognise DNT signals as expressions of your privacy preference. However, browser DNT implementations vary widely, and third-party services may not respond to DNT signals.

We recommend using our cookie preference centre for the most reliable control over cookies on our Website.

15. Information Commissioner's Office (ICO)

For more information about cookies and your rights, visit the ICO website:

• ICO Website: www.ico.org.uk
• ICO Guidance on Cookies: ico.org.uk/for-organisations/guide-to-pecr/guidance-on-the-use-of-cookies-and-similar-technologies
• File a Complaint: ico.org.uk/make-a-complaint

16. Definitions

• Cookie: A small text file stored on your device that contains data about your browsing activity.
• First-party cookie: A cookie set by the domain you are visiting (our domain).
• Third-party cookie: A cookie set by a domain other than the one you are visiting.
• Session cookie: A cookie that is automatically deleted when you close your browser.
• Persistent cookie: A cookie that remains on your device for a specified period.
• Consent: Your clear, affirmative agreement to our use of cookies (freely given, specific, informed, and unambiguous).
• Legitimate interest: A legal basis for processing data when you have a reasonable expectation of the processing and it does not override your privacy rights.

17. Your Privacy Rights

In addition to cookie preferences, you have rights under UK GDPR regarding personal data collected through cookies:

• Right of access – Request a copy of data we have collected about you via cookies
• Right to erasure – Request deletion of cookie-related data in certain circumstances
• Right to rectification – Correct inaccurate data
• Right to restrict processing – Limit how we use your cookie data
• Right to data portability – Receive your data in a portable format
• Right to object – Oppose certain types of processing

For more details, please review our Privacy Policy or contact us.

18. Key Compliance Points

This Cookie Policy ensures compliance with:

• ✅ Privacy and Electronic Communications Regulations (PECR) 2003 – Regulation 6 (Cookies)
• ✅ UK General Data Protection Regulation (UK GDPR) – Articles 4(11), 5, 7 (Consent and lawfulness)
• ✅ Data Protection Act 2018 (DPA 2018) – Privacy principles and accountability
• ✅ Electronic Commerce Regulations 2002 – Transparency requirements
• ✅ Information Commissioner's Office (ICO) Guidance – Current cookie compliance standards (December 2025)