1. INTRODUCTION

1.1 About This Policy

This Cookie Policy explains how Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom) (collectively "Unicorn", "we", "us", or "our") use cookies and similar tracking technologies on our website at www.unicorncurrencies.com (the "Website") and our online banking portal (the "Portal").

This Cookie Policy should be read in conjunction with our Privacy Policy, which provides detailed information about how we collect, use, and protect your personal data.

1.2 Regulatory Compliance

This Cookie Policy complies with:

(a) UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018;
(b) Privacy and Electronic Communications Regulations 2003 (PECR) as amended;
(c) Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada);
(d) Canada's Anti-Spam Legislation (CASL);
(e) Guidance from the UK Information Commissioner's Office (ICO) and Office of the Privacy Commissioner of Canada.

1.3 Your Consent

By continuing to use our Website and Portal, you consent to our use of cookies in accordance with this Cookie Policy, except for strictly necessary cookies which do not require consent under applicable law.

You can manage your cookie preferences at any time using the mechanisms described in Section 7 of this policy.

2. WHAT ARE COOKIES?

2.1 Definition

Cookies are small text files that are placed on your computer, smartphone, tablet, or other device (collectively "device") when you visit a website. Cookies are widely used by website owners to make their websites work more efficiently, provide a better user experience, and to gather analytical information about website usage.

2.2 How Cookies Work

When you visit our Website or Portal, cookies are stored in your device's browser. These cookies contain information that can be read by the website on subsequent visits, allowing the website to:

(a) Remember your preferences and settings;
(b) Recognize you as a returning visitor;
(c) Maintain your session and authentication status;
(d) Collect analytics data about how you use the website;
(e) Deliver personalized content and advertising.

2.3 First-Party and Third-Party Cookies

(a) First-party cookies are set by Unicorn and can only be read by our Website and Portal.
(b) Third-party cookies are set by external service providers (such as Google Analytics or Framer) and can be read by those third parties across multiple websites.

2.4 Session and Persistent Cookies

(a) Session cookies are temporary cookies that expire when you close your browser. They are used to maintain your session while you navigate the Website or Portal.
(b) Persistent cookies remain on your device for a set period (ranging from a few hours to several years) and are activated each time you visit the website that created the cookie.

3. COOKIES WE USE

3.1 Categories of Cookies

We use the following categories of cookies on our Website and Portal:

3.1.1 Strictly Necessary Cookies

Purpose: These cookies are essential for the Website and Portal to function properly. They enable core functionality such as security, authentication, network management, accessibility, and session management.

Examples of Strictly Necessary Cookies:

Cookie Name	Provider	Purpose	Duration
session_id	Unicorn Currencies	Maintains your logged-in session in the banking portal	Session
auth_token	Unicorn Currencies	Authenticates your identity and authorizes access to secure areas	Session
csrf_token	Unicorn Currencies	Prevents Cross-Site Request Forgery (CSRF) attacks	Session
cookie_consent	Unicorn Currencies	Remembers your cookie consent preferences	12 months
load_balancer	Framer / AWS	Ensures your requests are routed to the correct server for optimal performance	Session

Legal Basis: Legitimate interests (essential for service delivery). These cookies are exempt from consent requirements under GDPR Article 6(1)(f) and PECR Regulation 6(1).

Can You Block These Cookies? You can block these cookies through your browser settings, but doing so will prevent you from using essential features of the Website and Portal, including logging into your account and executing transactions.

3.1.2 Performance and Analytics Cookies

Purpose: These cookies collect information about how visitors use our Website and Portal, including which pages are visited most often, how long visitors spend on pages, and any error messages encountered. All information collected by analytics cookies is aggregated and anonymized (or pseudonymized).

Analytics Cookies We Use:

Cookie Name	Provider	Purpose	Duration
_ga	Google Analytics	Distinguishes unique users and tracks user behavior across sessions	2 years
_ga_<container-id>	Google Analytics (GA4)	Persists session state for Google Analytics 4	2 years
_gid	Google Analytics	Distinguishes unique users within a 24-hour period	24 hours
_gat	Google Analytics	Throttles request rate to prevent overloading servers	1 minute
framer_site_analytics	Framer	Tracks page views, session duration, and navigation patterns on Framer-hosted pages	1 year

What We Track: Pages visited and time spent; navigation paths and click behavior; referral sources; device type, browser, OS, screen resolution; geographic location (country/city only); error messages and technical issues.

Data Anonymization: We have configured Google Analytics to anonymize IP addresses, disable data sharing with Google for advertising, disable remarketing and advertising features, and respect "Do Not Track" where technically feasible.

Legal Basis: Consent (PECR) or legitimate interests where data is fully anonymized. Can You Block? Yes, via cookie preference center or browser settings; blocking will not affect your ability to use the Website or Portal.

Third-Party Privacy Policies: Google Analytics: https://policies.google.com/privacy | Opt-Out: https://tools.google.com/dlpage/gaoptout | Framer: https://www.framer.com/privacy

3.1.3 Functionality Cookies

Purpose: These cookies allow the Website to remember choices you make (such as language preference, region, or display settings) and provide enhanced, personalized features.

Functionality Cookies We Use:

Cookie Name	Provider	Purpose	Duration
user_language	Unicorn Currencies	Remembers your preferred language (English/French)	12 months
currency_display	Unicorn Currencies	Remembers your preferred currency for display purposes	12 months
dashboard_layout	Unicorn Currencies	Saves your customized dashboard layout and widget preferences in the Portal	12 months
timezone_pref	Unicorn Currencies	Remembers your timezone preference for displaying transaction times	12 months

Legal Basis: Legitimate interests (GDPR Art. 6(1)(f)). Under PECR, functionality cookies that are not strictly necessary require consent. Can You Block? Yes; blocking may result in a less personalized experience and settings reverting to default on each visit.

3.1.4 Targeting and Marketing Cookies (Currently Not Used)

Status: Unicorn does not currently use targeting, advertising, or marketing cookies on the Website or Portal.

Future Use: If we implement marketing cookies in the future, we will update this Cookie Policy, obtain explicit consent, and provide clear opt-out mechanisms. Any future marketing cookies will be used in strict compliance with GDPR, PECR, and CASL.

3.2 Other Tracking Technologies

3.2.1 Web Beacons (Pixels): We may use web beacons to track whether emails are opened and which links are clicked, monitor traffic patterns, and count visitors. Web beacons work with cookies; if you disable cookies, beacons will not be tied to your unique identifier.

3.2.2 Local Storage and Session Storage: We may use HTML5 local storage and session storage for performance and user experience (e.g. temporary form data, UI preferences, cached data). You can clear local storage via browser developer tools or privacy settings.

3.2.3 Device Fingerprinting: We do not use device fingerprinting or other invasive tracking that identifies users without their knowledge or consent.

4. WHY WE USE COOKIES

4.1.1 Essential Functionality: Authentication and security; session management; security features (CSRF prevention, fraud detection); load balancing.

4.1.2 Performance: Website analytics; error detection; A/B testing (where applicable).

4.1.3 User Experience: Personalization (language, currency, layout); convenience; accessibility preferences.

4.1.4 Compliance and Fraud Prevention: Fraud detection; regulatory compliance (FINTRAC, FCA); KYC support.

5. THIRD-PARTY COOKIES AND SERVICES

5.1.1 Google Analytics: Provider Google LLC (USA) / Google Ireland (EEA/UK). Purpose: web analytics. Data: page views, session duration, bounce rate, location (country/city), device, referral sources. Processing: US (SCCs in place). Privacy: https://policies.google.com/privacy. Opt-Out: https://tools.google.com/dlpage/gaoptout. Retention: 26 months.

5.1.2 Framer: Provider Framer B.V. (Netherlands). Purpose: website hosting, content delivery, site analytics. Data: page views, session data, navigation patterns, device information. Processing: EU and US (safeguards). Privacy: https://www.framer.com/privacy. Cookies: framer_site_analytics.

5.2 We do not sell your personal data. Data shared with third parties is subject to Data Processing Agreements, Standard Contractual Clauses where required, data minimization, and anonymization where possible.

5.3 Third-party providers operate under their own privacy policies. Unicorn is not responsible for their practices. You may opt out of cookies as described in Section 7.

6. LEGAL BASIS FOR COOKIE USAGE

6.1 UK GDPR and PECR: Strictly necessary cookies: legitimate interests (Art. 6(1)(f)) and PECR exemption. Analytics and functionality: consent (PECR Reg. 6(2)) or legitimate interests where anonymized. Consent must be freely given, specific, informed, and unambiguous. We do not use "cookie walls" that prevent access if you do not consent to non-essential cookies.

6.2 PIPEDA and CASL (Canada): We obtain implied or express consent for cookies that collect personal information. We clearly disclose what is collected and for what purposes. You may withdraw consent at any time. For strictly necessary cookies, consent may be deemed based on your use of the Website and Portal.

7. MANAGING YOUR COOKIE PREFERENCES

7.1 Cookie Preference Center

We provide a Cookie Preference Center to manage your cookie consent at any time.

How to Access: On first visit, a cookie consent banner appears. After initial consent, access via the "Cookie Settings" link in the footer, the cookie icon (if displayed), or by visiting www.unicorncurrencies.com/cookie-preferences.

Granular Control: Accept All; Reject Non-Essential; or Customize (toggle Performance/Analytics and Functionality on/off; Strictly Necessary are always active). Your choices are saved for 12 months (cookie_consent cookie).

7.2 Browser-Based Controls

You can block all cookies, block third-party cookies only, delete existing cookies, or set cookies to delete when you close the browser.

How to Manage by Browser:

Chrome: Settings > Privacy and Security > Cookies and other site data — https://support.google.com/chrome/answer/95647
Firefox: Settings > Privacy & Security > Cookies and Site Data — https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
Safari: Preferences > Privacy > Cookies and website data — https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
Edge: Settings > Cookies and site permissions > Cookies and site data — Microsoft Edge guide
Opera: Settings > Privacy & Security > Cookies — https://help.opera.com/en/latest/web-preferences/#cookies

Impact of Blocking: Strictly necessary: cannot use Portal or secure features. Analytics: no impact on functionality. Functionality: less personalized, settings revert to defaults.

7.3 Third-Party Opt-Out Tools

Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout | NAI: https://www.networkadvertising.org/choices/ | DAA: https://youradchoices.com/ | Your Online Choices (EU): https://www.youronlinechoices.com/. Unicorn does not currently use interest-based advertising cookies.

7.4 Do Not Track (DNT)

Our Website does not currently respond to DNT signals (no universally accepted standard). You can control tracking via the Cookie Preference Center and browser settings.

8. INTERNATIONAL DATA TRANSFERS

Cookie data may be transferred to the US (e.g. Google Analytics). We use Standard Contractual Clauses, Data Processing Agreements, supplementary measures (encryption, IP anonymization), and transparency in this policy. You may object (Privacy Policy Section 8.1.6), withdraw consent for analytics/functionality cookies, or block third-party cookies via browser or opt-out tools.

9. COOKIE RETENTION AND DELETION

9.1 Session cookies: deleted when you close your browser. Persistent cookies: as specified in Section 3 (1 minute to 2 years) or until you delete them.

9.2 Once a cookie expires, it is automatically deleted by your browser.

9.3 Manual deletion via browser settings will remove preferences, log you out, reset consent (banner reappears), and stop analytics until new cookies are set.

9.4 Google Analytics: 26 months. Framer: up to 12 months. After retention, providers delete or anonymize.

10. CHILDREN'S PRIVACY

Our Website and Portal are intended for individuals aged 18 and over. We do not knowingly collect personal data from children under 18 through cookies or any other means. If you are a parent or guardian and believe your child has provided personal data, contact us at privacy@unicorncurrencies.com. We will take steps to delete such data promptly.

11. UPDATES TO THIS COOKIE POLICY

We may update this Cookie Policy to reflect changes in our practices, new providers, or legal/technical developments. When we make material changes we will update the "Last Updated" date, post a prominent notice on the Website, and request renewed consent where required (e.g. new cookie categories). We encourage you to review this policy periodically.

12. CONTACT US

If you have questions, concerns, or requests regarding this Cookie Policy or our use of cookies, please contact:

Email: privacy@unicorncurrencies.com

For UK, EU, and Rest of World:
Data Protection Officer, Unicorn Currencies Ltd, 4th Floor, Silverstream House, Fitzroy Street, London, W1T 6EB, United Kingdom
Phone: +44 (20) 8064-0818

For Canadian and US Clients:
Privacy Officer, Unicorn Currencies Limited, 5577 153A Street, Suite 207, Surrey, V3S 5K7, British Columbia, Canada
Phone: +1 (548) 488-0818

To exercise your data protection rights in relation to data collected through cookies, see our Privacy Policy or contact us using the details above.

Complaints: UK — ICO: https://ico.org.uk, casework@ico.org.uk, 0303 123 1113. Canada — Office of the Privacy Commissioner: https://www.priv.gc.ca, info@priv.gc.ca, 1-800-282-1376.

13. ADDITIONAL RESOURCES

Learn More: All About Cookies: https://www.allaboutcookies.org | ICO Guidance: ICO cookies guide | OPC Canada: OPC tracking/cookies

14. SUMMARY TABLE: COOKIES AT A GLANCE

Cookie Category	Purpose	Consent Required?	Can Be Blocked?	Impact If Blocked
Strictly Necessary	Essential functionality, authentication, security	No (PECR exemption)	Yes, but not recommended	Cannot use Portal or secure features
Performance & Analytics	Website analytics, performance monitoring	Yes (PECR requirement)	Yes	No impact on functionality; we won't collect usage data
Functionality	Remember preferences, personalization	Yes (PECR requirement)	Yes	Less personalized experience; settings revert to defaults
Targeting & Marketing	Interest-based advertising (not currently used)	Yes (PECR requirement)	Yes	No impact (we don't use these cookies)

By using our Website and Portal, you acknowledge that you have read and understood this Cookie Policy. You can manage your cookie preferences at any time through our Cookie Preference Center.