Cookie Policy

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 NameProviderPurposeDurationsession_idUnicorn CurrenciesMaintains your logged-in session in the banking portalSession (deleted when browser closes)auth_tokenUnicorn CurrenciesAuthenticates your identity and authorizes access to secure areasSessioncsrf_tokenUnicorn CurrenciesPrevents Cross-Site Request Forgery (CSRF) attacksSessioncookie_consentUnicorn CurrenciesRemembers your cookie consent preferences12 monthsload_balancerFramer / AWSEnsures your requests are routed to the correct server for optimal performanceSession

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). We use this data to improve the performance, functionality, and user experience of our services.

Analytics Cookies We Use:

Cookie NameProviderPurposeDuration_gaGoogle AnalyticsDistinguishes unique users and tracks user behavior across sessions2 years_ga_<container-id>Google Analytics (GA4)Persists session state for Google Analytics 42 years_gidGoogle AnalyticsDistinguishes unique users within a 24-hour period24 hours_gatGoogle AnalyticsThrottles request rate to prevent overloading servers1 minuteframer_site_analyticsFramerTracks page views, session duration, and navigation patterns on Framer-hosted pages1 year

What We Track:

(a) Pages visited and time spent on each page;

(b) Navigation paths and click behavior;

(c) Referral sources (how you arrived at our Website);

(d) Device type, browser type, operating system, and screen resolution;

(e) Geographic location (country and city level only, not precise location);

(f) Error messages and technical issues encountered.

Data Anonymization: We have configured Google Analytics to:

(a) Anonymize IP addresses (last octet removed before processing);

(b) Disable data sharing with Google for advertising purposes;

(c) Disable remarketing and advertising features;

(d) Respect "Do Not Track" signals where technically feasible.

Legal Basis: Consent (required under PECR Regulation 6) or legitimate interests where data is fully anonymized (GDPR Article 6(1)(f)).

Can You Block These Cookies?: Yes. You can withdraw consent or block analytics cookies using the cookie preference center (see Section 7) or your browser settings. Blocking analytics cookies will not affect your ability to use the Website or Portal; we simply will not collect analytics data about your visit.

Third-Party Privacy Policies:

(a) Google Analytics: https://policies.google.com/privacy

(b) Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout

(c) 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. They may also be used to provide services you have requested, such as watching a video or commenting on content.

Functionality Cookies We Use:

Cookie NameProviderPurposeDurationuser_languageUnicorn CurrenciesRemembers your preferred language (English/French)12 monthscurrency_displayUnicorn CurrenciesRemembers your preferred currency for display purposes12 monthsdashboard_layoutUnicorn CurrenciesSaves your customized dashboard layout and widget preferences in the Portal12 monthstimezone_prefUnicorn CurrenciesRemembers your timezone preference for displaying transaction times12 months

Legal Basis: Legitimate interests (improving user experience) under GDPR Article 6(1)(f). Under PECR, functionality cookies that enhance user experience but are not strictly necessary require consent.

Can You Block These Cookies?: Yes. You can block functionality cookies, but doing so may result in a less personalized experience, and certain features may not function as intended (e.g., language settings will revert 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 decide to implement marketing cookies in the future (for example, to track conversion from online advertising campaigns or to deliver retargeted ads), we will:

(a) Update this Cookie Policy with details of the cookies used;

(b) Obtain your explicit consent before setting such cookies;

(c) Provide clear opt-out mechanisms.

Commitment: Any future marketing cookies will be used in strict compliance with GDPR, PECR, and CASL requirements.

3.2 Other Tracking Technologies

In addition to cookies, we may use other tracking technologies including:

3.2.1 Web Beacons (Pixels)

Web beacons (also called pixel tags or clear GIFs) are tiny graphics with a unique identifier embedded in web pages or emails. We may use web beacons to:

(a) Track whether emails we send are opened and which links are clicked;

(b) Monitor website traffic patterns;

(c) Count visitors to specific pages.

Web beacons work in conjunction with cookies. If you disable cookies, web beacons will still detect visits but 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 to store data locally on your device for performance optimization and to improve user experience. Unlike cookies, local storage data does not expire automatically and must be manually deleted.

What We Store:

(a) Temporary form data to prevent loss during navigation;

(b) User interface preferences;

(c) Cached data to reduce server requests and improve load times.

How to Clear: You can clear local storage through your browser's developer tools or privacy settings (see Section 7.2).

3.2.3 Device Fingerprinting

We do not use device fingerprinting or other invasive tracking technologies that identify users without their knowledge or consent.

4. WHY WE USE COOKIES

4.1 Purposes for Cookie Usage

We use cookies for the following purposes:

4.1.1 Essential Website and Portal Functionality

(a) Authentication and Security: Verifying your identity when you log into the Portal and maintaining your authenticated session securely.

(b) Session Management: Keeping track of your actions as you navigate between pages within the Portal to ensure a seamless experience.

(c) Security Features: Preventing Cross-Site Request Forgery (CSRF) attacks, detecting and preventing fraudulent activity, and protecting against unauthorized access.

(d) Load Balancing: Distributing traffic across multiple servers to ensure fast, reliable performance.

4.1.2 Performance Monitoring and Optimization

(a) Website Analytics: Understanding how visitors interact with our Website to identify popular content, navigation patterns, and areas for improvement.

(b) Error Detection: Identifying technical issues, broken links, and performance bottlenecks that may affect user experience.

(c) A/B Testing: Testing different versions of web pages or features to determine which provides the best user experience (where applicable).

4.1.3 User Experience Enhancement

(a) Personalization: Remembering your preferences (language, currency, layout) to provide a customized experience without requiring you to re-enter preferences on each visit.

(b) Convenience: Reducing the need for repetitive actions (e.g., re-entering timezone settings).

(c) Accessibility: Storing accessibility preferences to ensure the Website meets your needs.

4.1.4 Compliance and Fraud Prevention

(a) Fraud Detection: Analyzing usage patterns to detect and prevent fraudulent activity, unauthorized access, and account takeover attempts.

(b) Regulatory Compliance: Maintaining audit trails and logs as required by financial services regulations (FINTRAC, FCA).

(c) Know Your Customer (KYC): Supporting identity verification processes during account opening.

5. THIRD-PARTY COOKIES AND SERVICES

5.1 Third-Party Service Providers

Our Website and Portal use third-party services that may set their own cookies. These third parties are independent data controllers for their cookies and tracking technologies.

Key Third-Party Services:

5.1.1 Google Analytics

Provider: Google LLC (USA) / Google Ireland Limited (for EEA/UK users)

Purpose: Web analytics and performance monitoring

Data Collected: Page views, session duration, bounce rate, geographic location (country/city), device information, referral sources

Data Processing Location: United States (with Standard Contractual Clauses in place)

Privacy Policy: https://policies.google.com/privacy

Opt-Out: https://tools.google.com/dlpage/gaoptout

Data Retention: Google Analytics data is retained for 26 months, after which it is automatically deleted.

5.1.2 Framer

Provider: Framer B.V. (Netherlands)

Purpose: Website hosting, content delivery, and site analytics for Framer-hosted pages

Data Collected: Page views, session data, navigation patterns, device information

Data Processing Location: European Union and United States (with appropriate safeguards)

Privacy Policy: https://www.framer.com/privacy

Cookies Used: framer_site_analytics

5.2 Data Sharing with Third Parties

We do not sell your personal data to third parties. However, by using third-party services like Google Analytics and Framer, certain data (as described above) is shared with these providers for the purposes of analytics and hosting.

Safeguards in Place:

(a) Data Processing Agreements: We have contracts with third-party providers requiring them to comply with GDPR, PIPEDA, and applicable data protection laws.

(b) Standard Contractual Clauses: For transfers to the United States and other non-adequate jurisdictions, we use European Commission-approved Standard Contractual Clauses.

(c) Data Minimization: We configure third-party services to collect only the minimum data necessary.

(d) Anonymization: Where possible, we anonymize data before it is shared with third parties (e.g., IP address anonymization in Google Analytics).

5.3 Third-Party Privacy Policies

Third-party service providers operate under their own privacy policies. We encourage you to review these policies:

(a) Google: https://policies.google.com/privacy

(b) Framer: https://www.framer.com/privacy

Unicorn is not responsible for the privacy practices of third-party service providers. If you have concerns about third-party data collection, you may opt out of cookies as described in Section 7.

6. LEGAL BASIS FOR COOKIE USAGE

6.1 UK GDPR and PECR (UK and EEA Visitors)

Under UK GDPR and the Privacy and Electronic Communications Regulations (PECR), we rely on the following legal bases for cookie usage:

(a) Strictly Necessary Cookies: Legitimate interests (GDPR Article 6(1)(f)) and exemption from consent under PECR Regulation 6(1) as these cookies are essential for service delivery.

(b) Analytics and Functionality Cookies: Consent (PECR Regulation 6(2)) or legitimate interests where data is fully anonymized (GDPR Article 6(1)(f)).

Consent Requirements: Under PECR, consent for non-essential cookies must be:

• Freely given: Not bundled with other terms and conditions;

• Specific: Clearly differentiated by cookie category;

• Informed: Users must understand what they are consenting to;

• Unambiguous: Indicated by a clear affirmative action (e.g., clicking "Accept").

Cookie Walls: We do not use "cookie walls" that prevent access to the Website if you do not consent to non-essential cookies. You can browse our public Website and access essential information without accepting analytics or functionality cookies.

6.2 PIPEDA and CASL (Canadian Visitors)

Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and Anti-Spam Legislation (CASL):

(a) Consent: We obtain implied or express consent for cookies that collect personal information, depending on the sensitivity and intrusiveness of the data collection.

(b) Transparency: We clearly disclose what information is collected and for what purposes.

(c) Opt-Out: You may withdraw consent at any time by adjusting cookie preferences or using browser controls.

(d) Deemed Consent: For strictly necessary cookies essential to service delivery, 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 that allows you to manage your cookie consent preferences at any time.

How to Access:

(a) On First Visit: A cookie consent banner will appear when you first visit our Website, allowing you to accept all cookies, reject non-essential cookies, or customize your preferences.

(b) After Initial Consent: You can access the Cookie Preference Center at any time by:

• Clicking the "Cookie Settings" link in the footer of our Website;

• Clicking the cookie icon (if displayed) in the bottom corner of the page;

• Visiting: www.unicorncurrencies.com/cookie-preferences

Granular Control:

The Cookie Preference Center allows you to:

(a) Accept All Cookies: Consent to all cookie categories (strictly necessary, analytics, functionality).

(b) Reject Non-Essential Cookies: Consent only to strictly necessary cookies and reject all others.

(c) Customize Preferences: Toggle individual cookie categories on or off:

• Strictly Necessary Cookies: Always active (cannot be disabled as they are essential for the Website and Portal to function).

• Performance and Analytics Cookies: Toggle on/off.

• Functionality Cookies: Toggle on/off.

(d) Save Preferences: Your choices are saved and will be remembered for 12 months (via the cookie_consent cookie).

Updating Your Preferences:

You can change your cookie preferences at any time. Changes take effect immediately for new cookies, but existing cookies may remain on your device until they expire or you manually delete them (see Section 7.2).

7.2 Browser-Based Cookie Controls

All major web browsers allow you to control cookies through their settings. You can:

(a) Block All Cookies: Prevent websites from setting any cookies.

(b) Block Third-Party Cookies: Allow first-party cookies (from Unicorn) but block third-party cookies (from Google, Framer, etc.).

(c) Delete Existing Cookies: Remove cookies that have already been set.

(d) Set Expiration Preferences: Configure cookies to be deleted when you close your browser.

How to Manage Cookies by Browser:

(a) Google Chrome:
Settings > Privacy and Security > Cookies and other site data
Guide: https://support.google.com/chrome/answer/95647

(b) Mozilla Firefox:
Settings > Privacy & Security > Cookies and Site Data
Guide: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

(c) Apple Safari:
Preferences > Privacy > Cookies and website data
Guide: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

(d) Microsoft Edge:
Settings > Cookies and site permissions > Cookies and site data
Guide: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

(e) Opera:
Settings > Privacy & Security > Cookies
Guide: https://help.opera.com/en/latest/web-preferences/#cookies

Mobile Browsers: Mobile browsers (Safari on iOS, Chrome on Android) also provide cookie management settings. Consult your device's help documentation for instructions.

Impact of Blocking Cookies:

(a) Strictly Necessary Cookies: Blocking these cookies will prevent you from logging into the Portal, executing transactions, and accessing secure areas of the Website.

(b) Analytics Cookies: Blocking these cookies will prevent us from collecting usage data but will not affect your ability to use the Website or Portal.

(c) Functionality Cookies: Blocking these cookies may result in a less personalized experience, with settings reverting to defaults on each visit.

7.3 Third-Party Opt-Out Tools

In addition to browser controls, you can opt out of specific third-party tracking:

(a) Google Analytics Opt-Out Browser Add-On:
Download: https://tools.google.com/dlpage/gaoptout
This browser extension prevents Google Analytics from collecting data about your website visits.

(b) Network Advertising Initiative (NAI) Opt-Out:
https://www.networkadvertising.org/choices/
Opt out of interest-based advertising from NAI member companies.

(c) Digital Advertising Alliance (DAA) Opt-Out:
https://youradchoices.com/
Opt out of interest-based advertising from DAA member companies.

(d) Your Online Choices (EU):
https://www.youronlinechoices.com/
European-based opt-out tool for interest-based advertising.

Note: Unicorn does not currently use interest-based advertising cookies, but these tools may be useful if you wish to limit tracking by other websites you visit.

7.4 Do Not Track (DNT) Signals

"Do Not Track" (DNT) is a browser setting that sends a signal to websites requesting that they do not track your browsing activity.

Our Position: There is currently no universally accepted standard for how websites should respond to DNT signals. Our Website does not currently respond to DNT signals. However, you can control tracking through the Cookie Preference Center and browser settings as described above.

Industry Developments: If a standardized DNT protocol is adopted in the future, we will evaluate implementation and update this Cookie Policy accordingly.

8. INTERNATIONAL DATA TRANSFERS

8.1 Cross-Border Cookie Data

Some of our third-party service providers (particularly Google Analytics) are based in the United States or process cookie data through US-based servers. This means that cookie data may be transferred to, processed in, and stored in the United States.

8.2 Safeguards for International Transfers

We ensure appropriate safeguards are in place for international data transfers:

(a) Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses with US-based service providers.

(b) Data Processing Agreements: Our contracts with third-party providers require them to comply with GDPR and UK GDPR standards.

(c) Supplementary Measures: We implement technical measures such as encryption and IP anonymization to protect data transferred internationally.

(d) Transparency: We disclose in this Cookie Policy which providers may process data outside the EEA/UK and provide links to their privacy policies.

8.3 Your Rights

If you have concerns about international data transfers through cookies, you have the right to:

(a) Object to processing based on legitimate interests (see Privacy Policy Section 8.1.6);

(b) Withdraw consent for analytics and functionality cookies;

(c) Block third-party cookies using browser settings or opt-out tools.

9. COOKIE RETENTION AND DELETION

9.1 Cookie Expiration

Cookies have different lifespans depending on their purpose:

(a) Session Cookies: Deleted automatically when you close your browser.

(b) Persistent Cookies: Remain on your device for the duration specified in Section 3 (ranging from 1 minute to 2 years) or until you manually delete them.

9.2 Automatic Deletion

Once a cookie reaches its expiration date, it is automatically deleted from your device by your browser.

9.3 Manual Deletion

You can manually delete cookies at any time using your browser's privacy settings (see Section 7.2). Deleting cookies will:

(a) Remove your saved preferences (language, currency, layout);

(b) Log you out of the Portal;

(c) Reset your cookie consent preferences (you will see the consent banner again on your next visit);

(d) Stop analytics tracking until new cookies are set.

9.4 Data Retention by Third Parties

Third-party service providers (Google, Framer) retain cookie data in accordance with their own data retention policies:

(a) Google Analytics: Retains data for 26 months by default (we have configured this setting).

(b) Framer: Retains analytics data for up to 12 months.

After the retention period expires, third-party providers delete or anonymize the data.

10. CHILDREN'S PRIVACY

10.1 Age Restrictions

Our Website and Portal are intended for individuals aged 18 and over. We do not knowingly collect personal data from children under the age of 18 through cookies or any other means.

10.2 Parental Control

If you are a parent or guardian and believe that your child has provided personal data through our Website, please contact us immediately at privacy@unicorncurrencies.com. We will take steps to delete such data promptly.

11. UPDATES TO THIS COOKIE POLICY

11.1 Policy Changes

We may update this Cookie Policy from time to time to reflect:

(a) Changes in our cookie usage practices;

(b) New third-party service providers;

(c) Changes in applicable laws and regulations;

(d) Technical developments and industry best practices.

11.2 Notification of Changes

When we make material changes to this Cookie Policy, we will:

(a) Update the "Last Updated" date at the top of this policy;

(b) Post a prominent notice on the Website;

(c) Request renewed consent where required by law (e.g., if we introduce new cookie categories).

11.3 Your Responsibility

We encourage you to review this Cookie Policy periodically to stay informed about our use of cookies and how you can manage your preferences.

12. CONTACT US

12.1 Questions and Concerns

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

Data Protection Officer / Privacy Officer:

Email: privacy@unicorncurrencies.com

For UK, EU, and Rest of World Clients:
Data Protection Officer
Unicorn Currencies Ltd
4th Floor, Silverstream House, Fitzroy Street
London, W1T 6EB
United Kingdom
Phone: +44 (20) 8604-0818

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

12.2 Exercising Your Rights

To exercise your data protection rights (access, rectification, erasure, restriction, objection, portability) in relation to data collected through cookies, please refer to our Privacy Policy or contact us using the details above.

12.3 Complaints

If you believe we have violated your privacy rights in relation to cookies, you have the right to lodge a complaint with the relevant supervisory authority:

UK: Information Commissioner's Office (ICO)
Website: https://ico.org.uk
Email: casework@ico.org.uk
Phone: 0303 123 1113

Canada: Office of the Privacy Commissioner of Canada
Website: https://www.priv.gc.ca
Email: info@priv.gc.ca
Phone: 1-800-282-1376

13. ADDITIONAL RESOURCES

13.1 Learn More About Cookies

(a) All About Cookies: https://www.allaboutcookies.org

(b) ICO Guidance on Cookies: https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/cookies-and-similar-technologies/

(c) Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/en/privacy-topics/technology/online-privacy-tracking-cookies/

13.2 Related Policies

(a) Privacy Policy: www.unicorncurrencies.com/privacy

(b) Master Services Agreement: www.unicorncurrencies.com/terms

(c) Safeguarding Policy: www.unicorncurrencies.com/safeguarding

(d) Complaint Handling Procedure: www.unicorncurrencies.com/complaints

14. SUMMARY TABLE: COOKIES AT A GLANCE

Cookie CategoryPurposeConsent Required?Can Be Blocked?Impact If BlockedStrictly NecessaryEssential functionality, authentication, securityNo (PECR exemption)Yes, but not recommendedCannot use Portal or secure featuresPerformance & AnalyticsWebsite analytics, performance monitoringYes (PECR requirement)YesNo impact on functionality; we won't collect usage dataFunctionalityRemember preferences, personalizationYes (PECR requirement)YesLess personalized experience; settings revert to defaultsTargeting & MarketingInterest-based advertising (not currently used)Yes (PECR requirement)YesNo 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.

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