Legal
Cookie Policy
Effective date: 26 August 2026 (for bank due-diligence review — not yet published) • Version 0.1 (draft)
Document owner: EQVI LTD • Policy owner: Data Protection Contact • Status: Draft • Last reviewed: 26 August 2026 • Next review: 26 August 2027
1. Introduction
This Cookie Policy explains how EQVI LTD ("EQVI," "we," "us," or "our") uses cookies, software development kits (SDKs), device storage, attribution technologies, push-notification tokens, device identifiers, crash reporting, and similar technologies (together, "tracking technologies") when you visit our website or use the EQVI service, including where EQVI is embedded within a partner bank's application.
This policy should be read alongside our Privacy Policy, which explains more generally how we collect, use, and protect your personal data. Where a term is used here without definition, it has the meaning given in the Privacy Policy.
2. Where This Policy Applies
This policy covers two distinct contexts, which use different technologies:
1. our marketing website (eqvilibria.com), which may use browser cookies and similar web-based technologies; and
2. the EQVI service itself, including where accessed through a partner bank's mobile application, which primarily uses mobile SDKs, device identifiers, and similar app-based technologies rather than browser cookies.
Where EQVI is embedded within a partner bank's application, the partner bank's own cookie and tracking-technology practices for its app are governed by the bank's own policies, not this one. This policy covers only the tracking technologies used by EQVI within that experience.
3. What Are Cookies and Similar Technologies
Cookies are small text files placed on your device by a website you visit. Similar technologies used in mobile apps include SDKs (software components provided by us or third parties that collect data or enable functionality), device identifiers (such as advertising or device IDs), local device storage, and push-notification tokens (which allow us to send notifications to your device).
4. Categories of Tracking Technologies We Use
The table below summarises the categories of tracking technologies EQVI may use. Not every category applies to every user — this depends on which features you use and which technologies your partner bank's app permits.
| Category | Purpose | Consent basis / default |
|---|---|---|
| Strictly necessary | Enable core functionality, security, and authentication of the service | Not consent-based — necessary for the service; cannot be switched off |
| Functional | Remember your settings and preferences within the service | Not consent-based — necessary for the service; cannot be switched off |
| Analytics and performance | Understand how the service is used, diagnose errors, and ensure reliability | Legitimate interest — configurable in Data & Privacy settings where applicable |
| Attribution | Confirm that a merchant purchase was completed through EQVI, for attribution or commission purposes | Legitimate interest / contract, as described in Privacy Policy Section 7a |
| Push notifications | Send you notifications relevant to the service, where enabled | Consent — off until you enable notifications; manageable in device or in-app settings |
| Marketing | Measure the effectiveness of marketing content and partner offers, where you have opted in | Consent — off until you enable it; managed via Cookie Settings and Data & Privacy settings |
We do not use tracking technologies to infer or record health data, and we do not use cookies or SDKs to build advertising profiles based on sensitive categories of data.
5. Third-Party Tracking Technologies
Some tracking technologies on our website or within the service are placed by third-party providers (for example, analytics, crash-reporting, or attribution providers) who process data on our behalf under contractual confidentiality and data protection obligations, as described in our Privacy Policy. A list of categories of such providers, including the country in which each operates, is available on request from our Data Protection Contact.
We do not permit third parties to use tracking technologies on our website or within the service for their own independent marketing purposes without your consent.
6. How to Manage Your Preferences
You can manage your preferences for non-essential tracking technologies in the following ways:
1. on our website, using the Cookie Settings control available in the footer;
2. within the EQVI service, using the toggles available in Data & Privacy settings;
3. for push notifications, using your device's notification settings;
4. for browser-based cookies generally, using your browser's own cookie management settings.
Turning off a non-essential category stops that use going forward but does not delete tracking data already collected; see Section 11 of our Privacy Policy for how this differs from withdrawing consent, disconnecting a source, or deleting data.
Because strictly necessary and functional technologies are required for the service to work, disabling them (for example, by blocking all cookies at the browser level) may mean parts of the website or service do not function correctly.
7. Retention
We retain data collected through tracking technologies only for as long as necessary for the purpose described in the table above, consistent with the retention approach set out in our Privacy Policy.
8. Changes to This Policy
We may update this Cookie Policy from time to time to reflect changes in the technologies we use or legal requirements. Material changes will be communicated in-app or on our website before they take effect. The "Effective date" at the top of this document reflects the latest revision.
9. Contact Us
For any questions about this Cookie Policy or to exercise your data protection rights, contact:
EQVI LTD — Data Protection Contact
Registered office: 167-169 Great Portland Street, Fifth Floor, London, W1W 5PF, United Kingdom
Companies House number: 14060750
Email: privacy@eqvilibria.com