Cookie Policy

This Cookie Policy is published by Waivern Limited, a company incorporated in England and Wales (company registration number 16375372), whose registered office is at 14 Eastbury Road, Petts Wood, Orpington, England, BR5 1JW. Waivern Limited is the controller of the personal data generated by the cookies and similar technologies described in this policy.

This policy covers the website www.waivern.com and any pages served from that domain.

If you have any questions about how we use cookies, please contact us at info@waivern.com. For wider data-protection matters - including your rights, retention periods, and international transfers - please see our Privacy Policy.

A cookie is a small text file that a website places on your device - computer, phone, or tablet - when you visit. Cookies and similar technologies (such as pixels and tracking tags) are used to make websites work, remember your preferences, and gather information about how visitors use a site. Some are set by us directly; others are set by third-party services we use.

This policy tells you honestly and specifically what is stored on or read from your device when you visit www.waivern.com, why, by whom, for how long, and how you can control it.

We comply with the Privacy and Electronic Communications Regulations 2003 (PECR), as amended by the Data Use and Access Act 2025 (DUAA), and with the UK General Data Protection Regulation and the Data Protection Act 2018 (UK GDPR / DPA 2018) in respect of any personal data the cookies generate.

Under PECR, as updated by the DUAA, certain categories of cookie are exempt from the requirement to obtain prior consent where they are used solely for their stated purpose. Those exempt categories are: strictly necessary cookies (session management, security, load-balancing); analytics cookies used solely for aggregate statistics that do not significantly affect visitors; functionality cookies that remember user-chosen preferences; security cookies used for fraud prevention; and software-update cookies. The purpose-limitation rule is the critical gate: if a cookie serves any additional purpose - such as advertising, profiling, or cross-site tracking - the exemption is lost and prior opt-in consent is required. We explain the consent position for each cookie below. Where cookies process personal data - such as an analytics identifier or an advertising ID - the lawful basis for that personal data processing, your rights, applicable retention periods, and any international transfers are covered in our Privacy Policy rather than here.

Visitors from the European Economic Area are covered by EU ePrivacy rules and EU GDPR. Our consent management platform (Cookiebot) is configured to present the appropriate consent request for EEA visitors. The substantive EU-law analysis of transfers and lawful bases is set out in our Privacy Policy.

We use Cookiebot as our consent management platform (CMP). When you first visit www.waivern.com, a cookie banner is displayed. Non-essential cookies are required to be off by default - they must not load until you actively opt in. You may:

• Accept all cookies;
• Accept only strictly necessary cookies; or
• Manage your preferences by category.

The option to accept only strictly necessary cookies is available on the first screen without any additional clicks.

You may change or withdraw your consent at any time by contacting us at info@waivern.com and requesting that your cookie preferences be reset. We are implementing a persistent “Cookie settings” link in the website footer as part of our ongoing remediation work; once live, you will be able to manage your choices directly without contacting us. Withdrawing consent takes immediate effect for future page requests and does not affect the lawfulness of any processing that took place before withdrawal. Your consent record is stored in the Cookiebot consent log. We re-seek your consent after 12 months.

The table below sets out every cookie or similar technology we are aware of on www.waivern.com, based on our most recent scan (Waivern Consent Analyser, 11 August 2026). Cookies are grouped by category. The “Consent position” column shows whether the cookie is exempt from the requirement for prior consent under PECR/DUAA, or whether it requires opt-in consent.

5.1 Strictly necessary cookies

These cookies are essential for the website to function or to record your consent preferences. They do not require your prior consent under PECR. They are always active.

5.2 Analytics cookies

Analytics cookies help us understand how visitors interact with our website in aggregate so that we can improve it. Under PECR as amended by the DUAA, analytics cookies may be exempt from prior consent only where they are used solely for that statistical purpose and do not significantly affect visitors. Where they also process personal data - including online identifiers - our Privacy Policy governs the lawful basis, retention, and transfer details.

Current status: Google Analytics is currently treated as consent-required pending successful remediation of the consent-gating failures identified in our August 2026 scan (see Section 4). Once a passing rescan confirms that these cookies load only after affirmative opt-in, and that they are used solely for aggregate statistics with no significant effect on visitors, we will reassess whether the DUAA analytics exemption applies.

5.3 Advertising and marketing cookies

Advertising cookies track activity across websites to enable targeted and retargeted advertising. These cookies always require your prior opt-in consent under PECR, regardless of the DUAA updates, because they serve an advertising purpose rather than a solely statistical or functional one. They must be off by default and must not load unless you choose to accept them.

Current status: Our August 2026 scan identified that _gcl_au was observed after a consent interaction. This indicates a likely consent-gating failure. We are remediating this as a priority. These cookies must not load prior to your affirmative opt-in consent.

Several of the cookies in the table above are set by third parties whose services we have chosen to use on our website. Google LLC - operating Google Analytics 4, Google Ads, and DoubleClick - is an independent controller of the data it collects through its own cookies. We have linked to Google’s privacy policy in the tables above.

Because those services transfer data to the United States, the applicable transfer mechanism and the lawful basis for the personal data processing is set out in our Privacy Policy. We cause those third-party scripts to load on our site and accordingly we are responsible under PECR for disclosing them here, even though the cookies themselves are set by the third party.

You may also opt out of Google Analytics across all websites by installing the Google Analytics Opt-out Browser Add-on and opt out of Google advertising cookies via Google Ads Settings.

In addition to the controls provided by our Cookiebot banner, every major browser allows you to manage cookies directly. You can typically find these settings under your browser’s privacy or security menu. You may:

• Block all cookies;
• Delete existing cookies; or
• Set your browser to alert you before a cookie is placed.

Please be aware that blocking or deleting all cookies may affect how our website works. Strictly necessary cookies - such as the consent-preference record - may cease to function, which may mean the site cannot recall your preferences between visits.

Further guidance on managing cookies in the most common browsers is available at www.allaboutcookies.org.

When you first visit www.waivern.com, our Cookiebot banner asks for your consent to non-essential cookies. Non-essential cookies must be off by default - they must not load until you actively choose to allow them. You may refuse non-essential cookies on the first screen without any extra clicks by selecting “Accept only strictly necessary cookies”.

To change or withdraw your consent at any time, please contact us at info@waivern.com and we will arrange for your consent record to be reset. We are implementing a persistent “Cookie settings” link in the website footer as part of our remediation work; once that is live, you will be able to manage your choices directly without contacting us. Withdrawing consent is as straightforward as giving it.

Withdrawing consent takes effect immediately for all future requests. It does not affect the lawfulness of any processing that took place before you withdrew. Your consent record (including the date and scope of consent given) is stored in the Cookiebot consent log for 24 months from the date of collection, in accordance with the retention schedule in our Privacy Policy. We will re-seek your consent after 12 months.

Some of the cookies described in this policy - in particular the Google Analytics and advertising cookies - process personal data about you, including online identifiers (such as cookie IDs and IP addresses), device characteristics, and browsing behaviour. The full detail of:

• the lawful bases on which we rely for that personal data processing;
• your data-subject rights (access, rectification, erasure, restriction, portability, objection);
• how long we retain personal data; and
• the mechanisms we use for transfers of personal data to the United States

is set out in our Privacy Policy. This Cookie Policy does not restate that detail.

If you have a concern about how we use cookies, please contact us in the first instance at info@waivern.com and we will do our best to resolve it promptly. Most concerns can be resolved quickly through direct contact, and this should be your first step.

If you remain dissatisfied after contacting us, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection and electronic privacy matters. Waivern Limited’s ICO registration reference is ZB920277.

• ICO website: ico.org.uk
• ICO helpline: 0303 123 1113
• ICO postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are based in the European Economic Area, you may also lodge a complaint with your local supervisory authority.

We will update this policy from time to time - for example, when we add or remove cookies, when the law changes, or following a rescan of the website. When we make material changes, we will update the “last reviewed” date at the top of this page and, where appropriate, display a notice on the website or re-present the Cookiebot banner for fresh consent.

We recommend you review this policy periodically. Earlier versions are available on request by contacting us at info@waivern.com.