Purpose and application

1.1 This Cookies & Storage Technologies Policy explains how SULTRAFIED uses or may use technologies that store information on, or access information from, a user’s device.

1.2 It applies to sultrafied.com and SULTRAFIED services where this Policy is displayed or incorporated.

1.3 References in this Policy to “cookies” do not mean that the rules apply only to traditional browser cookies.

1.4 Depending on the technology used, the same legal framework may also apply to local storage, pixels, scripts, tags, device identifiers, fingerprinting techniques and other storage or access technologies.

1.5 This Policy should be read alongside applicable SULTRAFIED privacy and data-protection information.

What are cookies and similar technologies?

2.1 A cookie is a small piece of information that a website or related service may place on or read from a browser or device.

2.2 Other technologies can perform similar functions without using a traditional cookie.

2.3 These technologies can be temporary and disappear after a browser session, or remain for a defined period.

2.4 Some are controlled directly by SULTRAFIED and others may be supplied by an independent service provider.

The legal framework

3.1 UK rules concerning storage and access technologies are principally contained in the Privacy and Electronic Communications Regulations commonly referred to as PECR.

3.2 Where use of a technology also involves personal data, applicable data-protection law may apply in addition to PECR.

3.3 As a general rule, information must not be stored on or accessed from a user’s device unless:

3.4 Whether an exception applies depends on the real purpose and operation of the technology.

3.5 SULTRAFIED does not treat a technology as exempt merely because it has been labelled “necessary” by a supplier.

Strictly necessary technologies

4.1 Some technologies may be essential to provide a service or functionality that you request.

4.2 Depending on the circumstances, these may support:

4.3 A technology is not strictly necessary merely because it is useful to SULTRAFIED, commercially beneficial or convenient.

4.4 Where a technology is relied upon as strictly necessary, it should not be reused for unrelated advertising or tracking purposes.

Preference technologies

5.1 SULTRAFIED may use technologies to remember or recognise choices affecting how the Service appears or operates for you.

5.2 Examples may include:

5.3 Depending on the precise technology and applicable law, consent may be required.

5.4 In circumstances where the statutory appearance or functionality exception is lawfully relied upon, SULTRAFIED must satisfy the conditions of that exception, including applicable transparency and objection requirements.

5.5 The exception does not permit behavioural advertising or unrelated profiling merely because the resulting advert or Content changes what a user sees.

Analytics and statistical technologies

6.1 SULTRAFIED may wish to measure use of the Service to understand performance and identify improvements.

6.2 Examples may include measuring:

6.3 Some statistical technologies may fall within the statutory statistical-purpose exception where the strict legal conditions are met.

6.4 That exception is not a general exemption for every analytics product.

6.5 In particular, analytics used to identify, track, profile or make decisions about individual users, advertising audiences or categories of people may fall outside that exception and require consent.

6.6 Where SULTRAFIED relies on the statistical-purpose exception, the relevant technology must satisfy the applicable restrictions and users must be provided with the legally required information and simple means of objecting.

Marketing and advertising technologies

7.1 Marketing technologies may be used only where SULTRAFIED enables such functionality and the applicable legal requirements are satisfied.

7.2 Such purposes could include:

7.3 Advertising-related storage or access should not be treated as strictly necessary merely because advertising supports SULTRAFIED commercially.

7.4 Where consent is required, relevant advertising technology should remain disabled until valid consent has been obtained.

7.5 Rejecting marketing technologies should not prevent access to ordinary SULTRAFIED functionality that does not depend on them.

Service providers and third-party technologies

8.1 Certain parts of SULTRAFIED may depend on specialist service providers.

8.2 Depending on the functionality actually enabled, these may include providers involved in:

8.3 A provider may set or access technology directly where technically necessary for its service.

8.4 SULTRAFIED must consider the technology’s actual purpose and the respective roles of SULTRAFIED and the provider.

8.5 Third-party technologies are not automatically exempt merely because the third party provides an important service.

8.6 Where consent is required, relevant third-party technology should not be activated before the required choice has been made.

Managing your cookie choices

9.1 Where SULTRAFIED uses technologies requiring consent, the cookie banner or privacy settings control should allow you to make an appropriate choice before those technologies are activated.

9.2 Depending on the technologies enabled, available options may include:

9.3 It should be as straightforward to reject optional technologies as it is to accept them where the law requires consent.

9.4 Continuing to browse, scrolling or simply ignoring the banner is not treated as affirmative consent where valid consent is required.

9.5 You can also use browser or device controls, although those controls may operate differently from SULTRAFIED’s own consent mechanism.

Withdrawal of consent and objections

10.1 Where processing depends on your consent, you may withdraw that consent through the available cookie or privacy settings.

10.2 Withdrawal applies prospectively and does not make earlier processing carried out lawfully before withdrawal automatically unlawful.

10.3 Where SULTRAFIED relies on a statutory exception that requires a simple means of objecting, the relevant objection mechanism should be made available as required.

10.4 SULTRAFIED should not respond to withdrawal of valid cookie consent by attempting retrospectively to relabel the same non-exempt technology as being based on legitimate interests.

Blocking or deleting technologies

11.1 Most browsers provide controls allowing users to delete or restrict cookies and certain forms of website storage.

11.2 Browser controls may not prevent every type of technology covered by this Policy.

11.3 Blocking technologies that are essential to a requested service may affect functionality including:

11.4 Rejecting optional marketing or non-essential tracking should not itself prevent ordinary features that do not depend on that tracking.

Local storage and session storage

12.1 Websites and applications can store information in browser-based storage mechanisms other than traditional cookies.

12.2 These may include local storage and session storage.

12.3 SULTRAFIED applies applicable storage/access rules according to the technology’s actual operation and purpose rather than assuming that non-cookie storage falls outside privacy law.

12.4 Such storage may be used only for purposes consistent with the information and choices provided to users.

Other storage and access techniques

13.1 Technologies such as pixels, scripts, tags and device-fingerprinting techniques may be capable of collecting or accessing information about a device or browser.

13.2 Such technologies are not outside the rules merely because no traditional cookie file is created.

13.3 Device fingerprinting used for advertising, behavioural tracking or cross-service profiling should not be treated as strictly necessary.

13.4 Security-related device information may be treated differently where its use genuinely falls within an applicable statutory exception.

Technologies used by important SULTRAFIED functions

14.1 Certain SULTRAFIED functions may involve specialist security, verification, age-assurance or payment systems.

14.2 A provider may use technology to support the specific service the Member has requested.

14.3 Whether consent is required depends on the purpose and circumstances rather than the provider’s business category.

14.4 Technology genuinely essential for authentication, transaction security, requested verification or fraud prevention may be capable of operating under an applicable exception.

14.5 The same provider must not automatically use an exempt interaction for unrelated advertising, profiling or cross-site tracking without the appropriate legal basis and consent where required.

Logged-in Members and account identifiers

15.1 When a Member logs in, SULTRAFIED may need to use session or Account-related identifiers to recognise the authenticated Member.

15.2 This allows the Service to provide Member-specific functionality without requiring a fresh login on every page.

15.3 Account and authentication identifiers may constitute personal data.

15.4 They must therefore be processed consistently with applicable data-protection requirements in addition to any applicable PECR exception.

Session and persistent technologies

16.1 Technologies may operate for different periods depending on their purpose.

16.2 SULTRAFIED should configure durations so they are proportionate to the stated purpose.

16.3 The current duration of each technology should be available through the live Cookie Settings inventory where that technology is used.

Current cookie and technology inventory

17.1 The exact technologies used by an online service can change when infrastructure, verification, payment, analytics or other suppliers are added, removed or updated.

17.2 SULTRAFIED’s live Cookie Settings or consent management interface should form part of the information provided under this Policy and identify, where applicable:

When technology information is personal data

18.1 Storage and access information may constitute personal data where it relates to an identified or identifiable person.

18.2 Depending on the context, this may include:

18.3 Where personal data is processed, SULTRAFIED must also satisfy applicable data-protection requirements concerning transparency, lawful processing, security, minimisation and retention.

SULTRAFIED operates in a particularly privacy-sensitive context

19.1 SULTRAFIED is an adult community and information about a person’s use of the Service may be sensitive in context.

19.2 SULTRAFIED should therefore take particular care before using technologies capable of creating advertising profiles, tracking people across unrelated services or revealing sensitive associations.

19.3 Sensitive Member information should not be treated as ordinary advertising data merely because technology makes such use technically possible.

19.4 Additional information concerning sensitive personal information is available in the Privacy / Special Category & Biometric Data Policy .

Users outside the United Kingdom

20.1 SULTRAFIED may be accessed from jurisdictions that have their own requirements concerning cookies, tracking and similar technologies.

20.2 Where mandatory local law gives a user additional rights or requires a different consent mechanism, those requirements apply to the extent legally required.

20.3 SULTRAFIED may adapt consent choices or technology availability by jurisdiction where necessary for compliance.

Changes to this Policy

21.1 SULTRAFIED may update this Policy to reflect:

21.2 The current version and last-updated date should be displayed on this page.

21.3 Where a change requires fresh consent, SULTRAFIED should obtain that consent before using the affected non-exempt technology where required.