Cookie Policy

1. Terms and definitions

1.1. Policy — this cookie processing policy, describing the types of cookies processed by the Administration while users are on the Site, together with the purposes and conditions of their processing.

1.2. Site — the website sunrise-online.com, owned by the Administration.

1.3. User — any person who visits the Site.

1.4. Cookies — a small fragment of data stored on the User's device while browsing pages of the Site. Cookies make it possible to identify certain actions previously performed by the User on the Site.

1.5. IP address — the unique address of a device on the global computer network, by means of which information is transmitted and received.

2. Types of cookies, purposes and retention periods

2.1. Strictly necessary (technical) cookies. Critically required for the Site to work correctly. This type of cookie cannot be disabled without disrupting the normal functioning of the Site. The User's consent is not required for their processing. They are stored until the browser is closed or for the duration of the session.

2.2. Functional cookies. Store the settings chosen by the User — in particular the interface language — so that they need not be asked for on every visit. The User's consent is required for their processing. The retention period is up to 12 months.

2.3. Analytical cookies. Used to analyse the User's behaviour on the Site, including the pages visited, the time spent on them and traffic sources. Data collected: the type of action performed, date and time, page URL, Referer, IP address, User-Agent, browser identifier stored in a cookie, screen resolution. The User's consent is required for the processing of analytical cookies. The retention period is up to 24 months.

2.4. Marketing cookies. Used by advertising services to measure the results of advertising campaigns and to build an advertising profile of the User. Data collected: the fact and type of an action performed on the Site, date and time, page URL, Referer, IP address, User-Agent, advertising identifiers. The User's consent is required for the processing of marketing cookies. The retention period is up to 24 months.

3. Legal grounds for processing

3.1. Cookies are processed by automated means in accordance with the principles and rules laid down by the applicable personal data legislation, on the following grounds:

– technical (strictly necessary) cookies: for the conclusion and performance of a contract, and in pursuit of the Administration's legitimate interests;

– functional cookies: with the User's consent;

– analytical cookies: with the User's consent and for statistical purposes;

– marketing cookies: with the User's consent.

4. Transfer of data to third parties

4.1. Data on Users' behaviour on the Site is transferred to third-party analytics and advertising measurement services. The list of those services, together with their operators, the countries in which data is processed and the consent category under which each of them loads, is set out in section 10 of the Privacy Policy.

4.2. Until the corresponding consent has been given by the User, none of those services is loaded and no data is transferred to them. Strictly necessary (technical) cookies are processed without consent and are not transferred to third parties.

4.3. Where a third-party service is used, the data is also processed in accordance with that service's terms of use and privacy policy.

5. Managing cookies

5.1. On a first visit to the Site, the User is shown a banner requesting consent to the processing of cookies. The banner contains:

– an “Accept” button — the Administration becomes entitled to process all types of cookies, including functional, analytical and marketing ones;

– an “Only necessary” button — the Administration may process strictly necessary (technical) cookies only;

– a “Configure” section — the User may enable or disable functional, analytical and marketing cookies individually.

5.2. The User may change or withdraw consent previously given at any time through the “Cookie settings” entry at the foot of the Site. Withdrawal does not affect the lawfulness of processing carried out before it.

5.3. The User is entitled to manage cookies independently through browser settings. Blocking cookies may render individual components of the Site unavailable.

6. Security

6.1. To protect Users' cookies against unauthorised access, the Administration takes all necessary legal, organisational and technical measures in accordance with the requirements of applicable law.

6.2. Cross-border transfer of data, where it takes place, is carried out in compliance with the requirements of applicable law.

7. Final provisions

7.1. This Policy supplements the Privacy Policy published on the Site.

7.2. The current version of the Policy is permanently published on the Site together with its publication date. A new version takes effect from the date of its publication.

7.3. For any questions regarding the processing of cookies, including to withdraw consent, the User may write to invest@sunrise-online.com.