Cookie Policy

1. Introduction

This Cookie Policy explains how Aurne Private Advisory ("Aurne", "we", "us", "our") uses cookies and similar technologies on our website.

This Policy complies with:

• UAE Federal Decree-Law No. 45 of 2021 (PDPL)
• EU General Data Protection Regulation (GDPR) for EU/EEA visitors
• International best practices for transparency and digital privacy

By accessing or using our website, you agree to the use of cookies as outlined below.

2. What Are Cookies?

Cookies are small text files placed on your device when you visit a website.

They serve various functions, including enabling website functionality, improving user experience, and supporting analytics.

Cookies may be:

• Session cookies: expire when the browser closes
• Persistent cookies: remain until manually deleted
• First-party cookies: placed by Aurne
• Third-party cookies: placed by external services (e.g., analytics tools)

3. Types of Cookies We Use

3.1 Strictly Necessary Cookies

These cookies are essential for the operation of our website and cannot be disabled.

They include:

• Page navigation
• Secure session management
• Functionality required to load website features
• Cookie consent handling
• Cloudflare Turnstile, which protects our enquiry forms from automated abuse. It runs on our pages and assesses browser and interaction signals to tell a person from a bot. It does not identify you personally and is not used for advertising.

Legal basis: Legitimate Interest (GDPR Art. 6(1)(f)) / Essential Service Requirement

3.2 Performance & Analytics Cookies

Used to improve website functionality and user experience.

Examples include:

• Visitor counts
• Page usage statistics
• Browser/device types
• Interaction patterns

Providers we use:

• Google Analytics 4, loaded through Google Tag Manager (cookies _ga, _ga_<id>)
• Vercel, our hosting provider, for server-side request logging

Legal basis: Consent (GDPR Art. 6(1)(a))

Analytics cookies are not placed without explicit consent for EU/EEA visitors.

3.3 Functionality Cookies

These remember your preferences such as:

• Language selection
• Region
• Saved options

Legal basis: Legitimate Interest or Consent (depending on jurisdiction)

3.4 Marketing & Advertising Cookies

We run paid advertising campaigns and use advertising cookies to measure which adverts lead to an enquiry. These are set through Google Tag Manager.

Google Ads conversion tracking (conversion ID AW-18355804643):

• _gcl_au and _gcl_aw, set on aurne.org, store the Google click identifier so an enquiry can be attributed to the advert you clicked
• GCL_AW_P, set by google.com and googleadservices.com as third-party cookies
• The gclid parameter appended to our advert links is recorded with your enquiry

Meta (Facebook and Instagram) Pixel (pixel ID 2230694864453459), which sets the _fbp cookie and reports page views and completed enquiry forms to Meta.

Legal basis: Consent (GDPR Art. 6(1)(a)). These cookies are not placed for EU/EEA and UK visitors without consent.

See section 7 for the personal data shared with Google and Meta alongside these cookies, and our Privacy Policy for how to object.

4. How We Use Cookies

We use cookies to:

• Ensure the website functions securely and efficiently
• Improve user navigation
• Conduct anonymized analytics
• Detect and prevent security threats
• Enhance loading speed and performance
• Save user preferences
• Measure which adverts and campaigns lead to an enquiry
• Run A/B tests on page content, such as which headline is shown

We do not use cookies to store financial data or sensitive personal information. The Google Ads and Meta cookies described in section 3.4 are advertising cookies and are read by Google and Meta on their own services, so advertising measurement does extend beyond this website. Everything else is limited to aurne.org.

5. Third-Party Cookies

Trusted third-party providers place cookies on our website:

• Google (Tag Manager, Analytics 4, Google Ads) for analytics and advertising measurement
• Meta Platforms (Facebook, Instagram) for advertising measurement
• Vercel, our hosting and content delivery provider
• Cloudflare (Turnstile) for bot protection on our enquiry forms
• Embedded maps, videos, or forms, where present on a page

Each third-party provider must comply with:

• UAE PDPL
• GDPR (where applicable)
• Contractual data protection obligations

6. Managing Cookie Preferences

6.1 EU/EEA Visitors

In accordance with GDPR:

• Non-essential cookies require explicit consent
• Consent banners allow "Accept / Reject / Manage"
• Users may withdraw consent anytime

6.2 Browser Settings

You may disable cookies via browser settings (Chrome, Safari, Edge, Firefox).

However, disabling essential cookies may affect website functionality.

6.3 Device-Level Controls

Mobile devices and tablets may offer privacy controls to limit tracking.

7. Data Collected Through Cookies

Cookies may collect:

• Device information (browser, OS, screen size)
• IP address (may be anonymized)
• Usage statistics
• Page interactions
• Session identifiers

We do not collect:

• Passport data
• Financial data
• Legal documents
• UBO or corporate information
• Sensitive personal data

Such data is only collected through secure onboarding channels, not cookies.

7.1 Data shared with advertising providers

Separately from cookies, when you submit an enquiry form we share a hashed version of the email address and phone number you provided with Google and Meta. This is used only to confirm that an enquiry came from an advert we paid for.

• The values are irreversibly hashed (SHA-256) in your browser before transmission. We do not send Google or Meta your email address or phone number in readable form.
• Google refers to this as Enhanced Conversions; Meta refers to it as Advanced Matching.
• It is used for conversion measurement, not to build a profile of you for us.

Legal basis: Consent (GDPR Art. 6(1)(a)). You can object at any time using the contact details in our Privacy Policy.

8. Retention of Cookie Data

Cookie data is stored only as long as necessary:

• Session cookies: removed when browser closes
• Persistent cookies: retained per cookie duration settings
• Analytics data: anonymized and retained for performance analysis

We follow data minimization principles under PDPL and GDPR.

9. Changes to This Cookie Policy

We may update this Cookie Policy to reflect:

• Regulatory changes
• Website updates
• Technology changes
• Data protection requirements

The revised version will include a new "Last Updated" date.

10. Contact Information

For questions about cookie usage or privacy:

Aurne Private Advisory – Data Protection Office
Email: contact@aurne.org
Phone: +971 56 615 8490 (WhatsApp)
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.