Cookie Policy

1. Introduction

This Cookie Policy explains how AURNÉ Private Advisory ("AURNÉ", "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 AURNÉ
• 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

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

Common providers may include:

• Google Analytics
• Cloudflare Analytics
• Server-side logging tools

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 (IF APPLICABLE)

AURNÉ currently does not use targeted advertising cookies.

If we introduce them in the future, this policy will be updated, and consent will be required.

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

We do not use cookies to store financial data, sensitive personal information, or to track you across third-party websites.

5. Third-Party Cookies

We may use trusted third-party service providers that place cookies on our website. These may include:

• Analytics platforms
• Content delivery networks (CDNs)
• Cloud hosting environments
• Security and performance tools
• Embedded maps, videos, or forms

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.

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:

AURNÉ Private Advisory – Data Protection Office
Email: contact@aurne.org
Phone: +971 56 497 5840 (WhatsApp)
Phone: +971 56 615 8490 (WhatsApp)
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.