1. Introduction

1.1
This Cookie Policy explains how Evolution Ltd (“Evolution”, “we”, “us”, “our”) uses cookies and similar tracking technologies on our:

• Website

• Web-based banking components

• In-app browser views (where applicable)

1.2
This Policy explains:

• What cookies are

• Which cookies we use

• Why we use them

• Your rights and choices

• How to manage cookie preferences

1.3
This Policy should be read together with our Privacy Policy, which explains how we process personal data.

2. What Are Cookies?

2.1
Cookies are small text files stored on your device when you visit a website or use an application.

2.2
Cookies can be:

• First-party cookies — placed by Evolution

• Third-party cookies — placed by service providers

• Session cookies — deleted when you close your browser

• Persistent cookies — remain until they expire or you delete them

2.3
Cookies may collect information such as:

• Device information

• Browser type

• Preferences

• Login status

• Usage behavior

• Analytics data

3. Why We Use Cookies

Evolution uses cookies for the following purposes:

3.1 Essential / Strictly Necessary Cookies

These cookies are required for:

• Website functionality

• Secure login

• Account authentication

• Fraud prevention

• Performance stability

Without them, core banking features cannot function.

These cookies do not require consent.

3.2 Performance & Analytics Cookies

Used to measure:

• How users interact with the website

• Navigation patterns

• Error diagnostics

• Load times

Examples: Google Analytics (configured in GDPR mode), internal analytics systems.

These cookies require your consent.

3.3 Functional Cookies

These enable enhanced features such as:

• Saving your preferences

• Remembering region or language selection

• Personalization of content

These cookies require consent.

3.4 Marketing & Advertising Cookies

Used only with explicit consent.

They enable:

• Personalized advertising

• Retargeting

• Marketing measurement

• Conversion tracking

Examples include cookies from:

• Google Ads

• Meta/Facebook

• TikTok

• LinkedIn

Evolution does not share banking or financial data with advertisers.

3.5 Security Cookies

Used to:

• Detect suspicious behavior

• Prevent unauthorized logins

• Protect against bots

• Enforce session protection

Some security cookies may be considered essential depending on their purpose.

4. Cookies We Use

Below is an example list (adjustable depending on your stack):

Actual implementation may vary depending on services you enable.

5. Legal Basis for Using Cookies

The legal bases for processing cookie-related data under GDPR are:

• Article 6(1)(f) — legitimate interest (essential cookies)

• Article 6(1)(a) — consent (analytics, functional, marketing cookies)

Evolution never places non-essential cookies without your explicit consent.

6. Cookie Consent Banner

6.1
When you visit our website for the first time, we will show a cookie consent banner.

6.2
You can choose to:

• Accept all cookies

• Reject all non-essential cookies

• Customize preferences by category

6.3
Your choices will be saved and can be changed at any time.

7. Managing Cookie Preferences

You may manage cookies through:

7.1 Our Cookie Settings Panel

Accessible via:

• Website footer

• Account settings

• Consent banner

You can update preferences anytime.

7.2 Browser Settings

You may block or delete cookies through your browser.

Popular browser links:

• Chrome: chrome://settings/cookies

• Firefox: about:preferences#privacy

• Safari: Preferences > Privacy

• Edge: edge://settings/content/cookies

Blocking essential cookies may prevent the website from functioning properly.

7.3 Third-Party Opt-Outs

Some marketing providers offer additional opt-out tools (e.g., Google Ads Settings).

8. Third-Party Cookies

We may use trusted third-party cookies to:

• Measure site performance

• Deliver targeted ads (with consent)

• Improve functionality

• Ensure security

Evolution does not allow third parties to access financial data via cookies.

9. Tracking Technologies Other Than Cookies

We may also use:

• Web beacons

• Pixels

• Local storage

• Device fingerprinting (for security only)

These tools have similar purposes and follow the same consent rules.

10. Data Retention for Cookies

Cookie-related data is retained:

• Only as long as necessary for its purpose

• In accordance with GDPR principles

• For no longer than 25 months (analytics default)

You may delete cookies at any time through browser settings.

11. Updates to This Cookie Policy

Evolution may modify this Policy if:

• Legal changes require updates

• We introduce new features

• We use additional cookie types

Material changes will be communicated via:

• The website

• Cookie banner

• Email (if applicable)

12. Contact Information

For questions about this Policy:

Evolution Ltd — Data Protection Officer (DPO)
Email: [DPO Email]
Address: [Registered Address]
Website: [domain]