Cookie Policy

FIDUCIARY GROUP LIMITED

Last updated: June 2022

 

As described in our Privacy Policy, For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally.

This Cookie Policy sets out some further detail on how and why we use these technologies on our website. The term "Fiduciary Group", means Fiduciary Management Limited (a company incorporated in Gibraltar with company number 6507 and which is licensed and regulated by the Gibraltar Financial Services Commission), its successors, assigns and transferees, as well as its subsidiaries and its associated companies including, but not limited to, Fiduciary Trust Limited, Fiduciary Directors Limited, and Fiduciary Nominees Limited. References in this Cookie Policy to “we”, “us” and “our” shall be construed as references to Fiduciary Group. The terms “you” and “your” includes our clients, business partners and users of this website. By using our website, you consent to storage and access to cookies and other technologies on your device, in accordance with this Cookie Policy.

Our website has been designed so you can browse without providing personal data, but there may be sections of our website where you can choose to provide this. We ask that you please read our Privacy Policy before providing us with any information about you or any other person. If you do not accept these policies, you should immediately discontinue your use of our website.

To access this Cookie Policy online please visit: https://www.fiduciarygroup.com/cookie-policy.  

Terms defined in our Privacy Policy shall have the same meaning when used in this Cookie Policy, unless defined here.

 

What are cookies?

Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.

 

What are the different types of cookies?

A cookie can be classified by its lifespan and the domain to which it belongs.

By lifespan, a cookie fall into types of classification:

  • session cookiesallow websites to keep track of user movements from page to page. It is a way of linking the actions of a user during a browser session in order to enhance and speed up the experience. Session cookies are used, for example, to remember what a user has put in his shopping basket. They expire and are erased after a browser session ends and, for this reason, are not regarded as being as privacy intrusive as persistent cookies; or

  • persistent cookie are saved to the hard drive/storage device and remains on the user's computer or mobile device for a pre-defined period of time. They are designed to allow websites to remember user information and settings for when they visit again (e.g. user name and password, language selection, menu preferences). This speeds up access to the website (e.g. since users do not have to select their preferences or log in every time) and enhances the user experience. Persistent cookies are more privacy intrusive than session cookies since they do not expire at the end of a browser session.

As for the domain to which it belongs, cookies are either:

  • first-party cookieswhich are set by the web server of the visited page and share the same domain (i.e. set by us); or

  • third-party cookiesstored by a different domain to the visited page's domain.

 

What cookies do we use and why?

We list all the cookies we use on this website in the APPENDIX below. They include cookies set by Fiduciary Group via our web developers (first-party cookies), and those set by others (third-party cookies). We use session and persistent cookies on our website.

The legal bases we rely on for our use of cookies are:

  • our legitimate business interests: namely monitoring and improving our website and the proper protection of our business against risks, with respect to all cookies we use; and
  • your consent when agreeing to accept cookies that are not strictly necessary.

Cookies are also sometimes classified by reference to their purpose or functionality. We use the following cookies for the following purposes:

  • Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow us to comply with legal obligations. These cookies also help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Many types of session cookies will fall into this category.

  • Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it, as well as dates and times they visit. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. 
  • Functionality cookies, also referred to as preference cookies: These cookies enable our website to remember information that changes the way the website behaves or looks. They are used to recognise you when you return to our website, and may enable us to personalise our content for you, greet you by name and remember your preferences, choice of language or region for example. 
  • Targeting cookies, also referred to as statistic cookies: These help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. These cookies record your visit to our website, the pages you have visited and the links you have followed, as well as time spent on our website, and the websites visited just before and just after our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We may also share this information with third parties for this purpose. Statistic cookies may also:
  • (i) Register the date and time for the user's latest visit to the website
  • (ii) Log internet address linking to our website
  • (iii) Send data to third parties (e.g. Google Analytics(see below)) about the visitor's device and behaviour
  • (iv) Tracks the visitor across devices and marketing channels
  • (v) Registers statistical data on visitors' behaviour on the website for internal analytics by the website operator (e.g. time spent on each page, links clicked,
  • (vi) Assign unique ID that identifies the user on recurring visits (usually anonymising or pseudonymising Personal Data)
  • (vii) Record website traffic from a particular region/area
  • (viii) Log type of operating system, browser type, mobile network information, and Internet Protocol (IP) address (usually masking the last digits so you cannot be identified)
  • Security cookies: These are used to authenticate users, prevent fraudulent use of login credentials and protect user data from unauthorised parties. For example, Google LLC (“Google”) uses cookies called ‘SID’ and ‘HSID’ which contain digitally signed and encrypted records of a user’s Google account ID and most recent sign-in time. The combination of these two cookies allows it to block many types of attack, such as attempts to steal the content of forms that users complete on web pages. Such cookies ensure the long-term viability of our information technology systems and website technology, and provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
  • Marketing cookies: These are used to track visitors across websites; they overlap with targeting cookies and statistic cookies noted above. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. Marketing cookies may

Where cookies do not fall into a particular categorisation above, they may be labelled “unclassified” or “pending” whilst the website owner confirms the functionality with the provider of the individual cookie.

In general, we use cookies and other technologies (such as web server logs) on our website to enhance your experience and to collect information about how our website is used. This information is put together (‘aggregated’) and provides general and not individually specific information. None of this information is therefore associated with you as an individual and the cookie-related information is not used to identify you personally. It is therefore anonymised and ‘de-identified’. The pattern data is fully under our control and these cookies are not used for any purpose other than those described here.

We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. The information also helps us to understand which parts of this website are most popular and generally to assess user behaviour and characteristics to measure interest in and use of the various areas of our website. This then allows us to improve our website and the way we market our business.

This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website's capacity, efficiency and security.

We use strictly necessary and security cookies to make our site work. We would also like to set analytical, preference, statistics and marketing cookies to help us improve it. Our site will not set optional cookies unless you enable them, using a tool that will set a cookie on your computer / mobile device to remember your preferences.

 

Other Technologies

We may allow others to provide analytics services and serve advertisements on our behalf. In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services.

Pixels tags: Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails, and this information helps us and our partners provide you with a more tailored experience.

Device Identifiers: A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.

Browser web storage: This enables websites to store data in a browser on a device. This makes data retrievable even after a browser has been closed and re-opened.

Application data cache: This is a data repository on a device. It can, for example, enable a web application to run without an Internet connection and improve the performance of the application by enabling faster loading of content. 

Server logs: These are pieces of code stored on web servers that automatically record the page requests made when you visit a website. They typically include your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.

 

What data are collected by cookies and other technologies on our website?

This information may include:

  • the IP and logical address of the server you are using (but the last digits are anonymised so we cannot identify you).
  • the top level domain name from which you access the internet (for example .ie, .com, etc)
  • the type of browser you are using,
  • the date and time you access our website
  • the internet address linking to our website.

This website also uses cookies to:

  • remember you and your actions while navigating between pages;
  • remember if you have agreed (or not) to our use of cookies on our website;
  • ensure the security of the website;
  • monitor and improve the performance of servers hosting the site;
  • distinguish users and sessions;
  • Improving the speed of the site when you access content repeatedly;
  • determine new sessions and visits;
  • show the traffic source or campaign that explains how you may have reached our website; and
  • allow us to store any customisation preferences where our website allows this

We may also use other services, such as Google Analytics (described below) or other third-party cookies, to assist with analysing performance on our website. As part of providing these services, these service providers may use cookies and the technologies described below to collect and store information about your device, such as time of visit, pages visited, time spent on each page of our website, links clicked and conversion information, IP address, browser, mobile network information, and type of operating system used.

Third party advertisers: We may work with advertisers, and advertising service providers to serve ads that may be relevant to you based on your inferred interests, location or other information collected about you, which may use a cookie or the technologies described below, placed by us or the third party (although we would not share any other information that identifies you with an advertiser) on our website, or on a third party website or online service. The placing of these technologies on your device may enable you to be identified across multiple websites and online services.

 

Google Analytics Cookies

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google").

We use Google Analytics to track your preferences and also to identify popular sections of our website. Use of Google Analytics in this way, enables us to adapt the content of our website more specifically to your needs and thereby improve what we can offer to you.

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

In particular Google Analytics tells us

  • your IP address (last 3 digits are masked);
  • the number of pages visited;
  • the time and duration of the visit;
  • your location;
  • the website you came from (if any);
  • the type of hardware you use (i.e. whether you are browsing from a desktop or a mobile device);
  • the software used (type of browser);
  • your general interaction with our website; and
  • your search history (if you decide to use the search bar at the top of our page).

As stated above, cookie-related information is not used to identify you personally, and what is compiled is only aggregate data that tells us, for example, what countries we are most popular in, but not that you live in a particular country or your precise location when you visited our website (this is because we have only half the information-  we know the country the person is browsing from, but not the name of person who is browsing). In such an example Google will analyse the number of users for us, but the relevant cookies do not reveal their identities.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google Analytics, its purpose and function is further explained on the Google Analytics website.

 

For more information about Google Analytics cookies, please see Google's help pages and privacy policy: Google's Privacy Policy and Google Analytics Help pages. For further information about the use of these cookies by Google click here.

 

What if you don’t agree to us monitoring your use of our website (even though we don’t collect your personal data)?

We can store cookies on your device if they are strictly necessary for the operation of this site (i.e. strictly necessary cookies described above). For all other types of cookies, we need your permission (consent).

Enabling these cookies is not strictly necessary for our website to work but it will provide you with a better browsing experience. You can delete or block the cookies we set, but if you do that, some features of this website may not work as intended.

Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies and control and/or delete cookies as you wish – for details, see https://www.aboutcookies.org. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed. You should be aware that if you do this, you may have to manually adjust some preferences every time you visit an internet site and some services and functionalities may not work if you do not accept the cookies they send.

You can amend most web browser / device settings in order to:

  • delete all cookies;
  • block all cookies;
  • allow all cookies;
  • block third-party cookies;
  • clear all cookies when you close the browser;
  • open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the web without recording your browsing history or storing local data such as cookies (you should however be aware of the limitations of this feature in a privacy context); and
  • install add-ons and plugins that extend browser functionality.

Since each browser is different, you will need to refer to the guidance documentation for your preferred web browsing platforms in order to control such settings. If you have any further questions regarding disabling cookies you should consult with your preferred browser’s provider or manufacturer.

To opt out of being tracked by Google Analytics across all websites, Google have developed the Google Analytics opt-out browser add-on. If you would like to opt out of Google Analytics, you have the option of downloading and installing this browser add-on which can be found under the link: http://tools.google.com/dlpage/gaoptout.

Additionally, you can at any time change or withdraw your consent in respect of this website from the cookie declaration on our website. If you have any issues with removing your consent please contact us on the details provided in our Privacy Policy. It may be necessary to refresh the page for the updated settings to take effect.

In order to implement your objection, it may be necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. It is important to note, that for technical reasons, the opt-out cookie will only affect the browser from which you actively object from. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.

Advertisers and business partners that you access on or through our website may also send you cookies. We do not control any cookies outside of our website.


Revisions to this Cookie Policy

On our website https://www.fiduciarygroup.com/, you can always view the latest version of our Privacy Policy and our Cookie Policy. We may modify this Cookie Policy from time to time. If we make changes to this Cookie Policy, we will provide notice of such changes, such as by sending an email notification, providing notice through our website or updating the ‘Last updated’ date at the beginning of this Cookie Policy. The amended Cookie Policy will be effective immediately after the date it is posted. By continuing to access or use our website after the effective date, you confirm your acceptance of the revised Cookie Policy and all of the terms incorporated therein by reference. We encourage you to review our Privacy Policy and our Cookie Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Privacy Policy and/or Cookie Policy, you may not access or use this website. If you are an existing client and do not agree to the revised Privacy Policy and/or Cookie Policy, your only option will be to terminate your engagement with us under the applicable terms and conditions of our terms of business. Please contact us on the details found in our Privacy Policy should you wish to enforce any of your rights.

If you do not accept changes which are made to this Cookie Policy, or take any measures described above to opt-out by removing or rejecting cookies, you may continue to use this website but accept that it may not display and/or function as intended by us. Any social media channels connected to Fiduciary Group and third party applications will be subject to the privacy and cookie policies and practices of the relevant platform providers which, unless otherwise indicated, are not affiliated or associated with Fiduciary Group. Your exercise of any rights to opt-out may also impact how our information and content is displayed and/or accessible to you on this website and on other websites.

 

© FIDUCIARY GROUP. All rights reserved.

 

 

APPENDIX

Table: Overview of cookies placed and the consequences if the cookies are not placed

 

Which company places the cookie

(i.e. who controls/ accesses the cookie‑related information)

Name of cookie

Purpose(s) of cookie

Storage period  of cookie

Consequences if cookie is not accepted

Website

(Fiduciary Group)

CAKEPHP

Remember visitor's actions while navigating between pages

During user session

User's actions won't be available for next visited page

Website

(Fiduciary Group)

cookiesDirective

Remember user's acknowledgement of cookie policy

1 year from set/update

Cookie message will display on website

Website Hosting provider

DYNSRV

Improve server performance

During user session

Server performance will need to be determined through other means

Google Analytics (Google)

__utma

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

User activity won't be tracked

Google Analytics (Google)

__utmt

Used to throttle request rate.

10 minutes

User activity won't be tracked

Google Analytics (Google)

__utmb

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

User activity won't be tracked

Google Analytics (Google)

__utmc

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

End of browser session

User activity won't be tracked

Google Analytics (Google)

__utmz

Stores the traffic source or campaign that explains how the user reached the website. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update

User activity won't be tracked

Google Analytics (Google)

__utmv

Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

 

User activity won't be tracked