Cookie Policy & Tracking Technologies

01. Introduction & Corporate Identity

This Cookie Policy ("Policy") explains how KHODSHIMA SUMN ASSIST LTD ("Company", "we", "us", or "our"), a private limited company incorporated in England and Wales under company registration number 17435961, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX, uses cookies and similar tracking technologies on its website (khodshimasumnassistltd.com).

This Policy is issued in accordance with the UK Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and the Privacy and Electronic Communications Regulations 2003 (PECR). PECR requires organisations to provide clear information about cookies and, in most cases, to obtain user consent before storing or accessing cookies on a device.

02. What Are Cookies

Cookies are small text files placed on your device (computer, tablet, or mobile) by a website when you visit it. They allow the website to recognise your device and remember information about your visit, such as preferences, session state, and authentication tokens. Cookies are widely used to make websites function efficiently and to provide reporting and security information.

The Company uses cookies and similar technologies including session tokens, local storage, and security headers. This Policy covers all such technologies collectively referred to as "cookies".

03. Categories of Cookies We Use

The Company deploys only strictly necessary technical cookies. We do not use behavioural advertising cookies, marketing trackers, social media plugins, or third-party analytics cookies that require consent under PECR Regulation 6.

04. Cookies We Do Not Use

The Company is committed to a minimal-data, privacy-first approach. We explicitly confirm that we do not deploy:

• Behavioural Advertising Cookies: No Google Ads, Meta Pixel, or retargeting cookies;
• Third-Party Analytics: No Google Analytics, Hotjar, Mixpanel, or similar tracking platforms that profile user behaviour across sessions;
• Social Media Plugins: No Facebook, Twitter/X, LinkedIn, or other social embedding trackers;
• Cross-Site Tracking: No cookies that track your activity across other websites;
• Fingerprinting: No device fingerprinting or canvas fingerprinting techniques for advertising purposes.

05. Legal Basis for Cookie Use (UK GDPR & PECR)

Under PECR Regulation 6, cookies require informed consent unless they are strictly necessary for the service requested by the user. All cookies deployed by the Company fall within the strictly necessary exemption (PECR Reg. 6(4)(a)), meaning:

• They are essential for the website to function (e.g., session management, security);
• They enable the checkout and payment process to operate;
• They protect the website and its users from fraud, abuse, and automated attacks;
• Without them, the requested service (browsing, purchasing, payment) could not be provided.

The corresponding lawful basis under UK GDPR Article 6 is legitimate interests (Art. 6(1)(f)) — protecting our digital infrastructure from malicious attacks, preventing fraud, and ensuring operational stability — balanced against your fundamental privacy rights. For payment processing cookies, the lawful basis is contractual performance (Art. 6(1)(b)).

06. Third-Party Cookies & Payment Processors

When you proceed to checkout, you interact with our payment service providers — Stripe Payments Europe Ltd / Stripe Payments UK and Airwallex (UK) Limited. These providers may set their own strictly necessary cookies on their payment pages to process your transaction securely. These cookies are governed by the respective providers' cookie and privacy policies:

• Stripe: stripe.com/cookies & stripe.com/privacy
• Airwallex: airwallex.com/privacy

The Company does not control these third-party cookies. They are necessary for the payment service you have requested and are exempt from consent requirements under PECR.

07. Managing & Deleting Cookies

Since all cookies used by the Company are strictly necessary and exempt from consent requirements, there is no consent toggle to withdraw. However, you may still manage or delete cookies at any time through your browser settings:

• Chrome: Settings → Privacy and security → Cookies and other site data;
• Firefox: Settings → Privacy & Security → Cookies and Site Data;
• Safari: Preferences → Privacy → Cookies and website data;
• Edge: Settings → Cookies and site permissions → Cookies and site data.

Please note that deleting strictly necessary cookies may affect website functionality, including session continuity, security verification, and the ability to complete purchases.

08. Data Retention & Cross-Reference

Cookie data is retained in accordance with the retention schedule in our Privacy Policy. Security and web access logs (which may include cookie-related identifiers) are retained for 90 days for threat mitigation and forensic analysis, then rotated and deleted. Session cookies are deleted automatically when you close your browser.

09. Policy Amendments & Updates

The Company may update this Cookie Policy to reflect changes in technology, legal requirements, or business practices. Any changes will be published on this page with an updated revision date. As we do not use consent-based cookies, no re-consent mechanism is required.