URL: https://bhavpro.com/privacy-cookies/
Policy owner: Sentiora Consulting Ltd trading as BhavPro
Version: 1.0
Effective date: 1 September 2026
Last reviewed: 1 September 2026

1. About This Policy

This Cookies, Tracking & Advertising Technologies Policy explains how Sentiora Consulting Ltd trading as BhavPro (“BhavPro”, “we”, “us” or “our”) uses cookies and other technologies that store information on, or access information from, a user’s device.

This Policy applies when you use:

• https://bhavpro.com/;

• BhavPro landing pages;

• BhavPro forms and assessment tools;

• customer, company or partner portal pages where applicable;

• advertising campaign destinations operated by BhavPro; and

• other websites or digital services that expressly link to this Policy.

This Policy covers more than traditional browser cookies. It also addresses technologies such as:

• pixels;

• tags;

• local storage;

• session storage;

• software development kits;

• browser or device identifiers;

• conversion tags;

• advertising tags;

• tracking pixels;

• embedded content technologies;

• email tracking technologies;

• scripts that read or write information on a device; and

• similar storage and access technologies.

In this Policy, we refer to these collectively as “Storage and Access Technologies” or “SATs”.

This Policy should be read together with our:

• Privacy Policy;

• Terms and Conditions;

• Refund & Cancellation Policy; and

• Disclaimer.

Our Privacy Policy explains how we process personal data more generally. This Policy focuses specifically on information stored on or accessed from devices and related tracking, analytics, advertising and measurement activity.

2. Who We Are

The organisation responsible for the BhavPro website and the choices described in this Policy is:

Sentiora Consulting Ltd trading as BhavPro
Company number: 16596409
Registered in: England and Wales
Registered office: 45 Marston Road, Leicester, United Kingdom, LE4 9FE
Website: https://bhavpro.com/
Email: hello@bhavpro.com
Contact page: https://bhavpro.com/contact/

BhavPro is a trading name of Sentiora Consulting Ltd.

For questions about cookies, tracking, advertising technologies or privacy choices, email hello@bhavpro.com and include “Cookies & Privacy” in the subject line.

3. Legal Framework

Our use of Storage and Access Technologies is governed principally by:

• the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”), as amended;

• the UK General Data Protection Regulation (“UK GDPR”);

• the Data Protection Act 2018; and

• relevant changes introduced by the Data (Use and Access) Act 2025.

The rules apply whether or not the information stored or accessed is itself personal data.

Where the resulting information is personal data, UK data-protection law also applies to our subsequent processing.

4. What Is a Cookie?

A cookie is a small piece of information placed on or read from a browser or device when a website or digital service is used.

Cookies can perform different functions, for example:

• maintaining a secure session;

• remembering a requested preference;

• keeping a user signed in;

• preventing fraud;

• remembering cookie choices;

• measuring website usage;

• attributing a conversion to an advertising campaign;

• building an advertising audience; or

• personalising advertising.

Cookies may be:

Session cookies

These generally expire when the browser session ends.

Persistent cookies

These remain for a defined period or until deleted.

First-party cookies

These are set in the context of the BhavPro domain.

Third-party cookies

These may be set or accessed by another organisation whose technology is present on a BhavPro page, subject to our consent controls and that provider’s technical implementation.

A technology does not have to be called a “cookie” for PECR rules to apply.

5. Other Storage and Access Technologies

BhavPro may use or permit other technologies that perform functions similar to cookies.

These can include:

Local and session storage

Browser storage that can retain settings, identifiers or other information.

Pixels and web beacons

Small technical elements that can signal that a page, message or other content has been loaded or interacted with.

JavaScript tags

Scripts used for analytics, advertising, conversion measurement, security or functionality.

Advertising conversion tags

Technologies used to determine whether a visit, form submission, order or other event followed an advertisement.

Device or browser identifiers

Identifiers that may be used for security, session management, analytics or advertising depending on the context.

Embedded content technologies

External video, map, social-media, booking, chat or other embedded services can store or access information when activated.

Email pixels and tracked links

Marketing email technologies can in some cases signal that an email has been opened or a link has been clicked.

Server-assisted advertising measurement

Some advertising platforms support server-to-server conversion APIs. A server-side implementation does not automatically remove privacy or consent obligations. If a server-side advertising event depends on information obtained from a user’s device or is used for advertising profiling, matching or measurement, we assess the relevant PECR and UK GDPR requirements before using it.

6. Our Core Rule

BhavPro does not treat continued browsing, scrolling, closing a banner or using the website as consent to non-essential advertising or tracking technologies.

Where consent is required:

• the relevant technology should not be activated for that purpose before valid consent;

• consent must be based on a clear positive choice;

• refusing non-essential technologies must be a genuine option;

• withdrawing consent should be as straightforward as giving it;

• consent choices must not be bundled into acceptance of our Terms and Conditions;

• marketing email consent is separate from cookie consent; and

• payment or account access must not ordinarily depend on agreeing to advertising tracking.

Our default UK configuration is to block advertising and personalised tracking technologies until the relevant consent is granted, unless a specific technology has been separately reviewed and can lawfully operate without that consent for the exact purpose used.

7. Cookie and Technology Categories

BhavPro groups Storage and Access Technologies into the following categories.

8. Strictly Necessary Technologies

These technologies are used where necessary to:

• provide a service you expressly request;

• maintain essential website or portal operation;

• secure login and authentication;

• maintain a requested session;

• remember privacy choices;

• protect forms;

• provide checkout functionality;

• detect or prevent fraud or abuse;

• balance network traffic where necessary;

• maintain security; or

• perform another function that falls within an applicable PECR exception.

Examples may include technologies used for:

• authentication;

• security;

• anti-forgery protection;

• session continuity;

• fraud prevention;

• consent-preference storage;

• load balancing;

• checkout or basket continuity; and

• secure portal operation.

Where the statutory exception applies, these technologies do not require consent under PECR.

We still provide information about them where appropriate.

Disabling necessary technologies through browser settings may prevent parts of the website, checkout or portal from functioning correctly.

9. Communication Technologies

PECR contains an exception where storage or access is used solely for transmitting a communication over an electronic communications network and the communication cannot be carried out without it.

Where BhavPro relies on this exception, the technology is used only for the necessary communications function.

We do not use the communication exception to justify advertising tracking, profiling or unrelated analytics.

10. Statistical Technologies Used Under the Statistical-Purposes Exception

Following changes to PECR, certain limited technologies used solely to collect aggregate statistical information about how a website or online service is used may qualify for an exception from consent.

BhavPro may rely on this exception only where the requirements are satisfied.

Where we do so:

• the sole purpose must be statistical analysis of use of the BhavPro website or service;

• the purpose must be to improve that website or service;

• the information must be aggregated;

• the technology must not be used to identify, track or monitor people;

• individual-level information must not be retained beyond what is necessary for aggregation;

• information must not be used for advertising, personalised targeting or profiling;

• a third-party provider, if used, must be limited to assisting with that statistical/improvement purpose;

• we must provide clear information; and

• we must provide a simple and free way to object.

Examples of the type of aggregate statistics that may potentially fall within this exception include:

• total visits;

• pages viewed;

• average time on pages;

• aggregate scroll depth;

• aggregate device/browser types;

• page speed;

• bounce or exit statistics;

• aggregate user journeys; and

• aggregate information about how visitors reached our website.

The statistical exception is not used for:

• advertising conversion tracking;

• linking visitor IDs to purchases;

• remarketing;

• profiling;

• advertising audience creation;

• cross-site monitoring;

• individual session replay for analytics; or

• sending identifiable conversion activity to advertising partners.

Where analytics does not satisfy the exception, we seek consent where required.

11. Appearance and Preference Technologies

PECR also provides an exception in certain circumstances for technologies used solely to adapt the appearance or functionality of a service according to a user’s preference.

Where BhavPro relies on this exception:

• the purpose must fall within the applicable statutory conditions;

• the preference must relate to how the service appears or functions for the user;

• we must give clear information about the use; and

• we must provide a simple and free means of objecting.

Examples may include a user-requested presentation or interface preference where the conditions are met.

This exception is not used to justify behavioural advertising or unrelated profiling.

12. Analytics Technologies Requiring Consent

Some analytics technologies go beyond the statutory statistical-purpose exception.

Where an analytics tool:

• tracks identifiable or pseudonymous visitors over time;

• retains individual visitor identifiers;

• builds profiles;

• combines information across services;

• records individual browsing behaviour;

• connects a visitor to a conversion sent to an advertising platform; or

• is otherwise outside an applicable exception,

we obtain consent where required before using the technology for that purpose.

Analytics consent may be offered separately from advertising consent where the technologies and purposes are genuinely different.

13. Advertising and Targeting Technologies

Advertising technologies may be used to:

• attribute visits to advertising;

• measure advertising conversions;

• create or update advertising audiences;

• perform remarketing or retargeting;

• personalise advertising;

• optimise advertising delivery;

• limit or analyse advertising frequency;

• match website visitors to advertising-platform users; or

• understand campaign performance.

Storage and access technologies used for online advertising purposes require consent under our UK approach.

This applies to:

• ad selection and delivery technologies;

• conversion tags that store or access device information;

• advertising pixels;

• advertising cookies;

• retargeting;

• profiling;

• audience matching based on website activity; and

• advertising measurement involving storage/access technologies.

Advertising measurement does not become exempt merely because it is labelled “analytics”.

We therefore treat advertising technology as a distinct consent category.

14. Advertising Measurement

Advertising platforms can provide campaign measurement such as:

• advertisement clicks;

• visits;

• form submissions;

• calls;

• purchases;

• revenue events;

• subscription events;

• conversion value; and

• campaign attribution.

Where storage or access technologies are used for advertising measurement, we treat that use as part of the advertising purpose for consent management.

We do not rely on the statistical-purposes exception for advertising conversion tracking or advertising-partner conversion sharing.

15. Our Cookie/Tracking Preference Centre

Where available, BhavPro provides a Cookie/Tracking Preference Centre that lets you:

• accept available non-essential categories;

• reject non-essential categories;

• review categories;

• review vendors or technologies;

• change an earlier choice; and

• withdraw consent.

The preference centre should remain accessible after the first visit, for example through a Cookie Settings, Privacy Choices or similar link on the website.

Where a category is necessary and lawfully exempt from consent, it may remain active even when non-essential technologies are rejected.

Where we rely on the statistical-purposes or appearance exception, we provide the required simple means to object.

16. Accept and Reject Choices

Our consent interface is intended to provide a genuine choice.

Where consent is required:

• Accept must not be the only easy option;

• rejecting non-essential technologies should not require unnecessary additional effort;

• optional categories should not be pre-enabled in a way that manufactures consent;

• consent must not be inferred solely because you continue using the website; and

• the website should remain generally usable when advertising consent is refused, subject to functionality that genuinely depends on an optional third-party service.

We do not intentionally use a “take it or leave it” advertising cookie wall for ordinary access to BhavPro’s public website.

17. Changing or Withdrawing Your Choice

You can change your Storage and Access Technology choices through the BhavPro preference centre where available.

Withdrawing consent:

• does not make prior processing unlawful;

• should stop future activation of technologies dependent on that consent, subject to reasonable technical propagation time; and

• does not necessarily delete information lawfully collected before withdrawal.

You can also delete cookies or site data using your browser.

However, browser deletion alone may not communicate a marketing objection or privacy request to BhavPro, and it may remove the cookie used to remember your consent choice.

18. How Long Cookie Consent Lasts

PECR and UK GDPR do not set one universal expiry period for cookie consent.

BhavPro reviews whether consent should be refreshed based on factors including:

• the scope of the original choice;

• changes in technology or vendors;

• changes in purpose;

• changes in law or guidance;

• how frequently users interact with the service; and

• whether the original choice can still reasonably be treated as informed.

We may ask you to make a fresh choice if:

• material technologies are added;

• purposes materially change;

• our consent categories materially change;

• a significant period has elapsed; or

• legal or regulatory changes make fresh consent appropriate.

A user may change their choice at any time through the preference centre.

Advertising and Measurement Providers

19. Google Technologies

BhavPro may use Google technologies when enabled for a particular service or campaign.

These may include:

• Google Ads;

• Google tag;

• Google Ads conversion tracking;

• Google Analytics;

• Google Consent Mode;

• remarketing;

• enhanced conversions;

• audience features; and

• other Google measurement services.

Google technologies can be used for purposes such as:

• measuring visits;

• analysing website usage;

• measuring advertising conversions;

• attributing conversions;

• understanding campaign performance;

• remarketing;

• personalising advertising; and

• improving advertising effectiveness.

Google consent signals

Where relevant, Google Consent Mode supports consent states including:

• ad_storage — storage related to advertising;

• ad_user_data — sending user data to Google for advertising-related measurement;

• ad_personalization — personalised advertising; and

• analytics_storage — analytics-related storage.

BhavPro’s consent-management implementation should map a user’s choices to the appropriate signals.

Our default UK approach is that advertising functionality requiring consent should remain blocked or in a legally reviewed restricted state unless and until the user gives the relevant consent.

Google acts under its own privacy, advertising and product terms for information it receives.

Google Privacy Policy:
https://policies.google.com/privacy

Google technologies and their exact cookie names or durations can change. The live BhavPro preference centre or technology register should identify the active configuration.

20. Meta / Facebook / Instagram Technologies

BhavPro may use technologies and services supplied by Meta Platforms where enabled and consented to as required.

These may include:

• Meta Pixel;

• Meta advertising conversion events;

• Custom Audiences;

• retargeting;

• advertising measurement;

• Meta Lead Ads or lead-generation forms;

• Conversions API;

• campaign optimisation; and

• related Meta business tools.

Possible purposes include:

• understanding whether a Meta advertisement led to a BhavPro visit or conversion;

• creating audiences;

• retargeting visitors;

• optimising advertising;

• measuring campaign effectiveness; and

• connecting an advertising interaction with a subsequent enquiry or purchase.

Where a browser or device technology is used for these advertising purposes, it is controlled by our advertising-consent settings.

Where BhavPro sends conversion information through a server-side Meta integration, we assess the underlying source of the information, consent status, purpose, lawful basis and platform requirements. Moving an advertising event from the browser to a server does not automatically make the processing exempt from privacy rules.

Meta may process information under its own privacy and business-tool terms.

Meta Privacy Policy:
https://www.facebook.com/privacy/policy/

The exact technologies and identifiers used by Meta can change and should be reflected in our live vendor register when active.

21. Microsoft Advertising / Bing Technologies

BhavPro may use Microsoft Advertising, including Bing Ads, where enabled.

Microsoft advertising technologies can include:

• Universal Event Tracking (“UET”);

• conversion tracking;

• remarketing;

• audience creation;

• advertising measurement; and

• campaign attribution.

Microsoft UET Consent Mode

Microsoft UET supports an ad_storage consent state.

The platform distinguishes states such as:

• granted — advertising storage can operate according to the configured Microsoft implementation; and

• denied — storage is restricted in accordance with the provider’s consent-mode rules.

Microsoft offers different consent-mode implementations.

BhavPro’s default UK approach is to avoid activating advertising storage/access before the required consent. If a restricted or advanced consent mode is used, it must be separately assessed to ensure that our specific implementation remains consistent with UK requirements.

Microsoft Privacy Statement:
https://privacy.microsoft.com/en-gb/privacystatement

The exact UET identifiers and retention periods are governed by the active Microsoft configuration and should be shown in the live technology register.

22. LinkedIn Advertising Technologies

BhavPro may use LinkedIn advertising services where enabled and consented to as required.

These may include:

• LinkedIn Insight Tag;

• Website Actions;

• conversion tracking;

• retargeting;

• Matched Audiences;

• campaign attribution;

• aggregate professional demographic reporting;

• Lead Gen Forms; and

• enhanced matching where separately approved.

LinkedIn states that the Insight Tag can collect information concerning website visits, including:

• page URL;

• referrer;

• IP address;

• browser/device characteristics; and

• timestamp.

Enhanced matching can involve hashed email information where specifically enabled.

BhavPro does not intentionally deploy LinkedIn advertising tracking on a page where doing so would inappropriately transmit sensitive information.

LinkedIn Privacy Policy:
https://www.linkedin.com/legal/privacy-policy

The exact technologies, identifiers and durations depend on the active LinkedIn configuration and should be shown in the live technology register.

23. Other Advertising Platforms

BhavPro may in future use other approved advertising platforms.

Examples could include:

• other search advertising providers;

• social-media advertising providers;

• programmatic advertising platforms;

• professional or industry advertising networks; or

• emerging advertising services.

Before a materially new advertising provider is activated, BhavPro should assess:

1. purpose;

2. information collected;

3. storage/access technology;

4. consent requirements;

5. UK GDPR lawful basis;

6. provider privacy role;

7. international transfers;

8. retention;

9. audience and profiling behaviour;

10. contract/data-processing terms;

11. appropriate cookie-banner category; and

12. whether this Policy and the live vendor register require an update.

A new provider should not be silently activated merely because a marketing plugin or tag manager makes it technically possible.

Payments, Forms and Portal Technologies

24. Stripe and Payment Technologies

BhavPro may use Stripe for:

• payment processing;

• Checkout;

• subscriptions;

• payment authentication;

• fraud prevention;

• payment security;

• refunds; and

• payment-related risk controls.

Stripe-hosted or Stripe-powered payment pages may use cookies or similar technologies for security, fraud prevention, session continuity and payment functionality.

Some payment technologies can be strictly necessary to provide a payment service requested by the user or to maintain appropriate security. Others, if used for a separate advertising or analytics purpose, must be assessed according to that separate purpose.

BhavPro does not treat a payment cookie as advertising consent.

Stripe Privacy Center:
https://stripe.com/gb/privacy

If Stripe or another payment provider processes information on its own hosted domain, its own cookie and privacy arrangements may also apply to that interaction.

25. Website Forms

BhavPro forms may use essential technologies for:

• anti-spam protection;

• security;

• form session continuity;

• fraud prevention;

• duplicate-submission prevention;

• remembering a requested step in a multi-step form; and

• preserving information necessary to complete a requested transaction.

A form may also be associated with advertising conversion tracking.

Advertising conversion tags must not be treated as necessary merely because they are attached to a contact or purchase form.

The form should continue to function where reasonably possible even if advertising consent is refused.

26. Portal Authentication and Security

BhavPro portals may use necessary session and security technologies to:

• authenticate a user;

• maintain a secure session;

• remember authorised session state;

• enforce security controls;

• prevent cross-site request forgery;

• detect abuse;

• support multi-factor authentication; and

• protect account access.

Such technologies are separate from advertising consent.

Advertising technologies should not be introduced into authenticated portal areas merely for convenience. Any use in an authenticated area requires separate privacy and security review.

27. Consent Preference Storage

BhavPro may store information needed to remember:

• whether you responded to the consent interface;

• categories you accepted or rejected;

• applicable policy/consent version;

• date of choice; and

• technical preference information.

This technology is generally necessary to honour your privacy choice and avoid repeatedly asking for the same preference on every page.

Email Tracking

28. Marketing Email Tracking

Marketing emails may contain technologies that can record:

• delivery;

• bounce;

• complaint;

• unsubscribe;

• link click;

• and, where lawfully enabled, email open activity.

A traditional tracking pixel can involve storage or access to information on a recipient’s device and therefore requires assessment under PECR.

BhavPro’s default approach is that privacy-intrusive email open tracking should not be silently enabled simply because an email provider offers the feature.

Where a marketing email uses tracking that requires consent:

• the relevant consent must exist before that tracking is used;

• the purpose must be transparent; and

• withdrawal or objection must be respected.

Delivery status, suppression and unsubscribe records may still be processed where necessary to operate lawful email communications and honour preferences.

For more information about marketing communications, see our Privacy Policy.

Embedded and Third-Party Content

29. Video, Maps, Social Media and Other Embedded Services

A BhavPro page may embed or link to third-party services such as:

• video platforms;

• maps;

• social-media content;

• scheduling tools;

• chat tools;

• forms;

• webinars;

• document viewers; or

• other interactive content.

An embedded provider may wish to store or access information on a user’s device.

Where that storage/access is non-essential and requires consent, BhavPro should prevent the embedded service from loading until the relevant consent has been granted.

Where practical, a placeholder may be displayed instead, explaining that the content requires a privacy preference to be enabled.

Simply linking to an external website does not itself mean BhavPro has placed that third party’s cookies.

30. Tag Management Systems

BhavPro may use a tag-management system to control website tags.

A tag manager is a delivery mechanism, not a legal basis.

The fact that a tag is deployed through a tag manager does not make that tag necessary or exempt.

Our tag-management configuration should ensure:

• consent-dependent tags respect the relevant category;

• newly created tags do not bypass the consent layer;

• tag triggers are documented;

• old or unused tags are removed; and

• production tags are periodically audited against this Policy.

Technology Register

31. Live Technology Register

Cookie names, provider identifiers and technical durations can change when providers update their services.

For that reason, BhavPro maintains the policy at two levels:

This Policy

Explains:

• the legal categories;

• purposes;

• consent rules;

• principal advertising/payment providers; and

• how BhavPro controls technologies.

The live Cookie/Tracking Preference Centre or Technology Register

Should identify the technologies actually active on the website, including where technically available:

• technology or cookie name;

• provider;

• domain;

• category;

• purpose;

• first- or third-party status;

• expiry/duration;

• consent or exception status; and

• provider information.

The live register is intended to provide the most current technical inventory.

Only technologies that are genuinely deployed should be represented as active.

A provider listed in this Policy is not necessarily active on every page, in every country or at all times.

32. Approved Provider Categories

Subject to the live configuration, BhavPro’s technology register may include the following provider categories:

This table describes our classification framework. The live register should state which technologies are actually active.

33. Cookies Used by Third Parties Can Change

Third-party providers can:

• rename cookies;

• add or remove identifiers;

• change expiry periods;

• alter technical implementations;

• change domains;

• introduce new features; or

• modify privacy terms.

BhavPro therefore periodically reviews deployed technologies and updates:

• tag configuration;

• consent mapping;

• vendor information;

• this Policy; and

• the live technology register

where required.

A third-party platform update does not give BhavPro permission to silently activate a materially new tracking purpose.

Data Protection and Advertising

34. Relationship Between PECR and UK GDPR

PECR controls whether BhavPro may store information on or access information from a device for a particular purpose.

If the resulting information is personal data, the UK GDPR then governs the processing of that personal data.

For example:

1. advertising consent may be required before a tracking technology accesses information on a user’s device;

2. BhavPro must also have an appropriate UK GDPR basis for subsequent processing;

3. BhavPro must provide transparency;

4. data must be limited to what is necessary;

5. retention must be appropriate; and

6. data-subject rights must be respected.

A UK GDPR lawful basis such as legitimate interests does not by itself remove a PECR consent requirement.

35. Consent for Cookies Is Not Marketing Email Consent

Agreeing to advertising cookies does not automatically subscribe you to BhavPro marketing emails.

Likewise:

• subscribing to a newsletter does not automatically mean you agree to advertising cookies;

• accepting Terms and Conditions does not automatically create marketing consent;

• making a payment does not automatically create advertising consent; and

• becoming a customer does not automatically permit every form of direct marketing.

BhavPro maintains these permissions separately.

36. Cookie Consent Is Not Contract Acceptance

Cookie consent is not the same as accepting:

• Terms and Conditions;

• a quotation;

• a contract;

• subscription terms;

• a Refund & Cancellation Policy; or

• another commercial agreement.

Commercial acceptance is collected and recorded through the relevant purchase, quote, contract or checkout workflow.

37. Advertising IDs Are Not Customer IDs

Advertising click IDs, browser identifiers, platform IDs and campaign identifiers remain advertising/provider identifiers.

They are not BhavPro’s canonical customer identity.

Where advertising attribution is linked to a subsequent lead or customer, it is stored as source/attribution evidence rather than replacing the customer/account identity.

38. No Special-Category Advertising Audiences

BhavPro does not intentionally create advertising audiences based on special category personal data such as:

• health information;

• racial or ethnic origin;

• political opinions;

• religion;

• trade-union membership;

• genetic or biometric data used for identification;

• sex life; or

• sexual orientation.

We also do not intentionally place advertising tags on pages where the page context itself would inappropriately disclose sensitive personal information to an advertising provider.

39. Children

BhavPro’s services are directed at businesses and professional users and are not targeted at children.

We do not intentionally use advertising tracking to profile children.

If a service is later introduced that is likely to be accessed by children, we will conduct an appropriate privacy review before using tracking or advertising technologies in that context.

Your Choices

40. How to Reject Non-Essential Technologies

Where our website displays a consent interface, you can use it to reject non-essential categories.

A typical set of controls may include:

• Accept All;

• Reject Non-Essential; and

• Manage Preferences.

The exact labels may vary, but the interface should provide a clear genuine choice.

Necessary technologies remain active where required to provide the requested service or where another applicable exception applies.

41. How to Object to Exception-Based Statistical or Appearance Technologies

Where BhavPro relies on the statutory statistical-purpose or appearance exception, we provide a simple and free means to object.

Where technically integrated, this may be available through the same Privacy/Cookie Preference Centre.

An objection to exception-based analytics should be honoured prospectively for the applicable technology.

42. Browser Controls

Most browsers allow users to:

• inspect cookies;

• delete cookies;

• block cookies;

• block third-party cookies;

• clear site data; and

• apply tracking-protection features.

Browser controls can be useful but they do not replace BhavPro’s responsibility to obtain consent where required.

Blocking all cookies may prevent necessary website or portal functions from working correctly.

43. Global Privacy Signals and Browser Privacy Features

Where technically and legally appropriate, BhavPro may consider recognised browser privacy signals or platform-level privacy settings as part of its consent architecture.

A browser signal is not automatically treated as consent to optional tracking.

Where a signal clearly communicates an objection or opt-out recognised by applicable law and supported by our system, we may use it to help honour that preference.

44. Ad Platform Controls

Advertising providers also offer their own privacy or advertising controls.

These settings operate independently from BhavPro’s own consent controls and may include:

• Google advertising settings;

• Meta advertising preferences;

• Microsoft advertising preferences; and

• LinkedIn advertising settings.

Changing a provider setting may affect how that provider uses information across its services.

You should also use BhavPro’s own preference controls if you want to change what BhavPro permits on this website.

Retention and Records

45. Cookie and Technology Retention

Retention varies according to the technology.

A technology may last:

• for the browser session;

• for a fixed number of minutes, hours, days or months;

• until the user clears browser storage; or

• until another technical event removes it.

The active duration of each technology should be shown in the live register where available.

BhavPro periodically reviews whether retention remains necessary.

46. Consent Records

BhavPro may retain records demonstrating:

• the consent interface or policy version;

• consent categories;

• accepted/rejected state;

• date and time;

• technical consent identifier;

• withdrawal or change; and

• related audit information.

Consent evidence is retained for accountability and dispute/compliance purposes for an appropriate period.

A consent record should not contain unnecessary personal data.

47. Withdrawal Records

When consent is withdrawn, we may retain limited evidence of:

• the previous choice;

• the withdrawal;

• date/time;

• consent version; and

• technical preference.

This allows BhavPro to demonstrate that the preference was honoured.

International Processing and Third Parties

48. International Transfers

Advertising, analytics, payment and technology providers may process information outside the United Kingdom.

Where personal data is transferred internationally, our Privacy Policy explains the safeguards we use where applicable.

A user’s cookie choice does not remove the need for BhavPro to assess international-transfer requirements.

49. Third-Party Responsibility

Third-party providers may process data under their own privacy roles and terms.

BhavPro is responsible for deciding whether to deploy a third party’s technology on its services and for implementing appropriate controls within our sphere of responsibility.

A provider may separately be responsible for how it processes information after it receives it.

You should review relevant provider privacy information for further details.

Governance

50. New Tag and Vendor Approval

BhavPro’s internal deployment rule is that a new tracking or advertising technology should not be published to the production website until the following have been identified:

• owner;

• provider;

• purpose;

• data involved;

• pages affected;

• cookie/storage mechanism;

• category;

• PECR exception or consent requirement;

• UK GDPR lawful basis where personal data is processed;

• international transfer position;

• retention;

• consent-manager integration;

• vendor privacy terms;

• security implications; and

• documentation update requirement.

This helps prevent a marketing, plugin or development change from silently bypassing privacy controls.

51. Tag Audits

BhavPro may periodically audit:

• page source;

• tag-manager configuration;

• cookies;

• local storage;

• pixels;

• network requests;

• advertising events;

• consent behaviour;

• embedded services; and

• provider configuration.

The purpose is to identify:

• unknown tags;

• obsolete tags;

• tags firing before consent;

• misclassified technologies;

• forgotten test integrations;

• duplicate measurement;

• excessive retention; and

• differences between the live website and published policy.

52. Consent Enforcement Testing

For each material advertising or analytics integration, BhavPro aims to test at least:

Before any choice

What technologies fire and what information is stored/accessed?

Reject non-essential

Do advertising technologies remain blocked?

Accept analytics only

Does advertising remain blocked?

Accept advertising

Do approved advertising tags activate correctly?

Withdraw advertising consent

Do future advertising tags stop activating?

New browser/session

Does the saved preference operate as designed?

Portal/checkout

Are necessary security/payment technologies separated from advertising consent?

A cookie banner is not considered effective merely because it is visible; its technical behaviour must match the user’s choice.

53. Policy and Configuration Versioning

BhavPro may maintain version information for:

• this Policy;

• consent wording;

• consent categories;

• vendor register;

• tag-manager configuration; and

• major advertising integrations.

This supports auditability and allows BhavPro to determine what rules and technologies applied at a particular time.

Your Privacy Rights

54. Personal Data Generated by Tracking Technologies

Where information generated by cookies or similar technologies is personal data, your rights may include:

• access;

• rectification;

• erasure in applicable circumstances;

• restriction;

• objection;

• withdrawal of consent;

• data portability where applicable; and

• rights relating to certain automated processing.

Our Privacy Policy contains full information about these rights and how to exercise them.

55. Right to Withdraw Consent

Where processing depends on consent, you can withdraw that consent at any time.

For website technologies, use the Cookie/Tracking Preference Centre where available.

You can also contact:

hello@bhavpro.com

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

56. Right to Object to Direct Marketing

Cookie or advertising preferences are separate from direct-marketing objections.

If you do not want BhavPro marketing emails, use the unsubscribe facility in the email or contact:

hello@bhavpro.com

BhavPro may retain a limited suppression record to make sure your marketing objection continues to be honoured.

Complaints and Contact

57. Questions or Complaints

If you have a question or concern about our use of cookies or tracking technologies, contact:

Sentiora Consulting Ltd trading as BhavPro
Company number: 16596409
Registered office: 45 Marston Road, Leicester, United Kingdom, LE4 9FE
Email: hello@bhavpro.com
Website: https://bhavpro.com/

Please use “Cookies & Privacy” as the email subject where possible.

58. Information Commissioner’s Office

If you are dissatisfied with how we handle a data-protection concern, you have the right to complain to the UK’s data-protection supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/

We would appreciate the opportunity to address your concern directly before you approach the ICO, but you are not required to do so.

Provider Privacy Links

59. Principal Provider Information

Depending on which technologies are active, relevant provider information may include:

Google

Privacy Policy:
https://policies.google.com/privacy

Meta / Facebook / Instagram

Privacy Policy:
https://www.facebook.com/privacy/policy/

Microsoft

Privacy Statement:
https://privacy.microsoft.com/en-gb/privacystatement

LinkedIn

Privacy Policy:
https://www.linkedin.com/legal/privacy-policy

Stripe

Privacy Center:
https://stripe.com/gb/privacy

These providers can update their products, cookies, identifiers and privacy terms. The live BhavPro technology register should reflect the current technologies actually deployed.

Changes to This Policy

60. Updates

We may update this Policy to reflect:

• changes in law;

• ICO guidance;

• changes introduced by the Data (Use and Access) Act or future regulations;

• changes to our website;

• changes to consent technology;

• addition or removal of advertising providers;

• changes to analytics configuration;

• changes to payment or portal technology; or

• changes to how we use Storage and Access Technologies.

The current version and effective date are shown at the top of this Policy.

Where a change materially affects a purpose that requires consent, we will obtain fresh consent where required rather than relying on an earlier consent that is no longer sufficiently specific or informed.

We may retain previous versions for compliance, audit and evidential purposes.

Summary of BhavPro’s Cookie and Tracking Rules

61. Our Commitments

BhavPro’s operating principles are:

1. Necessary means necessary. We do not label advertising technology as necessary simply because it benefits marketing.

2. Advertising tracking requires a genuine choice.

3. Rejecting non-essential technologies must be straightforward.

4. Consent must be a positive action where required.

5. Continued browsing is not consent.

6. Cookie consent is separate from email marketing consent.

7. Cookie consent is separate from commercial Terms acceptance.

8. Payment/security technology is kept separate from advertising technology.

9. The statistical-purpose exception is limited to qualifying aggregate website/service improvement statistics.

10. The statistical exception is not used for advertising conversion tracking, profiling or retargeting.

11. A server-side advertising API does not automatically remove privacy obligations.

12. A tag manager does not create a legal basis for a tag.

13. New vendors require privacy review before production activation.

14. The live technology register must match the technologies actually deployed.

15. Consent choices must be technically enforced, not merely displayed in a banner.

16. Users must be able to change their choices.

17. Exception-based statistical/appearance technologies must provide a simple and free objection mechanism where required.

18. Advertising IDs remain provider/attribution identifiers, not BhavPro customer IDs.

19. We do not intentionally build advertising audiences from special-category personal data.

20. We periodically audit tags, cookies, storage, consent behaviour and vendor configuration.

62. Contact

For any question about this Policy or your privacy choices:

Sentiora Consulting Ltd trading as BhavPro
Company number: 16596409
Registered office: 45 Marston Road, Leicester, United Kingdom, LE4 9FE
Email: hello@bhavpro.com
Website: https://bhavpro.com/
Contact: https://bhavpro.com/contact/

End of Cookies, Tracking & Advertising Technologies Policy — Version 1.0 — Effective 1 September 2026