Draft for legal review. Items in square brackets need to be confirmed before this is published.
Cookie Policy
This policy explains the cookies and similar storage used by the Prasmo compliance portal (the “Portal”). It should be read with our Terms and Conditionsand privacy notice. [Confirm the published privacy notice URL before launch.]
1. What we use
The cookies Prasmo sets are strictly necessary: without them you cannot stay signed in to a form, and your answers cannot be saved against your invitation. We set no analytics, advertising or profiling cookies of our own, and we do not track you across other websites.
2. The cookies we set
| Cookie | What it does | Expires |
|---|---|---|
prasmo_customer_kyc | Keeps you signed in to the Know Your Customer form after you enter your keypass. | 12 hours |
prasmo_customer_credit | Keeps you signed in to the Credit Application form. | 12 hours |
prasmo_customer_technical | Keeps you signed in to the Technical Information form. | 12 hours |
prasmo_customer_fusf | Keeps you signed in to the FUSF declaration. | 12 hours |
prasmo_admin_session | Signs in Prasmo reviewers. Never set on a customer's browser. | 8 hours |
Each form has its own cookie so that working through several forms at once does not sign you out of the others. All of them are set by us on this domain, are inaccessible to scripts, are restricted to requests originating from the Portal, and are transmitted only over an encrypted connection. They hold a signed reference to your invitation and email address — not your answers, and not your keypass.
3. Storage in your browser
Your answers are saved to our servers as you move through a form. If one of those saves fails, the Portal keeps a copy of your answers in your own browser’s local storage so that your work is not lost, and sends it once saving succeeds again. That copy stays on your device, is not a cookie, and is never transmitted anywhere other than back to us. Clearing your browsing data removes it.
4. Information recorded when you submit or sign
This is not collected using cookies, but it is collected about your device, so it is set out here. When a form is submitted, and again when the authorised signatory certifies it, we record the IP address the request came from, the approximate location derived from that address, and what the browser reports about itself: browser and operating system, device type, language, time zone, screen and window size, colour depth, processor and memory characteristics, touch support, connection type, and whether cookies are enabled.
We record this as evidence that the certification was made, and from where. It forms the audit trail on the archived copy of an approved form. It is not used to track you across websites and is not shared with advertisers.
5. Service providers
- Email delivery. Invitations and status notifications are sent through Brevo, which processes the recipient address and message content.
- IP geolocation. To turn an IP address into an approximate location we query a third-party lookup service. Only the IP address is sent; none of your form answers are.
- Hosting and document storage. The Portal and the documents you upload are hosted with our infrastructure providers in [hosting region].
[Confirm each provider’s name and processing location for the published version.]
6. UK GDPR and your rights
PRASMO LTD is the controller for personal data collected through the Portal unless a separate written agreement says otherwise. The lawful bases for processing are expected to include contract, legitimate interests and legal obligation. No consent-based cookies are set. [Confirm lawful bases, retention periods, international transfer safeguards and the published privacy notice before launch.]
Individuals may have rights to access, correct, delete, restrict or object to the use of their personal data, and to complain to the UK Information Commissioner’s Office. Privacy requests should be sent to privacy@prasmo.com. [Confirm privacy contact and ICO wording before publication.]
7. Controlling cookies
You can block or delete cookies in your browser settings. Blocking ours means you will not be able to sign in to a form or submit one, and deleting them signs you out — you can sign back in with your keypass while it remains valid.
8. Changes
If we introduce any further cookie that is not strictly necessary, we will update this policy before setting it. The date above shows when this policy last changed.
9. Contact
PRASMO LTD, 128 City Road, London EC1V 2NX, United Kingdom. Company number 17296533.
Telephone [contact phone]. Privacy queries: privacy@prasmo.com.