Cookie Policy

1. Introduction
This Cookie Policy explains how Cloverum uses cookies and similar technologies when you visit or interact with our websites and online interfaces (the “Website”). It should be read together with our Privacy Policy.
This Cookie Policy supports transparency and compliance with applicable data protection and e-privacy requirements. For EU/EEA users, Cloverum Finance (CY) Limited is subject to the GDPR and Cyprus data protection laws; for non-EU users, services may be provided by Cloverum Finance Limited under Gibraltar’s applicable framework.
2. Who we are? (Controller information)
Cloverum operates under the Cloverum brand through the legal entities below. Each entity acts as a controller for its respective users, depending on residency and the contractual relationship.

Entity	Registration / Registered office	Contact
Cloverum Finance (CY) Limited (Cyprus)	Reg. No.: HE 474703 Kypranoros 13, Evi Building, 2nd Floor, Office 201, 1061 Nicosia, Cyprus	Email: [email protected] / [email protected]
Cloverum Finance Limited (Gibraltar)	Reg. No.: 124609 Madison Building, Midtown, Queensway, Gibraltar GX11 1AA, Gibraltar	Email: [email protected] / [email protected]

If you have questions about our use of cookies, please contact us using the details above.
3. What are cookies?
Cookies are small text files placed on your device by a website. They help websites function, improve user experience, and inform site owners about how the site is used. Cookies may be:
• First-party cookies (set by Cloverum).
• Third-party cookies (set by external service providers).
• Session cookies (expire when you close your browser).
• Persistent cookies (remain until they expire or are deleted).
We may also use similar technologies (e.g., pixels, SDKs, local storage) that operate similarly to cookies; for simplicity, we refer to them as “cookies” in this Policy.
4. Why we use cookies
We use cookies for purposes such as:
• Maintaining website functionality and essential features
• Security, authentication, and fraud/bot protection
• Remembering preferences (e.g., language, session settings)
• Analytics to understand usage and improve performance
• Where enabled and lawful, marketing and content optimisation
5. Categories of cookies we use
We classify cookies into the categories below. Final categories should be aligned with your cookie banner / consent management platform (CMP).
1. Strictly Necessary Cookies (always on)
   These cookies are essential for the operation of the Website and cannot be disabled in our systems. They are usually set in response to actions made by you (e.g., logging in, setting privacy preferences, filling forms) and for core security functions. If you block these cookies, parts of the Website may not function properly.
2. Functional / Preference Cookies (optional)
   These cookies enable enhanced functionality and personalisation, such as remembering choices you make (e.g., language, region, interface settings).
3. Performance / Analytics Cookies (optional)
   These cookies help us understand how visitors use the Website (e.g., which pages are visited, errors encountered). The data is typically aggregated and used to improve performance and user experience.
4. Marketing / Targeting Cookies (optional)
   These cookies may be set through our Website by marketing partners to build a profile of your interests and show you relevant content on other sites. Marketing cookies are used only where enabled and where lawful.
5. Unclassified Cookies (temporary)
   Unclassified cookies are cookies that are under review and have not yet been assigned to a category. We will update classification as our review is completed.
6. Cookie inventory
1. Strictly Necessary Cookies

   Cookie	Domain	Provider	Path	Type	Expiration	Purpose
   auth-token	Same site	Cloverum	/	Strictly Necessary	15 minutes	Used to authenticate the user and maintain a secure session by storing a signed JWT access token required for core website functionality.

2. Functional / Preference Cookies

   Cookie	Domain	Provider	Path	Type	Expiration	Purpose

3. Performance / Analytics Cookies

   Cookie	Domain	Provider	Path	Type	Expiration	Purpose
   _hjSessionUser_user-id	Same site	Hotjar	/	Analytics	1 year	Used to store a unique user ID and identify returning visitors for analytics purposes. This cookie helps Hotjar understand user behavior across sessions.
   _hjSession_user-id	Same site	Hotjar	/	Analytics	30 minutes	Used to hold current session data and ensure subsequent requests during the session are attributed to the same session for behavioral analytics.

4. Marketing / Targeting Cookies

   Cookie	Domain	Provider	Path	Type	Expiration	Purpose

5. Unclassified Cookies

   Cookie	Domain	Provider	Path	Type	Expiration	Purpose

7. Third-party cookies
We may use third-party service providers on the Website (e.g., analytics, security, customer support tools). These third parties may place cookies on your device to deliver their services and, in some cases, recognise you across websites that use the same services. Third-party providers currently used:
• Google LLC – used for security, website functionality, analytics, personalization, and advertising. Cookies include: AEC, SEARCH_SAMESITE, SID, SIDCC, HSID, NID, OTZ, __Secure-1P*, __Secure-3P*.
• Hotjar Ltd. – used for performance monitoring and analytics to understand user behavior and improve website usability. Cookies include: _hjSession_, _hjSessionUser_.
8. Legal basis (EU/EEA users)
For EU/EEA users:
• Strictly Necessary cookies: used based on our legitimate interests in providing a secure and functional Website (GDPR Art. 6(1)(f)).
• All other cookies: used only with your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time via cookie settings.
9. How you can control cookies
You can control cookies in two primary ways:
1. Cookie banner / Cookie Settings (recommended)
You can accept or reject non-essential cookies and change your preferences at any time via: [COOKIE_SETTINGS_LINK] (insert link to the CMP preference centre).
2. Browser controls
Most browsers allow you to block or delete cookies via settings. If you disable cookies, the Website may not function optimally; disabling strictly necessary cookies may prevent access to secure areas.
10. Updates to this Cookie Policy
We may update this Cookie Policy from time to time to reflect changes in our practices, technologies, or legal requirements. The “Last updated” date at the top indicates when this Cookie Policy was last revised.
11. Contact us
If you have questions about our use of cookies, please contact: [email protected].