Cookie Policy

Burrow Capital Management Ltd

Company number: HE 454836
3rd Floor, Iris House, John Kennedy Street, 3106, Limassol, Cyprus

This Cookie Policy explains how Burrow Capital Management Ltd (“Burrow Capital”, “we”, “us” or “our”) uses cookies and similar technologies on our corporate website (the “Website”), and how you can control them.

1. What are cookies?

Cookies are small text files or similar pieces of information that a website may store on, or read from, your browser or device. They can help a website function, remember choices, improve security, measure use of the website or support other features.

Similar technologies may include local storage, pixels, tags, scripts or other mechanisms that store information on or access information from a device. In this Cookie Policy, references to ‘cookies’ include similar technologies where appropriate.

2. Legal basis for cookies

Our use of cookies is governed by applicable European Union and Cyprus law, including Article 5(3) of Directive 2002/58/EC (the ePrivacy Directive), as implemented in Cyprus through section 99(5) of the Regulation of Electronic Communications and Postal Services Law of 2004 (Law 112(I)/2004), as amended, together with the GDPR where cookie data constitutes personal data.

Cookies that are strictly necessary for the transmission of a communication or for providing a service you have expressly requested may be used without consent. Other cookies are used only after the required consent has been obtained.

3. Categories of cookies

The types of cookies that may be used on the Website are described below. The actual cookies in use depend on the Website’s current technical configuration and enabled services.

Category

What they do

Consent

Strictly necessary

Enable core website functions, security, network management, load balancing, consent preferences or other functionality that is necessary for the Website or a service you request.

Generally not required where the legal exemption for strictly necessary cookies applies.

Preference / functionality

Remember choices or settings that are not essential to the basic operation of the Website, such as certain display or interface preferences.

Consent may be required unless the cookie is strictly necessary for a feature you expressly request.

Analytics / performance

Help us understand how visitors use the Website, such as pages viewed, traffic sources and technical performance, so that we can improve the Website.

Used only after consent where required.

Marketing / advertising

May be used to measure campaigns, build audiences, track activity across websites or deliver more relevant advertising.

Used only after consent where required.

Third-party / embedded content

May be set by third-party services embedded in the Website, such as video, maps, social media or other external content.

Non-essential third-party cookies are enabled only after consent where required.

4. Cookies currently used

Because website services and providers can change, the most reliable list of individual cookies is the list displayed in the Website’s cookie settings or consent-management panel, where such a panel is in use. That list should identify, as applicable, the cookie name, provider, purpose, category and duration.

If the Website is configured to use only strictly necessary cookies and no consent-requiring technologies are active, a cookie consent banner may not be shown. If non-essential cookies are introduced, they should remain disabled until you make the relevant consent choice.

5. Cookie consent and your choices

Where consent is required, the Website will provide a mechanism that allows you to make a genuine choice before non-essential cookies are activated. Depending on the Website configuration, you may be offered options such as ‘Accept all’, ‘Reject non-essential’ and ‘Manage preferences’.

You can withdraw or change consent at any time through the cookie settings tool available on the Website. Withdrawing consent does not affect the lawfulness of processing that took place before withdrawal.

6. Browser controls

Most browsers also allow you to block or delete cookies through browser settings. If you block strictly necessary cookies, some parts of the Website may not function correctly. Browser settings operate separately from the Website’s own consent tool and may need to be configured on each browser or device you use.

7. Third-party cookies and services

If the Website uses third-party services, those providers may set or read cookies in accordance with the choices you make and their own privacy documentation. Where required, Burrow Capital will seek consent before enabling non-essential third-party technologies.

Third-party providers may process information in countries outside the European Economic Area. Where GDPR transfer rules apply, appropriate safeguards should be used as described in our Privacy Policy.

8. Cookie duration

Some cookies are session cookies and are deleted when you close your browser. Others are persistent cookies and remain for a defined period unless deleted earlier. Where a cookie settings panel is used, the duration or expiry period of individual cookies should be shown there.

9. Changes to this Cookie Policy

We may update this Cookie Policy when the Website, our service providers or applicable legal requirements change. The latest version will be published on the Website and the ‘Last updated’ date will be revised.

10. Contact

If you have questions about our use of cookies or other technologies, please contact Burrow Capital Management Ltd using the contact details published on the Website or by post at:

Burrow Capital Management Ltd
3rd Floor, Iris House, John Kennedy Street, 3106, Limassol, Cyprus
Company number: HE 454836

For information about how we process personal data more generally, including your GDPR rights and how to complain to the Cyprus supervisory authority, please see our Privacy Policy.