Cookie Policy and User Tracking Disclosure

Last Updated: 01-01-2025 Cookie Policy This Cookie Policy explains how FX Recap (“We,” “Us,” or “Our”) uses cookies, web beacons, pixels, and other tracking technologies when you visit our website, FX Recap (the “Platform”). This policy provides you with comprehensive, transparent information about the technologies used and how you can manage your preferences, in accordance […]

Last Updated: 01-01-2025

Cookie Policy

This Cookie Policy explains how FX Recap (“We,” “Us,” or “Our”) uses cookies, web beacons, pixels, and other tracking technologies when you visit our website, FX Recap (the “Platform”). This policy provides you with comprehensive, transparent information about the technologies used and how you can manage your preferences, in accordance with the ePrivacy Directive (EPD), the General Data Protection Regulation (GDPR), and other applicable privacy laws.

1. What Are Cookies?

Cookies are small text files that are stored on your device (computer, phone, or tablet) when you visit a website. These files hold a small amount of data specific to you and the Platform.

Insofar as cookies and tracking technologies are used to identify users, particularly when combined with unique identifiers and other information, they qualify as Personal Data and are fully subject to data protection laws like the GDPR.

2. Why We Use Tracking Technologies

We use cookies and other tracking technologies for the following primary purposes:

Purpose of Use	Description	Legal Basis (GDPR/UK GDPR)
Strictly Necessary	To enable core website functionality, security, and navigation (e.g., managing user sessions, security authentication).	Legitimate Interest (Exempt from consent under EPD)
Performance/Analytics	To count visits and traffic sources, allowing us to measure and improve the performance and usability of the Platform.	Consent
Functionality	To remember choices you make (such as language preference or location), providing enhanced, personalized features.	Consent
Marketing/Advertising	To track browsing history and deliver targeted advertising, and to share tracking data with affiliates for compensation and conversion analysis.	Consent

3. Types of Tracking Technologies We Use

We utilize both proprietary and third-party tracking mechanisms:

A. Cookies

We use session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period or until manually deleted).

B. Pixels, Web Beacons, and SDKs

We use non-cookie-based tracking technologies such as web beacons, pixels, and third-party libraries (SDKs) to gather data that is shared with third parties for analytics or advertising purposes.

Affiliate Tracking: These technologies enable us to track conversion events when you click an affiliate link, ensuring our affiliate partners are correctly compensated, and are related to the sharing of consumer data for compensation.

4. Your Consent and Control Over Tracking

We adhere to the rigorous standards set by the ePrivacy Directive and the GDPR regarding user consent for tracking.

4.1 Prior, Explicit Consent

We must obtain your prior, informed, explicit, and unambiguous consent before placing any non-essential cookies or tracking technologies on your device. This means you must actively and freely agree to the usage of marketing and analytics cookies through a dedicated consent mechanism (e.g., a cookie banner or Consent Management Platform).

4.2 Transparency Obligations

Before consent is received, we provide you with accurate and specific information about:

The data each cookie tracks.
The precise purpose for which the data is used.

4.3 Your Rights to Control and Withdraw Consent

You must be able to access our Services even if you refuse to allow the use of non-essential cookies.

Withdrawing Consent: We make it as easy for you to withdraw your consent to cookie usage as it was for you to give your consent in the first place. You can manage and revoke your consent at any time via our Cookie Preferences Center.
Browser Settings: You can also manage your consent through your browser settings, which allow you to block websites from seeing your browsing history or to delete your browsing history after a session.
Opting Out of Personalized Ads: Your browser’s privacy settings allow you to choose whether to allow or block personalized ads based on your browsing history. Your mobile device’s operating system (e.g., Apple or Google) also provides settings to opt out of personalized ads in the “advertising” section of its privacy settings.

5. Third-Party Data Sharing (Sale/Share Disclosure)

As noted in Section 4, the use of tracking technologies may involve the disclosure of personal information to third parties (such as AdTech vendors or analytics providers) in exchange for free or discounted services, which may be interpreted as the “sale” or “sharing” of data under privacy laws like the CCPA/CPRA.

We assess our tracking technology vendors for compliance with these interpretations and ensure that your choices (including any signal to opt out of the sale/share of personal information) are respected across all downstream data flows.

6. Maintaining Your Policy

The rules regulating cookies and the technologies themselves are continually evolving. Maintaining an accurate and current Cookie Policy is a continuous responsibility. We will update this policy and inform you of material changes as necessary.