§ 1. What cookies are
Cookies are small text files saved by the web browser on the User's terminal device (computer, tablet, phone). They contain information about the visit to the Site — including the session identifier, language preferences, and the status of consent given for selected functions.
Cookies do not, in themselves, identify the User; however, in combination with other data they may constitute personal data within the meaning of the GDPR. To that extent, the Privacy policy applies to their processing.
§ 2. Legal bases for the use of cookies
The use of cookies on the Site is governed by:
- Article 398 of the Polish Act of 12 July 2024 — Electronic Communications Law (Prawo komunikacji elektronicznej, PKE) — which has replaced the previous Article 173 of the Telecommunications Act and requires the User's consent for the storage of information on the terminal device, or for access to information already stored — except where it is strictly necessary for the provision of a telecommunications service or an information society service expressly requested by the User;
- the GDPR — to the extent that cookies serve as a means of processing personal data. The legal basis for processing data from cookies that are necessary for the operation of the Site is Article 6(1)(f) of the GDPR (legitimate interest of the Controller in ensuring the Site functions properly); for analytical, statistical and marketing cookies — Article 6(1)(a) of the GDPR (consent).
§ 3. Categories of cookies used
The following categories of cookies are used on the Site:
Strictly necessary (technical) cookies
These are necessary for the proper functioning of the Site and do not require the User's consent. Without them, certain functions of the Site (e.g. remembering the choice made in the cookie banner, basic security) would not be possible.
Analytical and statistical cookies
The Site does not use analytical or statistical cookies. To measure overall traffic on the Site we use Plausible Analytics, a service provided by Plausible Insights OÜ established in Estonia, with data processed in data centres located within the European Union (Germany). Plausible does not store any cookies on the User's device, does not use advertising identifiers, does not build User profiles and does not transfer data to third countries. Only aggregated, anonymous statistics are collected (e.g. page views, country, traffic source, device type) — without any possibility of identifying the User. Because the tool does not store information on the User's terminal device or access information stored on it, its use does not require consent under Article 398 of the Polish Electronic Communications Act. The legal basis for processing aggregated statistical data is Article 6(1)(f) GDPR — the legitimate interest of the Controller in analysing the effectiveness of, and developing, the Site.
Functional cookies
These remember User preferences (e.g. language version). They require consent unless they are necessary to provide a service expressly requested by the User.
Marketing cookies
The Site does not use marketing cookies or cookies for advertising profiling, unless otherwise indicated in the list set out in § 4 below. Should they be introduced in the future, the relevant information and the consent mechanism will be updated accordingly.
§ 4. List of cookies used
Current list of cookies used on the Site:
| Name | Purpose | Category | Retention period |
|---|---|---|---|
ltf-cookie-consent |
Stores the User's choice regarding cookies | strictly necessary | 12 months |
The list above constitutes the complete list of cookies used on the Site as at the date of the last update of this Policy. The Site does not use any analytical, marketing or advertising cookies. The list will be updated should any new cookies be introduced.
§ 5. Third-party services used on the Site
The Site does not use any third-party cookies. External tools are used solely to the following extent:
- Plausible Analytics (Plausible Insights OÜ, Estonia) — a cookieless analytics tool collecting only aggregated, anonymous traffic statistics. Provider's privacy policy: https://plausible.io/privacy. Data centre located in Germany, within the EEA.
Web fonts used on the Site are served directly from the Site's own server (self-hosting) — using the Site does not involve transferring any data (including IP addresses) to external font providers.
Should the catalogue of tools used on the Site be expanded (e.g. embedded maps, embedded forms, marketing tools), this list will be updated, and any cookies of such third parties will be used only after the User has given consent.
§ 6. Managing cookies
The User may at any time change their decision regarding cookies — both at the level of the Site and through the web browser.
Managing cookies on the Site
The cookies decision can be changed by re-displaying the cookies banner — to do this, the ltf-cookie-consent cookie must be deleted from the browser, or the Controller may be contacted.
Managing cookies in the browser
Most browsers allow Users to manage cookies independently — to block, restrict or delete them. Detailed instructions for the most popular browsers:
Please note that restricting or disabling cookies may affect certain functions of the Site — including making it impossible to use selected elements of the Site.
§ 7. Changes to the cookies policy
The Controller reserves the right to amend this Cookies policy — in particular if new technological tools are introduced, the law changes, or following a request from the supervisory authority. The current version of the Policy is available at all times at https://ltfadvisers.com/en/cookies-policy.html.
In the event of any discrepancies between the Polish-language and English-language versions of this Policy, the Polish version shall prevail.