This Cookie Policy ("Cookie Policy") explains how Grovcap ("Grovcap", "we", "our", or "us") uses cookies, local storage, session storage, and similar technologies when individuals access or use:
- the Grovcap website;
- the ETF Masterclass;
- Investor Pulse;
- Market Signals;
- educational resources;
- newsletters;
- user accounts (where applicable);
- institutional services; and
- any other websites, products or services that incorporate or reference this Cookie Policy (collectively, the "Services").
This Cookie Policy should be read together with Grovcap's:
- Privacy Policy;
- Terms of Use; and
- any additional privacy notices applicable to specific Services.
The purpose of this Cookie Policy is to explain:
- what technologies Grovcap uses;
- why those technologies are used;
- how users may control their preferences;
- how consent is managed;
- what third-party services are involved; and
- how these technologies support the operation, security and improvement of the Services.
Grovcap seeks to use only those technologies that are reasonably necessary for the operation of the Services or that users have expressly agreed to through the applicable consent mechanisms.
Where required by applicable law, non-essential technologies are used only after the appropriate consent has been obtained.
Nothing in this Cookie Policy limits any rights available under applicable privacy or data protection laws.
This Cookie Policy applies to technologies used by Grovcap in connection with the Services regardless of whether those technologies operate through:
- browser cookies;
- local storage;
- session storage;
- similar browser-based technologies;
- server-side session management;
- consent records; or
- comparable technologies used to improve the functionality, security and reliability of the Services.
This Cookie Policy applies only to technologies used by or on behalf of Grovcap.
It does not apply to:
- third-party websites linked from the Services;
- technologies controlled solely by third parties;
- browser extensions;
- operating system settings;
- applications or websites that do not reference this Cookie Policy.
Where third-party services are used as part of the Services, those providers may operate under their own privacy and cookie policies. Users are encouraged to review those policies directly.
Grovcap currently uses a limited number of browser technologies.
These technologies fall into the following categories.
4.1 Essential Technologies
Essential technologies are necessary for the operation, security and integrity of the Services.
These technologies cannot be disabled through the Grovcap preference centre because the Services would not function correctly without them.
Examples include technologies used to:
- authenticate users;
- maintain secure sessions;
- record consent preferences;
- prevent unauthorised access;
- maintain platform security;
- support core application functionality.
4.2 Preference Technologies
Preference technologies remember choices made by users in order to improve usability.
Examples include:
- interface preferences;
- navigation settings;
- sidebar state;
- user interface customisation.
Preference technologies do not collect information for advertising purposes.
4.3 Analytics Technologies
Where users have provided the appropriate consent, Grovcap may collect limited first-party analytics information regarding how the Services are used.
Analytics information assists Grovcap in understanding:
- which educational materials are most useful;
- lesson completion rates;
- feature usage;
- page navigation;
- platform performance;
- user experience improvements.
Grovcap currently uses first-party analytics only.
At the time of this Policy:
- Google Analytics is not used;
- Google Tag Manager is not used;
- Meta Pixel is not used;
- LinkedIn Insight Tag is not used;
- advertising cookies are not used.
Analytics processing begins only after the user has granted Analytics consent through the Grovcap consent management system.
Users may withdraw Analytics consent at any time.
4.4 Research Technologies
Where users voluntarily participate in Investor Pulse or other research activities, Grovcap may use browser storage to maintain anonymous research identifiers and consent records.
These technologies assist in:
- preventing duplicate submissions;
- maintaining research integrity;
- recording consent choices;
- improving statistical reliability.
Research participation remains voluntary.
Where research consent is required, research processing will not occur until the appropriate consent has been provided.
4.5 Marketing Technologies
At the date of this Cookie Policy, Grovcap does not use marketing or advertising cookies.
In particular, Grovcap does not currently deploy:
- Meta Pixel;
- Google Ads tracking;
- LinkedIn Insight Tag;
- X (Twitter) Pixel;
- Reddit Pixel;
- TikTok Pixel;
- advertising retargeting technologies.
Should such technologies be introduced in the future, this Cookie Policy will be updated and, where required by applicable law, users will be asked to provide the appropriate consent before such technologies are activated.
The following table summarises the technologies currently used by the Services.
| Technology | Purpose | Essential | Duration |
|---|---|---|---|
| Supabase Authentication (Local Storage) | Maintains authenticated user sessions for signed-in users. | Yes | Until sign-out or session expiration. |
| Consent Preferences (Local Storage) | Stores user consent choices for analytics, research and newsletter communications. | Yes | Persistent until updated or withdrawn. |
| Anonymous Research Identifier (Local Storage) | Maintains a pseudonymous identifier supporting research integrity and consent management. | No (used only where applicable) | Persistent. |
| Analytics Session Identifier (Session Storage) | Maintains a temporary analytics session after Analytics consent has been granted. | No | Browser session only. |
| Sidebar Preference Cookie | Remembers whether the navigation sidebar is expanded or collapsed. | No (preference) | Approximately 7 days. |
Third-Party Infrastructure
The Services also rely on certain infrastructure providers.
These providers may process limited technical information necessary to deliver the Services.
Current providers include:
- Supabase, providing authentication, database and application infrastructure;
- Cloudflare, providing content delivery, security and hosting infrastructure;
- Google Fonts, providing web font delivery for the user interface.
These providers process information in accordance with their own privacy documentation and applicable legal obligations.
Grovcap does not currently use third-party advertising networks or third-party behavioural advertising cookies.
Where new technologies are introduced, this Cookie Policy will be updated accordingly, and where required by applicable law, additional consent will be obtained before such technologies become active.
In addition to browser cookies, Grovcap uses browser storage technologies that support the secure and reliable operation of the Services.
These technologies currently include:
- Local Storage;
- Session Storage; and
- similar browser storage mechanisms where supported by the user's browser.
Unlike traditional cookies, browser storage is maintained locally within the user's browser and is not automatically transmitted with every HTTP request.
Grovcap uses browser storage for purposes including:
- maintaining authenticated user sessions;
- recording user consent preferences;
- supporting anonymous research participation;
- maintaining temporary analytics sessions where Analytics consent has been granted;
- improving application functionality.
6.1 Local Storage
Local Storage enables information to remain available after the browser has been closed and reopened.
Grovcap currently uses Local Storage to support:
- authenticated sessions managed through Supabase Authentication;
- user consent preferences;
- anonymous research identifiers;
- certain application preferences and functionality.
Information stored in Local Storage remains available until:
- it is removed by the user;
- it is removed by the application;
- the browser data is cleared; or
- the applicable storage item is replaced or updated.
6.2 Session Storage
Session Storage is used for temporary information that exists only during the current browser session.
Current uses include:
- temporary analytics session identifiers, where Analytics consent has been granted.
Session Storage is automatically removed when the relevant browser tab or browsing session ends.
6.3 Similar Technologies
As the Services evolve, Grovcap may introduce additional browser-based technologies that perform functions substantially similar to cookies or browser storage.
Any such technologies will be implemented in accordance with applicable law and, where required, subject to the applicable consent mechanisms described in this Cookie Policy.
Grovcap respects user privacy choices and operates a consent management framework designed to comply with applicable privacy and data protection laws.
Except for technologies that are strictly necessary for the operation of the Services, technologies are activated only where the appropriate consent has been obtained.
7.1 Consent Categories
Grovcap currently recognises the following categories.
Essential
Essential technologies are required for:
- authentication;
- security;
- consent management;
- core platform functionality.
Essential technologies cannot be disabled through the Grovcap preference centre because the Services would not operate correctly without them.
Analytics
Analytics technologies help Grovcap understand how the Services are used.
Analytics processing includes only Grovcap's first-party analytics implementation.
Analytics technologies remain disabled until Analytics consent has been provided.
Users may withdraw Analytics consent at any time.
Following withdrawal:
- future analytics events cease;
- new analytics sessions are not created;
- analytics processing no longer continues unless consent is subsequently granted again.
Research
Research technologies support voluntary participation in Investor Pulse and other research initiatives.
Research processing occurs only where the required Research consent has been provided.
Withdrawal of Research consent does not affect processing already carried out lawfully before consent was withdrawn.
Newsletter
Newsletter consent governs communications relating to newsletters, updates and similar communications where consent is required.
Users may withdraw Newsletter consent at any time.
7.2 Managing Consent
Users may manage their privacy preferences through the Grovcap Cookie Preferences centre.
The preference centre enables users to:
- accept all optional technologies;
- reject non-essential technologies;
- manage individual consent categories;
- withdraw previously granted consent.
Changes take effect as soon as reasonably practicable following submission.
7.3 Consent Records
Grovcap maintains records of consent decisions where reasonably necessary to demonstrate compliance with applicable legal obligations.
Consent records may include:
- consent categories;
- timestamps;
- policy version;
- anonymous identifiers;
- changes to consent status.
Such records are maintained solely for compliance, audit and governance purposes.
Grovcap uses a limited number of carefully selected third-party service providers to support the operation of the Services.
These providers may process limited categories of technical or personal information on Grovcap's behalf.
Current providers include:
Supabase
Supabase provides:
- user authentication;
- database infrastructure;
- secure application services.
Supabase processes information necessary to provide these services in accordance with contractual arrangements and applicable law.
Cloudflare
Cloudflare provides:
- hosting;
- content delivery;
- network security;
- performance optimisation.
Cloudflare may process technical information necessary to securely deliver the Services.
Depending on infrastructure configuration, Cloudflare may set operational cookies required for security or network integrity.
Such cookies are controlled by Cloudflare rather than by Grovcap.
Google Fonts
Grovcap currently uses Google Fonts to deliver certain web fonts used throughout the Services.
As part of providing these fonts, Google may receive limited technical information including IP address and browser information necessary to deliver font resources.
Grovcap may replace externally hosted fonts with self-hosted fonts in the future.
Future Third-Party Services
As the Services evolve, Grovcap may engage additional service providers.
Where additional providers introduce technologies requiring disclosure or consent under applicable law, this Cookie Policy will be updated accordingly.
Grovcap retains information associated with cookies and browser storage only for as long as reasonably necessary to fulfil the purposes described in this Cookie Policy or as otherwise required by applicable law.
Retention periods vary depending upon the technology used.
Examples include:
- session-based technologies that expire automatically when the browser session ends;
- persistent browser storage that remains until removed, replaced or updated;
- consent records retained for compliance purposes;
- authentication information retained in accordance with authentication requirements;
- preference information retained until changed by the user or otherwise removed.
Where browser storage or cookie-related information is no longer required, Grovcap will take reasonable steps to remove, anonymise or otherwise dispose of such information in accordance with applicable law and its internal data governance practices.
Nothing in this Cookie Policy limits any longer retention period required under applicable law or necessary for the establishment, exercise or defence of legal claims.
Grovcap seeks to process personal information and browser-related information within jurisdictions that provide an appropriate level of data protection.
However, because the Services rely upon selected third-party infrastructure providers, certain information associated with cookies, browser storage or similar technologies may be transferred to, stored in or otherwise processed in countries outside the user's country of residence.
Where applicable data protection laws require safeguards for international transfers, Grovcap will implement one or more recognised transfer mechanisms, including where appropriate:
- adequacy decisions adopted by the European Commission;
- the European Commission's Standard Contractual Clauses ("SCCs");
- approved certification mechanisms;
- other safeguards recognised under applicable law.
Grovcap seeks to work with service providers that maintain appropriate technical and organisational measures designed to protect personal information.
Users may request additional information regarding applicable transfer safeguards by contacting:
office@grovcap.com
The use of internationally distributed infrastructure does not alter Grovcap's commitment to processing personal information in accordance with applicable privacy and data protection laws.
Grovcap may amend or update this Cookie Policy from time to time.
Updates may be made to reflect, among other things:
- changes to applicable laws or regulations;
- guidance issued by supervisory authorities;
- changes to browser technologies;
- changes to cookies or browser storage used by the Services;
- changes to third-party service providers;
- improvements to the Services;
- security enhancements;
- operational requirements.
The Last Updated date appearing at the beginning of this Cookie Policy indicates when the most recent version became effective.
Where required by applicable law, Grovcap will provide additional notice or obtain consent before material changes become effective.
Where technically appropriate, updated versions of this Cookie Policy will also reflect the applicable Policy Version used by Grovcap's consent management framework.
Continued use of the Services following the effective date of an updated Cookie Policy constitutes acknowledgement of the revised Cookie Policy to the extent permitted by applicable law.
Questions regarding this Cookie Policy or Grovcap's use of cookies, browser storage or similar technologies may be directed to:
Grovcap
Privacy & Cookie Enquiries
Email: office@grovcap.com
Grovcap will use reasonable efforts to respond to cookie and privacy-related enquiries within the timeframes required by applicable law.
Where appropriate, requests relating to cookies may also be handled together with requests submitted under the Privacy Policy.
For the purposes of this Cookie Policy, the following terms have the meanings set out below.
Analytics Technologies
Technologies used to understand how users interact with the Services in order to improve functionality, performance and educational effectiveness.
Browser Storage
Technologies including Local Storage and Session Storage that allow information to be stored within a user's browser.
Consent
Any freely given, specific, informed and unambiguous indication of a user's wishes by which the user agrees to the processing of personal information or the use of non-essential technologies where required by applicable law.
Cookie
A small text file placed on a user's device that enables websites to recognise browsers, remember preferences and support certain functionality.
Essential Technologies
Technologies that are strictly necessary for the secure operation and core functionality of the Services.
Local Storage
A browser technology that stores information locally on a user's device and retains that information across browsing sessions.
Policy Version
The version identifier associated with Grovcap's consent management framework and applicable legal documentation.
Session Storage
Browser storage that exists only for the duration of a browser session or browser tab.
Third-Party Service Provider
An external organisation that provides infrastructure or services supporting the operation of the Services on behalf of Grovcap.
In designing and operating the Services, Grovcap seeks to apply the following principles to the use of cookies, browser storage and similar technologies:
- lawfulness, fairness and transparency;
- purpose limitation;
- data minimisation;
- privacy by design;
- privacy by default;
- security and confidentiality;
- accountability;
- user choice and control.
Grovcap seeks to use the minimum technologies reasonably necessary to provide secure, reliable and effective Services.
Where non-essential technologies are used, Grovcap seeks to ensure that users receive clear information, meaningful choices and practical mechanisms for granting, managing and withdrawing consent.
Nothing in this Cookie Policy creates contractual rights beyond those provided under applicable law.
End of Cookie Policy