Cookie Policy
Draft — counsel review required
This document is a working draft prepared as a starting point for review by qualified U.S. counsel. It has not been reviewed or approved by an attorney, it is not legal advice, and it is not yet in force. Do not rely on it.
Cookies we use
Strictly necessary cookies. Used for authentication, session security, and protection against cross-site request forgery. The Services cannot function without them.
Preference cookies. Used to remember choices you make, such as a display preference.
Analytics. Where analytics are used, they are configured to be privacy-conscious: automatic capture of page contents and session recording are disabled, and only a defined set of product events is collected. Application answers, personal financial information, and free-text fields are never included in analytics data.
What we do not use
We do not use advertising cookies, cross-site tracking pixels, or data brokers, and we do not sell personal information.
Managing cookies
Most browsers let you refuse or delete cookies. Blocking strictly necessary cookies will prevent sign-in from working.
DRAFT NOTE FOR COUNSEL: whether a consent banner is required, and its mechanics, depend on the analytics configuration and the jurisdictions targeted. Counsel to confirm before launch.