COOKIE POLICY

Effective Date: 13 May 2026 | Last Updated: 13 May 2026
Version 1.1

This Cookie Policy explains how Nagram LTD (“Nagram”, “we”, “us”, or “our”) (registered in England and Wales, Company No. 15833908) uses cookies and similar technologies when you visit https://www.nagram.net (the “Website”) or interact with our online services. This Cookie Policy should be read together with our Privacy Policy and Terms and Conditions. This Cookie Policy is provided in accordance with our obligations under the Privacy and Electronic Communications Regulations 2003 (PECR), UK GDPR, and the ICO’s guidance on cookies and similar technologies.

1. Who We Are

Nagram LTD
Company Registration Number: 15833908.
B10 Harben House, Tickford Street, Newport Pagnell, England, MK16 9EY
Email: info@nagram.net

2. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. Cookies help websites function efficiently, remember preferences, improve performance, and provide analytics or marketing insights. Cookies may be set by:

• First-party cookies – placed directly by Nagram;
• Third-party cookies – placed by service providers or partners acting on our behalf or providing integrated services.

We may also use similar technologies such as pixels, tags, SDKs, scripts, local storage, and device identifiers. Under PECR Regulation 6, we are required to obtain your informed consent before placing cookies on your device, except for cookies that are strictly necessary for a service you have requested. This Cookie Policy explains how we obtain and manage that consent.

3. Why We Use Cookies

We may use cookies and related technologies for purposes including:

• enabling website functionality;
• remembering preferences;
• maintaining security;
• supporting account login sessions;
• fraud prevention;
• measuring traffic and performance;
• improving user experience;
• understanding engagement with pages or services;
• supporting subscription journeys and checkout flows;
• measuring marketing campaign effectiveness;
• diagnosing technical issues.

4. Categories of Cookies We May Use

4.1 Strictly Necessary Cookies
These cookies are required for the Website to function properly and may include cookies used for page navigation, load balancing, security protections, session continuity, consent preferences, checkout continuity, and fraud prevention. These cookies generally do not require consent where exempt under applicable law. Under PECR Regulation 6(1)(b), strictly necessary cookies are exempt from the consent requirement where they are used solely for transmitting a communication over an electronic communications network, or are strictly necessary to provide a service explicitly requested by the user. We do not place any cookies designated as “strictly necessary” beyond what is genuinely required for these purposes.

4.2 Functional Cookies
These cookies help remember settings and preferences such as language choice, region selection, display preferences, remembered form inputs, and user interface customisation. Where functional cookies are not strictly necessary for the operation of the Website, we will obtain your consent before placing them, in accordance with PECR Regulation 6.

4.3 Analytics / Performance Cookies
These cookies help us understand how visitors use the Website, such as pages visited, time spent on pages, click behaviour, referral sources, device/browser types, aggregate traffic statistics, and error diagnostics. Analytics cookies are non-essential and require your prior consent under PECR. Where we use Google Analytics or equivalent services, we have configured such tools to: (i) anonymise IP addresses before storage; (ii) disable data-sharing with Google for advertising purposes; and (iii) apply the minimum retention period. Where analytics data is transferred outside the UK (for instance to the US), we rely on appropriate transfer mechanisms including the UK IDTA or UK-US Data Bridge where applicable.

4.4 Advertising / Marketing Cookies
Where used, these cookies may help measure campaign effectiveness, understand conversions, prevent duplicate advertising, personalise marketing, build audience segments, and retarget users across platforms where lawful. Such cookies are generally subject to consent where required. Marketing cookies require prior, specific, informed, and freely-given consent under PECR Regulation 6 and UK GDPR Article 7. Pre-ticked boxes, consent inferred from continued browsing, and consent bundled with acceptance of terms are not valid consent. Consent may be withdrawn at any time without detriment to your use of the Services.

4.5 Security and Fraud Prevention Cookies
We may use cookies or device signals to detect suspicious behaviour, prevent payment fraud, secure login sessions, block abusive traffic, and investigate misuse. Where security and fraud prevention cookies are strictly necessary to protect the integrity of the subscription or payment process, they may be deployed without consent under PECR. Where they go beyond what is strictly necessary, consent will be sought.

5. Examples of Third-Party Services That May Use Cookies

Depending on operational setup, the Website may use third-party providers such as analytics vendors, hosting providers, CDN providers (including Cloudflare or equivalent), payment processors, fraud prevention vendors, customer support tools, marketing platforms, tag management tools, and security monitoring systems. These third parties may set cookies subject to their own privacy notices. A full list of third-party cookie providers currently operating on this Website is set out in the Cookie Categories Table in Clause 10. Where third-party providers act as independent data controllers, their own privacy and cookie notices govern their processing. Where they act as processors, we maintain Data Processing Agreements in accordance with Article 28 UK GDPR.

6. Payment and Subscription Cookies

If you proceed to purchase a subscription or paid service, cookies may be used to preserve cart or checkout state, route payment sessions, verify transactions, reduce fraud risk, remember selected plan options, and maintain continuity between checkout steps. Payment processors may place their own cookies under their own legal terms. Cookies used solely for the purpose of completing a transaction or checkout process you have initiated may be treated as strictly necessary and do not require separate consent under PECR. However, any marketing or analytics cookies associated with the checkout journey remain subject to consent.

7. Consent and Cookie Banners

Where required under UK GDPR, PECR, or similar laws, we seek consent before placing non-essential cookies. Users may be offered options such as Accept All Cookies, Reject Non-Essential Cookies, Manage Preferences, and Withdraw Consent later. Your consent choices may be stored through a cookie or equivalent preference signal. Our consent management tool is configured to: (i) record a time-stamped log of each consent decision in accordance with UK GDPR Article 7(1); (ii) prevent non-essential cookies from loading before consent is given; (iii) give equal visual prominence to the Accept All and Reject All options; and (iv) allow category-level granular consent. This design is compliant with ICO guidance on valid consent for cookies.

8. Legal Basis for Cookie Processing

• Consent (PECR Regulation 6 / UK GDPR Article 6(1)(a))
  For analytics, marketing, personalisation, and other non-essential cookies where legally required. Consent must be freely given, specific, informed, and unambiguous. It is obtained before non-essential cookies are placed.
• Legitimate Interests (UK GDPR Article 6(1)(f))
  For limited security, fraud prevention, network protection, and certain operationally necessary functions where lawful. We carry out a Legitimate Interests Assessment for each reliance on this basis.
• Contractual Necessity (UK GDPR Article 6(1)(b))
  Where cookies are necessary to deliver requested services such as secure login or subscription checkout.

9. International Data Transfers

Some cookie providers or analytics partners may process data outside the United Kingdom. Where applicable, we implement appropriate safeguards such as:

• UK International Data Transfer Addendum (IDTA);
• adequency decisions made by the UK Secretary of State;
• equivalent lawful protections.

Details of the safeguards applicable to each third-party provider that transfers data outside the UK are set out in the Cookie Categories Table. Where transfers involve the United States, we rely on the UK–US Data Bridge (where the provider participates) or the UK IDTA to Standard Contractual Clauses.

10. Retention Periods and Cookie Categories Table

Cookie duration varies depending on purpose.

• Session Cookies: deleted when you close your browser.
• Persistent Cookies: remain for a defined period or until manually deleted.

Cookie Categories Table:

This table is reviewed and updated whenever cookie technologies are added, changed, or removed. The current version is always published on the Website.

11. How to Control Cookies

Browser Controls
Most browsers allow you to block cookies, delete cookies, clear browsing data, restrict third-party cookies, and receive alerts before cookies are placed.

Website Cookie Preferences
Where available, you may update cookie preferences through our consent banner or settings link.

Device Controls
Mobile devices may allow advertising identifiers or tracking restrictions.

Please note that disabling certain cookies may affect functionality. Withdrawing consent for cookies will be effective promptly and will not affect your access to paid Services, other than any loss of functionality directly dependent on those cookies.

12. Consequences of Rejecting Cookies

If you reject some cookies:

• parts of the Website may not function correctly;
• login sessions may be less reliable;
• checkout or subscription flows may be interrupted;
• preferences may not be remembered;
• analytics used to improve services may be limited.

Strictly necessary cookies may still be used where legally permitted. Rejecting non-essential cookies will not result in any loss of access to paid content or services for which you have subscribed. Rejection of analytics or marketing cookies does not affect the performance of core service features.

13. Children’s Privacy

We do not knowingly use cookies to intentionally profile children in breach of applicable law. Parents or guardians who have concerns may contact us. Under the ICO’s Age Appropriate Design Code (Children’s Code), where our services are likely to be accessed by children under 18, we will apply high privacy settings by default and will not use profiling or targeted advertising cookies in respect of under-18 users. Where we become aware that a user is under 13, no non-essential cookies will be placed without verifiable parental consent.

14. Changes to This Cookie Policy

We may update this Cookie Policy periodically to reflect legal developments, changes in technologies used, new service providers, operational changes, and regulatory guidance. Material changes including changes to the categories of cookies used, third-party providers, or purposes of processing, will be notified to users by prominent notice on the Website no less than 30 days before taking effect. Where changes require fresh consent under PECR or UK GDPR, we will re-present the consent banner before the updated cookies are placed.

15. Contact Details

If you have questions regarding this Cookie Policy or our use of cookies, please contact:
Nagram LTD
B10 Harben House, Tickford Street, Newport Pagnell, England, MK16 9EY
Email: info@nagram.net
Supervisory Authority: Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113. Website: www.ico.org.uk