Cookie Policy

1. About Us and Scope

1.1 Company details

The Website is operated by:

SA Futures Limited, trading as Halow CapitalCompany number: 14219285Registered office: Martlet House E1 Yeoman Gate, Yeoman Way, Worthing, West Sussex, United Kingdom, BN13 3QZEmail: halow@halowcapital.comTelegram: @Halowhq

1.2 Scope

This Policy applies to cookies and other technologies used on www.halowcapital.com, its pages, forms, dashboards and associated applications operated through Base44. It also explains our approach to Google Analytics, Google Consent Mode, built-in Base44 functionality and any embedded third-party content.

1.3 Third-party services

Third-party websites and platforms that you open from the Website, including Telegram, Myfxbook, FX Blue, MetaTrader, broker websites and independent Developer websites, operate under their own cookie and privacy information. A normal link does not place that third party’s cookies on your device merely because the link appears on our Website. Embedded third-party content may operate differently, as explained in Section 7.

2. What Are Storage and Access Technologies?

Cookies are small text files placed on a browser or device. The legal rules also apply to other methods that store information on, or access information from, a device. In this Policy we refer to all of them as “storage and access technologies”. They may include:

a. cookies, including session and persistent cookies;b. browser local storage and session storage;c. scripts, tags and software-development tools;d. tracking pixels and similar web beacons;e. consent-preference records;f. device or browser identifiers; andg. other technologies that store or read information on a computer, phone, tablet or similar device.

2.1 Session and persistent technologies

A session technology normally expires when the browser session ends. A persistent technology remains until its stated expiry, it is replaced, or you delete it.

2.2 First-party and third-party technologies

First-party technologies are set through the Halow Capital domain. Third-party technologies are supplied or controlled by another organisation, such as Google or an embedded-content provider. A first-party cookie may still be used by a third-party service operating on our behalf.

3. Legal Framework and Our Approach

3.1 PECR and data-protection law

Our use of storage and access technologies is governed principally by the Privacy and Electronic Communications Regulations, as amended, together with the UK General Data Protection Regulation and the Data Protection Act 2018 where personal information is involved.

3.2 Technologies that do not require optional consent

Some technologies may be used without optional consent where a legal exception applies. This may include technologies that are strictly necessary to transmit communications, provide a service you requested, protect Website security, process a form, retain your cookie choice or maintain essential network and session functions.

3.3 Statistical and preference exceptions

UK law may permit limited technologies used solely for statistical improvement or to apply a user-selected appearance or functionality preference without prior consent, provided the legal conditions are met and a simple, free means of objecting is available. Halow Capital currently treats Google Analytics as optional and seeks consent before allowing Analytics storage.

3.4 Optional technologies

Where no exception applies, we seek a positive choice before using the technology. Consent is not obtained through silence, inactivity, pre-ticked controls or continued browsing.

3.5 No targeted-advertising cookies

Halow Capital does not currently use Google Ads remarketing, social-media advertising pixels, cross-site behavioural advertising cookies or technologies designed to build advertising profiles. If this changes, we will update this Policy and the cookie controls before the new technology is activated where required.

4. Current Technology Register

The table below describes the technologies currently known to be used or capable of being used on the Website. Exact platform-generated names can change when Base44, Google or another provider updates its technology. The purpose, provider and control category are more important than the name alone.

Technology / Name

Provider

Purpose

Category / Control

Typical duration

Consent preference record(name may vary)

Halow Capital / Base44

Remembers whether you accepted, rejected or customised optional technologies so the banner does not ask on every page.

Strictly necessary

Normally up to 12 months, then refreshed; may be replaced sooner after a policy or configuration change.

Essential session, security and network technologies(names may vary)

Base44 and hosting/security providers

Delivers pages, protects forms and infrastructure, prevents abuse, preserves essential session state and enables requested Website functions.

Strictly necessary

Session or a limited period appropriate to the security or operational purpose.

Essential form and navigation state(cookie or browser storage; names may vary)

Halow Capital / Base44

Supports form submission, page navigation, error handling and a feature specifically requested by the visitor.

Strictly necessary where required for the requested feature

Usually session or short-term.

_ga

Google Analytics 4

Distinguishes users for Website measurement after Analytics consent.

Optional analytics

Up to 2 years, subject to browser limitations and our configuration.

_ga_<container-id>(commonly _ga_FHRHZRGGL1 for the current property)

Google Analytics 4

Persists session state for the Halow Capital GA4 property after Analytics consent.

Optional analytics

Up to 2 years, subject to browser limitations and our configuration.

Google Consent Mode signals(not necessarily a cookie)

Google tag / Google Analytics

Communicates the consent state to Google tags. When Analytics storage is denied, the tag must not set or read GA Analytics cookies. Depending on the deployed Consent Mode configuration, limited cookieless measurement or consent-status signals may still be sent.

Consent-control technology; associated Analytics remains optional

Request/session based; the consent choice itself is retained by the consent preference record.

Base44 built-in analytics and technical logs

Base44

Provides visit, page, device, performance and operational information in the Base44 dashboard. Some information may be collected through server logs rather than device storage.

Server-side logs are addressed in the Privacy Policy; any non-essential device storage is subject to the applicable consent or objection control

According to the applicable Base44 plan, configuration and legal retention requirements.

4.1 Technology audit

The live Website configuration is authoritative. Halow Capital will review the Website periodically and after material changes to identify new cookies, local-storage keys, tags, embedded content or similar technologies. If a new non-exempt purpose is introduced, the banner and this register must be updated before or when the technology is deployed.

5. Google Analytics and Consent Mode

5.1 Purpose

We use Google Analytics 4 (“GA4”) to understand how visitors use the Website, identify technical or navigation problems and improve Website content and performance. Our current GA4 measurement identifier is G-FHRHZRGGL1.

5.2 Information measured

Subject to the consent configuration, GA4 may process information such as pages viewed, approximate location derived from an IP address, browser and device characteristics, referral source, session information and selected Website interactions. We do not use GA4 to provide financial advice, make automated trading decisions or access a visitor’s broker account.

5.3 Analytics cookies

When Analytics consent is granted, GA4 may set the _ga and _ga_<container-id> first-party cookies described in the register. Google states that their default expiration is two years, although browsers may impose shorter limits and our configuration may shorten or remove them.

5.4 Consent Mode

The Website uses Google Consent Mode to communicate cookie choices to Google tags. Analytics storage must be denied by default until the applicable choice is made. Granting Analytics consent allows the Analytics tag to use its permitted storage. Rejecting or withdrawing Analytics consent prevents further optional Analytics storage.

Google supports both basic and advanced Consent Mode. In basic mode, Google tags are blocked until consent. In advanced mode, Google tags can load with storage denied and may send limited cookieless pings for measurement modelling. These pings do not set or read GA Analytics cookies, but they may still transmit limited technical and event information to Google. The Website configuration and Privacy Policy should be read together with this disclosure.

5.5 No advertising use

We do not currently use GA4 data for personalised advertising, remarketing or cross-site advertising profiles. Google advertising consent categories should remain denied unless Halow Capital intentionally introduces an advertising feature and updates its notices and controls.

5.6 Withdrawing Analytics consent

You may withdraw Analytics consent through Cookie Settings. This stops future optional Analytics storage and changes tag behaviour. It does not automatically delete cookies already stored on your device; you may remove them through your browser controls.

6. Base44 Platform Technologies

6.1 Hosting and operation

The Website is built and hosted through Base44. Base44 may provide essential infrastructure, page delivery, security, forms, database functions, authentication where enabled, error reporting and operational logs. Technologies required to provide a feature that you request or to secure the Website may operate without optional consent where a legal exception applies.

6.2 Built-in analytics

Base44 provides app analytics and logging features that may record visits, pages, devices, approximate location, referral information and custom events. Some of this collection may occur through server-side logs rather than a cookie or local-storage identifier. Server-side processing that does not store or access information on your device is explained in the Privacy Policy rather than controlled solely by the cookie banner.

6.3 Non-essential Base44 storage

If a Base44 feature uses non-essential device storage, the feature must be classified and controlled according to its purpose. It must not be treated as essential merely because Base44 supplies it.

6.4 Platform changes

Base44 may change platform-generated cookie or storage names. Halow Capital will use reasonable efforts to keep the register accurate and to configure the Website so that visitor choices are respected.

7. Embedded Content and External Services

7.1 Embedded content

A page may display or later include embedded charts, account records, videos or other content supplied by Myfxbook, FX Blue, YouTube, Telegram or another provider. Embedded content can allow that provider to receive device, IP, page and interaction information and may cause its own technologies to operate.

7.2 Consent before loading

Where embedded content uses non-essential storage or access technologies, it should be blocked or replaced with a consent-controlled placeholder until the relevant choice is made, unless a legal exception applies. A visitor may instead be given a normal external link.

7.3 External links

When you follow an external link, the destination service may place its own cookies or similar technologies under its own policies. Halow Capital does not control those independent technologies.

7.4 Payment pages

When a Customer uses a bank, wallet or crypto exchange to make a direct payment to SA Futures Limited, that service may use essential security, session, fraud-prevention and payment technologies under its own notices and controls. Halow Capital does not use cookies to access your private keys, seed phrase or wallet recovery information.

8. Your Choices and Controls

8.1 Cookie banner

When the cookie banner is shown, the available choices should include:

a. Accept All, which enables the optional categories described by the banner;b. Reject All or Essential Only, which leaves only exempt or strictly necessary technologies active; andc. Customise, where more than one optional category is used.

Rejecting optional technologies should not be made materially harder than accepting them. A refusal does not prevent access to public Website content or BASE purchase information.

8.2 Cookie Settings

You may review or change your choice through the Cookie Settings control made available through the Website, normally in the footer. When you change a choice, the Website should update the relevant consent signals without unnecessary delay.

8.3 Remembering a choice

A consent-preference cookie or local-storage record is used to remember your selection. This is treated as necessary to provide the cookie-control service and evidence that the Website respected your choice.

8.4 Browser controls

Most browsers allow you to view, block or delete cookies and clear local storage. Blocking all storage may affect forms, consent preferences, security and other Website functions. Browser controls may not prevent server-side logs or remove information already transmitted before the setting changed.

8.5 Google controls

Google provides browser and account controls, including a Google Analytics opt-out browser add-on. These tools are independent of Halow Capital’s Cookie Settings and may provide an additional layer of control.

8.6 Withdrawal

Withdrawing consent is as easy as giving it. Withdrawal applies to future use and does not make earlier processing unlawful. Where a technology is used under a legal exception rather than consent, the Website will provide the applicable objection control where required.

9. Information, Lawful Bases and International Processing

9.1 Personal information

Cookies and related technologies may involve personal information, including IP address, device information, approximate location, identifiers and Website interactions. The Privacy Policy explains the purposes, lawful bases, recipients, international transfers, retention and individual rights connected with that information.

9.2 Providers outside the United Kingdom

Base44, Google and other technology providers may process information outside the United Kingdom. Halow Capital uses the contractual and organisational safeguards described in the Privacy Policy where required. The use of a cookie banner does not by itself provide or replace an international-transfer safeguard.

9.3 Consent and UK GDPR lawful basis

Where PECR consent is required and the technology involves personal information, consent will ordinarily also be the relevant UK GDPR lawful basis for the collection through that technology. Later use may require a separate lawful basis and must remain compatible, fair and transparent.

10. Retention and Consent Records

10.1 Technology duration

We use technologies for no longer than is reasonably necessary for their stated purpose. Typical durations appear in the register. Provider defaults are not automatically accepted where a shorter duration is appropriate.

10.2 Consent records

We may retain a record of the consent choice, time, region, policy or banner version and related technical information for a period appropriate to demonstrate compliance, investigate a complaint and apply the preference on later visits.

10.3 Refreshing consent

We may ask again after a reasonable period, when the preference record expires, when a different person may be using the device, or when the purposes, providers or technologies change materially. A refreshed request will not use misleading design or imply that a previous rejection was invalid.

11. Website and Cookie Audits

Halow Capital will use reasonable efforts to:

a. audit the Website for cookies, local storage, tags, pixels, embedded content and similar technologies;b. identify the provider, purpose, duration and legal control for each technology;c. test that optional Analytics storage is denied before consent and after withdrawal;d. test that Reject All or Essential Only works as stated;e. review Google Consent Mode and Base44 changes;f. remove obsolete or unnecessary technologies; andg. update this Policy and the banner when the live configuration changes materially.

A Cookie Policy cannot correct a defective technical implementation. The banner, tag ordering and provider settings must operate consistently with the wording in this document.

12. Changes to This Policy

We may update this Policy to reflect changes in law, official guidance, Website technology, providers, consent tools or business operations. The updated version will be published with a revised “Last Updated” date.

Where a material change introduces a new non-exempt purpose, we will obtain the required choice before activating that purpose. Continued browsing does not replace consent where a positive choice is required.

13. Contact Details

Questions or complaints about cookies or Website tracking should be sent to:

SA Futures Limited, trading as Halow CapitalCompany number: 14219285Registered office: Martlet House E1 Yeoman Gate, Yeoman Way, Worthing, West Sussex, United Kingdom, BN13 3QZEmail: halow@halowcapital.comTelegram: @HalowhqWebsite: www.halowcapital.com

For a formal privacy or cookie complaint, email is the preferred contact method. You may also have the right to complain to the Information Commissioner’s Office. Further information is available at ico.org.uk.

© 2026 SA Futures Limited, trading as Halow Capital. All rights reserved.