Cookie Policy

Last updated: 5 September 2026

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1. Scope & Purpose

1.1 This Cookie Policy ("Policy") describes how Hitomorrow Assessment Data Classification and Analysis L.L.C and its group entities ("hi2morrow", "we", "us", or "our") utilize cookies, local storage, pixel tags, and related tracking technologies across www.hi2morrow.com, its subdomains, and the Client Section.

1.2 This Policy constitutes an integral part of our Privacy Policy. Where identifiers collected via tracking technologies can be associated with an identified or identifiable natural person, such information is treated as personal data and processed in accordance with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where applicable, Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC (ePrivacy Directive).

1.3 This Policy does not govern third-party platforms or services accessed through outbound links from our platform. Such external services operate under their own terms and privacy notices.

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2. Tracking Technologies and Their Functions

2.1 Cookies are standard data files placed by a web server on your browser or device, enabling the platform to recognize your session across page transitions, maintain authenticated states, and remember user preferences.

2.2 Complementary Technologies. We also employ functionally equivalent technologies, including:

(a) Local and session storage: Browser-managed client data stores utilized to preserve session continuity, preference persistence, and authentication status across browser lifecycles;

(b) Pixels and web beacons: Embedded scripts and graphic elements utilized to verify page interaction, evaluate campaign efficacy, and facilitate partner attribution;

(c) Diagnostic and telemetry scripts: Client-side modules deployed to assess system performance, interface stability, and technical interaction integrity.

2.3 While tracking identifiers do not directly reveal your identity, they may be linked to your user profile where you authenticate into your account, and are treated with rigorous confidentiality and technical protection.

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3. Categories of Cookies We Use

3.1 Strictly Necessary Technologies (Essential). These are indispensable for the core operation, security, and administrative functionality of our platform and the Client Section. They facilitate:

(a) Continuous user authentication and secure session maintenance;

(b) Cross-Site Request Forgery (CSRF) protection and security validation;

(c) Server load balancing and network routing;

(d) Transaction state integrity throughout the payment lifecycle;

(e) Systematic recording and enforcement of your privacy preferences.

These technologies are deployed on the basis of legitimate necessity pursuant to Article 5(3) of Directive 2002/58/EC and applicable data protection regulations. Because the platform cannot operate securely without them, they cannot be deactivated via the consent management interface.

3.2 Performance and Analytical Technologies. These collect aggregated, non-directly identifying metrics concerning platform utilization, system health, and navigation patterns. They assist us in:

(a) Evaluating page latency, server response times, and application uptime;

(b) Understanding aggregate audience journeys, technical bottlenecks, and interface friction points;

(c) Diagnosing technical anomalies, form submission errors, and system responsiveness;

(d) Validating the technical stability and scalability of platform features.

All analytical telemetry operates on an aggregated basis. Where interface diagnostic modules operate to identify rendering errors or navigation obstacles, sensitive input fields (including credential entries, personal identifiers, and payment data) are masked and obfuscated by default. Analytical technologies are activated strictly pursuant to your prior affirmative consent.

3.3 Marketing and Attribution Technologies. These are utilized to verify campaign effectiveness, monitor authorized referral relationships, and attribute platform acquisitions. They allow:

(a) Verification and attribution of visits originating from verified marketing partners and affiliates;

(b) Measurement of promotional conversion funnels and advertising campaign return-on-investment;

(c) Prevention of multi-channel attribution conflicts and affiliate commission fraud;

(d) Audience categorization for targeted promotional engagements across external networks.

Marketing and attribution technologies are deployed exclusively upon receipt of your explicit consent.

3.4 Qualification Integrity. No marketing or advertising identifiers are utilized in the evaluation of your trading performance or within the automated risk controls governing the Qualification Program.

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4. Summary of Technologies Deployed

4.1 The following table summarizes the primary categories of cookies and identifiers utilized across the platform:

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5. Consent Architecture and Preference Management

5.1 Affirmative Consent Standard. On your initial visit to the Website, a consent management banner is presented. Non-essential technologies (performance, analytics, and marketing) are withheld by default until you deliver an explicit, affirmative choice.

5.2 Silence or Inaction. Continued browsing without affirmative acceptance is treated as a refusal of non-essential technologies. No tracking cookies are placed and no marketing identifiers are recorded absent explicit action.

5.3 Modifying Your Preferences. You retain the right to modify or revoke your consent at any time. You may adjust your choices via the Cookie settings control accessible in the footer of every page. Revocation takes effect immediately for all subsequent operations.

5.4 Consequences of Revocation. When consent is withdrawn, analytical and marketing scripts cease execution, and dependent client-side identifiers are cleared from your browser so far as technically feasible.

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6. Third-Party Service Providers

6.1 We partner with established enterprise service providers to deliver hosting, traffic telemetry, audience measurement, and secure payment processing. These providers operate under rigorous data protection agreements and confidentiality covenants.

6.2 Where third-party technologies operate on our platform, the provider processes data either as our processor subject to contractual restrictions, or, where required by the service model (such as social network conversion measurement), under standard joint-controller or controller terms published by that provider.

6.3 Payment Gateways. During the transaction phase, authorized payment service providers place strictly necessary security cookies to authenticate transactions and prevent financial fraud. These operations are governed by the respective provider's regulatory standards and privacy disclosures.

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7. Browser-Level Controls and Opt-Out Mechanisms

7.1 In addition to our consent management interface, modern browsers enable you to configure cookie preferences, reject third-party cookies, or clear stored site data:

(a) Google Chrome: Settings > Privacy and security > Third-party cookies and Site data;

(b) Apple Safari: Settings > Privacy > Manage Website Data;

(c) Mozilla Firefox: Settings > Privacy & Security > Enhanced Tracking Protection;

(d) Microsoft Edge: Settings > Cookies and site permissions.

7.2 Please note that blocking all cookies—including strictly necessary technologies—may impede secure authentication, account administration, and transaction processing within the Client Section.

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8. Storage Duration and Data Retention

8.1 Session-Based Technologies expire automatically when the browser session is terminated.

8.2 Persistent Technologies remain stored on your device for the duration defined in Section 4 or until deleted manually or upon revocation of consent.

8.3 Upon revocation of consent or account closure, non-essential tracking values are cleared or decoupled from your user profile.

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9. International Data Transfers

9.1 Technical data generated by platform tracking technologies may be transferred to and processed across infrastructure located in jurisdictions outside your country of residence, including the United Arab Emirates, Cyprus, the European Economic Area, and other jurisdictions where our cloud infrastructure providers operate.

9.2 Where data is transferred across international borders, we implement recognized transfer safeguards, including Standard Contractual Clauses approved by the European Commission, data transfer agreements, and supplementary organizational protections in compliance with applicable law.

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10. Individual Rights and Inquiries

10.1 Under applicable data protection legislation, you possess rights to access, rectify, erase, restrict, or object to the processing of personal data associated with tracking identifiers, as well as the right to lodge a complaint with a competent supervisory authority.

10.2 Because tracking identifiers are tied to a browser instance rather than directly to a name, we may require additional contextual details to verify and address requests concerning specific device records.

10.3 To exercise your statutory rights or submit questions concerning this Policy, please contact our Data Protection Officer at privacy@hi2morrow.com.

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11. Policy Amendments

11.1 We may amend this Policy periodically to reflect architectural updates, regulatory developments, or operational modifications. The latest revision date is indicated at the beginning of this document.

11.2 Material changes that introduce new tracking purposes or third-party recipients will be accompanied by an updated consent prompt prior to deployment.

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12. Contact Information

If you have questions, comments, or requests regarding this Cookie Policy or your privacy preferences, please contact our Data Protection Team at privacy@hi2morrow.com.

For comprehensive corporate details and regulatory disclosures, please refer to our Privacy Policy.

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This Cookie Policy constitutes part of hi2morrow's contractual and legal compliance framework.