Cookie Policy

Last updated: 7 October 2026

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1. Scope

1.1 This Policy explains the cookies and similar technologies used on www.hi2morrow.com and its subdomains, what each of them is for, how long it is stored, who receives the data, and how you may give, refuse or withdraw your consent.

1.2 It forms part of the Privacy Policy, which describes how we process personal data generally and sets out your rights in full. Where a cookie or identifier is linked to your account, the resulting data is personal data and the Privacy Policy applies to it.

1.3 This Policy does not cover the trading terminal's operation during a Qualification Program. Data generated by trading activity is described in the Qualification Privacy Policy.

1.4 Nor does it cover cookies set by third-party sites you reach by following a link from ours. Those sites publish their own notices.

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2. Cookies and Similar Technologies

2.1 A cookie is a small text file which a website asks your browser to store on your device and to send back on later visits. Cookies allow a site to recognise a browser between page loads, which is what makes a signed-in session, a shopping basket or a remembered preference possible.

2.2 We also use technologies which are not cookies but serve the same function and are treated the same way in this Policy:

(a) local storage — a store within your browser which retains values indefinitely and is not cleared when the browser is closed, used here to keep a copy of the identifiers also held in cookies so that they survive the loss of a cookie;

(b) pixels and tags — small pieces of code loaded from a third party which record that a page was viewed or an action was taken, and which allow that third party to set or read its own cookies;

(c) software development kits and scripts loaded from a third party, which may collect device and connection information as a consequence of being loaded.

2.3 A cookie on its own does not usually identify you by name. Combined with the other information we hold, and in particular with your account, some of the identifiers below can be linked to you, and we treat them accordingly.

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3. Consent

3.1 Cookies which are strictly necessary are set without asking, because the Website cannot be provided without them and no law requires consent for them.

3.2 When other cookies are set. On your first visit to the Website a banner names the purposes involved, links to this Policy, and allows you to accept or to refuse. On the Website, if your device is set to a time zone of Europe, including every part of the European Economic Area and the United Kingdom, the analytics and marketing services described in Section 6 set their cookies and identifiers only after you accept them. Elsewhere they start when you arrive on the Website, and you may refuse them at any time. The marketing cookies set by hi2morrow and listed in Section 5 are set in either case, as Section 3.6 explains. The Client Section is described in Section 3.7.

3.3 Refusal. The banner offers a refusal which takes one action, in the same place and with the same prominence as acceptance. Refusing leaves the Website fully usable except for the features which depend on the cookies you refused.

3.4 Effect of taking no action. On the Website, if your device is set to one of the time zones described in Section 3.2, silence is not treated as consent: until you accept, the Google tags described in Section 6 run with their consent settings denied, so that they store and read no cookies and send only measurements which do not use cookies, the Meta Pixel is loaded but sends no events and sets no cookie, and the Yandex Metrica tag is not loaded. Elsewhere on the Website, until you refuse, the services described in Section 6 run and set their cookies and identifiers as described there, and the Google tags run with their consent settings granted.

3.5 Record of your choice. The choice is stored in the cookie_consent cookie described in Section 5 and applies on every page of hi2morrow.com. It is not available to subdomains such as the Client Section at trader.hi2morrow.com. You may change it at any time, as described in Section 9.

3.6 Effect of a refusal or withdrawal. A refusal on the Website, or a withdrawal of consent given earlier, is recorded at once. From that moment the Google tags run with their consent settings denied, so that they no longer read or write their cookies and send only measurements which do not use cookies, and the Meta Pixel sends no events. From the next page you open, Yandex Metrica, including session recording, is no longer loaded. Cookies and identifiers already set are not removed by a refusal; you may delete them in your browser, as described in Section 10. The marketing cookies and local storage values set by hi2morrow and listed in Section 5 are set whatever you choose in the banner, on the basis of our legitimate interests in attributing registrations and purchases to the advertisement or link that produced them (Section 5.1(c) of the Privacy Policy).

3.7 Client Section. The Client Section at trader.hi2morrow.com does not show the banner, and a choice made on the Website does not apply there (Section 3.5). Google Analytics and Google Ads, Yandex Metrica with session recording, the Meta Pixel and the Intercom support chat are loaded there from the moment it opens, whatever the time zone of your device, on the basis of our legitimate interests (Section 5.1(c) of the Privacy Policy). You may block them in your browser, as described in Section 10.

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4. Categories of Cookies

4.1 Strictly necessary. These keep the Website and the Client Section working: they maintain a signed-in session, protect against forged requests, distribute load between servers, carry a payment through to its result, and record the cookie choice you have made. They are set under the exemption for storage which is strictly necessary to provide a service you have requested, in Article 5(3) of Directive 2002/58/EC and the national legislation implementing it, and consent is therefore not required for them. Where the information they hold is afterwards processed as personal data, that later processing rests on Article 6(1)(b) or Article 6(1)(f) of the GDPR. They cannot be switched off through the banner.

4.2 Analytics and performance. These tell us how many people visit, which pages they read, where they arrive from, how long they stay, where they leave, and which parts of a page cause difficulty. We use them to decide what to fix and what to build. On the Website, where your device is set to one of the time zones described in Section 3.2, they are set only with your consent. Elsewhere on the Website they are set when you arrive, on the basis of our legitimate interests (Section 5.1(c) of the Privacy Policy), and you may refuse them at any time through the banner (Section 3.6). In the Client Section they are set as Section 3.7 describes.

4.3 Marketing and advertising. These measure which advertisement or affiliate link brought a visitor to the Website, whether a registration or purchase followed, and allow advertising platforms to attribute that result and to build audiences. On the Website, where your device is set to one of the time zones described in Section 3.2, they are set only with your consent. Elsewhere on the Website they are set when you arrive, on the basis of our legitimate interests (Section 5.1(c) of the Privacy Policy), and you may refuse them at any time through the banner (Section 3.6). In the Client Section they are set as Section 3.7 describes. The marketing cookies set by hi2morrow and listed in Section 5 are set whatever you choose, as Section 3.6 explains.

4.4 We do not use cookies to make decisions about your Qualification, and no advertising or analytics identifier is used in the automated controls described in the Qualification Privacy Policy.

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5. Cookies Set by hi2morrow

5.1 The following are set by hi2morrow on the hi2morrow.com domain.

5.2 Local storage. The values h2m_cid, h2m_attribution and t360_tracking are also held in your browser's local storage, so that attribution survives if the corresponding cookie is lost. They remain until you clear your browsing data. The value t360_tracking is kept for no longer than ninety (90) days, the storage period of its cookie.

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6. Cookies and Technologies Set by Third Parties

6.1 The following third-party services are used on the Website. Each sets its own cookies and receives the data described. When each of them starts, and what changes when you refuse it, is explained in Sections 3.2 to 3.7.

6.2 Google Analytics 4 and Google Ads

Provider: Google Ireland Limited and Google LLC. Measurement identifier: G-S79WWR8PR0, loaded from www.googletagmanager.com.

We use it to count visits, see which pages are read and which campaigns bring people to the site. It sets cookies in the _ga family which contain a randomly generated identifier for your browser, and it receives your IP address, the pages you view, and the technical characteristics of your device. The same Google tag loads the Google Ads conversion and remarketing tags of accounts AW-17890673101 and AW-17890883623, which set cookies in the _gcl family and allow Google to measure the result of our advertising and to build audiences. Google Consent Mode is implemented on the Website: the four consent settings it defines (storage for advertising, advertising user data, advertising personalisation and analytics storage) start as denied where your device is set to one of the time zones described in Section 3.2 and as granted elsewhere; they are set to granted when you accept and to denied when you refuse. While they are denied, the Google tags send only measurements which do not use cookies. In the Client Section the Google tags run as Section 3.7 describes.

Category: analytics, and marketing where the advertising settings are enabled. Storage period: up to two (2) years, as set by Google.

Google's privacy notice: policies.google.com/privacy.

6.3 Meta Pixel

Provider: Meta Platforms Ireland Limited. Pixel identifier: 743897428136355, loaded from connect.facebook.net.

It records that a page was viewed, that a button such as "Become an Affiliate" was pressed, and that a registration or purchase followed, so that the result of an advertising campaign can be measured and audiences can be built. It sets the _fbp cookie, reads the fbclid value from the address, and transmits to Meta the page address, your IP address, and browser and device characteristics. Where you hold a Meta account, Meta may connect this activity to it. For the collection and transmission of this data we and Meta act as joint controllers within the meaning of Article 26 of the GDPR, on the terms of Meta's controller addendum; you may exercise your rights against either of us, and Meta's own notice governs what it does with the data thereafter.

Category: marketing. Storage period: up to ninety (90) days for _fbp, as set by Meta, and, in respect of data held by Meta, for the period stated in Meta's own terms.

Meta's privacy notice: facebook.com/privacy/policy.

6.4 Yandex Metrica

Provider: the Yandex group entity which operates Yandex Metrica for your region, as identified in the Yandex Metrica terms of use. Counter number: 103272272, loaded from mc.yandex.ru.

We use it for visit statistics, to see which links are followed, where attention falls on a page, and to record sessions as described in Section 7. It sets cookies in the _ym family and receives your IP address, the pages you view, your interaction with those pages, and device characteristics.

Category: analytics. Storage period: up to one (1) year, as set by the provider. See Section 11 on where this data is processed.

The provider's privacy notice: yandex.com/legal/confidential.

6.5 Google Fonts

Typefaces are loaded from fonts.googleapis.com and fonts.gstatic.com. No cookie is set, but loading a font transmits your IP address and browser characteristics to Google. This happens as part of displaying the page.

6.6 Payment providers

When you reach the payment step, the payment provider handling your transaction may set cookies which are strictly necessary to process the payment and to prevent fraud. These are set by the provider, are governed by the provider's own notice, and are limited to the payment.

6.7 Intercom

Provider: Intercom R&D Unlimited Company and Intercom, Inc. Workspace identifier: pg83m5iw, loaded from widget.intercom.io.

We use it for the support chat on the Website and in the Client Section. Its code is loaded when a page opens, which transmits your IP address and browser characteristics to Intercom. When the chat is started, it sets the following first-party identifiers, as published by Intercom: intercom-session-pg83m5iw, which keeps your conversations available, for one (1) week; intercom-device-id-pg83m5iw, which identifies the device in order to prevent abuse, for two hundred and seventy (270) days, renewed with use; and intercom-id-pg83m5iw, an anonymous visitor identifier held in local storage without an expiry of its own.

Category: strictly necessary for the support chat you choose to use.

Intercom's privacy notice: intercom.com/legal/product-privacy-notice.

6.8 The identifiers listed above are set by the third party concerned, and the periods stated are those published by that third party. A provider may change them without reference to us. The list is reviewed periodically and this Policy is updated when a change comes to our attention.

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7. Session Recording

7.1 Yandex Metrica is configured with session recording, which the provider calls Webvisor. When it is active it records your movements and clicks on the page, how far you scroll, and how you move through a form, so that we can see where a page is confusing or broken.

7.2 Session recording is part of the analytics category. On the Website, where your device is set to one of the time zones described in Section 3.2, it runs only after you accept; elsewhere on the Website it runs from your arrival. In either case it is no longer loaded from the next page you open after you refuse cookies in the banner. In the Client Section it runs from the moment the Client Section opens (Section 3.7).

7.3 Masking and what a recording contains. The provider applies automatic recognition to fields which appear to carry personal information and replaces their contents with asterisks in the recording. The provider does not warrant that recognition is accurate in every case. Passwords are never recorded, and card details are never entered on our pages: they are entered on the payment provider's own page. You should nonetheless know that a recording captures the page as it was displayed, which on a signed-in page can include information already shown on screen. Session recording also operates in the Client Section at trader.hi2morrow.com, where a recording can include information already displayed on a signed-in page.

7.4 Recordings are retained by the provider for fifteen (15) days and are used to improve the Website. They are not used to assess a Participant, and they play no part in any Qualification decision.

7.5 If you do not want your sessions recorded on the Website, refuse cookies in the banner. Section 9 explains how. In the Client Section, block session recording in your browser, as described in Section 10.

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8. Storage Periods

8.1 A session cookie is deleted when you close your browser. A persistent cookie remains until the period stated in Sections 5 and 6 has run, or until you delete it.

8.2 The periods stated are maximum periods. A cookie may be replaced or renewed on a later visit, which starts its period again.

8.3 Where you refuse or withdraw consent, the services concerned change as described in Section 3.6. Cookies already set remain in your browser until their period runs out or until you delete them. Data already transmitted to a third party before withdrawal is dealt with by that third party under its own notice and its retention rules, and we cannot recall it.

8.4 Local storage has no expiry of its own. The values in Section 5.2 remain until you clear your browsing data, and t360_tracking in any event no longer than ninety (90) days, as stated in Section 5.2.

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9. Giving, Refusing and Withdrawing Consent

9.1 On your first visit to the Website the banner describes the cookies we use and offers two choices, Decline and Accept all. Where your device is set to one of the time zones described in Section 3.2 it appears at once; elsewhere it appears a few seconds after the page opens. Until you choose, the position is as described in Section 3.4.

9.2 To change your choice at any time, use the Cookie settings control in the footer of any page. It reopens the banner. An acceptance takes effect at once; a refusal has the effect described in Section 3.6.

9.3 Withdrawal. No explanation is required, and withdrawal does not affect the lawfulness of the processing carried out before it.

9.4 Effect of withdrawal. Withdrawal has the effect described in Section 3.6. Cookies and local storage values already set, including third-party cookies set under the third party's own domain, are not removed by it; you may clear them in your browser, as described in Section 10.

9.5 Limits of withdrawal. Withdrawal does not sign you out, does not delete your account, and does not affect the records described in the Qualification Privacy Policy, which are not held through cookies.

9.6 You may also write to privacy@hi2morrow.com to withdraw consent and to ask for the identifiers associated with your browser to be deleted.

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10. Browser Controls

10.1 Your browser can block cookies, block only third-party cookies, delete cookies already stored, or ask you each time. The controls are usually found here:

(a) Chrome — Settings, then Privacy and security, then Third-party cookies and Site data;

(b) Safari — Settings, then Privacy, then Manage Website Data;

(c) Firefox — Settings, then Privacy & Security, then Cookies and Site Data;

(d) Edge — Settings, then Cookies and site permissions.

10.2 Blocking all cookies, including those which are strictly necessary, may prevent you from signing in to the Client Section, completing a payment, or taking part in a Qualification Program.

10.3 Browser settings apply to the browser you set them in. A different browser, a different device or a private window does not carry your choice, and the banner appears again.

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11. International Transfers of Cookie Data

11.1 The third parties in Section 6 may be established outside the country in which you are reading this page, and the data described is transferred to them.

11.2 Transfers to Google and to Meta from the European Economic Area and the United Kingdom rely on the safeguards published by those providers, which include Standard Contractual Clauses and, where the recipient is certified, the EU-US Data Privacy Framework and its United Kingdom extension.

11.3 For visitors outside the Russian Federation the service is provided by Air Smart Advertising Solutions FZ-LLC (4 Internet City Road, Al Sufouh 2, Dubai, United Arab Emirates), which acts as our processor under standard contractual clauses. The provider does not publish the countries in which its infrastructure is located; the list of sub-processors and their locations is available from the provider on written request. There is no adequacy decision for that country under the GDPR. On the Website, where your device is set to one of the time zones described in Section 3.2, Yandex Metrica is loaded only after you accept, and your consent is the basis on which that transfer is made. Elsewhere on the Website it is loaded when you arrive, and the transfer takes place until you refuse cookies in the banner (Section 3.6). In the Client Section it is loaded from the moment the Client Section opens (Section 3.7). In every case you are informed here that the country concerned does not offer a level of protection which the European Commission has found to be adequate, and that your rights may be harder to enforce there.

11.4 Section 7 of the Privacy Policy describes our approach to international transfers generally.

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12. Your Rights

12.1 The rights described in the Privacy Policy apply to data collected through cookies: to know what is held, to obtain a copy, to have it corrected, to have it deleted, to restrict its use, to receive it in a portable form, to object, and to complain to a supervisory authority.

12.2 Because a cookie identifier is tied to a browser rather than to a name, we may need further information to connect a request to the right records, and in some cases we may be unable to identify you from a cookie identifier alone. Where that is the case, we shall tell you.

12.3 Requests are made at the address in Section 14.

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13. Changes to This Policy

13.1 We review this Policy when a service is added or removed and when a provider changes what it sets. The date at the top shows when it was last changed.

13.2 Where a change introduces a new purpose or a new third party, this Policy is updated before the change takes effect.

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14. Contact

Hi2morrow — Data Protection Hitomorrow Assessment Data Classification and Analysis L.L.C United Arab Emirates, Commercial License No. 1275729 Email: privacy@hi2morrow.com · Support: support@hi2morrow.com · Formal notices: legal@hi2morrow.com Telephone: +971 54 358 5747

Complaints may be made to a supervisory authority, as described in Section 14 of the Privacy Policy.

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This Cookie Policy forms part of the Privacy Policy and does not constitute legal advice.