TOURLINK COOKIE POLICY

This Policy applies to all visitors to our Website, including customers purchasing e‑SIM services and participants in our Affiliate Program. For comprehensive details on how we handle personal data, please see the Tourlink Privacy Policy.

This Policy complies with UK privacy laws, including the Privacy and Electronic Communications Regulations (PECR), UK GDPR, and prepares for the Data (Use and Access) Act 2025 changes effective June 2026.

1. What Are Cookies?

Cookies are small text files placed on your computer or mobile device when you visit a website. Cookies help websites remember your actions and preferences (such as login status, language, shopping cart contents, and other display settings) over a period of time, so you don't have to repeatedly re‑enter them when you return to the site or browse from one page to another.

1.1 Types of Cookies

• Session cookies are deleted when you close your browser
• Persistent cookies remain on your device until they expire or are manually deleted
• First‑party cookies are set by OMAX directly
• Third‑party cookies are set by other organizations through our Website

1.2 Similar Technologies

This Policy also covers similar technologies such as web beacons, pixels, local storage, and other tracking technologies that serve similar functions to cookies.

2. Cookies We Use

2.1 Cookie Categories

2.2 Detailed Cookie Purposes

Strictly Necessary Cookies:

• Authentication: Keeping you logged in securely
• Security: Protecting against cross-site request forgery (CSRF) attacks
• Shopping Cart: Maintaining your e‑SIM package selections
• Payment Processing: Enabling secure checkout functionality
• Cookie Consent: Remembering your cookie preferences
• Load Balancing: Ensuring optimal Website performance

Analytics Cookies:

• Website Performance: Measuring page load times and identifying technical issues
• User Behavior: Understanding navigation patterns and popular content
• Conversion Tracking: Measuring effectiveness of our marketing campaigns
• Service Optimization: Identifying areas for Website and service improvement
• Error Monitoring: Detecting and diagnosing Website problems

Marketing/Advertising Cookies:

• Campaign Attribution: Tracking which marketing channels drive conversions
• Remarketing: Showing relevant Tourlink ads to previous visitors
• Affiliate Tracking: Attributing sales to affiliate partners for commission calculation
• Cross-platform Analytics: Understanding user journeys across different devices
• A/B Testing: Optimizing marketing messages and Website design

Preference Cookies:

• Localization: Remembering your preferred language and currency
• Interface Settings: Maintaining your chosen Website theme and layout
• Accessibility Options: Preserving accessibility preferences for future visits
• Regional Content: Displaying relevant e‑SIM packages for your location

3. Third‑Party Services and Data Sharing

3.1 Analytics Providers (Consent Required)

Matomo Cloud (EU-hosted)

• Purpose: Privacy-centric web analytics and user behavior tracking
• Data Shared: Anonymized usage statistics, page views, session duration
• Retention: 26 months maximum
• Privacy Features: IP anonymization, user opt-out respect, GDPR compliant

Google Analytics 4 (with Consent Mode)

• Purpose: Website analytics and performance measurement
• Data Shared: Aggregated usage patterns, conversion events
• Retention: 26 months (automatically deleted thereafter)
• Privacy Features: consent mode, data minimization, user deletion controls

3.2 Marketing Platforms (Consent Required)

Meta (Facebook) Pixel

• Purpose: Conversion tracking and remarketing for Facebook/Instagram ads
• Data Shared: Purchase events, page views, custom audiences (hashed)
• Retention: 180 days for events, 28 days for pixel data
• Privacy Features: Limited data use settings, automatic deletion

Google Ads and Conversion Tracking

• Purpose: Campaign performance measurement and remarketing
• Data Shared: Conversion events, audience segments (anonymized)
• Retention: 540 days for conversion data
• Privacy Features: User-level conversion deletion, consent signals

3.3 Affiliate Program Tracking

Commission Attribution System

• Purpose: Tracking affiliate referrals and calculating commissions
• Method: QR codes, referral URLs, and alphanumeric codes (not cookies)
• Data Shared: Purchase attribution, commission calculations
• Retention: 7 years for tax and compliance purposes
• Privacy Features: Code-based tracking minimizes personal data collection

Performance Analytics

• Purpose: Measuring affiliate marketing effectiveness
• Data Shared: Aggregated conversion rates, popular products
• Retention: 5 years for business intelligence
• Privacy Features: Data anonymization, aggregate reporting only

4. Web Beacons, Pixels, and Email Tracking

4.1 Email Communications

Our service emails may contain tracking pixels to measure:

• Email Open Rates: Whether and when emails are opened
• Link Clicks: Which links within emails are most engaging
• Device Information: Email client and approximate location
• Engagement Patterns: Optimal sending times and frequency

Your Control: You can prevent email tracking by:

• Viewing emails in plain-text mode
• Blocking remote images in your email client
• Unsubscribing from marketing communications
• Contacting us to disable tracking for your account

4.2 Website Pixels

We use web beacons for:

• Page Performance: Measuring load times and technical issues
• Content Effectiveness: Understanding which content resonates with users
• Cross-device Tracking: Linking user sessions across devices (with consent)
• Fraud Prevention: Detecting suspicious activity and protecting users

5. Your Cookie Choices and Controls

5.1 Managing Consent

Cookie Banner:

• Appears on your first visit or when cookie settings change
• Allows granular consent for each cookie category
• Provides clear information about each cookie type
• Enables easy consent withdrawal

Cookie Settings Panel:

• Accessible via the "Cookie Settings" link in Website footer
• Available at any time to modify your preferences
• Provides detailed information about active cookies
• Offers one-click disable for non-essential cookies

Account Dashboard: (for registered users)

• Cookie preferences saved to your account
• Consistent settings across devices when logged in
• Detailed cookie activity logs
• Bulk consent management options

5.2 Browser Controls

Browser Settings:
Most browsers allow you to:

• Block all cookies (may impair Website functionality)
• Block third-party cookies while allowing first-party cookies
• Delete cookies periodically or when closing browser
• Get notifications before cookies are set

Browser-Specific Instructions:

• Chrome: Settings → Privacy and Security → Cookies and other site data
• Firefox: Options → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Cookies and website data
• Edge: Settings → Site permissions → Cookies and site data

Note: Disabling strictly necessary cookies may prevent core Website functions like logging in, maintaining your shopping cart, or completing purchases.

5.3 Industry Opt-Out Tools

Advertising Opt-Outs:

• Network Advertising Initiative: http://optout.networkadvertising.org
• Digital Advertising Alliance: http://optout.aboutads.info
• European Interactive Digital Advertising Alliance: http://youronlinechoices.eu
• Your Ad Choices: Provides browser-based opt-out tools

Social Media Platform Controls:

• Facebook: Ad Preferences in your Facebook account settings
• Google: Ad Settings in your Google account (ads.google.com/optout)
• LinkedIn: Account Settings → Privacy → Advertising data

6. Data (Use and Access) Act 2025 Compliance

6.1 Upcoming Changes (Effective June 2026)

The UK Data (Use and Access) Act 2025 introduces new cookie exemptions that will reduce consent requirements for certain categories:

New Exemptions Include:

• Statistical Analysis: Analytics cookies for service improvement
• Security Functions: Fraud detection and system protection
• Functionality Enhancement: User interface optimization
• Performance Monitoring: Service quality measurement
• Research Purposes: Academic and market research (anonymized)

Continued Requirements:

• Clear Information: Transparent disclosure of cookie usage
• Easy Opt-Out: Simple mechanisms to disable tracking
• Data Minimization: Collecting only necessary information
• Purpose Limitation: Using data only for stated purposes
• Regular Review: Periodic assessment and deletion of unnecessary data

7. Affiliate Program Cookie Considerations

7.1 Affiliate Tracking Methods

Our Affiliate Program primarily uses non-cookie tracking methods to minimize privacy impact:

QR Codes:

• No Personal Data: QR codes contain only affiliate identification
• Direct Attribution: Purchase attribution at checkout
• Privacy-Friendly: No tracking across websites or sessions
• Transparent: Users can see affiliate relationship clearly

Referral Links:

• URL Parameters: Affiliate identification embedded in links
• Session-Based: Attribution only during active shopping session
• First-Party: No third-party tracking services involved
• Opt-In Basis: Users actively click affiliate links

8. International Data Transfers

8.1 Transfer Safeguards

When cookies involve data transfers outside the UK/EEA:

Legal Mechanisms:

• Standard Contractual Clauses (SCCs): For non-adequate countries
• Adequacy Decisions: Where available (e.g., to EU/EEA)
• UK Extension Mechanism: Additional UK-specific protections
• Corporate Binding Rules: For intra-group transfers

9. Cookie Retention and Deletion

9.1 Automatic Deletion

Session Cookies:

• Automatic Removal: Deleted when browser session ends
• No Persistent Storage: Not saved to device permanently
• Fresh Start: New session creates new temporary cookies

9.2 Retention Schedules

10. Updates and Changes

10.1 Policy Updates

We may update this Cookie Policy to reflect:

• Legal Changes: New regulations or regulatory guidance
• Technology Updates: New cookie technologies or third-party services
• Service Changes: Modifications to Website functionality
• User Feedback: Improvements based on user suggestions

10.2 Notification Process

Material Changes:

• Email Notification: Sent to registered users 30 days in advance
• Website Banner: Prominent notice displayed for 30 days
• Version History: Previous versions archived and accessible
• Summary of Changes: Key modifications highlighted clearly

11. Contact Information

11.1 Cookie-Related Inquiries

Data Protection Officer:

• Email: [email protected]
• Subject Line: "Cookie Policy Inquiry"
• Response Time: Within 5 business days
• Languages: English, with translation services available

Privacy Team:

• Email: [email protected]
• Phone: +44 20 805 861 85
• Hours: Monday-Friday, 9 AM - 6 PM GMT
• Address: OMAX Group Ltd, 71‑75 Shelton Street, London WC2H 9JQ, UK

11.2 Technical Support

Cookie Technical Issues:

• Email: [email protected]
• Subject Line: "Cookie Technical Support"
• Support Portal: https://tourlink.me/support
• Live Chat: Available during business hours

Affiliate Program Cookies:

• Email: [email protected]
• Affiliate Portal: https://tourlink.me/affiliate-program
• Dedicated Support: Specialized assistance for affiliate partners

11.3 Regulatory Complaints

UK Supervisory Authority:

• Information Commissioner's Office (ICO)
• Website: https://ico.org.uk
• Phone: 0303 123 1113
• Online Complaints: https://ico.org.uk/make-a-complaint

EU Supervisory Authorities:

• For EU/EEA Residents: Contact your local data protection authority
• EDPB Website: https://edpb.europa.eu
• Cross-border Issues: ICO coordinates with EU authorities