COOKIE POLICY
Company: Melian Dialogue Limited Jurisdiction: Republic of Kenya Contact: info@meliandialogue.com Effective Date: [Insert Effective Date] Version: 1.0
1. Introduction
This Cookie Policy explains how Melian Dialogue Limited (the "Company", "we", "us", or "our") uses cookies and comparable tracking technologies on the Melian Dialogue platform (the "Platform"). It should be read together with our Privacy Policy.
This Policy is issued in compliance with: (a) the Kenya Data Protection Act, 2019, particularly Section 30 on lawful basis of processing; (b) the Kenya Information and Communications Act, Cap. 411A; (c) Article 5(3) of Directive 2002/58/EC (as amended) — the ePrivacy Directive — where the Platform is accessed from within the European Economic Area; (d) Section 1798.135 of the CCPA/CPRA where the Platform is accessed from California, United States.
2. What Are Cookies and Tracking Technologies?
2.1 Cookies
A cookie is a small text file that a web server places on a User's device (computer, tablet, or mobile phone) when the User accesses the Platform. The cookie enables the server to recognise the device on subsequent visits and to store information such as authentication state, language preference, or session identifier.
Cookies fall into two lifetime categories:
- Session cookies are erased when the User closes the browser.
- Persistent cookies remain on the User's device for a defined period or until manually deleted.
2.2 Web Beacons and Pixels
A web beacon (also known as a "pixel tag", "clear GIF", or "tracking pixel") is a small graphic — typically 1×1 pixel — embedded into a web page or email that, when loaded, communicates to a server that the page or email has been viewed. Beacons are commonly used to measure the effectiveness of email campaigns and to correlate cookie identifiers across domains.
2.3 Local Storage and Service Workers
Modern browsers expose additional persistent-storage APIs (localStorage, sessionStorage, IndexedDB, Cache API) used by progressive web applications. The Company treats these technologies as equivalent to cookies for the purposes of this Policy.
2.4 Device Fingerprinting
The Company does not use covert device fingerprinting techniques designed to identify a User across sessions without their knowledge or consent.
3. Categories of Cookies We Use
The Company classifies cookies and comparable technologies into four categories. Consent is obtained via the Platform's cookie consent banner, and non-essential categories are set to "off" by default until affirmatively enabled by the User.
3.1 Strictly Necessary Cookies (No Consent Required)
These cookies are essential to the operation of the Platform and cannot be switched off without breaking core functionality. They are set only in response to actions taken by the User, such as logging in, filling in forms, or setting privacy preferences.
| Cookie / Storage Key | Purpose | Duration |
|---|---|---|
access_token | Authentication session token (httpOnly, secure) | 24 hours |
session_token | Google Sign-In session identifier | 30 days |
md_ref | Referral attribution for the current visit | 30 days |
mlima_ab_view_* | A/B test variant assignment for statistical validity | Session |
mlima_cookie_consent | Record of the User's consent choices | 12 months |
mlima_theme | Light/dark theme preference | Persistent |
Legal basis: Contractual necessity (KDPA s.30(b); GDPR Art.6(1)(b)) and legitimate interest in service delivery (KDPA s.30(f); GDPR Art.6(1)(f)).
3.2 Functional Cookies (Consent Required)
These cookies enable enhanced functionality and personalisation, including remembering the User's language, region, and interface preferences.
| Cookie / Storage Key | Purpose | Duration |
|---|---|---|
mlima_global_share_dismissed | Records dismissal of the global share bar | Persistent |
mlima_locale | Preferred language / locale | 12 months |
mlima_last_ticker | Last-viewed ticker on the trading terminal | 6 months |
Legal basis: Consent (KDPA s.30(a); GDPR Art.6(1)(a)).
3.3 Analytical / Performance Cookies (Consent Required)
These cookies enable us to count visits and traffic sources, measure and improve the performance of the Platform, and understand which features are most and least popular. All information collected by these cookies is aggregated and anonymised where technically feasible.
Categories of providers used:
- Google Analytics (property GA4-[Insert Property ID])
- [Insert additional analytics providers, e.g. product-analytics platform]
Legal basis: Consent (KDPA s.30(a); GDPR Art.6(1)(a)).
3.4 Marketing / Targeting Cookies (Consent Required)
These cookies may be set through the Platform by third-party advertising, retargeting, or social-media partners. They build a profile of the User's interests to show relevant advertisements on other sites.
Categories of providers that may be used:
- Meta (Facebook) advertising pixel
- LinkedIn Insight Tag
- Google Ads conversion tracking
- [Insert additional providers]
Legal basis: Consent (KDPA s.30(a); GDPR Art.6(1)(a)).
4. Managing Your Preferences
4.1 Via the Platform Consent Banner
On first visit, and at any time thereafter by clicking the "Cookie Preferences" link in the Platform footer, the User may: (a) accept all cookie categories; (b) reject all non-essential categories; (c) grant or withdraw consent to each non-essential category individually.
The User's preference is stored in the mlima_cookie_consent cookie for twelve (12) months, after which the User will be re-prompted.
4.2 Via Native Browser Controls
Users may configure their browsers to block or delete cookies. Instructions vary by browser and are updated by the browser vendors from time to time. Illustrative starting points:
- Google Chrome: Settings → Privacy and security → Third-party cookies (or "Cookies and other site data")
- Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
- Apple Safari (macOS): Safari → Preferences → Privacy → Manage Website Data
- Apple Safari (iOS): Settings → Safari → Advanced → Website Data
- Microsoft Edge: Settings → Cookies and site permissions → Cookies and site data
- Brave: Settings → Shields → Cookies
Blocking strictly necessary cookies will impair core functionality of the Platform, including authentication and payment processing.
4.3 Do Not Track and Global Privacy Control
Where the User's browser transmits a Global Privacy Control ("GPC") signal, the Company shall treat that signal as a valid opt-out of sale or sharing of Personal Data as defined by the CCPA/CPRA. The Company does not currently honour legacy "Do Not Track" (DNT) headers due to the absence of an industry standard, but does honour GPC.
5. Third-Party Cookies
Certain third-party service providers may set their own cookies through the Platform. These cookies are governed by the privacy and cookie policies of the respective third parties, not by the Company. Category-level disclosure is provided in Clause 3. Users are encouraged to review the policies of each third party.
6. Retention of Cookies
Cookies are retained for the durations specified in the tables at Clause 3. Persistent cookies survive browser restart but may be deleted at any time by the User via native browser controls or by clearing the User's browser data.
7. Consent Withdrawal
The User may withdraw consent at any time by: (a) clicking "Cookie Preferences" in the Platform footer and toggling the relevant categories off; (b) clearing browser storage; (c) emailing info@meliandialogue.com with the subject line "Cookie Consent Withdrawal".
Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
8. Changes to this Policy
We may update this Cookie Policy from time to time to reflect changes in technology, applicable law, or our operational practices. Material changes will be notified via the consent banner and by email to registered Users.
9. Contact
Questions about this Cookie Policy may be directed to info@meliandialogue.com.
This Cookie Policy forms an integral part of the Melian Dialogue Terms of Service and Privacy Policy.