Cookie Policy
Last updated: November 2025
This Cookie Policy explains how Civic Web Solutions Ltd (operator of vpnCounselor™) uses cookies and similar tracking technologies on our websites and services (collectively, the “Site”). It should be read together with our Privacy Policy and Terms and Conditions.
Quick summary
- We use cookies for core site functionality, performance/analytics, experience improvements, security, and affiliate attribution.
- In regions where required (EU/EEA/UK and others), we only set non‑essential cookies after consent. You can Accept, Reject, or Customize via our banner.
- You can change your cookie preferences at any time via the Cookie Settings link in the footer.
- For California residents, we honor Do Not Sell/Share and Global Privacy Control (GPC) signals for cross‑context behavioral advertising.
1) Data Controller
Civic Web Solutions Ltd, 24–26 Arcadia Avenue, Fin009, London N3 2JU, United Kingdom
For the purposes of privacy and cookie compliance laws, we act as the Data Controller. For analytics and affiliate processing, certain vendors may act as processors or independent controllers, depending on their terms.
2) Cookies & Similar Technologies
- Cookies are small text files placed on your device by a website.
- First‑party cookies are set by us; third‑party cookies are set by others (e.g., analytics or affiliate partners).
- Session cookies expire when you close your browser; persistent cookies remain for a defined period.
- Similar tech: web beacons/pixels, local storage, session storage, SDKs, device identifiers, and server‑side tagging.
3) Legal Bases
- EU/EEA & UK (ePrivacy + GDPR/UK DPA): we request consent before setting non‑essential cookies. Strictly necessary cookies rely on legitimate interests (functionality, security, fraud prevention).
- US (including California CPRA/CCPA): where cookies constitute “selling” or “sharing” of personal information (e.g., cross‑context behavioral advertising), you may opt out. We honor GPC (Global Privacy Control) signals where detected.
- Other regions (e.g., Brazil LGPD, Canada PIPEDA, South Africa POPIA): we apply a consent‑ or opt‑out‑based approach consistent with local laws.
4) Cookie Categories
- Strictly Necessary – enable core features (e.g., page navigation, consent logging, load balancing, security). These cannot be switched off when delivering the Site.
- Performance & Analytics – help us measure traffic and understand how visitors use the Site (e.g., Google Analytics 4).
- Functionality & Experience – remember choices and improve features (e.g., language, layout).
- Advertising & Affiliate Attribution – measure campaigns, prevent fraud/duplicate attribution, and track referrals to VPN providers to calculate our commission fairly.
- Security & Anti‑Abuse – detect bots, protect against DDoS, enforce rate limits.
Default retention: Unless otherwise stated, non‑essential cookies are kept no longer than 13 months (EU/UK norm). Consent records are retained up to 24 months or as required by law.
5) Cookie & Vendor List
This list is illustrative and subject to updates. We will keep this table updated as we add or remove tools. Names and purposes may change as vendors update their services.
A) Strictly Necessary
| Cookie / Vendor | Purpose | Type | Duration |
|---|---|---|---|
| CookieConsent (CMP) | Stores your choices (Accept/Reject/Preferences). | 1st‑party | Up to 12 months |
Load balancer (e.g., __cf_bm, cf_clearance) | Ensure availability and mitigate bots. | 3rd‑party (CDN) | Minutes to 30 days |
WP essentials (e.g., wp_*, wordpress_*) | WordPress core, session, login (if applicable). | 1st‑party | Session to 12 months |
B) Performance & Analytics
| Vendor | Example Cookies/IDs | Purpose | Duration |
|---|---|---|---|
| Google Analytics 4 (Consent Mode) | _ga, _ga_* | Traffic, pages, events; IP anonymization enabled; aggregated reports. | 2–13 months |
| Microsoft Clarity (optional) | CLID, ANONCHK, MR | Session replay, heatmaps, UX metrics. | 1–12 months |
We may also use other similar analytics or experience‑enhancement tools in the future without prior notice, provided they serve the same purpose of improving user experience and website performance.
Note: When required, these tools load only after consent. Where available, we enable IP masking/anonymization and similar privacy controls.
C) Functionality & Experience
| Cookie / Vendor | Purpose | Duration |
|---|---|---|
| UI preferences (e.g., language, theme) | Remember choices you make. | Session to 12 months |
| Surveys/feedback widgets (if used) | Improve support and content. | Session to 12 months |
D) Affiliate Attribution
| Partner Type | What is set | Why | Typical Duration |
|---|---|---|---|
| Affiliate networks / VPN providers | Referral cookies or parameters when you click our affiliate links. | To attribute sign‑ups/purchases so we may earn a commission at no extra cost to you. | ~30–60 days (varies by provider) |
| Campaign tracking | utm_*, click IDs | Measure campaign performance and prevent fraud. | Session to 90 days |
| Google Ads / Meta (Facebook) Pixel | Conversion tags and tracking pixels (_gcl_au, _fbp, _fbc) | Measure ad performance, optimize campaigns, and deliver remarketing audiences. Set only after consent where required. | Up to 90 days |
Transparency on affiliate cookies: When you follow our outbound link to a VPN provider, that provider (or its affiliate network) may place cookies on your device to track any subsequent purchase during their cookie window. Typical windows are 30, 45, or 60 days (subject to each provider’s policy). For details, consult the respective provider’s privacy/cookie notices.
E) Security & Anti‑Abuse
| Vendor | Purpose | Duration |
|---|---|---|
| CDN / WAF (e.g., Cloudflare) | Bot mitigation, DDoS protection. | Minutes to 30 days |
| Anti‑spam / bot detection | Prevent form and comment abuse. | Session to 12 months |
6) Consent Management
- Banner & Preferences: In regions where consent is required, our banner will present Accept All / Reject All / Customize options. Non‑essential categories remain off until you opt in.
- Change your mind anytime: Use Cookie Settings in the footer to reopen the panel and adjust categories.
- Browser controls: You can block or delete cookies via your browser settings. Doing so may affect site functionality.
- Do Not Track / GPC: We currently honor Global Privacy Control (GPC) signals for opt‑out of sale/share where applicable under CPRA.
7) International Transparency
- EU/UK: Non‑essential cookies set only with consent; records of consent maintained; IP anonymization configured where available; retention capped per local guidance.
- US (California, Colorado, Connecticut, Virginia, Utah): To the extent cookies constitute sale or sharing of personal information, you may opt out. We will provide a “Do Not Sell or Share My Personal Information” link and respect GPC signals.
- Brazil (LGPD), Canada (PIPEDA), South Africa (POPIA) and others: We apply a consent/opt‑out approach aligned to local rules.
8) Children
Our Site is not intended for children under the age of 13 (or older, where local law sets a higher age). We do not knowingly place non‑essential cookies for profiling minors.
9) Data sharing and transfers
Analytics and other vendors may process data on servers outside your country. Where required, we implement appropriate safeguards (e.g., SCCs, UK IDTA, vendor certifications). See our Privacy Policy for details.
We do not sell, rent, or share personal data collected via cookies with third parties for direct marketing or unrelated purposes.
10) Retention
We keep personal data collected via cookies only as long as necessary for the purposes set out above, and in line with the categories table and legal requirements. Consent logs may be retained up to 24 months (or longer where law requires proof of consent).
11) Policy Updates
We may update this Policy to reflect legal, technical, or business developments. The “Last updated” date will be revised accordingly. Material changes will be highlighted on this page and, where appropriate, communicated via the banner.
12) Contact Us
If you have questions about this Cookie Policy or our use of cookies, please contact: privacy@vpncounselor.com
Civic Web Solutions Ltd, 24–26 Arcadia Avenue, Fin009, London N3 2JU, United Kingdom
This document is provided for general informational purposes and does not constitute legal or professional advice.