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Legal

Cookies Policy

IMPORTANT INFORMATION

This Cookies Policy explains how The Black Circle Group ("TBC", "we", "us" or "our") uses cookies and similar technologies on the website at theblackcircle.com (the "Website"). It should be read together with our Privacy Policy, which explains how we handle Personal Data more generally.

Effective date: 28 September 2026. We may update this policy from time to time; material changes will be reflected in the effective date shown on this page.

WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES?

Cookies are small text files placed on your device when you visit a website. "Similar technologies" includes web beacons, pixels, local storage and comparable techniques that collect or store information about how you use a site. Cookies may be "first-party" (set by us) or "third-party" (set by a provider whose services we use).

You can set your browser to accept, block or delete cookies. Doing so may affect how parts of the Website function.

OVERVIEW OF TECHNOLOGIES USED

Before you give consent for non-essential technologies, we only set strictly necessary cookies required to operate and secure the Website. Non-essential analytics and marketing technologies described below are only loaded after you have indicated your preference through our consent banner.

CATEGORIES OF COOKIES AND TECHNOLOGIES

1. Strictly necessary

These are required for the Website to function and to keep it secure. They cannot be switched off in our systems because the Website would not operate without them. They do not require your consent.

  • Purpose: enabling core functionality, security, fraud prevention and remembering your consent preference.
  • Provider: The Black Circle (first-party).
  • Example: a cookie recording whether you have accepted or rejected non-essential cookies.
  • Retention: up to 12 months.

2. Analytics and performance

These help us understand how visitors interact with the Website so we can improve it. They are only loaded with your consent.

  • Purpose: measuring traffic, page views, sessions and aggregate usage patterns.
  • Provider: Google Analytics (Google LLC). Google may transfer data outside your jurisdiction; see Google's cookie policy.
  • Provider: Zoho PageSense (Zoho Corporation). Used for experience analytics.
  • Retention: typically up to 14 months, depending on provider defaults.
  • Consent: optional; requires your opt-in.

3. Marketing and CRM

These may be used to support client-relationship and communication activities, where permitted. They are only loaded with your consent.

  • Purpose: contact capture, form handling and, where permitted, relevant communications.
  • Provider: HubSpot (HubSpot, Inc.).
  • Retention: in line with the provider's defaults and applicable law.
  • Consent: optional; requires your opt-in.

THIRD-PARTY PROVIDERS AND INTERNATIONAL TRANSFERS

The providers listed above are third parties that may set their own cookies and process data in jurisdictions outside your own, including the United States, India and other countries in which they operate. Their processing is subject to their own privacy terms. We encourage you to review the relevant provider's privacy policy.

YOUR CHOICES AND HOW TO MANAGE COOKIES

  • Consent banner: when you first visit the Website, you can accept or reject non-essential cookies. Your choice is stored so you are not asked again on every visit.
  • Change your preference: you can update your choice at any time using the "Cookie preferences" link in the footer of every page.
  • Browser controls: most browsers let you manage and delete cookies in their settings. Restricting cookies may limit some Website features.
  • Withdraw consent: withdrawing consent does not affect the lawfulness of processing that took place before you withdrew.

UPDATES TO THIS POLICY

We may update this Cookies Policy to reflect changes in the technologies we use, our practices, or legal requirements. The effective date shown above indicates when it was last reviewed. Where appropriate or required by law, we may provide additional notice of material changes.

CONTACT

For questions about this Cookies Policy or your cookie preferences, please contact TBCWM International Limited at legal@theblackcircle.com.