Cookie Policy

Last updated: July 4, 2026

⚠️ DRAFT — TEMPLATE ONLY. Not legal advice. This document is a working draft provided for review. It does not constitute legal advice and must be reviewed and approved by qualified legal counsel before it is relied upon. Entity, registration, and contact details are placeholders pending finalisation.

This Cookie Policy explains how MPRO Finance (collectively, "we", "us", or "our") uses cookies and similar tracking technologies on our Platform, in accordance with the EU ePrivacy Directive (Directive 2002/58/EC), the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and SOC 2 Privacy Criteria.


1. What Are Cookies & Similar Technologies

Cookies are small text files stored on your computer or mobile device when you visit a website. They allow the Platform to recognize your device, maintain security, remember preferences, and verify authorization. We also utilize local storage and secure HTTP-only cookies for cryptographic session handling.

2. ePrivacy & GDPR Compliance: How We Record Your Consent

Under the ePrivacy Directive and GDPR, we require your active, explicit consent before placing any non-essential cookies (such as analytical or marketing cookies) on your device.

  • Consent Logging: To meet auditability requirements under GDPR and SOC 2, your consent preferences are stored on your device and recorded in our secure backend database.
  • Audit Trail: Any change to your consent status triggers a CONSENT_UPDATED event, which is cryptographically logged in our linear, insert-only Audit Chain for compliance verification.

3. Cookie Inventory

The tables below list the specific cookies utilized on MPRO Finance, classified by their necessity and purpose:

A. Strictly Necessary Cookies (Always Active)

These cookies are required for the security, system resilience (DORA compliance), and basic functionality of the Platform. They cannot be deactivated.

| Cookie Name | Provider | Purpose | Duration | Type | | :--- | :--- | :--- | :--- | :--- | | mpro-consent | MPRO Finance | Stores your cookie consent preferences (essential, analytics, marketing). | ~180 Days | HTTP Cookie | | __Secure-next-auth.session-token | MPRO Finance | Maintains your authenticated session state and verifies MFA validation status. | Session / 30 Days | HTTP-only, Secure | | __Host-next-auth.csrf-token | MPRO Finance | Prevents Cross-Site Request Forgery (CSRF) attacks. | Session | HTTP-only, Secure | | __next_preview_data | MPRO Finance | Supports preview mode routing for dynamic MDX content. | Session | HTTP-only, Secure |

B. Analytics & Performance Cookies (Consent Required)

These cookies would help us measure user engagement and improve performance in alignment with SOC 2 Availability criteria. They are only ever placed after you grant analytics consent.

No analytics cookies are currently set. Analytics is not yet enabled on the Platform — the analytics loader is a consent-gated scaffold that loads nothing until an analytics provider is configured. If and when a provider is introduced, cookies will be placed only after you grant analytics consent, and this policy will be updated to list each cookie (provider, purpose, and duration) before any such cookie is used.

C. Marketing & Targeting Cookies (Consent Required)

We do not use third-party behavioural advertising or profiling.

No marketing cookies are currently set. If marketing cookies are introduced in the future, they will be placed only after you grant marketing consent, and this policy will be updated to list them before any such cookie is used.

4. Managing Your Choices

You can modify your consent settings at any time:

  1. Interactive Banner: Click the "Cookie Policy" links or the "Customize" option in our footer banner to toggle individual categories.
  2. Browser Controls: You can configure your browser to block or delete cookies. However, blocking strictly necessary cookies will render the secure dashboard inaccessible, as it breaks the MFA and CSRF verification chains.