Cookie Policy

This Cookie Policy explains the manner in which HVR Ventures (Pty) Ltd, trading as HVR Ventures ("the Company", "We", "Us" or "Our"), a Proprietary Limited (Pty) Ltd with registration number 8173799074, registered address at 214 Lois Avenue, 0181 Pretoria, South Africa, employs cookies and comparable tracking technologies upon the website published at havrento.site (the "Site"). This policy is furnished in compliance with the transparency obligations arising under the Protection of Personal Information Act, 2013 ("POPIA"), and should be read as a companion instrument to the Site's Privacy Policy and Terms of Use.

I. Definitions

For the purposes of this Cookie Policy, the following terms shall bear the meanings assigned to them below, save where the context indicates a contrary intention. A "cookie" means a small text file placed upon, and read from, the browser or device of a visitor to the Site for the purpose of enabling the Site, or a third party engaged by the Company, to recognise that device on subsequent occasions. A "session cookie" means a cookie that is automatically deleted upon the closure of the visitor's browser. A "persistent cookie" means a cookie that remains stored on the visitor's device for a defined period, or until manually deleted, and that survives the closure of the browser. "Necessary cookies" means those cookies without which the core technical functioning of the Site cannot be assured. "Analytics cookies" means cookies deployed to measure and analyse traffic to, and usage patterns upon, the Site in aggregate and anonymised or pseudonymised form. "Marketing cookies" means cookies deployed to track browsing behaviour across sessions and, where applicable, across other sites, for the purpose of presenting advertising material considered relevant to the visitor. "Data subject" and "processing" shall bear the meanings given to them under POPIA. "Visitor" means any natural person who accesses or uses the Site, irrespective of whether such person is a client, prospective client, or otherwise of the Company.

II. Application and Consent Mechanism

Upon a visitor's first access to the Site, a banner is presented offering the visitor the ability to accept all cookies, reject all non-essential cookies, or configure consent by category. No analytics or marketing cookie is set prior to the visitor's affirmative election, in accordance with the consent-based processing standard which the Company applies as a matter of policy notwithstanding that POPIA principally regulates the processing of personal information of identifiable natural persons rather than the placing of cookies as such. Necessary cookies are exempted from this consent requirement, as their deployment is required for the Site to function and does not depend upon the visitor's discretion, this being consistent with established practice regarding strictly necessary technical cookies. A visitor's election, once made, is itself recorded by way of a necessary cookie so that the visitor is not required to repeat the exercise upon each visit, and may be withdrawn or amended at any time through the cookie preference control accessible from the footer of every page of the Site.

III. Necessary Cookies

The Company deploys a limited category of necessary cookies whose function is confined to the preservation of the visitor's cookie consent preferences, the maintenance of session integrity where a visitor submits the contact form referred to in clause IV below, and the prevention of fraudulent or abusive submission of that form by way of basic security tokens. These cookies do not carry information capable of identifying a visitor beyond the technical parameters required for the stated purpose, are not shared with any third party for advertising or profiling purposes, and are retained for the duration of the browser session or, in the case of the consent-record cookie, for a period not exceeding twelve months from the date the preference was recorded.

IV. Analytics Cookies

Subject to the visitor's consent obtained pursuant to clause II, the Company may deploy analytics cookies for the purpose of understanding, in aggregate, how visitors navigate the Site, which pages are most frequently consulted, the duration of visits, and the general geographic and technical profile of traffic (such as browser type and device category), this information being used exclusively to improve the content, structure and performance of the Site and of the financial consulting services which the Company advertises upon it. Where an analytics provider is engaged for this purpose, such provider acts as an operator on the Company's instructions, and any data transmitted to it is configured, insofar as the provider's tooling permits, to minimise or mask the visitor's full internet protocol address. Analytics cookies of this kind are typically persistent and expire within a period of between thirteen and twenty-six months, according to the specific cookie concerned, after which they are automatically deleted from the visitor's device.

V. Marketing Cookies

Where the Company from time to time conducts promotional activity in respect of its financial consulting services, it may, subject always to the visitor's prior consent under clause II, deploy marketing cookies for the purpose of measuring the effectiveness of such promotional activity and of presenting to the visitor, whether upon the Site or upon third-party platforms, communications considered relevant to the visitor's expressed or inferred interest in the Company's services. No marketing cookie is activated by default, and a visitor who declines this category, or who has consented but subsequently withdraws that consent, will cease to be tracked for these purposes within a reasonable period thereafter, though this will not affect advertising already served on the basis of consent previously given.

VI. Cookies and the Contact Form

Where a visitor completes the contact form published upon the Site in order to make an enquiry regarding the Company's financial consulting services, no cookie is placed as a direct consequence of that submission beyond the necessary session-integrity cookie referred to in clause III; the personal information which the visitor supplies through the form (typically name, email address, telephone number and the substance of the enquiry) is transmitted to and processed by the Company as described in the Privacy Policy, and is not linked by the Company to any analytics or marketing cookie identifier for profiling purposes.

VII. Cookies and the Email Subscription

Where a visitor elects to subscribe to the Company's email updates concerning financial consulting insights, market commentary or service announcements, a necessary cookie may be used to confirm that the subscription request originated from the visitor's own browsing session, and, where the visitor has separately consented to analytics cookies, aggregate and anonymised data may be used to assess the general effectiveness of the subscription mechanism upon the Site. No cookie is used to track a subscriber's subsequent email-opening or click-through behaviour except where the visitor has been separately and specifically informed of, and has consented to, such tracking at the point of subscription.

VIII. Third-Party Cookies

Certain cookies described above may be set not by the Site directly but by third-party service providers engaged by the Company in connection with analytics or, where applicable, marketing functionality. The Company has satisfied itself, insofar as reasonably practicable, that such providers maintain data protection standards consistent with the obligations imposed upon the Company under POPIA, and has, where required, entered into appropriate operator agreements with them; nonetheless, the Company does not control the internal cookie practices of such third parties and refers visitors wishing to obtain further detail to the relevant provider's own cookie or privacy disclosures.

IX. Management and Withdrawal of Consent

A visitor may at any time review, amend or withdraw consent previously given in respect of analytics or marketing cookies by accessing the cookie preference control provided in the footer of the Site, and may additionally configure, block or delete cookies through the settings of the browser employed, though the visitor is advised that the disabling of necessary cookies may impair the proper functioning of the Site, including the operation of the contact form. Further information regarding browser-level cookie controls is ordinarily available through the "help" function of the browser concerned.

X. Amendment of this Policy

The Company reserves the right to amend this Cookie Policy from time to time, whether to reflect changes in the cookies actually deployed upon the Site, changes in applicable law, or changes in the Company's own practice. The version published upon the Site at any given time shall be the operative version, and material changes will, where practicable, be drawn to the attention of returning visitors by way of a renewed consent prompt.

XI. Contact

Enquiries or requests concerning this Cookie Policy, or concerning the exercise of any right a data subject may hold under POPIA in relation to information collected by means of cookies, may be directed to HVR Ventures (Pty) Ltd at 214 Lois Avenue, 0181 Pretoria, South Africa, by telephone on +27 12 772 4850, or by electronic mail at [email protected]. This policy was last reviewed in 2026.