Cookie Policy

Effective Date: November 8, 2025
Last Updated: November 7, 2025

1. Introduction

This Cookie Policy explains how Starkguards ("we," "us," or "our") uses cookies and similar technologies on our website https://www.starkguards.com.

This Cookie Policy should be read together with our Privacy Policy https://www.starkguards.com/, which provides detailed information about how we collect, use, and protect your personal data.

This policy complies with:

General Data Protection Regulation (EU) 2016/679 (GDPR)
ePrivacy Directive 2002/58/EC (as amended)
Portuguese Law No. 58/2019 (GDPR implementation)

2. What Are Cookies?

Cookies are small text files that are placed on your computer, smartphone, or other device when you visit a website. Cookies are widely used to make websites work more efficiently and provide information to website owners.

Types of Cookies:

Session Cookies: Temporary cookies that expire when you close your browser
Persistent Cookies: Cookies that remain on your device for a specified period or until manually deleted
First-Party Cookies: Set by the website you are visiting
Third-Party Cookies: Set by a domain other than the website you are visiting

3. Current Cookie Usage

3.1 Strictly Necessary Cookies (No Consent Required)

At present, our website only uses strictly necessary cookies that are essential for the website to function properly and securely. These cookies do not collect or store personal data for marketing or analytics purposes.

Under GDPR and ePrivacy Directive, strictly necessary cookies do NOT require your consent because they are essential for providing services you have explicitly requested (such as accessing and navigating our website).

Cookies We Currently Use:

Cookie Name: Session ID

Purpose: Maintains your session as you navigate the website

Type: Session

Duration: Until browser closes

Category: Strictly Necessary

Cookie Name: CSRF Token

Purpose: Protects against Cross-Site Request Forgery attacks

Type: Session

Duration: Until browser closes

Category: Security (Strictly Necessary)

Cookie Name:Load Balancer

Purpose: Ensures consistent server routing for optimal performance

Type: Session

Duration: Until browser closes

Category: Strictly Necessary

Why These Don't Need Consent:
These cookies are exempt from consent requirements under Article 5(3) of the ePrivacy Directive because they are:

Used solely for carrying out the transmission of communication over an electronic network, OR
Strictly necessary to provide a service explicitly requested by you (website functionality and security)

3.2 What We Do NOT Currently Use

We do NOT currently use:

Analytics cookies (e.g., Google Analytics)
Marketing or advertising cookies
Social media tracking cookies
Third-party tracking technologies
Profiling or behavioral targeting cookies

Therefore, you do NOT currently need to provide consent for cookies when visiting our website.

4. Future Cookie Usage (When SEO/Marketing Tools Are Implemented)

When we implement analytics, marketing, or other non-essential tools in the future, we will update this Cookie Policy and implement a cookie consent management system.

4.1 Potential Future Cookie Categories

Performance/Analytics Cookies (Consent Required):
These cookies collect information about how visitors use our website, such as which pages are visited most often. This helps us improve website performance and user experience.

Examples we may use in the future:

Google Analytics
Website performance monitoring tools

Marketing Cookies (Consent Required):
These cookies track your browsing activity to deliver relevant advertisements and measure campaign effectiveness.

Examples we may use in the future:

Google Ads
LinkedIn Insight Tag
Facebook Pixel
Retargeting pixels

Functional Cookies (May Require Consent):
These cookies enable enhanced functionality and personalization, such as remembering your preferences.

Examples we may use in the future:

Language preference cookies
Chat widget cookies
Video player cookies

4.2 When We Implement These Cookies

Before implementing any non-essential cookies, we will:

-Display a Cookie Consent Banner allowing you to accept or reject non-essential cookies

-Block Non-Essential Cookies until you provide consent (cookies will NOT load before consent)

- Provide Granular Controls allowing you to accept or reject specific cookie categories

- Update This Cookie Policy with detailed information about each cookie used

- Allow You to Manage Preferences and withdraw consent at any time

- Maintain Consent Records for compliance purposes

You will have full control over which cookies you accept.

5. Your Cookie Choices and Controls

5.1 Current Situation (Strictly Necessary Cookies Only)

Since we currently only use strictly necessary cookies, there are no opt-in/opt-out controls needed. These cookies are essential for website functionality and security.

However, you can still manage these cookies through your browser settings:

5.2 Browser Controls

You can control and delete cookies through your browser settings. Please note that blocking strictly necessary cookies may affect website functionality.

How to Manage Cookies in Popular Browsers:

Google Chrome:

Settings → Privacy and security → Cookies and other site data
Choose your preferred cookie settings

Mozilla Firefox:

Settings → Privacy & Security → Cookies and Site Data
Manage cookie preferences

Microsoft Edge:

Settings → Cookies and site permissions → Cookies and site data
Configure cookie settings

Safari (macOS):

Preferences → Privacy → Cookies and website data
Manage cookie settings

Safari (iOS):

Settings → Safari → Block All Cookies or Prevent Cross-Site Tracking

For more information, visit: https://www.allaboutcookies.org/

5.3 Future Cookie Management (When Consent Banner Is Implemented)

When we implement non-essential cookies, you will be able to:

Accept or reject all cookies
Accept or reject cookies by category (Analytics, Marketing, Functional)
Change your preferences at any time through a "Cookie Settings" link
Withdraw consent at any time

6. Do Not Track (DNT) Signals

Some browsers have a "Do Not Track" feature that signals to websites that you do not want your online activity tracked. Currently, there is no industry-wide standard for responding to DNT signals.

Our Approach:

We currently only use strictly necessary cookies that are not affected by DNT signals
When we implement tracking cookies in the future, we will respect your DNT preferences where technically feasible

7. Cookies and Personal Data

7.1 Current Cookie Usage

The strictly necessary cookies we currently use do not collect personal data for marketing or analytics purposes. They only:

Maintain your session for website functionality
Protect against security threats (CSRF attacks)
Ensure proper server load balancing

IP Addresses:
Your IP address may be logged in our server logs for security and technical purposes. This is considered personal data under GDPR and is processed based on our legitimate interest in maintaining website security. For more information, see our Privacy Policy.

7.2 Future Cookie Usage

When we implement analytics or marketing cookies:

These cookies may collect personal data (e.g., IP address, browsing behavior, device identifiers)
We will obtain your explicit consent before setting these cookies
Personal data collected via cookies will be processed in accordance with our Privacy Policy
You will have the right to access, rectify, erase, and object to processing of data collected via cookies

8. Third-Party Cookies (Future)

Currently, we do not use third-party cookies on our website.

When we partner with third-party service providers in the future (e.g., Google Analytics, marketing platforms), those providers may set their own cookies on your device.

What This Means:

Third-party cookies are controlled by the third party, not by Starkguards
Third parties have their own privacy policies governing their cookie usage
We will provide links to third-party privacy policies in our updated Cookie Policy
You will have the option to accept or reject third-party cookies through our consent banner

Third Parties We May Use in the Future:

Google Analytics (website analytics)
Google Ads (advertising)
LinkedIn (marketing and analytics)
Facebook/Meta (marketing and analytics)

9. Cookies for Cybersecurity Services

Client Portals / Platforms (Future):
When we launch our AI-powered red team platform or client portals, those services may use additional cookies for:

User authentication and session management
Security and fraud prevention
Platform functionality and performance

These will be covered by separate terms and conditions and privacy notices specific to those services.

10. Data Retention

Session Cookies: Deleted automatically when you close your browser

Strictly Necessary Persistent Cookies (if any): Retained for a maximum of 12 months or as long as necessary for their intended purpose

Future Analytics/Marketing Cookies: Retention periods will vary by cookie type and will be specified in our updated Cookie Policy when implemented (typically 12-24 months)

Consent Records (Future): When we implement a consent management system, we will retain records of your cookie consent choices for at least 5 years as required by GDPR accountability requirements.

11. Similar Technologies

In addition to cookies, we may use similar technologies:

11.1 Web Beacons / Pixels (Not Currently Used)

Small graphic images embedded in web pages or emails that track whether content has been accessed. We do not currently use web beacons.

Future Use: When implementing marketing tools, we may use pixels for:

Tracking email opens and clicks
Measuring advertising campaign effectiveness
Retargeting website visitors

11.2 Local Storage (Not Currently Used)

Browser storage mechanisms that allow websites to store data locally on your device. We do not currently use local storage beyond what is necessary for website functionality.

11.3 Server Logs

We maintain server logs for security, troubleshooting, and performance monitoring. These logs may include:

IP addresses
Browser information
Timestamps
Pages accessed
Error messages

Server logs are processed based on our legitimate interest in maintaining website security and functionality (GDPR Article 6(1)(f)).

12. Children's Privacy

Our website is intended for businesses and professionals. We do not knowingly collect data from individuals under the age of 16 through cookies or any other means.

If you believe a child under 16 has accessed our website, please contact us at dpo@starkguards.com.

13. International Data Transfers

Current Situation:
Cookie data (session IDs, security tokens) is stored on servers located within the European Economic Area (EEA).

Future Situation:
When we use third-party analytics or marketing tools (e.g., Google Analytics), data may be transferred to countries outside the EEA, including the United States.

In such cases:

We will ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses, EU-US Data Privacy Framework)
You will be informed through our updated Cookie Policy
You will have the choice to accept or reject cookies that involve international transfers

14. Updates to This Cookie Policy

We will update this Cookie Policy when we implement new cookies or tracking technologies.

How We Notify You:

Material Changes: We will display a prominent notice on our website and may request renewed consent if required
Minor Updates: Will be reflected on this page with an updated "Last Updated" date
Email Notification: If you have provided an email address, we may notify you of significant changes

What You Should Do:

Review this Cookie Policy periodically
Check the "Last Updated" date at the top of this page
When we implement a consent banner, update your cookie preferences as desired

15. Legal Basis for Cookie Processing

Strictly Necessary Cookies (Current):

Legal Basis: Legitimate interest (GDPR Article 6(1)(f)) and exemption under ePrivacy Directive Article 5(3)
Legitimate Interest: Ensuring website functionality, security, and providing services you explicitly request
No Consent Required: These cookies are exempt from consent requirements

Non-Essential Cookies (Future):

Legal Basis: Consent (GDPR Article 6(1)(a))
Consent Required: We will obtain your explicit, informed, and freely given consent before setting these cookies
Right to Withdraw: You can withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal

16. Your Rights Regarding Cookie Data

You have the following rights regarding data collected through cookies:

Right to Access: Request information about data collected through cookies
Right to Rectification: Request correction of inaccurate data
Right to Erasure: Request deletion of data collected through cookies (subject to legitimate grounds)
Right to Object: Object to processing of data collected through cookies
Right to Restriction: Request limitation of processing in certain circumstances
Right to Data Portability: Receive data in a machine-readable format (where applicable)
Right to Withdraw Consent: Withdraw cookie consent at any time (for non-essential cookies)

To exercise these rights, contact us at dpo@starkguards.com.

For more information about your data protection rights, see our Privacy Policy.

17. Questions and Complaints

Questions About Cookies:
If you have questions about our use of cookies, contact us at:

Email: dpo@starkguards.com
Website: https://www.starkguards.com

Complaints:
If you believe our cookie practices violate data protection laws, you have the right to lodge a complaint with:

Portuguese Data Protection Authority (CNPD):

Website: https://www.cnpd.pt
Address: Av. D. Carlos I, 134, 1º, 1200-651 Lisboa, Portugal
Phone: +351 21 392 84 00
Email: geral@cnpd.pt

18. Summary: What This Means for You

Right Now:
- We only use essential cookies for website functionality and security
- You do NOT need to accept a cookie banner
- Your privacy is protected by default
- No marketing or tracking cookies are active

In the Future (When We Add SEO/Marketing Tools):
- You will see a cookie consent banner
- You can choose which cookies to accept
- Non-essential cookies will NOT load without your consent
- You can change your preferences at any time
- We will provide detailed information about each cookie

Your Control:
- You can always manage cookies through browser settings
- You can exercise your GDPR rights at any time
- You can contact us with questions or concerns

19. Implementation Timeline

Phase 1 (Current)

Timeframe: Now

Cookie Requirements: Only strictly necessary cookies. No consent banner needed.

Phase 2 (SEO/Marketing)

Timeframe: When implementing analytics or marketing tools

Cookie Requirements: Consent banner required. Granular cookie controls. Updated Cookie Policy.

Phase 3 (Platform Launch)

Timeframe: When platform launches

Platform-specific cookie management. Separate consent for platform services.

Cookie Requirements: We will notify you before implementing Phase 2 cookie requirements.

20. Contact Information

Cookie Policy Questions:

Email: dpo@starkguards.com
Subject: "Cookie Policy Inquiry"

Data Protection Officer:

Email: dpo@starkguards.com

Company Address:
Estr. Malveira da Serra 920, 2750-834 Cascais, Portugal

Portuguese Data Protection Authority:

CNPD: https://www.cnpd.pt
Email: geral@cnpd.pt

This Cookie Policy was last updated on November 7, 2025.

Effective Date: November 8, 2025