Last updated
Cookie Policy
This Cookie Policy explains how AI Empowerment Ltd, trading as "Algominds" ("Algominds", "we", "us", "our"), uses cookies and similar technologies on our websites and applications. It should be read together with the Algominds Privacy Policy and the Algominds Terms of Service, which use the same defined terms and describe in full how we process personal data and the basis on which we provide our services. Where this policy refers to data-retention periods, transfer mechanisms, or your wider rights, the Privacy Policy is the controlling document.
If you have questions about this policy, contact our privacy lead, Edward Albazii, at [email protected], or our general team at [email protected]. We are registered with the UK Information Commissioner's Office (ICO) under reference ZC082052.
1. Introduction and scope
1.1 What this policy covers
This policy applies to:
- algominds.ai and its subdomains (our marketing and informational website), including connect.algominds.ai (our hosted account-connection wizard); and
- app.algominds.ai (the Algominds Signals application), our self-serve B2B SaaS platform for AI signal intelligence, prospect sourcing, data enrichment, and AI-generated outreach copy.
We refer to these together as the "Sites". Where a third-party page (for example, a payment page or a scheduling embed) sets its own cookies, that third party's own cookie and privacy notices apply, and we link to them in Section 4.
This policy covers cookies and similar technologies on the Sites. It does not cover tracking technologies in our cold-outreach email (for example, email open and link tracking), which is addressed separately in the Algominds Privacy Policy, including the lawful basis we rely on for outreach and the controls we apply in restricted jurisdictions.
1.2 What cookies and similar technologies are
A "cookie" is a small text file that a website places on your device (computer, tablet, or phone) when you visit. Cookies let a site recognise your device, remember your preferences, keep you signed in, and understand how the site is used.
We use "cookies" in this policy as shorthand for cookies and a range of similar technologies, including:
| Technology | What it is |
|---|---|
| HTTP cookies | Small text files stored by your browser, set by us (first party) or by a third party. |
| Local storage and session storage | Data stored in your browser by the site or app, used to keep you signed in and to hold preferences and session state. |
| Pixels, tags, and web beacons | Tiny invisible files or snippets used to record that a page was viewed, often used for analytics and marketing measurement on the Sites. |
| Software development kits (SDKs) and scripts | Code provided by third parties (for example, analytics or product-tooling providers) that runs in your browser. |
Cookies may be "session" cookies, which expire when you close your browser, or "persistent" cookies, which remain until they expire or you delete them. They may be "first party" (set by us) or "third party" (set by a provider we use).
1.3 Cookies and personal data
Some cookies collect information that is personal data under the UK GDPR, the EU GDPR, and applicable US state privacy laws (for example, online identifiers, device information, and IP-derived data). Where they do, our processing is also governed by the Algominds Privacy Policy, which explains the legal bases we rely on, the recipients of the data, international transfers, retention periods, and your rights.
For these website and product cookies, and for our own analytics, marketing, and prospecting, Algominds acts as a controller. Where you use the Signals platform to process prospect data, or where we run managed outbound on your instructions, our respective roles (controller, processor, joint controller, or independent controller) are as set out in the Privacy Policy and the Data Processing Agreement (DPA); those roles are not changed by this Cookie Policy.
2. Consent and the law
2.1 Legal framework
Our use of cookies is governed by:
- the Privacy and Electronic Communications Regulations 2003 (PECR) in the UK, as amended, including by the Data (Use and Access) Act 2025 and regulations made under it (where the relevant provisions are in force);
- the UK GDPR and the Data Protection Act 2018, where cookies involve personal data;
- the EU ePrivacy Directive (as implemented in EU member states) and the EU GDPR, for visitors in the EU and EEA; and
- applicable US state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA"), and similar state laws, as described in Section 6.
2.2 The consent rule
Under PECR (as amended), the ePrivacy Directive, and equivalent rules:
- Strictly necessary cookies do not require your consent. These are cookies that are essential to provide the service you have asked for (for example, signing you in, keeping the sign-in you requested secure, and remembering items you are working with). We use these on the basis that they are necessary to deliver the service you request and, where personal data is involved, our legitimate interests in operating a secure and functional service.
- All other cookies (functional/preferences, analytics/performance, and marketing) are non-essential and are only set after you give consent, except where the law permits a narrow exemption.
For visitors in the EU and EEA, non-essential cookies are set only with your consent. We do not rely on legitimate interests as a basis to set any non-essential cookie for EU or EEA visitors.
The Data (Use and Access) Act 2025 introduces, through regulations made under it, exemptions for certain low-privacy-risk statistical measurement and "appearance and functionality" cookies. Where, once those provisions are in force, we rely on any such exemption, we will say so in our cookie banner and update this policy. Until then, we treat analytics, functional, and marketing cookies as requiring consent.
2.3 How to give, refuse, and change your consent
When you first visit a Site, our cookie banner lets you:
- Accept all non-essential cookies;
- Reject all non-essential cookies (strictly necessary cookies remain, as they do not require consent); or
- Manage preferences and choose, by category (functional/preferences, analytics/performance, and marketing), which non-essential cookies you allow.
Non-essential cookies are switched off by default until you give consent. No non-essential cookie is set before you make an affirmative choice. On the first layer of the banner, "Accept all" and "Reject all" are presented with equal prominence; there are no pre-ticked boxes, and refusing is as easy as accepting.
You can change or withdraw your consent at any time, in one click, by reopening the cookie preferences via the always-available "Cookie settings" link in the footer of the Sites. Withdrawing consent is as easy as giving it. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it. Refusing or withdrawing consent for non-essential cookies will not block access to the Sites, although some preferences and conveniences may not be remembered.
We keep a record of your consent choices. We store your consent for up to 12 months, after which the banner is presented again so you can confirm or update your choices. You can also clear cookies through your browser at any time (see Section 5), which is an additional control rather than the primary way to withdraw consent.
For US visitors, we also honour the Global Privacy Control (GPC) browser signal as an opt-out of "sale" and "sharing", as explained in Sections 6 and 7.
3. Categories of cookies we use
We group cookies into four categories. The table below lists the purpose, the providers we use, whether the cookies are first or third party, and typical durations. Specific cookie names and lifespans can vary as providers update their tools; the current detailed list is always available through the "Cookie settings" link in our footer. A cookie's lifespan is how long the cookie itself stays on your device, which is different from how long we retain the underlying data. Data-retention periods (for example, our analytics retention) are set out in the Privacy Policy.
| Category | Purpose | Examples and providers | First or third party | Typical duration |
|---|---|---|---|---|
| Strictly necessary | Sign-in, session management, security of the sign-in and session you requested, load balancing, remembering your cookie choices, and core app functionality. Required to deliver the service you request; no consent needed. | Our own session and security cookies; authentication tokens and sign-in state (including Google and Microsoft scoped sign-in, which return OAuth tokens only and never your password); first-party session and security cookies set by our hosting and security infrastructure (Supabase, Vercel, and Cloudflare); the Unipile-powered connection wizard at connect.algominds.ai (only when you use that wizard); Stripe anti-fraud cookies loaded on the checkout page when you initiate a payment. | First party and third party | Session to 12 months |
| Functional / Preferences | Remembering your settings and choices (for example, language, layout, recently used views, and whether you have dismissed a notice) to give you a more consistent experience. Set only with your consent. | Our own preference cookies and local storage; preference state used by embedded tools and the app. | First party and third party | Session to 12 months |
| Analytics / Performance | Understanding how visitors and users find and use the Sites, which pages and features are used, and where errors or friction occur, so we can measure and improve performance. Includes privacy-protective monitoring to detect and prevent abuse and fraudulent use of the Sites. Set only with your consent. | Google Analytics, PostHog (product analytics and session/feature usage), HubSpot (website and traffic analytics). | Third party (and related first-party identifiers) | Session to 26 months |
| Marketing | Recognising returning visitors, measuring the effectiveness of our campaigns, and supporting our own B2B marketing and prospect sourcing. Set only with your consent. | HubSpot (marketing, visitor identification, and campaign measurement). | Third party (and related first-party identifiers) | Session to 26 months |
We do not use cookies to serve third-party behavioural advertising networks on the Sites. Our marketing cookies are used for our own first-party B2B marketing through HubSpot.
3.1 A note on our wider vendors
The providers above are the ones that may set or read cookies and similar technologies on the Sites. Algominds also relies on other sub-processors to deliver its services (for example, AI model providers such as OpenAI and Anthropic; data discovery and enrichment providers such as Apollo, Exa, Bright Data, and Findymail; sending and outreach providers such as Smartlead (email), HeyReach (LinkedIn), Unipile (LinkedIn and mailbox connect), Zapmail (mailbox provisioning), Resend (transactional email), and Twilio (cold SMS in the US and Canada where offered); CRM and integrations such as HubSpot and customer-connected Salesforce/HubSpot; and scheduling providers such as Cal.com and Calendly). These providers operate server-side and do not set cookies in your browser when you use the Sites. They are listed in full, with their roles and locations, in the Algominds Privacy Policy and the DPA sub-processor annex. Where you load a scheduling page or a payment page, that provider's own cookies and notices apply (see Section 4).
4. Third-party cookies and providers' own notices
Some cookies are set by third parties whose tools we embed or rely on. These providers process data under their own privacy and cookie notices, and many are based in the United States. International transfers are protected by the UK International Data Transfer Agreement (IDTA), EU Standard Contractual Clauses with the UK Addendum, adequacy decisions, and the EU-US Data Privacy Framework where the provider is certified, as described in the Privacy Policy.
| Provider | Role on the Sites | Notice |
|---|---|---|
| Google (Google Analytics, Google sign-in) | Analytics; identity sign-in | https://policies.google.com/privacy |
| PostHog | Product analytics | https://posthog.com/privacy |
| HubSpot | Analytics, marketing, CRM | https://legal.hubspot.com/privacy-policy |
| Stripe | Payments and fraud prevention (independent controller for payments; PCI-DSS Level 1; Algominds never stores full card data) | https://stripe.com/privacy |
| Cloudflare | Security and infrastructure | https://www.cloudflare.com/privacypolicy/ |
| Vercel | Hosting and infrastructure (first-party session/security cookies) | https://vercel.com/legal/privacy-policy |
| Supabase | Hosting, authentication, infrastructure (first-party session cookies) | https://supabase.com/privacy |
| Microsoft (Microsoft sign-in) | Identity sign-in | https://privacy.microsoft.com/privacystatement |
| Unipile | Mailbox and LinkedIn connection wizard at connect.algominds.ai (cookies set only inside the wizard) | https://www.unipile.com/privacy-policy/ |
| Cal.com | Scheduling embeds | https://cal.com/privacy |
| Calendly | Scheduling embeds | https://calendly.com/legal/privacy-notice |
We keep this list current, but providers occasionally change their URLs. If a link does not resolve, search for the provider's "privacy policy" or "cookie notice", or contact us at [email protected].
5. How to manage cookies
You have several ways to control cookies, in addition to our banner.
5.1 Our cookie banner and settings
Use the cookie banner on first visit, or the "Cookie settings" link in the footer of the Sites at any time, to accept, reject, or fine-tune non-essential cookies by category, and to change or withdraw your choices later.
5.2 Browser controls
Most browsers let you view, block, and delete cookies through their settings. You can usually choose to block all cookies, block third-party cookies only, or delete cookies when you close the browser. Blocking strictly necessary cookies may prevent the Sites from working properly. You can find these controls in the settings or preferences of your browser (for example, Google Chrome, Apple Safari, Mozilla Firefox, and Microsoft Edge each provide a privacy or cookies section in their settings). If you cannot locate the setting, search your browser's help pages for "cookies".
5.3 Google Analytics opt-out
To opt out of Google Analytics across all websites, you can install the Google Analytics Opt-out Browser Add-on, available from Google at https://tools.google.com/dlpage/gaoptout.
5.4 Global Privacy Control
We honour the Global Privacy Control (GPC) signal. If your browser or a browser extension sends a GPC signal, we treat it as a valid request to opt out of any "sale" or "sharing" of personal information under US state privacy laws, and as a signal to disable non-essential cookies where applicable. You can learn more and enable GPC at https://globalprivacycontrol.org.
6. US state privacy: "sale", "share", and your opt-out rights
This section applies to visitors covered by US state privacy laws, including California (the CCPA) and similar laws in other states (such as Colorado, Connecticut, Virginia, and others as they take effect).
6.1 Do we "sell" or "share" personal information
Algominds does not sell personal information in the conventional sense; we do not exchange it for payment. However, California law defines "sale" and "share" broadly to include disclosures of personal information for other valuable consideration, and "share" includes disclosure for cross-context behavioural advertising. Because our use of certain analytics and marketing cookies can involve passing online identifiers to providers such as Google Analytics and HubSpot for measurement, that use may constitute a "sale" or a "share" under California law. To be transparent and protective, we treat it as such and give you a clear way to opt out. This does not contradict Section 3: the disclosure here is to our measurement and marketing providers, not the sale of data to third-party behavioural advertising networks.
| Cookie category | Possible "sale" or "share" under US state law | Opt-out |
|---|---|---|
| Strictly necessary | No | Not applicable |
| Functional / Preferences | No | Manage in cookie settings |
| Analytics / Performance (Google Analytics, PostHog, HubSpot) | May qualify as a "sale" or "share" where identifiers are passed to a provider for cross-context purposes (providers we engage only as service providers, under contractual restrictions and with no cross-context behavioural advertising, are not treated as a "sale" or "share") | Reject in our banner, send a GPC signal, or use the controls in Section 5 |
| Marketing (HubSpot) | May qualify as a "sale" or "share" | Reject in our banner, send a GPC signal, or use the controls in Section 5 |
6.2 How to opt out
We provide a designated opt-out mechanism, which you can reach through the "Your Privacy Choices" control (also presented as "Do Not Sell or Share My Personal Information") in the footer of the Sites. You can opt out of any "sale" or "sharing" by:
- selecting "Reject all", or turning off the Analytics and Marketing categories, in our cookie banner or "Cookie settings" / "Your Privacy Choices" control;
- sending a Global Privacy Control signal from your browser, which we honour automatically as a valid opt-out-preference signal (see Section 7); or
- contacting us at [email protected] to exercise your rights.
We do not discriminate against you for exercising your privacy rights. For the full description of your US state privacy rights (including rights to know, delete, correct, and appeal), see the Algominds Privacy Policy.
7. Do Not Track and Global Privacy Control
Do Not Track (DNT): Some browsers offer a "Do Not Track" setting. There is no common industry standard for how sites must respond to DNT, and we do not currently respond to DNT signals. We instead give you direct control through our cookie banner and settings.
Global Privacy Control (GPC): We do recognise and honour the GPC signal. When we detect a GPC signal, we treat it as an opt-out of the "sale" and "sharing" of personal information under applicable US state laws, and we disable the corresponding non-essential cookies for that browser. GPC is a US-focused mechanism and does not, by itself, satisfy the consent requirements that apply to EU and EEA visitors, who are asked for consent through the cookie banner. GPC is applied at the browser or device level, so you may need to set it on each browser and device you use.
8. Changes to this policy and how to contact us
We may update this Cookie Policy from time to time to reflect changes in the cookies we use, in the providers we work with, or in the law. When we make material changes, we will update the "Last updated" date at the top and, where appropriate, re-present our cookie banner so you can review your choices. Please check this page periodically.
For any questions about this Cookie Policy or our use of cookies, or to exercise your privacy rights, contact:
AI Empowerment Ltd, trading as Algominds Privacy lead: Edward Albazii, [email protected] General enquiries: [email protected] ICO registration: ZC082052
This Cookie Policy is governed by the laws of England and Wales and should be read together with the Algominds Privacy Policy and Terms of Service. You also have the right to lodge a complaint with the ICO (https://ico.org.uk) or, in the EU/EEA, with your local supervisory authority.