Cookie policy

We keep cookies to a minimum. A couple are needed to make the site work at all; the only optional one is Google Analytics, and it doesn’t run unless you say yes.

Change your choice

You can change your mind at any time, right here. No forms, no emails.

What a cookie is

A cookie is a small file a website stores on your device so it can remember something between pages or visits. Similar technologies like localStorageand session storage do much the same job, and where we say “cookies” below we mean those too.

The cookies we use

Strictly necessary

These make the site function. They don’t track you, aren’t used for advertising, and can’t be switched off. Without them things like remembering your cookie choice simply wouldn’t work.

Note the irony we can’t avoid: remembering that you declined cookies itself requires storing something. That’s the one piece of storage that stays either way.

Analytics: optional, off by default

If you accept, we load Google Analytics 4to see which pages people read, how they arrived and what isn’t working. We use it to improve the site, not to build a profile of you, and never for advertising.

Until you accept, the Google Analytics script is never loaded and no request is made to Google at all.Declining isn’t a flag we set after the fact. Nothing is sent in the first place.

Google Analytics processes online identifiers and your IP address, which count as personal data under the Jersey Law, which is exactly why we ask first. We enable IP anonymisation, and we haven’t turned on advertising features, Google Signals or data sharing for advertising purposes.

Google’s own explanation is in its privacy policy, and Google publishes a browser opt-out add-on that works across every site.

What we don’t use

• No advertising or retargeting cookies
• No social media tracking pixels
• No cross-site tracking, and no data sold or shared with data brokers

The legal position in Jersey

Jersey doesn’t have its own cookie law. The EU ePrivacy Directive and the UK’s PECR regulations, the rules most cookie banners cite, do not apply here. The Jersey Office of the Information Commissioner has confirmed this.

What applies instead is the Data Protection (Jersey) Law 2018. Where a cookie processes personal data, we need a lawful basis under Schedule 2 and we have to be transparent about it under Article 12. For analytics we rely on your consent.

Strictly speaking, Jersey law would let us run analytics on legitimate interests without asking. We ask anyway, partly because people visit this site from the UK and Europe, where consent genuinely is required, and partly because asking is simply the right way to treat visitors.

Controlling cookies in your browser

Beyond the control above, every major browser lets you block or delete cookies, usually under Settings → Privacy. Blocking all cookies may break parts of this and other websites. Clearing your browser storage will also clear your choice here, so we’ll ask again next time.

One thing we can’t do for you: if you previously accepted and now decline, we stop loading Google Analytics immediately, but cookies Google has already set sit on Google’s side and have to be cleared through your browser.

Changes

If we add a cookie or a new service, we’ll update this page and ask for your consent again where it’s needed. Adding anything that changes what your existing choice meant automatically re-asks. We won’t quietly reinterpret a past yes.

Questions

Email info@halo.je. Our privacy policy covers everything else we do with personal data, including your rights and how to complain to the Jersey Office of the Information Commissioner.