Cookie Policy.
1. What cookies are
Cookies are small text files stored on your device when you visit a website. Similar technologies (local storage, pixels, SDKs) can perform comparable functions and are treated the same way in this Policy. Cookies set by hale-x.com are first-party; cookies set by other domains via content embedded on our pages are third-party.
2. Categories of cookies we use
Hale-X runs a deliberately minimal cookie footprint. We do not use advertising or cross-site tracking cookies. The table below lists every category we use or may activate, in line with the GDPR and ePrivacy rules.
| Category | Examples | Purpose | Legal basis | Duration | Provider |
|---|---|---|---|---|---|
| Strictly necessary | halex_cookie_consent, session, CSRF, load-balancing | Operate the site, remember your consent choice, protect against fraud and abuse. | Legitimate interest (Art. 6(1)(f) GDPR) — exempt from consent under Art. 82 of the French Data Protection Act and equivalent EU ePrivacy rules. | Session to 12 months | Hale-X (first-party) / hosting provider |
| Analytics (optional) | Not currently deployed. If activated, may include privacy-friendly analytics such as Plausible or self-hosted Matomo. | Aggregate, anonymised measurement of page visits and traffic sources to improve content. | Consent (Art. 6(1)(a) GDPR) | Up to 13 months | To be disclosed before activation |
| Marketing / advertising | None. | Hale-X does not run advertising or third-party marketing cookies on this Website. | Consent (Art. 6(1)(a) GDPR) — would apply if ever introduced. | n/a | n/a |
| Functional / embedded content | Embedded video, maps, or social widgets — only when you interact with such content. | Display third-party content you actively request. | Consent (Art. 6(1)(a) GDPR) | Set by the third party | YouTube / Vimeo / OpenStreetMap / others, only when used |
Strictly necessary cookies are loaded by default because the site cannot function without them. All other categories are off by default and are only set after you give consent.
3. Your choices and how to withdraw consent
When you first visit the Website, a cookie banner lets you Accept all, Reject all (non-essential), or Customize your choice per category. Reject and Accept are presented with equal prominence — there are no pre-ticked boxes and no dark patterns.
You can change or withdraw your consent at any time:
- Use our cookie settings panel: .
- Configure your browser to block or delete cookies (see the help pages of Chrome, Firefox, Safari, or Edge).
- Use browser-level privacy signals such as Global Privacy Control (GPC), which we honour as a signal to refuse non-essential cookies.
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, and does not delete cookies already stored — you can clear those via your browser.
4. International transfers
Strictly necessary cookies are processed within the EU/EEA by Hale-X and its hosting provider. If we ever enable third-party tools (analytics, embedded content), any transfer outside the EEA will rely on an adequacy decision or appropriate safeguards under Chapter V of the GDPR (typically the EU Standard Contractual Clauses with additional measures), and the relevant provider will be added to the table above before activation.
5. Retention
Each cookie's maximum lifetime is shown in the table in section 2. Your consent choice is stored for up to 6 months; after that, the banner is shown again so you can confirm or change your preferences.
6. Your rights
You have rights of access, rectification, erasure, restriction, portability, and objection regarding personal data processed through cookies, and a right to lodge a complaint with the Luxembourg supervisory authority (CNPD, www.cnpd.lu) or the authority of your habitual residence. See our Privacy Policy for details and contact channels.
7. Changes to this Policy
We may update this Cookie Policy to reflect new tools, legal developments, or technical changes. The "Last updated" date above will change accordingly. Material changes (e.g. a new category of cookies) will trigger a renewed consent request via the banner.
8. Contact
Questions about cookies: privacy@hale-x.com — Hale-X Luxembourg SA, L-4354 Esch-sur-Alzette, 27 rue Henri Koch, Luxembourg.