Cookie Policy – Orbas Learn
1. Introduction
1.1. Purpose of this Policy
This Cookie Policy explains how Orbas Learn, a sub-brand operated by Blackridge Group Ltd, uses cookies and similar tracking technologies on its website and related services ("Platform"). The purpose of this Policy is to provide transparency regarding what cookies are, how they are used on the Platform, and how users can manage their cookie preferences in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications Regulations (PECR).
1.2. Scope of Application
This Policy applies to all users who access, browse, register, or otherwise interact with the Orbas Learn Platform via web browsers or mobile devices. It covers the use of cookies and other similar tracking technologies (such as pixels, beacons, SDKs, and local storage objects) that may be employed on our domains, subdomains, and integrated third-party services.
This Policy should be read in conjunction with our Privacy Policy, which explains how we handle your personal data more broadly, including data collected through cookies where it constitutes personal information.
2. Controller Identity and Contact Information
For the purposes of this Policy and relevant data protection laws, the data controller responsible for the use of cookies and processing of related personal data is:
Blackridge Group Ltd
Registered in England and Wales
Company No: 16482166
Registered Office: 61 Bridge Street, Kington, Hertfordshire, United Kingdom, HR5 3DJ
Email: legal@orbas.io
If you have questions about this Policy or how we use cookies on Orbas Learn, you may contact our Data Protection Officer (DPO) at the above address or email.
3. Types of Cookies We Use
Orbas Learn uses a variety of cookies to ensure the secure, efficient, and personalised delivery of services through our Platform. Each category of cookie plays a distinct role in maintaining functionality, improving user experience, or supporting commercial objectives. The use of non-essential cookies is subject to user consent via our cookie banner or consent management platform, in accordance with UK GDPR and PECR requirements.
3.1. Strictly Necessary Cookies
These cookies are essential for the proper functioning of the Platform and cannot be disabled through our consent management tool. They are typically set in response to actions taken by users, such as logging in, setting privacy preferences, or completing forms. Without these cookies, certain services or features—such as account authentication, secure payment processing, or user session management—may not function properly.
Examples include:
- Session identifiers for secure login;
- CSRF (cross-site request forgery) tokens for form validation;
- Load balancing and routing indicators.
These cookies do not require prior consent under UK law, but their use is disclosed for transparency.
3.2. Performance and Analytics Cookies
These cookies help us understand how visitors interact with our Platform by collecting anonymised or pseudonymised data. This information allows us to measure usage patterns, monitor platform performance, detect technical issues, and improve the overall user experience.
Examples include:
- Page load metrics and bounce rate analysis;
- Tracking of navigation pathways and feature usage;
- Integration with analytics platforms such as Google Analytics.
These cookies are only placed with your explicit consent and are configured to avoid collecting personally identifiable information where possible. You may withdraw consent at any time via our cookie settings interface.
3.3. Functional Cookies
Functional cookies enable enhanced features and personalisation. They may be set by us or by third-party providers whose services we have integrated into the Platform. These cookies remember your preferences and choices to deliver a more tailored experience during subsequent visits.
Examples include:
- Remembering language, location, or display preferences;
- Saving draft progress or form input data;
- Enabling accessibility features or multimedia playback options.
Disabling these cookies may result in diminished Platform usability but will not affect core functionality.
3.4. Targeting or Advertising Cookies
These cookies are used to deliver content and advertisements more relevant to you and your interests. They may be set through our Platform by advertising partners and may track your browsing activity across websites. This enables the creation of a user profile that informs targeted advertising.
Examples include:
- Behavioural advertising networks such as Google Ads or Meta Pixel;
- Frequency capping to avoid ad repetition;
- Measurement of campaign performance or engagement.
These cookies require your opt-in consent. You may manage or revoke your preferences at any time using our cookie settings or by visiting your browser's privacy controls.
3.5. Third-Party Services and Embedded Content
Our Platform may contain content hosted by third parties (e.g., YouTube videos, SlideShare decks, social media widgets) that may set cookies independent of Orbas Learn. These third-party cookies are governed by the privacy and cookie policies of the respective providers.
We do not control the data collected by such third parties and recommend reviewing their terms to understand how your data may be processed. Examples of such providers include:
- Chatwoot or similar customer service widgets
Where possible, we take reasonable steps to audit and restrict third-party integrations to services that demonstrate compliance with UK data protection obligations.
4. Legal Basis for Using Cookies
The deployment and use of cookies on the Orbas Learn Platform is governed by the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR), as amended. This section explains the legal framework under which we process data through cookies and outlines the user rights and consent mechanisms applicable.
4.1. Consent Requirement Under UK GDPR & PECR
Under Regulation 6 of PECR and Article 6 of the UK GDPR, we are required to obtain users’ prior, informed consent before placing or accessing any cookies that are not strictly necessary for the provision of an online service explicitly requested by the user.
This includes cookies used for analytics, functionality enhancement, personalisation, advertising, and social media integration. Consent must be:
- Freely given, specific, informed, and unambiguous;
- Provided via a clear affirmative action (e.g., ticking a box or selecting cookie preferences);
- Granular, allowing users to select or reject categories of cookies.
No pre-ticked boxes or implied consent mechanisms are permitted. Consent logs are maintained in accordance with UK GDPR requirements and can be made available to supervisory authorities upon lawful request.
4.2. Exceptions for Strictly Necessary Cookies
Strictly necessary cookies do not require user consent. These cookies are essential to the basic operation of the Platform and are exempt from consent under PECR. Examples include:
- Authentication tokens for login functionality;
- Session cookies to manage data entry or transactions;
- Security cookies used to protect against fraud or abuse.
Although we do not require consent for these cookies, their usage is still disclosed in this Policy in the interests of transparency and accountability.
4.3. Cookie Banner and Consent Mechanism
Upon first visit to the Platform, users are presented with a cookie banner that enables them to:
- Reject non-essential cookies;
- Customise cookie preferences by category.
The cookie banner operates through a consent management platform that stores your preferences for a defined period (usually 6–12 months) or until you clear your browser cache or update your settings. Users may revisit and amend their cookie choices at any time by accessing the “Cookie Settings” link provided in the website footer.
Consent is applied on a per-device and per-browser basis, meaning changes to cookie preferences must be repeated for each device or browser you use to access the Platform.
We regularly review our consent management procedures and technologies to ensure compliance with evolving regulatory guidance issued by the Information Commissioner's Office (ICO) or other relevant supervisory authorities in the United Kingdom.
5. Managing and Disabling Cookies
Orbas Learn recognises the rights of users to control how cookies are used on their devices. This section outlines the procedures for withdrawing consent, customising preferences, and managing cookies through browser-level settings. Users are encouraged to review this information carefully to make informed decisions about their data.
5.1. How to Withdraw or Modify Consent
You may withdraw or modify your cookie consent at any time through our Cookie Preferences Centre, accessible via the footer link on every page of the Platform. Within this interface, you can:
- View current cookie settings
- Enable or disable categories of cookies (e.g., analytics, marketing, functionality)
- Access detailed descriptions of each cookie and its purpose
Changes made in the Cookie Preferences Centre will take effect immediately for future cookie placements. Previously stored cookies may need to be manually deleted through your browser (see 5.2 below).
Please note that withdrawing consent for certain cookie categories (e.g., performance or functional cookies) may reduce the overall quality or usability of the Platform.
5.2. Browser Settings and Control Options
In addition to our in-platform consent tools, you may manage cookie behaviour through your web browser’s settings. Most modern browsers allow you to:
- Block all cookies or specific types of cookies
- Receive notifications before cookies are set
- Delete cookies manually or automatically on browser close
- Set exceptions for trusted websites
Instructions for managing cookies vary depending on the browser you use. The following links provide browser-specific guidance
If you use multiple browsers or devices, you will need to configure settings for each separately. We do not guarantee the effectiveness or compatibility of all third-party cookie management tools or browser extensions.
5.3. Impact of Disabling Cookies on Platform Use
Disabling or restricting certain cookies may impair the functionality, performance, and security of the Orbas Learn Platform. Specifically:
- Strictly necessary cookies cannot be disabled without impairing core functions such as login authentication, course access, or checkout processes
- Disabling performance cookies may limit our ability to detect bugs, optimise features, or improve the user experience
- Blocking functionality cookies may result in your preferences not being remembered, requiring repetitive configuration across sessions
- Turning off targeting cookies will not affect your access to services, but may result in less relevant advertising or promotions being shown
We will make reasonable efforts to provide a functional experience regardless of cookie preferences, but full Platform optimisation depends on your consent to certain cookie categories.
6. Data Sharing and Retention
This section sets out Orbas Learn’s policies regarding the sharing of cookie-derived data with third parties, the duration for which such data is retained on user devices, and the safeguards applied where data may be transferred internationally.
6.1. Sharing Cookie Data with Third Parties
We may share limited cookie-derived data with selected third-party service providers for purposes consistent with the lawful bases outlined in Section 4 of this Policy. These include:
- Analytics providers (e.g., Google Analytics) for measuring traffic and user behaviour
- Marketing platforms (e.g., Meta Ads, LinkedIn) for targeted advertising and campaign optimisation
- Hosting and cloud service providers responsible for data storage and delivery performance
- Legal, audit, and compliance consultants where necessary to comply with regulatory obligations
All third parties are contractually bound by data processing agreements that reflect UK GDPR Article 28 requirements. These contracts ensure that third-party recipients:
- Process data only for authorised purposes
- Maintain appropriate technical and organisational security measures
- Do not re-sell, share, or otherwise exploit data outside of contractual scope
Where third parties are considered data controllers in their own right (e.g., when setting third-party cookies), they are independently responsible for compliance with applicable data protection laws. Users are encouraged to consult the privacy and cookie notices of those third parties via our Consent Management Platform.
6.2. Cookie Lifespan and Expiry Schedules
Each cookie deployed on the Orbas Learn Platform is assigned a defined lifespan based on its intended purpose. The durations generally fall into the following categories:
- Session cookies: Deleted when the browser session ends
- Functional and preference cookies: Typically expire within 6 to 12 months unless renewed by user interaction
- Analytics and performance cookies: Expire within 13 months or sooner, depending on vendor policies
- Targeting and advertising cookies: Lifespans vary, but are capped at a maximum of 13 months from the date of user consent in accordance with current ICO guidance
Users can view and manage the specific expiry dates of active cookies at any time through the Cookie Preferences Centre.
6.3. Transfers Outside the UK or EEA
Where cookie-derived personal data is transferred outside the United Kingdom or European Economic Area (EEA)—for example, to servers or cloud infrastructure operated by third-party analytics or hosting providers—we implement adequate safeguards to protect your data in accordance with Chapter V of the UK GDPR.
Such safeguards may include:
- Transfer to jurisdictions subject to adequacy decisions by the UK Government
- Use of the International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs) adopted or approved by the UK Information Commissioner’s Office
- Supplemental technical and organisational measures (e.g., encryption, data minimisation)
You may request further information about specific transfers and safeguards by contacting our Data Protection Officer (DPO) using the contact details provided in Section 1.3.
7. Updates to This Cookie Policy
Orbas Learn reserves the right to amend or update this Cookie Policy at any time to reflect changes in legal requirements, technological advancements, or business practices. Users are encouraged to review this Policy periodically to stay informed about our use of cookies and tracking technologies.
7.1. Notification of Material Changes
Where changes to this Policy are considered material—for example, if we introduce new categories of cookies, alter the purposes for which cookies are used, or significantly change our legal basis for processing cookie data—we will:
- Provide prominent notice via the Platform’s homepage or consent banner
- Send direct notifications to registered users where legally required
- Update the Cookie Preferences Centre to reflect any modifications.
Material changes will be clearly indicated and, where required by law, we will obtain renewed consent for the placement of new or modified cookies.
7.2. Effective Date of Updates
Each version of this Policy will display its effective date at the top or bottom of the document. Continued use of the Platform after the effective date of any updated version constitutes acceptance of those changes, provided that all applicable consent requirements are fulfilled.
8. Contact Us
8.1. How to Reach the Data Protection Officer
If you do not agree with the updated terms, you should update your cookie preferences and discontinue use of the Platform.If you have any questions, concerns, or requests regarding this Cookie Policy or our use of cookies on the Orbas Learn Platform, you may contact our designated Data Protection Officer (DPO) as follows:
Data Protection Officer
Blackridge Group Ltd
61 Bridge Street, Kington, Hertfordshire, United Kingdom, HR5 3DJ
Email: legal@orbas.io
We will make reasonable efforts to respond to all inquiries promptly and in accordance with applicable data protection laws.
8.2. How to Lodge a Complaint (e.g. ICO)
If you believe that our use of cookies or related data practices violate your rights under data protection legislation, you have the right to lodge a complaint with the relevant supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ICO):
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: https://ico.org.uk
Helpline: +44 (0)303 123 1113
We encourage you to contact us first to allow us an opportunity to address your concerns before escalating to the ICO.
