Cookie Policy

Version: 1.3

Last updated: 9 October 2026

1. About This Policy

This Cookie Policy explains how Talent Cloud Global Ltd ("Talent Cloud", "we", "our" or "us") uses cookies, local browser storage and other storage and access technologies on our public website.

It explains:

what cookies and storage and access technologies are;
which technologies we currently use;
why we use them;
which technologies are necessary;
how optional analytics technologies are handled;
when consent or another applicable exception may be relevant;
how third-party technologies are governed;
how long relevant technologies operate or store information;
how you can manage your choices; and
how this Policy relates to our wider privacy framework.

This Policy applies to:

talentcloudglobal.com

and public website pages operated by Talent Cloud that use the same storage, analytics and preference-management framework.

Our authenticated learner, administration and other product applications may use different technologies.

This Policy should be read alongside our Privacy Notice, which explains more generally how Talent Cloud processes personal information.

2. Who We Are

The public website is operated by:

Talent Cloud Global Ltd

Registered in England and Wales Company number: 16914164

Registered office:

Suite A 82 James Carter Road Mildenhall Suffolk IP28 7DE United Kingdom

Email: support@talentcloudglobal.com

3. What Are Cookies?

Cookies are small pieces of information that can be stored on a user's device when they visit or interact with a website.

Cookies can perform different functions.

For example, they may:

remember choices or preferences;
support website functionality;
support security;
maintain a session;
help understand how a website is being used; or
enable other website services.

Cookies may be:

Session Cookies

Temporary cookies that generally expire when the relevant browser session ends.

Persistent Cookies

Cookies that remain for a defined period or until they are deleted.

First-Party Cookies

Cookies set by or for the website or domain being visited.

Third-Party Cookies

Cookies set or accessed by another organisation through technology used on the website.

4. Storage and Access Technologies

Not every technology that stores or accesses information on a device is technically a cookie.

Websites may also use technologies such as:

local browser storage;
session storage;
scripts;
tags;
pixels;
software development components;
embedded third-party services; and
other technologies capable of storing or accessing information on a user's device.

For convenience, this Policy may sometimes use the term "cookies" when discussing these technologies collectively.

Where a material distinction matters, we identify it.

Our obligations are determined by what the technology actually does, not simply by whether it is technically described as a cookie.

5. Our Approach

We aim to use storage and access technologies in a transparent and proportionate way.

We distinguish between:

Necessary Technologies

Technologies required to provide a service requested by the visitor or to operate functionality that is necessary for that service.

Technologies that are not covered by an applicable exception and therefore require the visitor's consent before they are used.

Technologies Operating Under Another Applicable Exception

In some circumstances, applicable law may permit storage or access without prior consent where specific conditions are satisfied.

Those conditions depend on the purpose and implementation of the technology.

The existence of a legal exception does not mean that every technology that appears to have a similar purpose automatically qualifies for it.

Advertising and Behavioural-Marketing Technologies

Technologies used for activities such as advertising profiling, retargeting or cross-site behavioural advertising.

We do not currently operate an advertising or behavioural-marketing cookie programme on the public Talent Cloud website.

6. Current-Document Analytics Choices

Optional analytics starts disabled whenever a new website document loads. We require an affirmative choice in that document before enabling optional analytics.

Your analytics choice applies only to the current document. Navigation within that document without a full reload keeps the current choice. A full reload or a new document requires a fresh choice.

We do not save this analytics choice in cookies, local browser storage or another persistence mechanism, and we do not use a previously stored acceptance to enable analytics.

If your browser restores the same document using its back/forward cache, that document retains its current choice, including any withdrawal made in that document. This does not carry consent to a different document.

You can accept optional analytics, reject it or manage your choice through the website's preference controls. You can withdraw acceptance using Cookie Preferences. Rejecting or withdrawing optional analytics does not prevent use of the public website or its commercial enquiry forms.

7. Optional Analytics

The public website may use optional analytics technologies to help us understand how the website is being used.

Our current analytics implementation may include:

Google Tag Manager; and
Google Analytics.

Analytics may help us understand matters such as:

visits to public website pages;
how visitors interact with website content;
aggregate website usage;
website performance;
navigation patterns; and
opportunities to improve content and usability.

Our current operational position is that Google Analytics remains consent-gated.

Where our use of an analytics technology relies on consent, that technology must not be activated before the required consent has been obtained.

Rejecting optional analytics should not prevent a visitor from accessing the public website.

8. Statistical-Purpose Exceptions

Applicable storage and access rules may permit certain technologies used solely for statistical purposes to operate without prior consent where the requirements of the relevant exception are satisfied.

Those requirements can include matters such as:

the technology being used solely for an eligible statistical purpose;
the information being used with a view to improving the service;
appropriate transparency being provided; and
an appropriate means of objecting being available.

We do not assume that a technology qualifies for this type of exception merely because it is described as analytics.

In particular, the existence of a statistical-purpose exception does not mean that our current Google Analytics implementation automatically qualifies for it.

Unless and until we have assessed and documented that a deployed analytics configuration satisfies an applicable exception, our current Google Analytics implementation should remain subject to the consent mechanism described in this Policy.

Different technologies may have different legal requirements.

Where consent is required:

the relevant optional technology should remain inactive before consent;
consent should require an affirmative choice;
rejecting the technology should not prevent access to the public website where the technology is genuinely optional;
the visitor should be able to change or withdraw the choice; and
the technology should be used only for the purposes covered by the choice.

We do not treat:

continuing to browse;
closing or ignoring a cookie banner;
accepting our Website Terms;
receiving our Privacy Notice;
accepting platform terms;
activating a Talent Cloud account; or
enrolling in a workforce programme

as consent to optional website analytics.

Where an Exception Applies

Where a storage or access technology lawfully operates under an applicable exception, prior consent may not be required.

Some exceptions may nevertheless require:

clear information;
an appropriate means of objecting; or
other safeguards.

We assess the applicable requirements according to the actual technology, purpose and configuration.

We do not describe a technology as exempt merely because obtaining consent would be inconvenient.

10. Google Tag Manager

Google Tag Manager is a tag-management technology.

It can be used to manage the deployment of other website technologies.

The presence of Google Tag Manager does not by itself mean that every technology capable of being managed through it is active.

Our public website should use Google Tag Manager in accordance with the visitor's applicable cookie preferences and our approved configuration.

Where a tag deployed through Google Tag Manager requires consent, it should not be activated before that consent has been obtained.

Material changes to:

tags;
triggers;
analytics technologies;
third-party services; or
processing purposes

deployed through a tag-management service should be subject to appropriate review before production activation.

Google Tag Manager should not be treated as a route for introducing additional tracking technologies without corresponding privacy, cookie and governance review.

11. Google Analytics

Where analytics consent is granted, Google Analytics may be used to help us understand use of the public website.

Depending on the deployed configuration, analytics processing may involve information relating to:

website pages visited;
interactions with website content;
technical information;
device or browser information;
timestamps;
analytics identifiers; and
other website usage information associated with the configured analytics service.

Google's processing through its services is also subject to Google's applicable terms and privacy practices.

However, the involvement of a third-party provider does not remove Talent Cloud's responsibility for determining whether our use of that technology is lawful, appropriately configured and accurately described.

Use of Google Analytics does not mean that Talent Cloud operates Google advertising or behavioural-marketing services.

12. Current Public Website Technology Position

Our current public website position is set out below.

Current-Document Analytics Choice

Provider: Talent Cloud

Technology: In-memory state within the current website document; the analytics choice is not persisted in browser storage.

Purpose: To apply the visitor's analytics choice in the current document, including rejection and withdrawal.

Category: Preference management

Consent position: Optional analytics remains disabled unless the visitor makes an affirmative acceptance in the current document. Advertising consent remains denied.

Duration: The choice applies only to the current document, including navigation or back/forward-cache restoration of that same document. A full reload or new document starts with optional analytics disabled and requires fresh consent.

Google Tag Manager

Provider: Google

Purpose: To support management of approved website analytics technologies.

Category: Analytics / tag management

Current position: Optional in connection with our analytics implementation.

Consent position: Consent-gated where used to deploy optional analytics requiring consent.

Duration: Depends on the technologies deployed through the verified production configuration.

Google Analytics

Provider: Google

Purpose: To understand public website usage and help improve website content, performance and user experience.

Category: Analytics

Current position: Optional.

Consent position: Currently consent-gated.

Duration: The applicable identifiers and expiry periods must correspond to the verified production Google Analytics configuration.

Advertising and Behavioural Marketing

Current position: We do not currently operate an advertising or behavioural-marketing cookie programme on the public Talent Cloud website.

We do not ask visitors to accept an advertising-cookie category that we do not currently use.

13. Technology Duration and Retention

The duration of a cookie or other storage technology should reflect its purpose and configuration.

Different technologies may operate for:

a browser session;
a fixed period;
until a visitor changes a preference;
until browser storage is cleared; or
another configured period.

Where a technology has a defined expiry or storage duration, our public information should accurately reflect the production configuration.

We should not publish an assumed duration merely because it is a provider default where our actual implementation has not been verified.

The current production technology register or cookie information should therefore be reviewed when:

a technology is introduced;
a duration changes;
an analytics configuration changes; or
another material storage or access change is made.

Visitors can change their cookie preferences using the Cookie Preferences control available through the website.

Where processing relies on consent, withdrawal should be as straightforward as giving that consent.

Where a visitor withdraws analytics consent:

technologies relying on that consent should cease operating for future activity as soon as reasonably practicable through our preference mechanism;
new analytics events should not continue to be generated on the basis of the withdrawn consent; and
new analytics identifiers should not continue to be created on the basis of that withdrawn consent.

Withdrawal does not retrospectively make processing carried out lawfully before withdrawal unlawful.

Information already received by an analytics provider may also be subject to applicable retention, deletion and technical processes.

Where we request consent to optional technologies, we aim to present the choice clearly.

Our preference mechanism should not be designed to:

treat inactivity as consent;
hide the ability to reject optional technologies;
misrepresent optional technologies as necessary;
bundle unrelated purposes together without appropriate justification; or
make an equivalent available rejection choice materially harder to exercise merely to encourage acceptance.

The purpose of the mechanism is to provide a meaningful choice rather than simply obtain the maximum possible acceptance rate.

16. Browser Controls

Most browsers provide independent controls for managing cookies and browser storage.

Depending on the browser, these controls may allow a visitor to:

view cookies;
delete cookies;
block cookies;
restrict cookies;
clear local browser storage;
clear website data; or
manage permissions for particular websites.

Browser controls operate independently from Talent Cloud's website preference mechanism.

Your optional analytics choice is not saved in browser storage. Clearing or blocking that storage does not restore a previous analytics acceptance. A full reload or new website document requires a fresh choice regardless of whether browser storage is available.

Browser restrictions may separately affect other website functionality that relies on storage. You can continue to use our commercial enquiry forms without accepting optional analytics.

17. Third-Party Technologies

Where optional analytics is enabled, third-party technologies may process information in connection with website measurement.

Third-party providers may process information in jurisdictions outside the visitor's country.

Our Privacy Notice provides further information about international processing and our wider approach to personal information.

The use of a third-party service does not transfer responsibility for our own website configuration to that provider.

Before materially changing a third-party storage or access technology, we should consider matters including:

the provider;
the purpose;
information stored or accessed;
personal information involved;
storage duration;
whether consent is required;
whether an exception applies;
international processing;
provider terms;
privacy implications; and
whether this Policy requires updating.

18. Embedded Third-Party Content

Our public website may use or link to third-party services that provide embedded or interactive functionality.

Depending on how an embedded service is configured, the third party may receive technical information or store or access information on the visitor's device.

The relevant treatment depends on whether the service:

loads automatically;
operates only after interaction;
stores or accesses information before interaction;
is necessary for a service requested by the visitor; or
performs additional analytics, advertising or other functions.

We assess material embedded services according to their actual production behaviour.

A third-party embed should not be assumed to be free from storage or access activity merely because it appears as content within a Talent Cloud page.

Where an embedded service requires additional consent or transparency, the relevant controls and information should be provided.

At the date of this Policy, we do not currently operate an advertising or behavioural-marketing cookie programme on the public website.

This means we do not currently describe technologies such as:

advertising retargeting;
behavioural advertising;
cross-site advertising profiles; or
advertising audience tracking

as part of our public website cookie programme.

If we propose to introduce such technologies in future, they should be reviewed before production activation.

That review should consider:

the purpose;
provider;
information processed;
consent requirements;
preference category;
profiling implications;
international processing;
applicable privacy requirements; and
updates required to this Policy and our Privacy Notice.

20. Public Website and Product Applications

This Policy primarily describes the public Talent Cloud website.

Our learner, administration and other authenticated product applications may use different storage and access technologies.

For example, product applications may use browser storage or similar technologies for matters such as:

authentication;
security;
session management;
user preferences; or
application functionality.

A technology used in a product application should not automatically be described as advertising or analytics merely because it uses browser storage.

Where an authenticated product uses additional technologies requiring specific notice, consent or another user choice, those requirements should be addressed within the relevant product experience.

This Policy should not be used as evidence that a technology described for the public website is also used in an authenticated Talent Cloud application, or vice versa.

21. Changes to Website Technologies

Our website and technology providers may change over time.

Before introducing a materially different storage or access technology, we should consider whether the change affects:

the purpose of processing;
information stored or accessed;
consent requirements;
applicability of an exception;
objection requirements;
third-party recipients;
storage duration;
international processing;
privacy information;
the preference mechanism; or
this Policy.

A previous consent should not automatically be treated as covering a materially different purpose or technology where a new choice is required.

22. Technology Governance and Verification

Our Cookie Policy should reflect technologies actually operating on the public website.

We distinguish between:

technologies currently active in production;
optional technologies configured to operate only after consent;
technologies operating under an identified applicable exception;
technologies supported by code or configuration but not currently active;
historical technologies no longer in use; and
technologies being considered for future introduction.

Configured, historical or technically supported services should not be described as active merely because they exist within code or configuration.

Material changes to tag-management or analytics configuration should be reviewed against this Policy before or as part of production release.

23. Website Storage & Access Technology Register

We maintain, or should maintain as part of our governance process, an evidence-backed record of material storage and access technologies used on the public website.

The register should record appropriate information such as:

technology or provider;
relevant domain or service;
cookie, storage key or other identifier where applicable;
purpose;
first-party or third-party status;
information stored or accessed;
category;
storage or access duration;
consent requirement or applicable exception;
objection mechanism where relevant;
international-processing considerations;
production status;
responsible owner; and
date last verified.

The register supports accurate public disclosure and internal governance.

A technology should not be treated as currently active solely because it appears in an old register entry.

Production status should be verified where material.

24. Evidence Before Assurance

Our wider governance principle of Evidence Before Assurance applies to website tracking technologies.

Before stating that:

a technology is not active;
a technology operates only after consent;
a particular cookie has a specified duration;
a provider receives no information before interaction;
a technology qualifies for an exception;
withdrawal stops future analytics;
no advertising technology is present; or
a third-party embed behaves in a particular way,

we should have an appropriate evidential basis for that statement.

Website source code alone may not always establish production behaviour.

Where material, verification should include the behaviour of the deployed website.

25. Relationship With Our Other Governance Documents

This Cookie Policy forms part of our wider public governance framework.

Privacy Notice

Explains how Talent Cloud processes personal information more generally, including relevant international processing and privacy rights.

Website Terms of Use

Sets out the conditions applying to use of the public website.

Trust & Compliance Centre

Provides an overview of our public privacy, security and responsible-technology position.

Security Statement

Explains our public security position and the boundaries of our security claims.

These documents have different purposes and should be read according to the matter concerned.

26. Changes to This Policy

We may update this Cookie Policy where:

website technologies change;
analytics arrangements change;
providers change;
storage durations change;
our preference-management approach changes;
an applicable legal exception changes;
legal or regulatory requirements change; or
our privacy and governance arrangements develop.

The current version and last-updated date will be published on the website.

Where a change requires a new consent choice, publication of an updated Policy alone should not be treated as obtaining that consent.

Where a technology moves from a consent-based model to reliance on an applicable exception, we should first verify that the conditions of that exception are satisfied and make any required transparency or objection mechanism available.

27. Contact Us

If you have questions about this Cookie Policy or our use of cookies and storage and access technologies, contact: