1. General Information

This Cookie Policy sets out the rules for using cookies and similar technologies on the website operated by ETB Management Ltd, registered at 15 Ferme Park Road, London, N4 4DS, operating under the Samaya Estates brand (hereinafter: "the Controller").

Cookies are small text files stored on the user's device (computer, tablet, smartphone) when using the website.

2. Purposes of Using Cookies

Cookies are used for the following purposes:

• ensuring proper functioning of the website,
• improving the security and stability of the service,
• statistical analysis and content optimisation,
• conducting marketing and remarketing activities,
• tailoring advertising content to the user's interests.

3. Types of Cookies

The following types of cookies are used on the website:

Essential (Technical) Cookies

Cookies necessary for the proper functioning of the website. Their use does not require user consent.

Analytical Cookies

Cookies that enable the collection of anonymous statistical data about how the website is used (e.g. number of visits, traffic sources, user behaviour).

Marketing Cookies

Cookies used for marketing activities, including remarketing and ad personalisation.

4. Tools Used on the Website

The Controller uses the following external tools:

• Google Analytics 4 (GA4) — website traffic and user behaviour analysis,
• Google Ads — running advertising campaigns and measuring their effectiveness,
• Meta Platforms (Facebook, Instagram) — running marketing and remarketing campaigns.

These tools may use cookies or similar technologies (e.g. tracking pixels).

5. Legal Basis for Using Cookies

The use of cookies is based on:

• Art. 6(1)(f) GDPR — for essential cookies (the Controller's legitimate interest),
• Art. 6(1)(a) GDPR — for analytical and marketing cookies (user consent).

The user may withdraw their consent at any time.

6. Consent Mode v2

The website uses the Google Consent Mode v2 mechanism, which enables management of user cookie consents and adjusts the operation of analytical and advertising tools to the choices made.

Analytical and marketing tools operate in accordance with the user's consent settings and the Google Consent Mode mechanism.

7. Managing Cookies

The user may at any time:

• change cookie settings using the cookie banner available on the website,
• restrict or block cookies through browser settings.

Please note that restricting essential cookies may affect the proper functioning of the website.

8. Cookies and Personal Data

In some cases, cookies may constitute personal data within the meaning of the GDPR. Detailed information about the processing of personal data can be found in the Privacy Policy.

9. Changes to the Cookie Policy

The Controller reserves the right to amend this Cookie Policy, in particular in the event of changes to legislation or the tools used. The current version of the document is always available on the website.