Legal
Cookie Notice
This Cookie Notice explains the cookies and similar storage technologies used on https://265.capital (the "Site"), the purpose for which they are used, and how you can control them. It supplements our Privacy Statement.
Summary. The Site sets one first-party cookie (ncaf_gate), and only after you have completed the investor-eligibility attestation on the Asset Management or Investors pages. That cookie is strictly necessary to enforce a legally-required access restriction. The Site uses no advertising cookies, no analytics cookies, no marketing pixels, no fingerprinting, and no session-replay tools. No consent banner is displayed because no non-essential cookies are set.
1. What is a cookie
A "cookie" is a small text file stored by your browser on your device when you visit a website. Cookies allow a website to recognise your browser across requests, store small amounts of state, and operate certain features. Similar technologies include localStorage, sessionStorage, and signed tokens. Where this notice refers to "cookies", it means cookies and any equivalent client-side storage.
2. Cookies we set
The following first-party cookie is set by the Site:
| Name | Purpose | Type | Duration | Information stored |
|---|---|---|---|---|
ncaf_gate |
Records that you have completed the qualified-investor eligibility attestation required to access fund-related materials on the Asset Management and Investors pages. Without it, restricted content is not served. | First-party · Strictly necessary | 180 days from acceptance, or until you clear it | An HMAC-signed token containing: a random gate identifier, your declared country of residence, your declared investor category, the version and content-hash of the declaration text you accepted, and an expiry timestamp. The cookie is HttpOnly, Secure and SameSite=Lax; it cannot be read by client-side JavaScript and is transmitted only to 265.capital. |
The Site does not set any other cookies. Specifically, the Site does not use:
- advertising or marketing cookies;
- web analytics cookies (e.g. Google Analytics, Plausible, Matomo);
- social-media tracking pixels (e.g. LinkedIn, Meta, X);
- session-replay or heat-mapping tools (e.g. Hotjar, FullStory);
- fingerprinting or device-graph identifiers;
- third-party preference cookies.
3. Why we do not display a cookie consent banner
Under Article 5(3) of the ePrivacy Directive (Directive 2002/58/EC) as transposed into local law (including Article 11.7a of the Dutch Telecommunicatiewet and the UK Privacy and Electronic Communications Regulations 2003), prior consent is required before setting cookies on a user's device, with the exception of cookies that are strictly necessary for a service explicitly requested by the user.
The ncaf_gate cookie meets that exception: it exists solely to record the eligibility declaration that the law requires us to obtain before making restricted fund materials available to you. Setting the cookie is the means by which the Site avoids re-prompting you on every page request. You cannot opt out of this cookie while continuing to view the restricted content; you may decline the attestation, in which case the cookie is not set and the restricted content is not served.
Because we set no other cookies, no further consent prompt is required. If we ever introduce non-essential cookies (for example, web analytics), we will deploy a compliant consent mechanism before doing so and update this Notice.
4. Third-party requests that do not involve cookies
When you load the Site, your browser makes requests to the following third parties to render fonts. These requests transmit standard technical data (your IP address, user-agent, the URL of the page you are viewing) but do not set cookies on your device:
- Google Fonts (fonts.googleapis.com, fonts.gstatic.com) — to deliver the Site's typefaces. Google's processing of these requests is governed by the Google Privacy Policy.
In addition, when you submit the contact form or click the meeting-booking link, your data is processed by:
- Resend (transactional email delivery) for sending us your contact-form message;
- Microsoft Bookings / Outlook (meeting scheduling) when you click "Book a meeting".
These services may set their own cookies on the destination pages, governed by their respective privacy policies. The Site itself does not place any of those cookies on your device.
5. How to control cookies
You can clear or block cookies through your browser settings. Common paths:
- Chrome: Settings → Privacy and security → Cookies and other site data;
- Safari: Settings → Privacy → Manage Website Data;
- Firefox: Settings → Privacy & Security → Cookies and Site Data;
- Edge: Settings → Cookies and site permissions.
Clearing the ncaf_gate cookie will require you to complete the eligibility attestation again on your next visit to the restricted pages.
Browsers also typically allow you to refuse all cookies or to be prompted before cookies are set. If you refuse the ncaf_gate cookie, you will not be able to view the restricted fund-related content, but the public pages of the Site will continue to function normally.
6. Changes to this Notice
We may update this Notice to reflect changes in the cookies we use or applicable law. Material changes will be flagged here with a new "Last updated" date.
7. Contact
Questions about this Notice or our use of cookies should be directed to jorgo@265.capital.
265 Capital · See also our Privacy Statement and Terms.