Cookie Policy

1. What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, or mobile) when you visit a website. They help websites recognize your device and remember information about your visit, such as preferences or login status.

Types of Cookies

• Session Cookies: Temporary cookies deleted when you close your browser
• Persistent Cookies: Remain on your device for a set period or until manually deleted
• First-Party Cookies: Set by the website you're visiting
• Third-Party Cookies: Set by external services used by the website

2. How We Use Cookies

Currently, our website uses minimal cookies and similar technologies. Below is a comprehensive overview of how cookies may be used:

2.1 Strictly Necessary Cookies

These cookies are essential for website functionality and cannot be disabled. They include:

• Security Cookies: Help protect against security threats
• Session Management: Enable core website functionality
• Load Balancing: Distribute traffic for optimal performance

Legal Basis: Legitimate interest in providing website functionality (GDPR Article 6(1)(f))

2.2 Performance and Analytics Cookies

These cookies collect information about how visitors use our website, such as:

• Which pages are visited most often
• How long visitors stay on pages
• Navigation patterns through the site
• Error messages encountered

Current Status: We do not currently use analytics cookies, but may implement them in the future with proper consent mechanisms.

Legal Basis: Consent (GDPR Article 6(1)(a) and ePrivacy Directive)

2.3 Functional Cookies

These cookies remember your preferences and choices, such as:

• Language preferences
• Region or country selection
• Display preferences (dark mode, text size)
• Previous form entries to save time

Current Status: Not currently implemented

Legal Basis: Consent or legitimate interest depending on functionality

2.4 Marketing and Advertising Cookies

These cookies track your browsing to show relevant advertisements:

• Remember websites you've visited
• Track advertising campaign effectiveness
• Limit ad frequency
• Measure ad engagement

Current Status: We do not use marketing or advertising cookies

Legal Basis: Consent (GDPR Article 6(1)(a))

3. Third-Party Services

3.1 Current Third-Party Services

Our website currently uses the following third-party services that may set cookies or collect data:

3.2 Potential Future Services

We may implement additional services in the future. Before doing so, we will:

• Update this Cookie Policy
• Implement appropriate consent mechanisms where required
• Provide clear information about new cookies
• Honor your cookie preferences

4. Cookie Management and Your Choices

4.1 Browser Controls

Most browsers allow you to manage cookie preferences. You can:

• Block all cookies
• Block third-party cookies only
• Delete cookies after each session
• Accept or reject cookies on a case-by-case basis

Browser-specific instructions:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Cookies and website data
• Edge: Settings → Cookies and site permissions → Cookies and site data

4.2 Do Not Track (DNT) Signals

Some browsers support "Do Not Track" (DNT) signals. However, there is no industry standard for responding to DNT signals. We honor Global Privacy Control (GPC) signals as required by California law.

4.3 Opt-Out Links

For specific third-party services, you can opt out through:

• Google: Google Ad Settings
• Network Advertising Initiative: NAI Opt-Out
• Digital Advertising Alliance: DAA Opt-Out

4.4 Impact of Blocking Cookies

Blocking cookies may affect website functionality:

• Strictly Necessary: May prevent access to certain features
• Functional: May lose preference settings and personalization
• Performance: May reduce ability to improve user experience
• Marketing: Will still see ads, but they may be less relevant

5. Specific Regional Requirements

5.1 United States (Federal and State Laws)

As a Washington state-based company, we comply with applicable US federal and state privacy laws:

• We obtain consent before setting non-essential cookies where required
• You can withdraw consent at any time
• We provide clear information about cookie purposes
• We respect your cookie preferences and privacy choices
• We honor Global Privacy Control (GPC) browser signals

5.2 California (CCPA/CPRA)

California residents have specific rights under CCPA/CPRA effective January 1, 2026:

• Right to opt-out of cookie-based tracking for advertising purposes
• We honor Global Privacy Control (GPC) browser signals
• We do not sell or share personal information collected via cookies
• You can exercise rights through our Privacy Policy contact information

5.3 European Economic Area and UK (GDPR & ePrivacy)

For visitors from the EEA and UK, we comply with GDPR and the Privacy and Electronic Communications Regulations:

• We obtain consent before setting non-essential cookies
• You can withdraw consent at any time
• We provide clear information about cookie purposes and data processing
• We respect your cookie preferences under European privacy laws

5.4 Other Jurisdictions

We comply with applicable data protection and privacy laws in all jurisdictions where we operate. If your jurisdiction has specific requirements, please contact us for information.

6. Updates to This Cookie Policy

We may update this Cookie Policy to reflect:

• Changes in our use of cookies
• New third-party services
• Legal or regulatory requirements
• Best practice recommendations

Material changes will be notified through:

• Website banner notification
• Updated "Last Updated" date at the top of this policy
• Email notification if you are a client

7. More Information About Cookies

For more information about cookies and how they work, visit:

• All About Cookies: allaboutcookies.org
• UK ICO: ico.org.uk/cookies
• EU Cookie Law: Information about GDPR and ePrivacy Directive requirements

8. Contact Us

If you have questions about our use of cookies or this Cookie Policy, please contact us:

• Email: hello@tgrahamconsulting.com
• Website: www.tgrahamconsulting.com

We aim to respond within 24-48 hours for general inquiries.