Black Silo Commodity Consulting Limited and Black Silo SRL
Version: 1.0
1. About this Policy
This Cookie Policy explains how Black Silo Commodity Consulting Limited (Ireland) and Black Silo SRL (Romania) (together, "Black Silo," "we," "our," or "us") use cookies and similar technologies on our website https://black-silo.com (the "Site"). It should be read together with our Privacy Policy.
This Policy is written to comply with the EU General Data Protection Regulation (GDPR), the ePrivacy Directive (2002/58/EC) and its Irish (S.I. No. 336 of 2011) and Romanian (Law no. 506/2004) transpositions, and applicable equivalents in other jurisdictions.
2. What Cookies Are
Cookies are small text files that a website places on your device when you visit it. They are widely used to make websites work, to improve user experience, and to provide information to website operators. Cookies set by us are called "first-party cookies." Cookies set by third-party services we use are called "third-party cookies." Some technologies, such as web beacons, pixels, local storage, and JavaScript tags, work similarly to cookies and are covered by this Policy.
We classify cookies and similar technologies into four categories:
- Strictly necessary — required to operate the Site and provide services you have requested. These cannot be switched off.
- Functional — enabling enhanced features (such as remembering your preferences)
- Analytics — allowing us to understand how the Site is used so we can improve it
- Marketing — supporting our marketing and re-engagement activities
3. Your Choices
When you first visit the Site, our cookie banner allows you to:
- Accept all — consent to all cookie categories
- Reject all — refuse all non-essential cookies (strictly necessary cookies will still be set)
- Customise — choose which categories to enable
You can change your preferences at any time by clicking the "Cookie settings" link in the footer of the Site.
Non-essential cookies are not set before you have given consent, except for the cookie that records your consent choice itself. Withdrawing consent does not affect the lawfulness of any processing carried out before withdrawal, but it will stop future processing.
You can also manage cookies in your browser settings. Most browsers allow you to refuse cookies, delete cookies, or be notified when cookies are set. However, disabling strictly necessary cookies may make parts of the Site unusable.
For more information about managing cookies, see www.aboutcookies.org or www.allaboutcookies.org.
4. Cookies We Use
The following table lists the categories of cookies in use on the Site and the providers that set them. Specific cookie names, durations, and purposes are kept up to date in our cookie consent management tool, accessible via the "Cookie settings" link.
4.1 Strictly necessary
| Provider | Purpose | Typical lifetime | Consent required |
|---|---|---|---|
| Black Silo (first-party) | Session management, authentication, security, cookie consent recording, language preference | Session or up to 12 months | No (essential) |
4.2 Functional
| Provider | Purpose | Typical lifetime | Consent required |
|---|---|---|---|
| Black Silo (first-party) | Remembering interface preferences and settings | Up to 12 months | Yes |
4.3 Analytics
| Provider | Purpose | Typical lifetime | Consent required |
|---|---|---|---|
| Google LLC (Google Analytics 4) | Measuring visitor numbers, traffic sources, and engagement patterns to improve the Site | Up to 14 months | Yes |
| HubSpot, Inc. | Analysing visitor behaviour, page-level engagement, and lead-source attribution | Up to 13 months | Yes |
4.4 Marketing
| Provider | Purpose | Typical lifetime | Consent required |
|---|---|---|---|
| HubSpot, Inc. | Linking visitor activity to marketing campaigns and CRM records; supporting personalised re-engagement | Up to 13 months | Yes |
5. Third-Party Providers and International Transfers
Some of the cookie providers we use are based outside the European Economic Area, including in the United States. The relevant providers (Google LLC and HubSpot, Inc.) are certified under the EU-US Data Privacy Framework, which the European Commission has declared provides adequate protection for personal data (Decision (EU) 2023/1795 of 10 July 2023). This provides the legal basis for the transfer of personal data collected through their cookies.
You can review the privacy practices of these providers directly:
Google: policies.google.com/privacy
HubSpot: legal.hubspot.com/privacy-policy
You can also opt out of Google Analytics directly using the Google Analytics Opt-Out Browser Add-on: tools.google.com/dlpage/gaoptout.
For more detail on our international transfer practices generally, see our Privacy Policy, section 6.
6. Do Not Track
Some browsers offer a "Do Not Track" signal. There is currently no consensus among industry participants on how to respond to this signal. We rely on our cookie banner as the primary mechanism for recording your choice, and we honour the choices you make through it.
7. Consent Records and Retention
When you make a choice through our cookie banner, we record the date and version of your choice. This record is retained for as long as required to demonstrate compliance with consent requirements under GDPR Article 7. You can change your choice at any time, and the new choice replaces the previous one.
8. Changes to this Policy
We may update this Cookie Policy from time to time to reflect changes in the cookies we use, in technology, or in legal requirements. The "Effective date" above will be updated when changes are made. Material changes — such as the addition of a new analytics or marketing cookie provider — will trigger a re-prompt of the cookie banner so that you can review and update your choices.
9. Contact
Questions about this Cookie Policy can be sent to:
Black Silo Commodity Consulting Limited
Annagharvey, Tullamore, Offaly, Ireland
Email: [email protected]
This Cookie Policy is provided for informational purposes and does not constitute legal advice.
