Cookie Policy
Last updated 20 October 2026
Version 4.0 | Last updated 9 October 2026
1. About this Cookie Policy
1.1 This Cookie Policy explains how Earnly Limited, a private limited company registered in England and Wales (company number 16183799), registered office 41 New Cross Street, Swinton, Manchester, England, M27 4TU ("Earnly", "we", "us", "our"), uses cookies and similar technologies on our website at earnly.co.uk and in the Earnly platform (the "Platform"), through which the Services are provided.
1.2 The Platform is a responsive web application. We do not currently offer a native mobile app. If we release mobile apps, this Cookie Policy applies to them too, and we will update it to list anything the app stores on your device before the app is released.
1.3 Read it with our Privacy Policy, which explains how we process personal data. Terms defined in the Privacy Policy have the same meaning here, including "Account", "Business Day", "Business User", "Connected Account", "Consumer", "Individual", "Open Banking Data", "Organisation", "Outputs" and "Provider".
1.4 This Cookie Policy is incorporated into the agreement between you and Earnly (the "Agreement") under the "Documents forming part of the Agreement and order of precedence" clause of the Terms and Conditions. If there is a conflict between documents forming the Agreement, the order of precedence in that clause applies: in summary, the Privacy Policy prevails on the processing of personal data, and the Terms and Conditions prevail over this Cookie Policy.
1.5 We use cookies in accordance with regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 ("PECR"), as amended by the Data (Use and Access) Act 2025 ("DUAA"), and, where cookies involve personal data, the UK General Data Protection Regulation ("UK GDPR").
2. Our position in brief
2.1 We do not use analytics, advertising or tracking cookies, or any similar technology for those purposes, on our website or in the Platform.
2.2 Everything we store on your device is either strictly necessary to provide the service you have asked for, or remembers a preference about how the Platform looks or works for you.
2.3 Because of this, the law does not require us to ask for your consent, and we do not show a cookie consent banner.
2.4 Before we add any analytics, advertising, marketing or other cookie that needs consent, we will deploy a consent tool and update this Cookie Policy, and we will not set that cookie unless you opt in (section 9).
3. Who this applies to
3.1 This Cookie Policy applies to everyone who visits our website or uses the Platform, whether as a Consumer, as a sole trader or other Business User, as an individual acting for an Organisation, or as a visitor who does not have an Account.
3.2 What is stored on your device applies to your browser on that device only. If you are an individual acting for an Organisation, it does not affect anyone else in the Organisation.
4. What cookies and similar technologies are
4.1 A cookie is a small text file placed on your device by a website. Similar technologies include without limitation local storage and session storage in your browser, pixels, tags, scripts and software development kits in mobile apps. PECR applies to all of them because they store information on, or read information from, your device. In this Cookie Policy we call all of them "cookies" unless we need to tell them apart.
4.2 Local storage keeps information in your browser until it is cleared. Session storage keeps information only until you close the browser tab or window.
4.3 A first-party cookie is set by Earnly. A third-party cookie is set by another organisation. We use first-party cookies only.
5. Cookies and your banking information
5.1 We do not use cookies to access, collect, transmit or store your online banking credentials, and we do not use cookies to access a Connected Account.
5.2 The connection to a Connected Account is made through the Provider, Finexer Ltd, in an authenticated journey with your own bank. Your online banking credentials are entered only with your bank and never reach Earnly.
5.3 Cookies do not give anyone access to your Open Banking Data. Access to that data requires you to sign in to your Account.
5.4 No advertising or third-party tracking technology runs on our website or in the Platform, including on pages that display Open Banking Data, Outputs or other financial information.
6. How the law treats each type of cookie
6.1 PECR requires us to tell you clearly about every cookie we use. Whether we also need your consent depends on the type:
| Type | Do we need your consent? | Do we use it? |
|---|---|---|
| Strictly necessary, including security | No. Exempt under regulation 6 PECR because the cookie is strictly necessary to provide the service you have asked for, or to keep it or your device secure | Yes |
| Appearance and preferences | No, under the DUAA exemption for enabling the way the service appears or functions to adapt to your preferences, provided we give you clear information and a simple, free way to object | Yes |
| Statistical (first-party analytics to improve our service) | No, under the DUAA exemption, provided we give you clear information and a simple, free way to object | No |
| All other cookies, including third-party analytics, session recording, marketing, advertising, social media and cross-site tracking | Yes. Prior opt-in consent | No |
6.2 We do not use cookies for emergency location purposes.
7. Cookies we use
7.1 The table lists every cookie and similar technology used in the Platform and on our website, from our audit carried out on 9 October 2026. All are first party and set by Earnly.
| Name | Type | Purpose | Duration |
|---|---|---|---|
| sb-<project>-auth-token | localStorage | keeps you signed in | until sign-out or session expiry |
| earnly-theme | localStorage | light/dark preference | until cleared |
| earnly:app-mode | localStorage | business or personal view | until cleared |
| earnly:active-entity | localStorage | the company you were last viewing | until cleared |
| earnly:onboarding:v2 | localStorage | saves your onboarding progress | cleared on completion |
| earnly:pin | localStorage | salted hash of your device PIN | until cleared |
| earnly:pin-prompted | localStorage | PIN setup prompt shown | until cleared |
| earnly_sidebar_open | cookie and localStorage | sidebar state | 365 days |
| sidebar_state | cookie | sidebar state | 7 days |
| earnly:2fa-pending | sessionStorage | sign-in verification step | session |
| earnly:pin-unlocked | sessionStorage | PIN unlocked this session | session |
| earnly:pending-onboarding | sessionStorage | signup in progress | session |
7.2 In the name "sb-<project>-auth-token", "<project>" stands for the identifier of our database project, which is the same for every user.
7.3 Category of each item:
7.3.1 strictly necessary, including security: sb-<project>-auth-token, earnly:onboarding:v2, earnly:pin, earnly:pin-prompted, earnly:2fa-pending, earnly:pin-unlocked and earnly:pending-onboarding. These sign you in, complete two-step verification, protect the Platform with your device PIN, and keep the details you have entered while you complete sign-up and onboarding;
7.3.2 appearance and preferences: earnly-theme, earnly:app-mode, earnly:active-entity, earnly_sidebar_open and sidebar_state. These remember your light or dark theme, whether you were in the business or personal view, which company you were last viewing, and whether the sidebar is open or closed.
7.4 What some items contain. While you complete onboarding, earnly:onboarding:v2 holds the details you have entered so far (such as your name, email address, mobile number, company details, address and VAT details, but never your password), so that you do not lose your progress. It is deleted from your browser when onboarding is complete. earnly:pin holds only a salted hash of your device PIN, never the PIN itself, and is not sent to us.
7.5 Our website. Visitors to our website, including people who join the waitlist, have no cookies or storage set on their device. The only item the website stores is a sign-in token used by Earnly staff who edit the site.
7.6 We re-audit cookies and storage at least every 6 months and before any new script, tag or third-party service goes live, and we update this table before any change takes effect.
8. Other technologies that are not cookies
8.1 Visitor statistics. Our hosting platform, Lovable, may produce aggregate, cookieless visitor statistics, such as the number of visitors and page views, from the requests your browser makes. Nothing is stored on or read from your device for this, and we cannot use the statistics to identify you.
8.2 Google Fonts and jsDelivr. While we use them, some pages load web fonts from Google Fonts (provided by Google LLC) and bank logo images from the jsDelivr content delivery network. These are not cookies. When the page loads, your browser requests the files directly from those providers, which exposes your IP address to them. No other information is sent, and no cookie is set by them through our pages. We are moving these files to our own hosting; once that is done, these providers will no longer receive your IP address and we will remove this paragraph. Google's privacy policy is at https://policies.google.com/privacy, and jsDelivr publishes its privacy policy at jsdelivr.com. Both are listed on our Sub-processor List.
8.3 Server logs. Our hosting providers record technical details of each request, such as your IP address and browser type, to deliver and secure the Platform. This is described in the Privacy Policy.
9. Your choices
9.1 No consent needed. We do not ask for consent to the items in section 7, because none of them needs it. We do not show a cookie banner, and there is nothing to accept or reject.
9.2 Objecting to appearance and preference items. You can object to the appearance and preference items in 7.3.2 at any time, free of charge, in either of these ways:
9.2.1 for the theme, by choosing the "System" theme in the Platform, which follows your device's own setting; or
9.2.2 for any of them, by deleting those items (or all cookies and site data for earnly.co.uk) in your browser settings. Deleting all site data will also sign you out.
Objecting does not affect what you can do in the Platform. It only means the Platform will not remember those preferences. If you need help, email privacy@earnly.co.uk.
9.3 Strictly necessary items. If you block or delete strictly necessary items, you will be signed out and you will not be able to use the Platform until you allow them again.
9.4 Browser controls. Most browsers let you block cookies, delete cookies and site data, and be told when a cookie is set. Browser settings apply only to that browser on that device.
9.5 Global Privacy Control and Do Not Track. Because we do not use any tracking, analytics or advertising cookies, there is nothing for a Global Privacy Control or "Do Not Track" signal to switch off.
9.6 If we introduce a cookie that needs consent. Before we use any analytics, advertising, marketing or other cookie that needs consent, we will:
9.6.1 deploy a consent tool that offers "Accept all" and "Reject all" options with equal prominence and a "Manage settings" option;
9.6.2 not set any such cookie unless and until you opt in, and not use pre-ticked boxes or treat continued browsing as consent;
9.6.3 provide a permanent "Cookie settings" link so that you can withdraw consent as easily as you gave it;
9.6.4 keep a record of your choices (date and time, the version shown to you and what you chose) for 2 years; and
9.6.5 update this Cookie Policy first.
10. Cookies and personal data
10.1 Some items in section 7 contain personal data, such as the sign-in token and the onboarding details. That personal data is processed under the Privacy Policy, and you have the rights set out in it, including the rights of access and objection.
10.2 Items are kept on your device for no longer than the durations in section 7. The Privacy Policy and our Data Retention Policy explain how long we keep personal data on our own systems.
11. Changes to this Cookie Policy
11.1 We may update this Cookie Policy to reflect changes to the cookies we use, the Services or the law. The version number and date at the top show when it last changed.
11.2 Before we start using a new strictly necessary or preference item, we will add it to section 7. Before we start using any cookie that needs consent, we will update this Cookie Policy, deploy the consent tool described in 9.6 and ask for your consent.
11.3 Because this Cookie Policy forms part of the Agreement, any material change is made in accordance with the "Changes to the Agreement" clause of the Terms and Conditions, including at least 30 days' notice. This does not affect your right to object to preference items or to refuse or withdraw consent to cookies at any time.
12. Contact and complaints
12.1 Data Protection Lead: Adam Marsh, Director, privacy@earnly.co.uk
12.2 Post: Earnly Limited, 41 New Cross Street, Swinton, Manchester, England, M27 4TU.
12.3 If you are unhappy with how we use cookies or handle your personal data, you can complain to us using the procedure in the "How to complain" section of the Privacy Policy, including through our online complaint form at https://earnly.co.uk/complaints. We will acknowledge your complaint within 2 Business Days (and in any event within the 30-day statutory maximum) and tell you the outcome. You also have the right to complain to the Information Commission (ICO) at ico.org.uk or on 0303 123 1113.