Template — not yet an adopted policy. Before publication, replace every [REPLACE: …] item, confirm these statements against SurePlace’s actual practices, and have the final text reviewed by qualified Eswatini counsel. No effective date is implied.
Prepared 27 September 2026 · Publication details require completion and approval.
1. Scope and controller
This policy explains how Twinpeaks Investment [CONFIRM: full registered legal form and company number], operator of the SurePlace platform, uses cookies and similar technologies. Privacy contact: support@sureplace.twinpeaksinvestment.com. Registered address: [REPLACE: ADDRESS, ESWATINI]. Confirm the mailbox is active and monitored. It should be read with the Privacy Policy.
3. What SurePlace currently uses
The application currently stores authentication tokens in browser local storage when “remember me” is selected and otherwise in session storage. It stores your cookie-preference choices in local storage under the key “sureplace-cookie-preferences”. These storage entries are used to support sign-in/session behavior and remember your choice; they are not conventional HTTP cookies.
The cookie-preference interface includes optional functional, analytics and marketing choices, but the current application does not load analytics or marketing trackers when those choices are selected. Do not describe optional categories as active until the relevant technology is implemented, tested and disclosed.
4. Essential storage
Essential storage supports features you request, such as keeping your account signed in and remembering your preference selection. These functions cannot be disabled through the optional-category controls; you can clear browser storage in your browser settings, but doing so may sign you out or reset preferences.
5. Optional categories
At present, the controls for functional, analytics and marketing preferences record your choice only. They do not enable tracking services. If SurePlace later introduces optional technologies, update this policy with each provider, identifier, purpose, duration, recipient, international transfer and opt-in/withdrawal behavior before enabling them.
6. Managing your preferences
Use “Cookie preferences” in the site footer to review or update the saved choice. You can also clear local and session storage through your browser controls. Browser settings can block or remove cookies and storage, although essential site features may not work correctly afterward.
7. Third-party technologies
SurePlace loads OpenStreetMap map tiles when a map is displayed. This transfers map requests to OpenStreetMap Foundation servers; those servers are operated independently and their privacy policy applies to their processing. The application does not currently load analytics or advertising trackers when optional cookie categories are selected.
If a future map, analytics, chat, video, advertising or other third-party integration uses cookies or browser storage, list its provider, purpose, identifiers and duration here before it is enabled.
8. Changes and contact
We will update this policy when our technologies or practices change and revise the “Last updated” date. Questions about cookies or browser storage: support@sureplace.twinpeaksinvestment.com. Confirm this mailbox is active and monitored before publication.