COOKIE POLICY
trucklo.eu
| Version | 1.0 |
|---|---|
| Effective from | 01.10.2026 |
| Parent document | The trucklo.eu Privacy Policy — this policy supplements it and does not replace it |
| Document owner | Management Board of Trucklo Sp. z o.o. |
| Review cycle | every 12 months and upon any material change to the cookie configuration, tools, suppliers, or consent management mechanism |
1. WHAT ARE COOKIES AND LOCALSTORAGE
Cookies are small files stored on the User's device by the browser and sent back to the server with subsequent requests. LocalStorage is a browser mechanism for persistently storing information — on trucklo.eu, solely consent preferences — without automatically sending it with every HTTP request.
Scope of technologies. To the extent that a given technology involves storing information on the User's device or gaining access to information already stored on that device, Article 399 of the Electronic Communications Law (PKE) applies to it. This applies in particular to cookies and mechanisms such as LocalStorage and SessionStorage. Pixels, scripts, and device identifiers may also be subject to separate rules on the processing of personal data and are applied in accordance with the relevant legal bases.
2. LEGAL BASIS
The legal basis is Article 399 of the Act of 12 July 2024 — Electronic Communications Law (PKE) in conjunction with Regulation (EU) 2016/679 (GDPR):
- for necessary technologies — Article 399(3) PKE, to the extent that storing information or gaining access to it falls within one of the exceptions to the consent requirement, in particular where necessary to carry out the transmission of a communication or to provide a service requested by the User; as regards personal data, the basis for processing is the relevant basis under Article 6 GDPR;
- for all other categories — Article 399(1) PKE, which requires the User's prior consent to the storage of information or to gaining access to information already stored on their device; where the technology in question involves the processing of personal data on the basis of consent, Article 6(1)(a) GDPR also provides the basis.
The consent required under Article 399 PKE is separate from the legal basis for processing personal data under the GDPR and is required regardless of whether the User uses the Platform for private or professional purposes.
3. CATEGORIES
| Category | Purpose | Default state |
|---|---|---|
| Necessary | Basic operation of the site, including maintaining the session in the Manufacturer Panel and the functioning of the consent management mechanism. | always active, consent is not required |
| Analytics | Measuring traffic and usability: visit statistics, the path from arrival to submitting an enquiry, analysis of on-site behaviour. | disabled until consent is given (analytics_storage) |
| Advertising | Measuring campaign conversions, remarketing, ad personalisation. | disabled until consent is given (ad_storage, ad_personalization, ad_user_data) |
| Functional | Embedded external content, in particular the manufacturer location map. | disabled until consent is given |
The categories are selected independently of one another in the consent banner. Refusing any of them does not restrict access to the content of the site or to the enquiry form.
4. LIST OF COOKIES AND SIMILAR TECHNOLOGIES
| Name | Provider | Type | Duration | Purpose |
|---|---|---|---|---|
| PHPSESSID | Trucklo (first-party) | Necessary | session | Keeping the user logged in to the Manufacturer Panel |
| tl_consent_v2 | Trucklo (localStorage) | Necessary | until deleted or preferences changed | Storing the Consent Mode v2 decision |
| _ga, _ga_*, _gid | Google Analytics 4 | Analytics | up to 2 years (per Google) | Traffic statistics — after analytics_storage consent |
| _gcl_* | Google Ads | Advertising | per Google | Conversion measurement and remarketing — after ad_* consents |
| _gat, _dc_gtm_* | Google Tag Manager | depends on the tag | per configuration | Injecting tags according to consent status |
| _clck, _clsk, CLID | Microsoft Clarity | Analytics | per Microsoft | UX analysis and session recordings — after analytics_storage consent |
| _fbp, fr | Meta | Advertising | per Meta | Marketing — only if the pixel is enabled and after ad_* consents |
| NID, SID, CONSENT | Google Maps | Functional | per Google | Displaying the manufacturer location map |
The exact set of third-party cookies depends on the current Google Tag Manager configuration in the given environment. The list above covers the identifiers used when the tools are enabled. The current, complete list, together with the validity period of each file, is available in the cookie settings panel, and that is the authoritative source.
Google Search Console, used to monitor the site's visibility in search results, does not require any cookies or other information to be stored on the User's device in connection with using the Platform and does not appear in the banner.
5. CONSENT MODE V2
Google scripts are embedded in consent mode (Consent Mode v2). Until the User makes a decision, all four parameters are set to denied:
| analytics_storage | measurement of on-site traffic and behaviour |
|---|---|
| ad_storage | advertising identifiers stored on the device |
| ad_user_data | transmission of user data for advertising purposes |
| ad_personalization | ad personalisation and remarketing |
Until the relevant consent is given, Google tools requiring consent do not store on the device any information covered by the corresponding consent parameters. Depending on the configuration of the Google services, limited signals regarding use of the Platform may be transmitted, in accordance with how Consent Mode operates. The User's decision is stored in localStorage under the key tl_consent_v2 and is read on subsequent visits. In this respect, LocalStorage contains only information about consent settings, and its use falls within the necessary category and does not require consent.
Tools other than Google tools — in particular Microsoft Clarity and the Meta pixel — are injected by Google Tag Manager only after the corresponding consent has been read. They do not use Consent Mode, so before consent they are not loaded at all.
6. MANAGING CONSENT
Consent can be managed in three ways:
- the consent banner, shown on the first visit and after any saved preferences are deleted or expire;
- the cookie settings icon, available on every page of the site, opening the preferences panel at any time;
- browser settings — blocking or deleting cookies. Blocking necessary cookies will make it impossible to log in to the Manufacturer Panel.
The principles we apply:
- the banner does not use manipulative design patterns — the refuse button is just as visible and just as accessible as the accept button;
- continuing to use the site, or merely scrolling the page, does not constitute consent;
- withdrawing consent is as easy as giving it (Article 7(3), fourth sentence, GDPR) and takes a single click in the preferences panel;
- until consent is given, we do not run any analytics, advertising, or functional scripts.
Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal (Article 7(3) GDPR). After consent is withdrawn, the relevant scripts are not run on the User's subsequent actions within the scope covered by the withdrawn consent, in accordance with the current configuration of the consent management mechanism. Withdrawing consent does not automatically delete files previously stored by third parties on the User's device; deleting them may require using the browser settings.
7. RECIPIENTS AND TRANSFERS OF DATA OUTSIDE THE EEA
The providers of the tools listed in § 4 may process data as processors under appropriate agreements or other legal bases relevant to the given scope of service. To the extent that Google or Meta process data for their own purposes, in particular in connection with maintaining and developing their own advertising services, they act as separate controllers. The scope and bases of such processing follow from the terms and policies of those providers.
Transfers of data to third countries take place solely on the basis of a European Commission adequacy decision (Article 45 GDPR) — in particular the Implementing Decision of 10 July 2023 on the EU–US Data Privacy Framework, where the provider is certified under that framework — or standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914 (Article 46(2)(c) GDPR), supplemented by a transfer impact assessment and, where necessary, additional technical, organisational, or legal measures.
Data contained in Enquiries submitted by Buyers, including their content and contact details, is not transmitted to analytics or advertising tools. Data concerning use of the Platform, including technical information and online identifiers, may reach these systems, in accordance with the consent given and the configuration of the individual tools.
8. CHANGES TO THE POLICY
The Controller may amend this Policy, in particular in connection with a change to the Google Tag Manager configuration, a change in how the tools are used, the deployment of a new tool, or a change in the law. We inform you of material changes with reasonable advance notice, of no less than 14 days, through a notice on the site. If the change results in the application of a new technology requiring consent under Article 399 PKE, consent will be obtained before that technology is used.
9. MORE INFORMATION
The Controller's details, the purposes and legal bases for processing, retention periods, categories of recipients, and the rights of data subjects are set out in the trucklo.eu Privacy Policy.
| General matters | contact@trucklo.eu |
|---|---|
| GDPR rights, objections, withdrawal of consent | legal@trucklo.eu |
| Supervisory authority | President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw |