Cookie Notice
At Brackly Group of Companies (“we,” “us,” or “our”), we respect your concerns about privacy and value the relationship that we have with you. Like many companies, we use technology on our website to collect information that helps us enhance your experience and our products and services. The cookies that we use at Brackly Group allow our website to work and help us to understand what information and advertising is most useful to visitors.
Please take a moment to familiarise yourself with our cookie practices and let us know if you have any questions by sending us an email at [email protected]. We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then we encourage you to read about these key terms.
Any personal data provided to or collected by Brackly Group via cookies and other tracking technologies is controlled by Brackly Group of Companies, the data controller. This Cookie Notice applies to any websites, apps, branded pages on third-party platforms (such as Facebook, LinkedIn, or YouTube), and applications accessed or used through such websites or third-party platforms (hereinafter, “our websites”) which are operated by or on behalf of Brackly Group. References to “Brackly Group” in this Notice include any Brackly Group companies, subsidiaries, affiliates, joint ventures and franchises that you are interacting with or have a business relationship with.
By using our websites, you are consenting to our use of cookies in accordance with this Cookie Notice and our Privacy Notice. If you do not agree to our use of cookies in this way, you should set your browser settings accordingly, disable the cookies that we use, or not use our websites at all. If you disable the cookies we use, this may impact your user experience while on the websites.
What are Cookies?
Cookies, pixel tags and similar technologies (collectively ‘cookies’) are files containing small amounts of information which are downloaded to any internet enabled device – such as your computer, smartphone or tablet – when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences, generally improving your online experience, and helping us to offer you the best products and services. There are many types of cookies. They all work in the same way, but have minor differences.
Why do we use cookies?
We use cookies to make Brackly Group websites easier to use, to deliver a personalised experience on our websites, and to better tailor our products, services and websites to your interests and needs. Cookies are used to help speed up your future activities and your experience on Brackly Group websites. The cookies you consent to, are also used to collect your personal data which we then profile into audiences so that we can deliver targeted advertising tailored to your interests and limit the number of times you see an advertisement. For more detailed information about the profiling activities Brackly Group undertakes with your personal data for advertising, please see our Privacy Notice.
We also insert cookies in emails and newsletters to improve our content and advertising. Lastly, we use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our websites and to help us improve their structure and content and also help us measure the effectiveness of advertising campaigns on Brackly Group and non-Brackly Group websites.
Legal Framework in Pakistan
As of the effective date of this Notice, Pakistan has not enacted a comprehensive data protection law. However, the Personal Data Protection Bill 2023 (PDPB) has been drafted and is under parliamentary consideration. The PDPB recognizes and provides for consent to be an essential requirement to process personal data of the data subject[reference:0]. Consent must be freely given, specific, informed and unambiguous[reference:1]. The data controller bears the burden of proof to demonstrate that consent was obtained[reference:2]. The PDPB also provides that the data controller may not disclose personal data without the consent of the data subject for any purpose other than the purpose for which the same was to be disclosed at the time of collection or to any third party not earlier notified[reference:3].
Regulatory bodies such as the Pakistan Telecommunication Authority (PTA) and the State Bank of Pakistan monitor compliance with data regulations within their domains. Once operational, the National Commission for Personal Data Protection (NCPDP) will oversee compliance with the Draft Bill, impose penalties for violations and manage grievances. The Draft Bill does not specifically address requirements regarding the use of cookies; however, it has laid the groundwork for consent-based processing of personal data[reference:4].
We are committed to complying with all applicable laws, including the PDPB once it becomes effective, and will update this Notice accordingly. In the meantime, we adhere to internationally recognized privacy principles, including the protection of your rights under Article 14 of the Constitution of Pakistan, which recognizes privacy as a fundamental right.
How to Manage Your Cookies
There are many ways to manage your cookies:
- You can refuse your consent;
- You can disable Brackly Group or third-party cookies by use of your browser settings; or
- You can use our cookie management tool (available on every page) to disable Brackly Group or third-party cookies.
Control via your browser settings
Most internet browsers are initially set up to automatically accept cookies. If you do not want our websites to store cookies on your device, you can change your browser settings so that you receive a warning before certain cookies are stored. You can also adjust your settings so that your browser refuses most of our cookies or only certain cookies from third parties. You can also withdraw your consent to cookies by deleting the cookies that have already been stored. If you disable the cookies that we use, this may impact your experience while on the Brackly Group website, for example you may not be able to visit certain areas of a website or you may not receive personalized information when you visit a website.
If you use different devices to view and access the Brackly Group website (e.g., your computer, smartphone, tablet) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences. The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser or click on one of the links below to go directly to the user manual for your browser. There are also software products available that can manage cookies for you. You can also use www.ghostery.com to evaluate the use of cookies used on our websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Control via our cookie management tool
You can disable Brackly Group or third-party cookies by use of our cookies consent tool and you will find a link to this tool on every page. Switching off tracking cookies, for example, ensures that Brackly Group will no longer track your online behaviour. However please note that opting-out from tracking cookies does not necessarily mean that you will receive less Brackly Group advertising. It just means that the advertising you receive will not be tailored to your interests.
Types of Cookies We Use
The cookies used on Brackly Group websites may be generally categorised as follows:
1. Necessary Cookies
These cookies are essential to make Brackly Group websites work correctly, they enable you to move around our websites and use our features. Without these cookies, services like shopping baskets cannot be provided. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session.
Do these cookies collect personal data/identify me? These cookies do not identify you as an individual. If you do not accept these cookies, it may affect the performance of the website, or parts of it.
2. Performance Cookies
These cookies collect information about how you use our websites, for instance which pages you go to most often, the time spent on our websites, and any issues encountered, such as error messages. These cookies are also used to let affiliates know if you came to one of our websites from an affiliate and if your visit resulted in the use or purchase of a product or service from us, including details of the product or service purchased. This helps us improve the performance of our websites.
Do these cookies collect personal data/identify me? These cookies do not identify you as an individual. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
3. Functionality Cookies
These cookies allow our websites to remember the choices you make (such as your user name, language or the region you are in) to provide a more personalised online experience. These cookies may also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. Similarly, they may be used to keep track of what featured products or videos have been viewed to avoid repetition, and to enable you to play games and engage with social tools, such as blogs, chatrooms and forums.
Do these cookies collect personal data/identify me? The information these cookies collect may include personal data that you have disclosed. If you do not accept these cookies, it may affect the performance and functionality of the website and may restrict access to content on the website.
4. Targeting or Advertising Cookies
These cookies are used to deliver content that is more relevant to you and your interests. They are also used to deliver targeted advertising or limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns on Brackly Group and non-Brackly Group websites. They remember that you have visited one of our websites and this information is shared with other parties, including advertisers and our agencies. These cookies may also be linked to site functionality provided by third-parties.
Do these cookies collect personal data/identify me? Most types of these cookies track consumers via their Device ID or IP address therefore they may collect personal data.
5. Third-Party Cookies
We use a number of partners that may also set cookies on your device on our behalf when you visit our websites to allow them to deliver tailored Brackly Group advertising within their domains, for example Facebook, LinkedIn and Google DoubleClick. We endeavour to identify these cookies before they are used so that you can decide whether you wish to accept them or not. We also use a number of partners to provide digital experiences and functionalities on our websites. For example, while browsing Brackly Group websites you may be served cookies from third-parties who provide some of its features on our websites (e.g., a YouTube video), although you have withdrawn or declined your consent to our cookies. This happens because you have directly given your consent to the use of their cookies. In such cases, you should directly withdraw your consent on the relevant third-party website.
Do these cookies collect personal data/identify me? Based on the type of cookies used by the relevant third-party, the information these cookies collect may include personal data.
Duration of Cookies
In terms of duration, we may use two different types of cookies on our websites:
- Session Cookies: These cookies are temporary cookies that remain on your device until you leave our websites.
- Persistent Cookies: These cookies remain on your device for much longer or until you manually delete them (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie, as well as your browser settings).
Changes to This Cookie Notice
We may update this Notice from time to time to reflect changes in our practices, legal requirements, or other factors. The “Effective Date” at the top of this Notice indicates when it was last revised. We will notify you of material changes by posting the updated Notice on our website or through other appropriate channels. Your continued use of our services after the changes become effective constitutes acceptance of the revised Notice.
Contact Us
If you have questions, concerns, or requests regarding this Cookie Notice or our data practices, please contact us at:
Brackly Group of Companies – Privacy Office
[email protected]
+92 213 2370620
6th Floor, Brackly Tower, Shahrah-e-Faisal Road, Karachi-75350, Pakistan
We aim to respond to all legitimate requests within 30 days. If your request is complex or numerous, we may take longer, but we will notify you of any delay.
