1. 1.1. This Cookie Policy (“Policy”) explains how Escrowfy GmbH, operating under the Oxen Finance brand (“Oxen”, “we”, “our”), uses cookies and similar tracking technologies on the website at oxen.finance and any associated digital properties (collectively, the “Website”).
1.2. This Policy should be read in conjunction with our Privacy Policy (OXN-POL-PRIV-001), which provides detailed information about how we collect, use, and protect your personal data.
1.3. By continuing to use the Website with cookies enabled, or by clicking “Accept” on our cookie consent banner, you consent to the use of cookies as described in this Policy, except for strictly necessary cookies which do not require consent.
2.1. Cookies are small text files that are placed on your device (computer, tablet, smartphone) when you visit a website. They are widely used to make websites work more efficiently, to provide a better user experience, and to supply information to the operators of the website.
2.2. In addition to cookies, we may use similar tracking technologies, including:
Web beacons (pixel tags): Small transparent images embedded in web pages or emails that track whether a page has been viewed or an email has been opened;
Local storage: Browser-based storage mechanisms (such as HTML5 local storage) that allow websites to store data locally on your device;
Session storage: Similar to local storage but cleared when the browser session ends;
Fingerprinting technologies: Techniques that collect information about your device configuration (e.g., browser type, screen resolution, installed plugins) to create a unique identifier.
2.3. References to “cookies” in this Policy include all such similar technologies unless the context requires otherwise.
We classify cookies into four categories based on their purpose. The table below describes each category, its purpose, and whether your consent is required.
The following table provides details of the specific cookies currently used on the Website. This list is reviewed and updated periodically.
Note: This list is indicative and may change as we update our Website, integrate new tools, or change service providers. We review this list at least quarterly. Cookies marked with an asterisk (*) indicate variable-name cookies where the exact name includes a dynamically generated identifier.
5.1. Some cookies on our Website are set by third-party services that we use, including analytics providers (e.g., Google Analytics), advertising platforms (e.g., Meta, Google Ads, LinkedIn), security services (e.g., Cloudflare), and customer communication tools (e.g., Crisp).
5.2. We do not control the cookies set by these third parties. Each third-party provider operates under its own cookie and privacy policies. We encourage you to review their respective privacy policies:
Google: https://policies.google.com/privacy
Meta (Facebook/Instagram): https://www.facebook.com/privacy/policyLinkedIn: https://www.linkedin.com/legal/privacy-policy
Cloudflare: https://www.cloudflare.com/privacypolicy
Crisp: https://crisp.chat/en/privacy
5.3. We have entered into data processing agreements with third-party providers where required by applicable data protection law. Third-party analytics data is processed in anonymised or pseudonymised form wherever possible.
The following conflicts are inherent in the nature of our business model. We have implemented specific controls for each:
UAE / ADGM: Where applicable, we rely on consent for non-essential cookies in accordance with the ADGM Data Protection Regulations 2021 and UAE Federal Decree-Law No. 45 of 2021.
When you first visit our Website, a cookie consent banner is displayed, allowing you to accept or reject non-essential cookies. You can modify your preferences at any time by clicking the “Cookie Settings” link available in the footer of every page on the Website.
You can also manage cookies through your browser settings. Most browsers allow you to:
Instructions for managing cookies in common browsers:
You can opt out of specific analytics and advertising cookies using the following tools:
8.1. Some browsers offer a “Do Not Track” (DNT) setting that sends a signal to websites you visit indicating that you do not wish to be tracked. There is currently no universally accepted standard for how websites should respond to DNT signals.
8.2. At present, our Website does not respond to DNT signals. However, you can manage your cookie and tracking preferences using the methods described in Section 7 above.
8.1. All Relevant Persons receive training on conflicts of interest as part of their induction and on an annual basis thereafter. Training covers the identification of conflicts, reporting obligations, personal conduct requirements, and the consequences of non-compliance.
8.2. Additional targeted training is provided to individuals in roles that present heightened conflict risk, including client-facing staff, treasury, compliance, and senior management.
8.3. Training records are maintained by the Compliance function and are available for regulatory inspection.
9.1. Some cookies, particularly those set by third-party analytics and advertising providers (e.g., Google, Meta), may involve the transfer of data to countries outside Switzerland, the EEA, or the United Kingdom, including the United States.
9.2. Where such transfers occur, we ensure appropriate safeguards are in place in accordance with our Privacy Policy (Section 6), including EU/Swiss Standard Contractual Clauses (SCCs), the EU-US Data Privacy Framework (where applicable), or other approved transfer mechanisms.
10.1. Session cookies are automatically deleted when you close your browser.
10.2. Persistent cookies remain on your device for the duration specified in the cookie details (see Section 4), or until you delete them manually.
10.3. We review cookie retention periods periodically to ensure they are proportionate to the purpose for which the cookie is used, in accordance with the data minimisation principle.
11.1. We may update this Cookie Policy from time to time to reflect changes in the cookies we use, changes in applicable law, or updates to our Website. Any revised version will be published on the Website with an updated Effective Date.
11.2. Where changes are material, we will re-display the cookie consent banner so that you can review and update your preferences.
11.3. The most current version of this Policy is available at oxen.finance/cookies.
If you have questions about our use of cookies, please contact:
