Cookie Policy
Last updated: 21 September 2026 · Version: 1.0 · Applies to spruce.eco and any other website that Spruce operates
1. What this policy covers
This policy explains how Spruce Energy Limited uses cookies and similar technologies (including tracking pixels, local storage and software development kits) on our websites, in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended, including by the Data (Use and Access) Act 2025) in the United Kingdom, and S.I. No. 336 of 2011 in the Republic of Ireland. How we use personal data more generally is described in our Privacy Policy at spruce.eco/legal/privacy-policy.
2. Your choices
When you first visit, a banner lets you Accept all, Reject all or choose categories. Rejecting is as easy as accepting, and nothing other than strictly necessary technologies and our cookieless analytics tool (Fathom, see section 3) runs until you choose. You can change your choices at any time using the Cookie Settings link in the website footer, which also shows exactly which technologies are currently active. Your choice is remembered for 6 months, after which we will ask again. Strictly necessary technologies cannot be switched off because the site does not work without them.
3. The categories we use
Strictly necessary
What it does: Makes the site work and remembers the cookie choices you make
Technologies currently used: Framer (site platform and consent storage); security and load-balancing
Consent: Not required
Analytics
What it does: Helps us understand how the site is used so we can improve it
Technologies currently used: Fathom Analytics (cookieless: stores nothing on your device); Microsoft Clarity (session replay and heatmaps, with form inputs masked); PostHog (website analytics); Segment (routes website events to our analytics tools)
Consent: Fathom sets no cookies, stores no identifier on your device and does not track you across sites. We consider that it falls outside the cookie consent rules in the UK and Ireland (in the UK it would in any case fall within the statistical-purposes exception in PECR as amended by the Data (Use and Access) Act 2025), so it runs without consent; you can object at any time by emailing dataprotection@spruce.eco. Clarity, PostHog and Segment run only with your consent
Marketing and attribution
What it does: Measures the performance of our advertising, tells us which campaigns and channels visitors come from, and shows relevant Spruce advertising to business audiences on other platforms, including retargeting
Technologies currently used: Meta Pixel; LinkedIn Insight Tag; Google Ads conversion tracking (via Google Tag Manager); Microsoft Advertising (Bing UET)
Consent: Only with your consent
A detailed list of the individual cookies set by each technology, with their names and lifetimes, is available in Cookie Settings.
4. The Spruce platform (app.spruce.eco)
Signed-in users’ sessions rely on strictly necessary technologies (authentication and security) and our own first-party product analytics (PostHog, EU-hosted), which does not use cookies and stores nothing on your device, as described in section 8 of our Privacy Policy. No advertising, retargeting or cross-site tracking technologies run on the Spruce platform. The only analytics on the platform is our own product analytics, operated for us by PostHog and configured without cookies or device storage (unlike the website deployment in section 3); it is never shared with or used by advertising partners, and no homeowner or end-customer information ever is.
5. How we work out where visitors come from without tracking you
Where you decline marketing cookies we still record, at the moment you submit a form or book a demo, the campaign or referral parameters in the page address (for example utm_source) together with your enquiry. This is first-party data processed under our legitimate interest in understanding how people find us; it does not involve storing anything on your device beyond the form you submit, and it is not shared with advertising platforms. Google tags are implemented with Google Consent Mode in its basic mode: no Google tag loads and no data is sent to Google until you consent.
6. Third parties
The providers named above may process your data under their own privacy policies: Framer B.V., our website platform (framer.com/legal/privacy-statement), Meta Platforms Ireland (facebook.com/privacy/policy), LinkedIn Ireland (linkedin.com/legal/privacy-policy), Google Ireland (policies.google.com/privacy), Microsoft Ireland (privacy.microsoft.com), Fathom Analytics (Conva Ventures Inc., Canada; usefathom.com/privacy), PostHog, Inc. (US; posthog.com/privacy) and Segment (Twilio Inc., US; twilio.com/legal/privacy). Where these providers process data outside the UK/EEA, transfers rely on an adequacy decision (Canada), the EU-US Data Privacy Framework and UK Extension, or Standard Contractual Clauses with the UK Addendum or International Data Transfer Agreement. Our full list of service providers is at spruce.eco/legal/sub-processors.
7. Changes and contact
We will update this policy when the technologies we use change and revise the “last updated” date. Questions: dataprotection@spruce.eco.