Use of cookies
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies and may use various other online tracking devices on this website to:
• recognise you whenever you visit this website (this speeds up your access to the site as you may not have to log on each time)
• obtain information about your preferences, online movements and use of the internet
• carry out research and statistical analysis to help improve our content, business and services and to help us better understand our visitor AND/OR customer requirements and interests
• target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalised to your interests
• make your online experience more efficient and enjoyable.
The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you—but only where you voluntarily provide it (e.g. by completing an online form).
In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested.
Consent (notification on home page)
There is a notice on our home page which describes how we use cookies and which also provides a link to our Website privacy policy. If you use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in our Website cookie policy and Website privacy policy.
Third-party cookies
We work with third-party suppliers who may also set cookies on our website, for example e.g. Facebook, Twitter, YouTube and Adobe Flashplayer which we use to display video content)]. These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.
Description of cookies
The list below is designed to provide more information about the cookies we use and why:
Web analysis with Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. (Google). Google Analytics uses cookies, i.e. text files stored on your computer to enable analysis of website usage by you. Information generated by the cookie about your use of this website is usually transmitted to a Google server in the United States and stored there. In case of activated IP anonymization on this website, however, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf this website’s owner, Google will use this information to evaluate your use of the website, compile reports about website activities, and provide the website’s operator with further services related to website and Internet usage. The IP address sent from your browser as part of Google Analytics is not merged with other data by Google. You can prevent storage of cookies by appropriately setting your browser software; in this case, however, please note that you might not be able to fully use all functions offered by this website. In addition, you can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google, by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en
This website uses Google Analytics with the extension “anonymizeIP()”, IP addresses being truncated before further processing in order to rule out direct associations to persons.
How to turn off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.
Website cookie policy
Use of cookies
It may not always be the case that internet protocol (‘IP’) addresses can identify individuals. Many IP addresses are dynamic (ie they change each time a user connects to his internet service provider) which means that it is very difficult to identify an individual from the collection of dynamic IP addresses in the absence of other information. However, the same is not the case for static IP addresses which can be linked to specific computers and, possibly, to individual users. Static IP addresses used to create profiles may be personal data if, together with other information, they can identify individual users.
It is possible to use cookies (or other tracking devices) without identifying individuals as they are not always used to build profiles of individual site visitors. If the data controller’s website is not designed to collect personal data through the use of cookies then this section should be modified accordingly. However, if the cookies are used to collect personal data for any reason, then this must be brought to the attention of the individual.
The Information Commissioner has issued guidance on how to obtain consent on the use of cookies: see Guidance on the rules on use of cookies and similar technologies. Two examples of how consent can be obtained are included in this Cookie Policy for illustration purposes only.
Consent–option 1 (browser settings)
Under Privacy and Electronic Communications (EC Directive) Regulations 2003, SI 2003/2426 reg 3A ‘consent may be signified by a subscriber who amends or sets controls on the internet browser which the subscriber uses or by using another application or programme to signify consent’. The settings must be capable of being used in a way that allows the user to indicate his consent to cookies being set. The Information Commissioner’s view (as at May 2012) is that most browser settings are not yet sophisticated enough to be used in this way and that most users are not sufficiently aware to know that these settings are available and can be changed. Consent requires a positive indication of agreement on the part of the user–which means that, for browser settings to be used to obtain consent, the user must be prompted to consider the settings and then be able to indicate in some way that he agrees with the default, or be able to change the settings. The Commissioner has stated: ‘For now relying solely on browser settings will not be sufficient [to obtain consent to set cookies] and even when browser options are improved it is likely not all website visitors will instantly have the most up-to-date browser with these enhanced privacy settings’–see Guidance on the rules on use of cookies and similar technologies (May 2012) p 15. Notwithstanding the Commissioner’s reservations, the browser settings option to obtain consent has been adopted by some organisations and is supported by the legislation. For this reason, a browser setting option to obtain consent has been included in this Form together with the caveat that it is not yet wholly approved by the Commissioner as a valid means of obtaining consent and should be used with caution.
Consent–option 2 (notification on home page)
For this option to be effective it is important to make the notice as clear as possible on the webpage. This option may not be effective where the home page is not the only landing page, since users may access the site via other pages and thereby miss the notice on the home page. This issue can be remedied by having the notice appear on every page (until such time as a box is ticked to indicate that the user has seen it and then it disappears), but this practice can be intrusive and annoying to users, especially if the notification is large.
Description of cookies
The Privacy and Electronic Communications (EC Directive) Regulations 2003, SI 2003/2426 do not specify the type of information that should be provided to users. The inclusion of a table with information about cookies is one option, but it is not obligatory. The requirement is for the organisation setting the cookie to provide a sufficiently full and intelligible description of the cookies used so that users can understand what it means for them to accept the cookies. The table should not be populated with technical information that would be meaningless to the user.
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