When you visit our website, we may use the following web technologies:
Cookies: Subject to your web browser’s settings, we collect information that is sent to us automatically by your web browser when you access our website by help of a cookie. This information typically includes the IP address currently assigned to your computer and the type of operating system and browser installed. However, in accordance with the applicable laws/regulations, we shall give you the opportunity to understand how cookies are used on our websites and to consent to cookies being stored on your computer (including, but not limited to, laptop, mobile, tablet) or on any of your electronic devices (together hereinafter referred to as “computer”).
THE AMENDED Regulation 6 of the Privacy and Electronic Communications Regulations 2003
The article 5(3) of the Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, as amended by Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 amending Directive 2002/58/EC, provides that “the storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user is only allowed on condition that the subscriber or user concerned has given his or her consent, having been provided with clear and comprehensive information, in accordance with Directive 95/46/EC, inter alia, about the purposes of the processing.”
The above-quoted provision has been implemented in the United Kingdom law via the amendment (on the 4th of May 2011) of the Regulation 6 of the Privacy and Electronic Communications Regulations 2003 (regarding (i) the storage of or access to information on the terminal equipment of end users, and (ii) the signification of consent which must be sought as a result of the above-mentioned changes to the Directive 2002/58/EC) which came into force on the 26th of May, 2012.
Thus, such Regulation 6 provides the following:
6. – (1) Subject to paragraph (4), a person shall not store or gain information, or to gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.
(2) The requirements are that the subscriber or user of that terminal equipment:
(a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and
(b) has given his or her consent.
(3) Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.
(3) For the purposes of paragraph (2), 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.
(4) Paragraph (1) shall not apply to the technical storage of, or access to, information:
(a) for the sole purpose of carrying out the transmission of a communication over an electronic communications network; or
(b) where such storage or access is strictly necessary for the provision of an information society service requested by the subscriber or user.
In other words, this means that we may not store information or gain access to information stored in your computer (or any other web-enabled device of yours) of a user unless the user “is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information” and “has given his or her consent”.
The term “consent” is not defined in the UK Regulations or the Data Protection Act 1998. It is, however, defined in the Data Protection Directive of 1995, as “any freely given specific and informed indication of his wishes”. This Directive was implemented in the UK by the Data Protection Act 1998.
A cookie is (i) a small text file that is placed/stored on your computer’s hard disk by a web server, and (ii) used by websites to keep track of visitors and registered users and to relate one computer transaction to a later one.
We distinguish between “session cookies” and “persistent cookies.”
We use session cookies to assign a randomly-generated unique identification number to your computer each time you visit our website. A session cookie expires after you close your browser. We use session cookies to support the functionality of our website and to understand your use of our website, i.e. which pages you visit, which links you use, and how long you stay on each page.
Session cookies do not require your prior consent, if they are necessary for the functioning of our website and will expire once you have left our website.
Where admitted, we use persistent cookies, which do not expire immediately after you close your browser, but stay on your computer until they expire after a set period of time or you delete them. Each time you visit our website, our web server will recognise the persistent cookie on your computer’s hard drive. By assigning your computer a persistent, unique identifier, we are able to create a database of your previous choices and preferences. The unique identifier also helps us keep a more accurate account of how often you visit our website, how often you return, how your use of our website may vary over time, and the effectiveness of our promotional efforts. This information is however not revealing any of your personal data as it solely reveals movements made on your computer. If you access our website through an e-mail we have sent to you or if you have created a “user identity” during one of your visits, the information provided by us or by our third party cookie service provider may be linked to information in our records that identifies you personally.
Persistent cookies that track your previous choices and preferences but which are not necessary for the functioning of the website require your express prior consent.
We will not send you any third-party persistent cookie until you have consented through an opt-in function on our website. If you do consent, we will set a persistent cookie that will track your cookie preference for future site visits. For a list of cookies on our website and their purpose, please see below. Please keep in mind that while these cookies may not be necessary, they are mainly used to customise and thereby improve your website browsing experience.
The current state of our cookie use, their purpose, intrusiveness and persistence is as follows:
- Consent Cookie
- Session ID cookies
- Site Navigation
- Third Party Cookies
- Flash Local Shared objects (LSOs) also called “Flash Cookies”
Session ID cookies: Our web server may create session ID cookies which are essential for your use of some of the interactive elements of the website, such as contact forms and logging in. The cookie contains a session ID which is a mechanism for distinguishing your visit to our website from any other visitors that may be using the website at the same time. Session ID cookies also help minimize load times and save on server processing. Session ID cookies are considered necessary for the use of the website and do not require your consent.
Analytics: We use Google Analytics, which creates a number of first-party cookies, which allow us to ensure that subsequent visits to our website are recorded as belonging to the same (unique) visitor and to show us how you found us.
Content Management and Site Navigation: Our content management tool creates a number of first-party cookies, which are session cookies and are deleted when you close your browser. These cookies help our websites to function correctly. This data is aggregated and not personally identifiable.
We use the data that is collected using these first-party cookies to report, in aggregate, how our visitors find and use our website; we use those reports to understand overall visitor behaviour and we use that understanding to update and improve our websites.
Third party cookies are cookies created by our partners; when allowing these partners to embed a cookie on a page of our website, we request them to obtain your prior consent before collecting information through such cookie. As well as using cookies from our advertising partners, from time to time we may also embed external content from other third party websites within our website. These cookies are specific to the third party’s domain and accordingly the data held in them can be seen and managed by the third party solely. These include, but not limited to, sites such as Facebook and Twitter, the respective cookie usage policy of which can be viewed by you on their websites.
These cookies make it quicker and easier for you to access sites on subsequent visits that use Flash technology. Deleting them means you may have to re-enter information each time you visit the same site. But just like any cookie, you can delete Flash cookies by going to the Settings Manager on your Adobe Flash Player. You will be taken to the Adobe website, which lists the websites with the cookies in your browser. Just click Delete opposite the relevant website.
You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.