Cookies Policy
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1. Introduction
1.1 Our website uses cookies.
1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. / By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
2. Credit
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. About cookies
3.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
3.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
3.4 Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
4. Our cookies
4.1 We use [only session cookies / only persistent cookies / both session and persistent cookies] on our website.
4.2 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
(a) we use [cookie name] on our website to [recognise a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the website’s usability / analyse the use of the website / administer the website / prevent fraud and improve the security of the website / personalise the website for each user / target advertisements which may be of particular interest to specific users / [describe purpose(s)]];
__smToken
_ga
_gat
devicePixelRatio Session
gp_scc_cookie
(b) [repeat as necessary.]
5. Analytics cookies
5.1 We use [Google Analytics] to analyse the use of our website.
5.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
5.3 The analytics cookies used by our website have the following names: [_utma, _utmb, _utmc and _utmz]
5.4 The information generated relating to our website is used to create reports about the use of our website.
5.5 Our analytics service provider’s privacy policy is available at: [http://www.google.com/policies/privacy/].
6. Third party cookies
6.1 Our website also uses third party cookies.
6.2 [[We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using the DoubleClick cookie. / We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using the DoubleClick cookie. This behaviour tracking allows Google to tailor the advertisements you see on other websites to reflect your interests (we do not publish interest-based advertisements on this website).] You can view, delete or add interest categories associated with your browser by visiting: http://www.google.com/settings/ads/. You can also opt out of the AdSense partner network cookie using those settings or using the NAI’s (Network Advertising Initiative’s) multi-cookie opt-out mechanism at: http://www.networkadvertising.org/choices/. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-in available at: https://www.google.com/settings/ads/plugin.]
6.3 Details of [other] third party cookies used by our website are set out below:
(a) [third party cookie details;]
(b) [repeat as necessary.]
7. Blocking cookies
7.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
7.2 Blocking all cookies will have a negative impact upon the usability of many websites.
7.3 [If you block cookies, you will not be able to use all the features on our website.]
8. Deleting cookies
8.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
(b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
8.2 Deleting cookies will have a negative impact on the usability of many websites.
9. Cookie preferences
9.1 You can manage your preferences relating to the use of cookies on our website by visiting: [URL]
10. Our details
10.1 This website is owned and operated by [name].
10.2 [We are registered in [England and Wales] under registration number [number], and our registered office is at [address].]
10.3 Our principal place of business is at [address].
10.4 You can contact us by writing to the business address given above, by using our website contact form, by email to [email address] or by telephone on [telephone number].
Drafting notes for free cookies policy
Both UK and EU law require that websites making use of cookies (that is, most websites) make certain disclosures about those cookies. This policy is intended to help you with those disclosures. It is a more detailed version of the basic cookies policy incorporated into our privacy policy template. Depending upon your circumstances, you may need to supplement the policy with consent procedures.
This is a template cookies policy, designed to help website owners comply with the EU and UK laws concerning the disclosure to users of information about cookies used on a website.
See: Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the amendments thereto in the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.
Under the “new” cookies law, the use of many cookies will require the express consent of the user.
In addition, where the use of cookies involves the processing of personal data, data protection law requires the disclosure of information about such processing to data subjects.
Section 1 – Introduction
Section 1.2
How will you gain users’ consent to the use of cookies?
The inclusion of this statement in your privacy policy will not in itself satisfy the requirements of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as regards consent to the use of cookies. Guidance concerning methods of obtaining such consent is included on the Information Commissioner’s website (http://www.ico.gov.uk).
Section 4 – Our cookies
Section 4.1
What types of cookies will be used on the website?
Section 4.2
(a) – What is the name of the cookie? For what purpose is the cookie used? Describe the purpose or purposes for which the cookie is used.
Section 5 – Analytics cookies
Are cookies used to generate analytics data for the website?
The drafting in this provision assumes that Google Analytics is being used, but can easily be adapted for other cookie-based analytics systems.
Section 5.1
Will you use Google Analytics?
Section 5.3
What are the names of the analytics cookies used on the website?
Section 5.5
At what web address can users view a copy of your analytics service provider’s privacy policy?
Section 6 – Third party cookies
Does the website serve any third party cookies to users?
Section 6.2
Will Google AdSense advertisements be published on the website?
Will Google AdSense interest-based advertisements be published on the website (that is, advertisements tailored to a user’s particular interests as Google perceives them)?
This provision should be included if you publish Google AdSense interest-based advertisements on your website. Additional disclosures will be required if you have not opted out of third-party ad serving.
If the website sets any other cookies to users’ machines that track behaviour, information about those cookies will also need to be disclosed.
Section 6.3
(a) – Provide details of third party cookie use: identify the third party in question, identify the cookie in question, and provide details of the purpose or purposes for which the cookie is used.
Section 7 – Blocking cookies
Section 7.3
Will the blocking of cookies have a negative effect upon the use of the website from a user perspective?
Section 9 – Cookie preferences
Are there any cookie preference management facilities available to users on the website?
Section 9.1
Identify the web page users should visit to manage their cookie preferences.
Section 10 – Our details
UK companies must provide their corporate names, their registration numbers, their place of registration and their registered office address on their websites (although not necessarily in this document).
Sole traders and partnerships that carry on a business in the UK under a “business name” (i.e. a name which is not the name of the trader/names of the partners or certain other specified classes of name) must also make certain website disclosures: (i) in the case of a sole trader, the individual’s name; (ii) in the case of a partnership, the name of each member of the partnership; and (iii) in either case, in relation to each person named, an address in the UK at which service of any document relating in any way to the business will be effective. All websites covered by the Electronic Commerce (EC Directive) Regulations 2002 must provide a geographic address (not a PO Box number) and an email address. All website operators covered by the Provision of Services Regulations 2009 must also provide a telephone number.
Section 10.1
What is the name of the company, partnership, individual or other legal person or entity that owns and operates the website?
Section 10.2
Is the website operator a company?
In what jurisdiction is the website operator registered? What is the website operator’s company registration number or equivalent? What is the website operator’s registered address?
Section 10.3
Where is the website operator’s head office or principal place of business?
Section 10.4
What is the website operator’s contact email address? What is the website operator’s contact telephone number?
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Last Updated : 26th August 2014