Last updated: September 2020
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1. About this policy
3. Cookie Law
Also known as the ‘Cookie Directive’, the instrument that defines the requirements for consent for cookies across the EU is Directive 2009/136/EC of the European Parliament and of the Council, an excerpt of which is reproduced below:
“Member States shall ensure 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”.
The UK introduced the amendments on 25 May 2011 through The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. The relevant section is below:
“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.
(3A) 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.”
In summary, to comply with the law, we need to give clear information about what the cookies are used for, why, and obtain consent from you, the user. These are the objectives this Policy is set out to achieve.
4. Types of cookies and purpose
Cookies can be categorised in many ways, one is with regards to their longevity, i.e. for how long they are stored in your browser. According to this classification, cookies can either be:
- Session cookies: temporary cookies that identify and track users within our website. These are automatically deleted by your browser when you close your browser or end the session; and
- Persistent cookies: cookies which enable our website to ‘remember’ who you are and your preferences within our website. These cookies are stored in your browser (the specific location depends on the browser and version) for a period of time.
We assess the cookies present in our website periodically, to ensure they are aligned with the requirements of current legislation. For instance, we remove persistent cookies set to hold data for an excessive period of time, which do not meet the principle of storage limitation, as per Article 5.1.e of the General Data Protection Regulation (GDPR).
|What Cookies Do||Reason to have the cookies on our website|
|Enhance our website’s performance||This type of cookies helps us understand how our website are being used, mainly for analytical purposes, so that we can work on providing an improved user experience. Cookies used for this purpose do not collect information that identifies a user, but the data is aggregated and made anonymous. For example, data on error messages displayed to users will be collected and the developer team will assess whether the problem is prevalent and solve it.|
|Web beacons and parameter tracking||These cookies and similar software known as web beacons are used to count the number of users visiting our website, or the number of actions made by the users.|
|Internet Protocol (IP) address and traffic data||A set of data such as IP addresses, access rates, and page views are recorded in our servers. These data do not allow to identify any individual, i.e. no personal data is collected.|
6. How to disable cookies?
As cookies are stored in the web browser used to access the website, users need to change the settings pertaining that browser in particular. Below are some of most popular browsers and corresponding links to the vendors’ guidance on disabling cookies:
In addition, Google Analytics gives you the option to install an opt-out browser add-on for Internet Explorer 11, Firefox, Chrome, Safari, and Opera:
7. Rejecting cookies
8. Further information