Last updated: 14th April 2023
Navigating this Notice
You can click on the below links to navigate to the relevant section:
- WHO WE ARE AND HOW TO CONTACT US
- WHAT ARE COOKIES?
- THE COOKIES WE USE AND WHY
- YOUR CONSENT AND REMOVING COOKIES
- ADDITIONAL INFORMATION
- WHO WE ARE AND HOW TO CONTACT US
- Cookies are a feature of web browser software that allows web servers to recognise the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. Cookies enables a website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.
- Cookies can be classified by lifespan, domain or functionality, with further sub-categories in those broad classes.
- By lifespan, a cookie fall into types of classification:
- Session cookies allow websites to keep track of user movements from page to page. It is a way of linking the actions of a user during a browser session in order to enhance and speed up the experience. Session cookies are used, for example, to remember what a user has put in his shopping basket. They expire and are erased after a browser session ends and, for this reason, are not regarded as being as privacy intrusive as persistent cookies.
- Persistent cookies are saved to the hard drive/storage device and remains on the user's computer or mobile device for a pre-defined period of time. They are designed to allow websites to remember user information and settings for when they visit again (e.g. user name and password, language selection, menu preferences). This speeds up access to the website (e.g. since users do not have to select their preferences or log in every time) and enhances the user experience. Persistent cookies are more privacy intrusive than session cookies since they do not expire at the end of a browser session.
- As for the domain to which it belongs, cookies are either:
- First-party cookies, which are set by the web server of the visited page and share the same domain (i.e. set by us); or
- Third-party cookies, which are set by another website or server, on a different domain to the visited page's domain.
- Cookies can also be classified by functionality: either:
- Necessary cookies (also referred to as ‘strictly necessary cookies’) help make a website usable by enabling basic functions like page navigation and access to secure areas of the website (e.g. allowing you to place items in an online shopping ‘cart’ / ‘basket’, or make use of e-billing services). The website cannot function properly without these cookies. Many types of session cookies will fall into this category.
- Preference cookies (sometimes referred to as ‘functional cookies’) enable a website to remember information that changes the way the website behaves or looks. They are used to recognise you when you return to our website, and this enables us to personalise our content for you. They can be set by us or by third parties whose services we may use on our website. If you do not allow these cookies, some or all of these services may not work properly and our website may not display properly (or as we intended the website to display). Preference cookies may:
- enable cookie consent across multiple websites;
- remember the user's selected language version of a website; or
- anonymously record settings for the user's preferences when browsing (e.g. website size/display settings)
- Statistic cookies (sometimes referred to as ‘performance cookies’) help website owners to understand how visitors interact with their websites by collecting and reporting information anonymously such as number of visitors, popular times, country from where the site is accessed etc. This helps us measure and improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We will use this information to make our website easier to navigate. Information collected by these cookies is aggregated so that it is de-identified and therefore anonymised. We may also share this information with third parties for this purpose. Statistic cookies may also:
- allow us to recognise and count the number of visitors;
- understand which pages are most popular, and which are least used;
- register the date and time for the user's latest visit to our website;
- log internet address linking to our website;
- register statistical data on visitors' behaviour on the website for internal analytics by the website operator (e.g. time spent on each page or links clicked);
- assign a unique ID that identifies the user on recurring visits (usually anonymising or pseudonymising any Personal Data);
- record website traffic from a particular region/area; or
- log type of operating system, browser type, mobile network information, and Internet Protocol (IP) address (usually masking the last digits so you cannot be identified).
- Marketing cookies (sometimes referred to as ‘targeting cookies’) are used to track visitors across websites. They record your visit to our website the pages you have visited and the links you have followed, as well as time spent on our website and other websites visited just before and just after our website. Marketing cookies may:
- deliver a series of advertisement products such as real time bidding from third party advertisers (e.g. used by Facebook);
- report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user; or
- estimate a user’s bandwidth on pages with integrated videos, and store the user's video player (e.g. YouTube) preferences.
- Where cookies do not fall into a particular categorisation above, they may be labelled “unclassified” or “pending” whilst the website owner confirms the functionality with the provider of the individual cookie.
- Our primary purposes for using cookies are to make our website work more effectively, to produce statistics, and to distinguish you from other users of our website. This helps us to offer you the best experience when browsing our website and to improve our website, as we learn about which user settings are most popular or which areas of the website persons are most interested in. Cookies also allow us to learn more about how users landed on our website, and whether they access links to other sites, social media platforms and mobile device applications/ ‘apps’.
- We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes, to understand how people use our website so that we can make it more intuitive.
- We may also use other third-party cookies to assist with analysing performance on our website. This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website's capacity, efficiency and security.
- This information is put together as Aggregated Data and provides general and not individually specific information. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. None of this information is therefore associated with you as an individual and the cookie-related information is not used to identify you personally. It is therefore anonymised and ‘de-identified’ so that it is no longer Personal Data.
- YOUR CONSENT AND REMOVING COOKIES
- Cookies can be removed in two ways:
- automatically, when they expire; or
- when you manually delete them.
- You can also prevent certain cookies from being set by a website where you withhold your consent.
- We use (strictly) necessary cookies to make our website work, and these are always set by default.
- We would also like to set security, preference, statistics and marketing cookies (sometimes grouped together as ‘analytics’ cookies) to help us improve our website. These are not set by default and are optional. In other words, our website will not set optional cookies unless you enable them, using a tool that will set a cookie on your computer / mobile device to remember your preferences.
- In order to implement your objection, it may be necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. It is important to note, that for technical reasons, the opt-out cookie will only affect the browser from which you actively object. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.
- Not all websites allow you to manage cookies, and some may ask you to “accept all” by default. If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted.
- Most web browser software is set up to initially enable cookies. However, you may also be able to amend your web browser / device settings in order to:
- delete all cookies;
- block all cookies;
- allow all cookies;
- block third-party cookies;
- clear all cookies when you close the browser
- open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the web without recording your browsing history or storing local data such as cookies (you should however be aware of the limitations of this feature in terms of website functionality); or
- install add-ons and plugins that extend browser functionality.
- Since each browser is different, you will need to refer to the guidance documentation for your preferred web browsing platform(s)/software in order to control such settings. If you have any further questions regarding disabling cookies, you should consult with your preferred browser’s provider or manufacturer and/or your mobile device settings.
- Please be aware that where you remove your consent for cookies, or set your browser settings to disable these, you may lose some of the functionality of our website and other websites. Additionally, you may have to manually adjust some preferences every time you visit any site and some services and functionalities may not work if you do not accept the cookies they send.
- ADDITIONAL INFORMATION
- In addition to cookies, we may use other technologies on our website to enhance your experience and to collect information about how our website is used. The placing of these technologies on your device may enable you to be identified across multiple websites and online services. Such technologies include:
- Pixels tags: Also called clear GIFs, web beacons, or pixels. Pixel tags are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails; this information helps us, and our partners, to provide you with a more tailored experience.
- Device Identifiers: A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.
- Browser web storage: This enables websites to store data in a browser on a device. This makes data retrievable even after a browser has been closed and re-opened.
- Application data cache: This is a data repository on a device. It can, for example, enable a web application to run without an Internet connection and improve the performance of the application by enabling faster loading of content.
- Server logs: These are pieces of code stored on web servers that automatically record the page requests made when you visit a website. They typically include your web request, Internet Protocol (IP) address (with the last digits anonymised), browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.
- This website uses Google Analytics, a web analytics service provided by Google. Google Analytics tracks your preferences and identifies popular sections of our website. Use of Google Analytics in this way enables us to adapt the content of our website more specifically to your needs and thereby improve what we can offer to you. Cookie-related information is not used to identify you personally, and what is compiled is only aggregate data that tells us, for example, what countries we are most popular in, but not that you live in a particular country or your precise location when you visited our website.
- Google Analytics, its purpose and function is further explained on its website:
- To opt out of being tracked by Google Analytics across all websites, Google have developed the Google Analytics opt-out browser add-on. If you would like to opt out of Google Analytics, you have the option of downloading and installing this browser add-on, which can be found under the following link:
- For further information on cookies generally, including how to control, manage and disable them, you may wish to consult the following:
Classification of cookies by lifespan
Classification of cookies by domain
Classification of cookies by functionality
Managing your consent on our website(s)
Managing your consent on other websites and using browser settings
Other (third-party) websites