11. Third
party websites
11.1 Our
website includes hyperlinks to, and details of, third party websites.
11.2 We
have no control over, and are not responsible for, the privacy
policies and practices of third parties.
12. Updating
information
12.1 Please
let us know if the personal information that we hold about you needs
to be corrected or updated.
13. Cookies
13.1 Our
website uses cookies.
13.2 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.
13.3 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.
13.4 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.
13.5 We
use [only session cookies / only persistent cookies / both session
and persistent cookies] on our website.
13.6 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)]];
(b) [repeat
as necessary.]
13.7 Most
browsers allow you to refuse to accept cookies; for example:
(a) in
Internet Explorer (version 11) you can block cookies using the cookie
handling override settings available by clicking "Tools",
"Internet Options", "Privacy" and then
"Advanced";
(b) in
Firefox (version 36) 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 41), 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.
13.8 Blocking
all cookies will have a negative impact upon the usability of many
websites.
13.9 If
you block cookies, you will not be able to use all the features on
our website.
13.10 You
can delete cookies already stored on your computer; for example:
(a) in
Internet Explorer (version 11), you must manually delete cookie files
(you can find instructions for doing so at
http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in
Firefox (version 36), you can delete cookies by clicking "Tools",
"Options" and "Privacy", then selecting "Use
custom settings for history" from the drop-down menu, clicking
"Show Cookies", and then clicking "Remove All
Cookies"; and
(c) in
Chrome (version 41), 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 "Cookies and other site and plug-in data"
before clicking "Clear browsing data".
13.11 Deleting
cookies will have a negative impact on the usability of many
websites.
14. Data
protection registration
14.1 We
are registered as a data controller with the UK Information
Commissioner's Office.
14.2 Our
data protection registration number is [number].
15. Our
details
15.1 This
website is owned and operated by [name].
15.2 We
are registered in [England and Wales] under registration number
[number], and our registered office is at [address].
15.3 Our
principal place of business is at [address].
15.4 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 privacy policy
Our
standard website privacy policy template, designed to aid compliance
with data protection legislation. This includes disclosures about the
categories of personal information that are collected, website
cookies, the ways in which that personal information may be used, the
persons to whom the personal information may be disclosed, the
security measures used to protect the personal information, and much
else besides.
Our
privacy policy document is designed for use in relation websites
which collect and process personal information. Its purpose is to
help website operators meet their obligations under UK data
protection legislation.
The
privacy policy document covers, amongst other things, the following
matters: details of personal information collected by the website;
information about cookies used by the site; details of how personal
information is used; details of specific situations in which personal
information may be disclosed to third parties; information about
extra-EEA transfers of personal data; and information about data
security.
Please
read the notes accompanying the privacy policy very carefully. You
will of course need to adapt the privacy policy to suit your website
and business.
It
may not be suitable for websites which collect or process large
volumes of personal information or sensitive personal information;
nor may it be it suitable for websites which make complex or unusual
or unexpected uses of personal information.
In
relation to cookies, the privacy policy includes a statement to the
effect that users consent to the use of cookies. However, this will
not necessarily satisfy the cookies consent requirement under the new
cookie laws.
Free
privacy policy body (with cookies)
Section
1 - Introduction
Section
1.1
"Personal
information": for day-to-day purposes, it is best to assume that
all information which relates to a living individual constitutes
personal information.
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
3 - Collecting personal information
Section
3.1
What
types of personal information will or might the website operator
collect?
(a)
- What analytics data will you collect?
(b)
- What information will be collected from users who register with the
website?
(c)
- What profile information is collected through the website?
(d)
- What information will be collected from users who subscribe to
website services, email notifications and/or newsletters?
(e)
- What information is processed in connection with the provision of
website services?
(f)
- What can be purchased through the website: goods, services or both?
What transactional data will be collected from users?
(g)
- What personal information can a user publish through the website?
(h)
- What communications information may be collected?
(j)
- What other types of information might you collect?
Section
4 - Using personal information
Section
4.2
For
what purposes will the website operator use personal information
collected through the website?
(j)
- Might marketing communications relate to third party businesses?
(n)
- Will private messages sent by users be monitored to ensure
compliance with website terms and conditions?
(o)
- For what other purposes might personal data collected through the
website be used?
You
must list here the uses to which you will (or may in future) put
personal data. We have suggested some common categories.
As
a general rule, where you plan to use personal information you have
collected for the purpose of direct marketing, this should be made
clear on the page where the information is collected, and you should
ensure that this only happens if users opt in to the marketing (eg
"Click here if you would like us to send you information by
email about products which we think will interest you."). There
are, however, exceptions to this general rule. There are also rules
about the content of direct marketing communications. If you are in
any doubt about complying with your legal obligations in relation to
direct marketing, you should seek professional advice.
Section
4.3
Will
users have the opportunity to publish any personal information on the
website?
Section
4.4
Optional
element.
Section
4.5
Will
the website undertake in this document not to supply any user's
personal information to a third party for the purpose of third party
direct marketing?
Section
4.6
Will
the website operator pass any personal information to any third party
payment services provider?
What
is the name of the payment services provider that processes website
transactions? At what web address can the privacy policy of the
payment services provider be found?
Section
5 - Disclosing personal information
Section
5.1
To
which categories of person may personal information collected through
the website be disclosed?
Section
5.2
Is
the website operator part of a group of companies in circumstance
where one or more of those other group companies might need access to
personal information collected by reference to this document?
Section
5.3
(d)
- Does the website operator need a right to disclose personal data to
business purchasers and potential business purchasers?
(e)
- Does the website operator require a right to disclose personal data
in anticipation of a court judgment or regulatory action?
A
website operator may be obliged to disclose personal data to a third
party under various laws. For example, under the Defamation Act 2013
and the Defamation (Operators of Websites) Regulations 2013, a
website operator may be required to pass personal data between a
complainant and a poster - i.e. a person who posts on the website
material which may be defamatory of the claimant.
Section
6 - International data transfers
Give
as much detail as possible about any such international transfers.
You need to be aware that the inclusion of this provision will not be
sufficient to ensure that all international transfers of personal
data are lawful. If in doubt, you should seek professional advice on
this point.
Section
6.2
Will
any personal data be transferred outside the EEA?
To
which countries outside the EEA may personal data be transferred?
Section
6.3
Will
users have the opportunity to publish personal information on the
website?
Section
6.4
This
consent statement is unlikely to create an effective consent to
extra-EEA transfers on its own.
Section
7 - Retaining personal information
Section
7.3
Does
the website operator have any specific policies in place regarding
time periods for the deletion of personal data?
(a)
- Specify a category of personal data. Specify the date/time when
that personal data will usually be deleted.
Section
8 - Security of personal information
Section
8.2
There
is an obligation upon data controllers to store personal data
securely.
Section
8.3
Optional
element.
Section
8.5
Optional
element.
Section
9 - Amendments
Section
9.3
Will
you ever contact users to notify them of changes to the document?
How
will users be notified of changes to the document?
Section
10 - Your rights
Section
10.1
(b)
- What evidence of identity will you require before fulfilling a data
protection subject access request?
Section
13 - Cookies
Section
13.5
What
types of cookies will be used on the website?
Section
13.6
(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
14 - Data protection registration
Section
14.2
What
is the website operator's data protection registration number?
Section
15 - 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
15.1
What
is the name of the company, partnership, individual or other legal
person or entity that owns and operates the website?
Section
15.2
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
15.3
Optional
element.
Where
is the website operator's head office or principal place of business?
Section
15.4
What
is the website operator's contact email address? What is the website
operator's contact telephone number?