Unless otherwise expressly stated, terms in this Cookie Notice have the same meaning as defined in our Privacy Notice.
SCOPE OF NOTICE
WHAT ARE COOKIES AND RELATED TECHNOLOGIES
Cookies are small data files, which are downloaded to an individual’s browsing device (such as a computer or smartphone) when they visit a website. Cookies allow us and our third-party partners and providers to collect certain information about an individual’s interactions with our email communications, websites and other online services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
WHAT WE COLLECT WHEN USING COOKIES
HOW WE USE THAT INFORMATION
Cookies do lots of different jobs, like helping website operators understand how their website is being used, letting a user navigate between pages efficiently, remembering a user’s preferences, and generally improving browsing experience. Cookies can also help ensure the advertisements an individual sees online are more relevant to their interests.
WHAT TYPES OF COOKIES ARE USED BY Value-Privacy.com?
The types of cookies used on Value-Privacy.com’s websites can generally be put into one of the following categories: strictly necessary; analytical or performance; functional; and targeting:
|Strictly Necessary Cookies||These cookies are essential to making Value-Privacy.com’s websites work. They enable core functionality such as security, network management and accessibility. Without these cookies, services that are necessary for an individual to use a site, such as accessing secure areas or remembering the information inputted into a webform, are not available. These cookies do not track browsing history on non-Value-Privacy.com websites. The legal basis for our use of strictly necessary cookies are our legitimate interests, namely being able to provide and maintain our website.|
|Analytical or Performance Cookies||These cookies collect information about how the number of visitors to our websites and online services, and to see how visitors move around our websites and online services when they are using them. This helps us to improve the way our websites and online services work, for example, by ensuring that users are finding what they are looking for easily. Information collected from these cookies may be aggregated and used on an anonymous basis. The legal basis for our use of analytical/performance cookies is an individual’s consent.|
|Functional Cookies||These cookies enable a website to remember information that changes the way the website behaves or looks, such as preferred language or the region that an individual is accessing our website from. The legal basis for our use of functional cookies is an individual’s consent.|
|Targeting Cookies||These cookies record an individual’s visit to our website, the pages they have visited and the links they have followed. They are used to track visitors across our websites. We use this information to make our website and the marketing messages we send to an individual more relevant to their interests. We may also share this information with third parties who provide a service to us for this purpose. The legal basis for our use of targeting cookies is an individual’s consent.Please see the Interest Based Advertising section below for more information.|
The list of some of the specific cookies which are most frequently used by Value-Privacy.com may be found in the Cookies Used By Value-Privacy.com annex below.
HOW LONG WILL COOKIES STAY ON A BROWSING DEVICE
The length of time a cookie will stay on a browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on a device until the individual stops browsing. Persistent cookies stay on a browsing device until they expire or are deleted (i.e. after an individual has finished browsing). Details of “persistent” and “session” cookies set on Value-Privacy.com websites can be found in the Cookies Used By Value-Privacy.com annex below.
FIRST- AND THIRD-PARTY COOKIES
“First-party cookies” are cookies that belong to Value-Privacy.com and that Value-Privacy.com places on a device. “Third-party cookies” are cookies that another party places on a browsing device through an Value-Privacy.com website.
CHOICES ABOUT COOKIES
If an individual prefers not to accept cookies, most browsers will allow them to: (i) change their browser settings to notify them when they receive a cookie, which lets them choose whether or not to accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject cookies. The following links may be helpful:
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookies settings in Safari web and iOS.
HOW WE USE TRACKING TECHNOLOGIES IN OUR EMAILS
Our emails may contain tracking pixels that identify if and when an individual has opened an email that we have sent them, how many times they have read it and whether they have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, provide more relevant emails to an individual’s interests and to know if an individual has opened and read any important administrative emails we have sent them.
An individual may set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our emails and performed certain functions with it.
Some browsers also give the option of downloading and installing extensions that block pixels and other tracking technologies.
We may share your personal data with other organisations in the following circumstances:
- If the law or a public authority says we must share the personal data;
- If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
- From time to time, we will employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it; or
- reCAPTCHA from Google helps protect websites from spam and abuse. A “CAPTCHA” is a test to tell human and bots apart. It is easy for humans to solve, but hard for “bots” and other malicious software to figure out. By adding reCAPTCHA to our site, we can block automated software while helping us welcome real users like you. First, the reCAPTCHA algorithm will check to see if there’s a Google cookie placed on the computer being used. Then, an additional reCAPTCHA-specific cookie will be added to your browser, and a complete snapshot of the browser window at that moment in time will be captured, pixel by pixel.
Some of the browser and user information collected at this time includes:
- All cookies placed by Google over the last 6 months,
- How many mouse clicks you’ve made on that screen (or touches if on a touch device),
- The CSS information for that page,
- The date,
- The language your browser is set to,
- Any plug-ins you have installed on the browser,
- The data you supply via the form
- For the purpose of their promotional activities we will not share your information with any third parties for the purposes of direct marketing.
- We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct. The key processors we use are;
|Accounting software||Finance||Quickbooks||United States|
|Client Management System||Operations||Hubspot||International|
|Email marketing tool||Marketing||Hubspot/Outlook||International|
Value-Privacy.com is committed to transparency in the way we collect, process, share, and store your personal information within our environment. When we transfer any personal data to a data processor in a country without an adequacy decision by the EU Commission, we ensure that an adequate safeguard under GDPR Article 46 is present. We are aware of the recent Schrems II ruling and its implications on the U.S.-E.U. Privacy Shield and potentially the continued use of the Standard Contractual Clauses. When relying on Standard Contractual Clauses, evidence is available upon request from the data subjects.
We are diligently reviewing our privacy practices in light of this, but nevertheless remain devoted to handling your data in an ethical manner, including:
- Processing your data only when it is fulfilling a contract or has a legitimate interest;
- Mandating by contract that all sub-processors adhere to GDPR requirements;
- Ensuring that any data transfers are encrypted in transit;
- Storing your data on encrypted servers and networks;
- Performing frequent penetration and firewall testing;
- Undergoing yearly security audits;
We will continue to monitor guidance from authorities and stay closely aligned with these developments including adjusting our practices accordingly.Subject Access Request as a Service (SARsaaS)
We are committed to providing the information you request as part of your Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.
We do have agreements in place with any third-party platforms that offer “Subject Access Requests as a Service”. As a responsible data controller of your personal information this represents significant risks when sharing data. The right of access afforded to you, does not obligate data controllers to share data with 3rd parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.
We will monitor future guidance from the Information Commissioner’s Office but currently undertake our own reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.
Please contact us by email at firstname.lastname@example.org with any questions or comments regarding this Cookie Notice.