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. Cookies serve as the memory of the internet and are small text files which serve the purpose of giving websites recall ability. Once, cookies were the ability of the internet to remember, today, they have also become its ability to predict.
All data processing activity carried out in LSL Estate Agency Division [EAD] must be carried out in accordance with all applicable data protection and privacy laws including the General Data Protection Regulation (Regulation (EU) 2016/679) [GDPR], the Data Protection Act 2018 [DPA] and the Privacy and Electronic Communications (EC Directive) Regulations 2003 [PECR].
The application of the Cookies is regulated by PECR however the use of data that the Cookie files collect and any data subject preferences are regulated by the GDPR and DPA in the same way as any other personal data.
While conducting its operations, EAD must always co-operate with it’s regulators including the Information Commissioner’s Office [ICO] in relation to data protection in the UK.
Whilst this document contains guidance that is often labelled as ‘policy’ it should be read in the same context as the Privacy or Fair Processing Notices which provide Data Subjects with clear communication as to how their data is used in regards to Cookies. The over-arching applicable EAD Level 2 policy, is the Data Protection policy.
The requirements for this consent are in line with other standards of consent and to that end the consent for cookies must be:
• Freely given
• Specific and;
The functionality of the website must ensure that these requirements are met for every visitor of the site.
CUSTOMER FACING ‘POLICY’ INFORMATION
The following summary should be published on the relevant EAD business unit’s website and reviewed on an, at least annual basis to ensure that it contains accurate information.
This is a suggested wording and it is anticipated that although there may be some amendments in some businesses to reflect the reality of the cookies used in a website, the majority of this content should be included as a minimum. Any queries should be raised with the EAD Data Office before publication if you are unsure about how to comply with the ICO guidance.
Insurance First Brokers Limited (Insurance First), company number 2169477, having a registered address of Floor 2, Gateway 2 Holgate Park Drive, York, England, YO26 4GB. (“We/”Us/ Our”).
WHAT ARE COOKIES?
Cookies do not contain any confidential information about you.
THE TYPES OF COOKIES THAT WE USE
We use three types of cookies on our websites: [**This list needs to be amended as necessary**]
• Functional cookies that are essential for our website to work
• Analytical cookies that anonymously count interactions on our website
• Non-essential or tracking cookies that are used for marketing activities
Functional session cookies and persistent cookies are necessary in order for you to use our website. These cookies can be deleted via your browser, but this will restrict the functions that you are able to carry out on our website, such as logging into [My Move].
Session cookies expire when you leave the website and are not stored on your computer and do not contain any personal data. Persistent cookies last beyond your visit to our website.
We use Google Analytics on our website. This is a tracking cookie which enables us to track how popular our site is and to record visitor trends over time. The cookie does not contain any personal data but they may use your computer’s IP address to determine where in the world you are accessing the website from, and to track your pages visited within the site.
NON-ESSENTIAL (SERVICE PROVIDER) COOKIES
You can accept or block any cookies from any website through your browser settings. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
COOKIES AND DEMOGRAPHICS
COOKIES WE USE
This cookie tracks the cookie preferences so we know what we can and can’t use. It is a persistent cookie.
This cookie tracks interaction with the cookie banner and what version has been accepted so we can show it again if anything changes. It is a persistent cookie.
This cookie is essential for property search, My Move and form functionality to operate. This cookie is a session cookie. It is deleted when you close your
browser and expires after 1 day.
_ga, _gid, _gat, _dc_gtm_, AMP_TOKEN, _gac_, _gat_UA-1378743-4, _gac_UA-1378743-4,_ga_Q93C758E8H
This cookie is used to collect information about how visitors use our website. We use the information to compile reports and to help us
improve the website , including the number of visitors to the website and blog, where visitors have come to the website from and the pages they
visited.. The cookies collect information in a way that does not direc
MORE INFORMATION ON COOKIES
For more information about cookies, visit the Information Commissioner’s website https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/
Email: email@example.com; or
Post: Data Protection Officer, Newcastle House, Albany Court, Newcastle Business Park, NE4 7YB; or
Telephone: 0191 233 4600.