Privacy and Cookies

Background

The Privacy and Electronic Communications (EC Directive) Regulations 2003 (the Regulations) cover the use of cookies and similar technologies for storing information, and accessing information stored, on a user's equipment such as their computer or mobile. Recent legislation means that all websites need to disclose any information that a website stores in cookies and obtain consent by the user where cookies are used.

This is because cookies can potentially be used to store personal information or to monitor a user's activities online. We only use cookies when absolutely necessary and none of our cookies contain any personal information.

What are cookies?

A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies are then sent back to originating website on each subsequent visit. Cookies are useful because they allow a website to recognise a user's device. The Regulations apply to cookies and also to similar technologies for storing information. This could include, for example, Local Shared Objects.

The use of cookies and similar technologies has for some time been commonplace and cookies in particular are important in the provision of many online services. Using such technologies is not, therefore, prohibited by the Regulations but they do require that people are told about cookies and given the choice as to which of their online activities are monitored in this way.

This guidance will explain how the rules apply for those operating websites and using cookies. The guidance uses the term 'cookies' to refer to cookies and similar technologies covered by the Regulations.

For more information see: http://www.allaboutcookies.org/

How does our website use cookies?

There are a number of different types of cookies that can be used:

Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) these are "Session cookies" or they can be stored for longer - these are "Persistent cookies".

Session and persistent cookies

  • Session cookies - allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session cookies expire after a browser session so would not be stored longer term. For this reason session cookies may sometimes be considered less privacy intrusive than persistent cookies.
  • First and third party cookies - whether a cookie is 'first' or 'third' party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user - the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.
  • Persistent cookies - are stored on a users' device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users' preferences and choices when using a site or to target advertising.

Our trading website uses a session cookie - some modern browsers block these and the user cannot log in because they are regarded as third party cookies. This is because the same trading site is used for a few different products and therefore the top banner on the screen has a different URL to the trading website.

Here is a list of any cookies that are in use on our web site; the information held within them and the purpose of the cookie:

Cookie Name Cookie Type What it does

JSESSIONID

Session Cookie

This is essential to the running of the site as it allows us to maintain your session on the website after you have logged in.

This is for your own security as well as it means that the site can automatically log you off after 10 minutes of inactivity.

Example content for this cookie:

42AA50E638400CB64E9DA6045E1B99B5

Data protection and communication

We may use, store or otherwise process personal information provided by you in connection with the provision of the service for the purposes of providing the service, administering your account or for purposes ancillary thereto, including, without limitation, for the purposes of credit enquiries or assessments. In the UK, we operate, and have made all appropriate notifications in accordance with, applicable data protection legislation.

The information that we hold about you is confidential and will not be used for any purpose other than in connection with the provision of the service. Information of a confidential nature will be treated as such provided that such information is not already in the public domain. We will only disclose your information to third parties in the following circumstances:

  • where required by law or if requested by any regulatory authority or exchange having control or jurisdiction over us;
  • to investigate or prevent fraud or other illegal activity in connection with our provision of Service to you;
  • for purposes ancillary to the provision of the services or the administration of your account, including, without limitation, for the purposes of credit enquiries or assessments;
  • if it is in the public interest to disclose such information;
  • at your request or with your consent.

The above clause is subject to the proviso that we may disclose your information to certain permitted third parties, such as members of our own group and our professional advisers who are bound by confidentiality codes.

We do not sell, rent or trade your personal information to third parties for marketing purposes without your express consent.

When you speak to us on the telephone, some calls may be monitored or recorded. These recordings will be our sole property and may used for training or as evidence in the event of a dispute.