Overview

You must tell people if you set cookies, and clearly explain what the cookies do and why. You must also get the user’s consent. Consent must be actively and clearly given.

There is an exception for cookies that are essential to provide an online service at someone’s request (e.g., to remember what’s in their online basket, or to ensure security in online banking). See Consent Exemptions section.

The same rules also apply if you use any other type of technology to store or gain access to information on someone’s device referred to as Similar Technologies. Examples (non-exhaustive) include local storage objects (LSOs) or ‘flash’ cookies, software development kits (SDKs), pixel trackers (or pixel gifs), ‘like’ buttons and social sharing tools, and device fingerprinting technologies.

Consent for the setting of cookies must be of the standard defined in the General Data Protection Regulation Article 4(11), which says the ‘consent’ of the data subject means any “freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her”.

Key Recommendations

  • Continue browsing on the website is not a valid way of expressing consent.
  • Do not bundle consent into general terms and conditions or privacy notices. In fact, the request must be separate from other matters.
  • Analytics cookies are not strictly necessary. Therefore, they require consent.
  • Cookie walls are not allowed.
  • ‘Nudging’ designs in the consent mechanism aimed at influencing the user’s choice are not allowed.

Current Status

Healthium: Precision MedTech for every patient globally (healthiummedtech.com)

Currently no consent mechanism is presented to a user of the website.

A user cannot make a choice (consent) by an affirmative action (click yes, tick a box) to indicate their acceptance of cookies being placed on their device. The user does not have an option to reject or decline the setting of cookies.

https://www.qclose.com/

Currently no consent mechanism or banner is presented to a user of the website.

A user cannot make a choice (consent) by an affirmative action (click yes, tick a box) to indicate their acceptance of cookies being placed on their device. The user does not have an option to reject or decline the setting of cookies.

Currently a user does have any choice with respect to placement of cookies – this does constitute valid consent and does not inform the user in a granular way of what cookies will be placed and their intended use.

Suggested Actions

Website cookie banner

The website cookie banner as depicted above requires changing. There are many free cookie banners/plugins that can be configured to be compliant that provide the option to list cookies, their function, and obtain user consent for each individually. See Examples.

Cookie audit

It is recommended that you audit the cookies currently being deployed on the website and ascertain the value they provide to the organisation. If no value is realised the cookies/ cookie plugin should be disabled and the code removed from the website backend.
• What insights/analytics are being used currently?
• What benefits are cookie analytics providing the organisation?

Developer tab showing cookies (Google Analytics (ga,gat,gid)) deployed on device without Consent.

Consent Exemptions

The below is a list of cookies that are exempt from consent and will fall into the ‘strictly necessary’ category.

User-input cookies, (session-id) such as first-party cookies to keep track of the user’s input when filling online forms, shopping carts, etc., for the duration of a session or persistent cookies limited to a few hours in some cases.

Authentication cookies, to identify the user once he has logged in, for the duration of a session.

User-centric security cookies, used to detect authentication abuses, for a limited persistent duration.

Multimedia content player cookies, used to store technical data to play back video or audio content, for the duration of a session. Where an online service merely includes streaming content hosted by a third-party online content provider (e.g., where a website embeds YouTube videos, even those from its own YouTube channel), the exemption may not apply.

Load-balancing cookies, for the duration of session.

User-interface customisation cookies, such as language or font preferences, for the duration of a session (or slightly longer).

Third-party social plug-in content-sharing cookies, for logged in members only of a social network.

Where a clear exemption is not present the business must be able to justify the cookie as being strictly necessary.

Strictly necessary cookies: these are essential cookies enabled for the proper functioning of websites and are used to perform basic functions. Without these cookies a website may not function as intended.

Current Q-close cookie policy.

Cookie Policy

What are Cookies?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies

Necessary
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.

Performance
Performance cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.

Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.

Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.

How to block Cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
www.allaboutcookies.org provides further information about cookies and also how to use settings to manage them on different type of devices.
This Cookie Policy may change from time to time due to developments in technology or business, new services or when any legal guidance is published.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie/ID Purpose Category
_gat
Google uses this cookie to distinguish users.
Analytics
_ga
This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
Analytics
_gid
Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
Analytics
ARRAffinitySameSite
This cookie is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session.
Necessary
ARRAffinity
ARRAffinity This cookie is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session
Necessary
END OF POLICY

Examples

The first layer information must be completed by a setup system or panel by means of which users may choose between accepting or not accepting cookies one by one, or, alternatively, a link pointing to such system or panel.
Users can also be given a third option consisting of two buttons so that they may accept or set/reject cookies.

COOKIES

We use our own and third-party cookies to analyse our services and show ads related to your preferences based on your browsing habits (for example, websites visited). You can find more and set up your preferences HERE.

We use our own and third party cookies for analytic purposes and to show personalised ads according to profiling based on your browsing habits (for example, websites visited). Click HERE to know more. You may accept all cookies by clicking on “Accept” or reject or set up your preferred configuration by clicking HERE.

We use own cookies and third-party cookies for analytical purposes and to show you customised publicity based on a profiling made of your browsing habits (such as, for example, the pages you have visited). Click HERE to obtain more information.

You can accept all cookies by clicking on “Accept” or set or reject them by clicking on “Set”.

Our use of cookies

We use necessary cookies to make our site work. We’d also like to set analytics cookies that help us make improvements by measuring how you use the site. These will be set only if you accept.
For more detailed information about the cookies we use, see our Cookies page.

We use cookies

When you visit our website, if you give your consent, we will use cookies to allow us to collect data for aggregated statistics to improve our services and remember your choice for future visits.

If you don’t want this, we will only use cookies to remember your choice for future visits (i.e., essential cookies). If you don’t select any of the two options, no cookies will be deployed, but the banner will re-appear every time you enter our website.

More information on cookies.

This website uses necessary cookies to function.

If you give us your consent, we will also use cookies, when you visit our website, which allow us to collect data for aggregated statistics to improve our services.

More information on cookies.