Information Collection and Use
We may collect personally identifiable information when you visit or use our pages. We may also receive personally identifiable information from our business partners. We also automatically receive and record information on our server logs from your browser including your IP address, cookie information and the page you requested.
We may use this information for three general purposes: to customise the content you see, to fulfil your requests for certain services and information, and to contact you.
Information Sharing and Disclosure
We will not sell or rent your personally identifiable information to anyone. We will send personally identifiable information about you to other companies or people when:
- We have your consent to share the information;
- We need to share your information to provide the product or service you have requested;
- We need to send the information to companies who work on behalf of Stairways to provide a product or service to you (unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us);
- We respond to subpoenas, court orders or legal process
- We find that your actions on our web sites violate the above terms of service or any of our usage guidelines for specific products or services.
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 stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.
Cookies may be either ‘persistent’ cookies or ‘session’ cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the 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.
The key piece of legislation in the UK relating to cookies is the Privacy and Electronic Communications (EC Directive) Regulations 2003. This cookies policy will also help you to comply with the Data Protection Act 1998 insofar as it affects the use of web cookies.
Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) provides that:
- Subject to paragraph (4), a person shall not store or gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.
- The requirements are that the subscriber or user of that terminal equipment – (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent.
- Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.
- Paragraph (1) shall not apply to the technical storage of, or access to, information – (a) for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network; or (b) where such storage or access is strictly necessary for the provision of an information society service requested by the subscriber or user.”
Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.
We may use the information we obtain from your use of our cookies for the following purposes:
- To recognise your computer when you visit our website;
- To track you as you navigate our website, and to enable the use of the [specify feature – e.g. shopping cart] on our website;
- To improve the website’s usability;
- To analyse the use of our website;
- In the administration of this website;
- To prevent fraud and improve the security of the website;
- To personalise our website for you, including targeting advertisements which may be of particular interest to you.
When you use our website, you may also be sent third party cookies.
Our [advertisers/service providers] may send you cookies. They may use the information they obtain from your use of their cookies:
- To track your browser across multiple websites;
- To build a profile of your web surfing;
- To target advertisements which may be of particular interest to you.
Our advertising services providers may send you cookies for the purpose of enabling the service of advertisements based on your previous visits to our website.
Most browsers allow you to refuse to accept cookies. For example:
- In Internet Explorer you can refuse all cookies by clicking ‘Tools’, ‘Internet Options’, ‘Privacy’, and selecting ‘Block all cookies’ using the sliding selector;
- In Firefox you can block all cookies by clicking ‘Tools’, ‘Options’, and un-checking ‘Accept cookies from sites’ in the ‘Privacy’ box.
Blocking all cookies will, however, have a negative impact upon the usability of many websites. [If you block cookies, you will not be able to use the many features on this website.
You can also delete cookies already stored on your computer:
- In Internet Explorer, you must manually delete cookie files you can find instructions for doing so at http://support.microsoft.com/kb/278835;
- In Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you ‘clear private data’ this setting can be changed by clicking ‘Tools’, ‘Options’ and ‘Settings’ in the ‘Private Data’ box and then clicking ‘Clear private data’ in the ‘Tools’ menu.
This document was created based on a template supplied by SEQ Legal.