Cookie policy
Cookie policy
Note that by some definitions (potentially including legal definitions), a cookie is a piece of data used by a browser in which some state is stored. We do not limit ourselves to this definition. By our definition, a cookie is any piece of data (browser cookie, image, DNS reply, etc.) or any program which can be used to save a visitor's state, track the visitor, or otherwise identify the visitor. In other words, we are only concerned with the moral definition of cookie, not any strict technical or legal definition.
We define a first-party cookie as a cookie (per the above definition) for which all of the following criteria apply:
- it is hosted on, or set by, one of our own sites or applications;
- it is not shared, either wholly or in part, with any third party or third-party service;
- it does not transmit any data, of any kind, to a third party or third-party service.
Note that according to our definition of first-party cookie, it's irrelevant where a third party or third-party service is hosted, or what domain name it uses. For example, if a third-party service that we use is available at a DNS CNAME of
tracker.hackworthltd.uk, and one or more cookies on one of our sites is set by, or transmits data to, that service, then that cookie is not a first-party cookie.We define a third-party cookie as any cookie that does not meet our criteria for what constitutes a first-party cookie.
Regardless of whether we're collecting personal data or not, and regardless of the lawful basis for the collection of that information, if a web site we own sets one or more cookies, it must display a cookie banner.
The banner should describe each cookie that the site wants to set on that site. Cookies other than those that are mandatory for the site to function must be opt-out by default.
The cookie banner must, for each individual cookie, provide the following information, either in the banner or by pointing to a site-specific cookie policy page:
- who owns or sets the cookie (i.e., either Hackworth Ltd, or a third party);
- the cookie's domain;
- the purpose of the cookie;
- what information the cookie collects;
- if the cookie is collecting information by consent, an option to enable or disable the cookie, which must be opt-out by default;
The DPO must approve the content of every cookie banner, the specific cookies that each site sets, and the lawful basis for each cookie.
All of our sites must contain a link to our privacy policy.
Both our privacy policy and our site-specific cookie policies must be kept up-to-date at all times. This is the responsibility of the team or member who maintains each individual site.
All third-party cookies that we deploy on our sites must be approved by the DPO. The current list of approved third-party cookies is maintained here.
Once approved, the DPO must be promptly informed of any changes to the privacy & cookie policies by these third parties.
It is the responsibility of the member(s) who are maintaining the site (and/or who are in charge of the relationship with/usage of the third-party service) to stay up-to-date on these policies and to inform the DPO.