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In the light of the EU regulations entities storing cookies on visitors' computers are required to provide the users with clear and comprehensive information about how cookies are used by the given website, as well as to obtain their "consent" to such conduct.
In order to comply with this, we have taken the following steps:
- Identified cookies and other user data collection technologies used by this website, the purposes they are used for, how long they are stored for and what their source is (solely the visited website or third parties as well).
- Provided "clear and comprehensive" information about cookies within the scope corresponding to the nature of the threat to privacy related to a particular cookie.
An alternative solution is based on the assumption that tacit consent is sufficient, one that is expressed by means of acceptance of the cookie after receiving clear information regarding the data collection mechanisms and the simple, easily available method of blocking of these mechanisms. As a result, the website visitor can agree to some data collection methods and reject the other methods.The appropriate method of obtaining consent to the use of a particular data collection mechanism depends on how much of a threat this mechanism is to the user's privacy; taking into account the following information:
- the entity collecting the data (the visited website or a third party)
- the type of collected data
- the purpose the data is used for
- how long the data is stored
- the nature of the website collecting the data.
In the case of data collection methods requiring user's consent we apply a three-tiered approach:
- data collection methods threatening privacy to a small extent: we clearly inform the users about the used data collection mechanisms and provide an easy way to disable these mechanisms; the fact that the user has not done so is treated as an expression of consent
- data collection methods threatening privacy to an average extent: we apply the same approach as in the case mentioned above and also inform the users about the used data collection mechanisms in appropriate locations of the website (e.g. around targeted adverts or other elements of the website that require the use of particular data collection mechanisms)
- data collection methods threatening privacy to a high extent: a mechanism used to obtain prior consent of the users will be implemented (for example a banner or a pop-up window requiring the users to express consent to the use of a particular data collection mechanism).
Tacit consent to the use of most data collection mechanisms: The data collection mechanisms used by this website present a low or average threat to user privacy.
Informing about the types of used data collection mechanisms, not about the particular mechanisms: As websites use a lot of user data collection mechanisms, Annex A does not discuss particular mechanisms and does not assess the extent to which particular mechanisms present a threat to user privacy. Instead, it presents certain categories of mechanisms (e.g. "cookies used in ads", "cookies used for analysis", etc.), and then assesses each of these categories in terms of extent of threat to user privacy. This allows to inform the users about the used information collection methods in a simpler and clearer way.
NOTE: The assessment of information collection mechanisms used by this website is presented in Annex A, it contains information about the purposes for which these methods are used, how long the information will be stored for and how these mechanisms can be disabled (the part "How to do it").
Links to other websites
If you have any questions, comments or concerns regarding this policy regarding the use of user data collection mechanisms or the practices of these website, please contact us at:
Janssen-Cilag Polska Sp. z o.o., ul. Iłżecka 24, 02-135 Warszawa
Changes to the policy on the use of user data collection mechanisms