Cookie Policy of Diffley Partnership
This document informs Users about the technologies that help Diffley Partnership to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with Diffley Partnership.
For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
Diffley Partnership uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.
Activities strictly necessary for the operation of Diffley Partnership and delivery of the Service
Diffley Partnership uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Third-party Trackers
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Traffic optimisation and distribution
This type of service allows Diffley Partnership to distribute their content using servers located across different countries and to optimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Diffley Partnership and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Diffley Partnership, i.e., communication between Diffley Partnership and the User's browser, while also allowing analytical data from Diffley Partnership to be collected.
Personal Data processed: Trackers and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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SPAM protection
This type of service analyses the traffic of Diffley Partnership, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, Trackers and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Storage duration:
- _GRECAPTCHA: duration of the session
- rc::a: indefinite
- rc::b: duration of the session
- rc::c: duration of the session
Other activities involving the use of Trackers
Experience
Diffley Partnership uses Trackers to improve the quality of the user experience and enable interactions with external content, networks and platforms.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Diffley Partnership and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows Diffley Partnership to incorporate content of this kind on its pages.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts
Google Fonts is a typeface visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Diffley Partnership to incorporate content of this kind on its pages.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Measurement
Diffley Partnership uses Trackers to measure traffic and analyse User behaviour to improve the Service.
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Universal Analytics)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of Diffley Partnership, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:
- AMP_TOKEN: 1 hour
- _ga: 2 years
- _gac*: 3 months
- _gat: 1 minute
- _gid: 1 day
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Anonymised analytics services
The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymised form.
Google Analytics (Universal Analytics) with anonymised IP
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of Diffley Partnership, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:
- AMP_TOKEN: 1 hour
- _ga: 2 years
- _gac*: 3 months
- _gat: 1 minute
- _gid: 1 day
How to manage preferences and provide or withdraw consent
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences privacy widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent preferences.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
With regard to any third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.
Locating Tracker Settings
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
Consequences of denying the use of Trackers
Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help Diffley Partnership to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide related features.
Owner and Data Controller
Diffley Partnership, 2nd Floor, Prospect House, 5 Thistle Street, Edinburgh EH2 1DF
Owner contact email: info@diffleypartnership.co.uk
Since the use of third-party Trackers through Diffley Partnership cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by Diffley Partnership.