The Circulation Academy

COOKIES POLICY

Last updated: August 30, 2023

Note: This policy should be read in conjunction with the specific privacy policy for the THE CIRCULATION ACADEMY website (e.g. TheCirculationAcademy.com) that you were visiting or planning on visiting.

Introduction

As you navigate through and interact with THE CIRCULATION ACADEMY website, we may use technologies like cookies, web beacons, tags, tracking pixels, etc. (in this policy we will refer to all of these technologies simply as “cookies”).

What are “cookies”?

Cookies are small computer files that are placed on your device, by either website owners or third parties, when you visit websites. They allow certain information about your preferences and browsing actions on websites to be collected and then further processed.

Sometimes cookies may themselves store information relevant to your use of a website (e.g. what your language preference is). They may also just contain a unique ID that can be linked to information that is stored, by either the owner of the website or a third party, about your preferences and previous browsing actions.

Recipients of information collected through cookies

The information collected through cookies may be accessed by THE CIRCULATION ACADEMY entities and also by third parties for the purposes associated with the given cookie (e.g. analytics, marketing).

Purposes and legal bases for the cookies we use

We use cookies for “strictly necessary” purposes, and “analytics” purposes purposes. The table below outlines more detail about these purposes as well as the legal basis, as applicable under the European Union’s General Data Protection Regulation (GDPR), for the processing associated with each type of cookie.

Cookie type

Purpose

Legal basis

Strictly Necessary / Essential

These are cookies that are strictly necessary to support the performance of the website and to provide the service you have requested. The specific purposes for them can include remembering language preferences or remembering the goods a user wishes to buy when they go to the checkout.

The legal basis for the placement of these cookies on your device and the use of any data provided by them is legitimate interests (Article 6(1)(f) GDPR). The legitimate interest is that these cookies are strictly necessary to support the performance of the website and to provide the service that you have requested.

Analytics

Analytics cookies are used by website owners and third parties to collect data about how a user has acted while on a website (e.g. pages they have viewed, links they have clicked on, search terms used). This is so that this data, sometimes combined with data about other websites the user has visited and their demographic data (e.g. location, age, etc.), can be analysed and then used to improve the quality of a website. For example, if analytics shows that 80% of the links that are clicked on are at the top of a page, then this is where the most important links may then be placed.

The legal basis for the placement of analytics cookies on your device and the use of any data collected through them is “consent” (Article 6(1)(a) GDPR). This consent can be withdrawn at any time by clicking on the link to your Cookie Settings on each of our webpages. The withdrawal of consent shall not affect the lawfulness of any processing based on consent that was provided before consent was withdrawn.

Marketing

Marketing cookies are used by website owners and third parties to collect data about how a user has acted while on a website (e.g. pages they have viewed, links they have clicked on, search terms they have used).

Marketing cookies may also track user engagement.

The legal basis for the placement of marketing cookies on your device and the use of any data collected through them is consent (Article 6(1)(a) GDPR). This consent can be withdrawn at any time by clicking on the link to your Cookie Settings on each of our webpages. The withdrawal of consent shall not affect the lawfulness of any processing based on consent that was provided before consent was withdrawn.

 

Your choices regarding cookies

We use a consent management platform (CMP) in order to provide information to website users about the cookies that we use and to allow users to make choices about whether they consent to the use of cookies which require consent.

The CMP will appear as a banner the first time that you arrive on one of our websites and periodically after that when we again check with you about your preferences. You may also choose to update your preferences (including withdrawing, with future effect, any consent you have previously given) at any time by clicking on the link to your Cookie Settings on each of our webpages.

You will notice through the CMP that strictly necessary cookies will always be placed on your device and/or used when you visit our websites. This is simply because they are strictly necessary for the use of the website. In contrast, analytics and marketing cookies will only be placed on your device and/or used if you have consented to this processing through the CMP.

Through the cookie settings of your internet browser, you should also be able to delete stored cookies at any time, as well as deactivate or restrict the future transmission of cookies. Please note, however, that if you deactivate cookies, you may no longer be able to use all the functions of the website. In the menu of most browsers you will find setting options for the use of cookies.

Changes to this cookie policy

We may change this cookie policy from time to time to reflect changes to the cookies we use or for other operational, legal, or regulatory reasons. Please revisit this cookie policy regularly to stay informed about our use of cookies. You can see when this cookie policy was last updated by checking the “last updated” date displayed at the top of this cookie policy.

Questions or comments

If you have any questions or comments about this cookie policy, please contact us at DataProtectionInquiries@TheCirculationAcademy.com