Cookie policy

Policy Date: 30 April 2014
Policy Author: Lee Parker, European Data Privacy Officer, EU Compliance

1. Scope of this Policy
1.1 This document sets out guidelines on the use of cookies with which all Teva EU external websites should comply. It will help employees:
1.1.1 ensure that those responsible for designing Teva websites are aware of EU requirements for cookies; and
1.1.2 identify and categorise the types of cookies we use, so Teva can explain this clearly to website visitors and use an appropriate method to obtain informed consent from site visitors.
1.2 If you are responsible for setting up a new website, you must contact the Legal Department and Compliance Department to ensure the relevant data protection issues are properly addressed.
1.3 This policy gives guidance on drafting the cookies section in the Teva draft website privacy policy, which we should use as a basis to draft privacy policies for Teva EU external websites.
1.4 If you have any questions about this policy please contact the European Data Privacy Officer.
2. What is a Cookie?
2.1 A cookie is a small text file which is placed by an online provider (e.g. a website publisher or online advertising network) on to the hard disks of visitors to the site, so as to allow the provider to ‘recognise’ the device later.
2.2 Cookies can be used to store information about visitors such as their names, e-mail addresses and user preferences. They also allow the user to navigate between pages efficiently and ensure that the adverts seen online are more relevant to the user and his interests.
3. EU Law
3.1 Under EU law, Teva must clearly explain to Teva EU website visitors what cookies we use. In order to do this, Teva must itself identify the types of cookies we will be using on our sites.
3.2 The information provided to site users should be sufficiently full and intelligible to allow individuals to understand clearly the potential consequences of allowing cookies to be planted on their devices. The information only needs to be provided the first time a cookie is placed but not on subsequent occasions.
4. Types of Cookies
4.1 These different types of cookies are categorised based on the International Chamber of Commerce’s cookie guidance:

Category 1: strictly necessary cookies
These are required for the operation of a website.
Examples are cookies used for remembering login details or protecting against fraud. Notice from draft website Privacy Policy
These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details) cannot be provided
Category 2: analytical/performance cookies
These cookies collect information about how visitors use a website (for example, as part of Google Analytics or Omniture). Notice from draft website Privacy Policy
These cookies collect information on how people use the Site. For example, Teva uses [Google Analytics] cookies to help us understand how customers arrive at the Site, browse or use the Site and highlight areas where we can improve areas such as navigation, user experience and marketing campaigns. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works
Category 3: functionality cookies
These are used to recognise users when they return to a website. They remember user choices and enable the personalisation of content. Notice from draft website Privacy Policy
These cookies remember choices you make (such as language choices). These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites
Category 4: social media cookies
These are cookies that are placed by social media sites that allow their logged-in users interact with their services (eg. facebook/twitter/pinterest buttons). Notice for draft website Privacy Policy:
These cookies allow you to share what you have been doing on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the relevant social media outlet for how their cookies work.

5. Obtaining Consent
5.1 Strictly necessary cookies: no consent is required for these types of cookies.
5.2 All other types of cookies: use is only allowed if the user has:
5.2.1 been provided with clear and comprehensive information about the purposes for which the cookie is stored; and
5.2.2 given his consent.
5.3 Consent must involve some form of communication where the individual knowingly indicates their acceptance. To obtain consent, we should use a banner, or otherwise make a prominent statement on any page via which the visitor could first access a Teva site, stating that continued use of the site amounts to consent. This is an “implied consent” approach.
5.4 Wording for such a banner should give a basic overview of the reason cookies are used, and then provide a link to the Privacy Policy. For example:
This site uses cookies to improve your user experience.
5.5 Consent must be “freely given, specific and informed” – to achieve this, it is important that the appropriate cookie wording templates set out in paragraph 4.1 above are included in the final website privacy policy.