Legal and Privacy Information

<div class="container_title"><h1>Legal and Privacy Information</h1></div><div class="container_content">Please click the links below to review the relevant policies and information</div><pd4ml-page-break><div class="container_title"><h1>Privacy Code</h1></div><div class="container_content"><div class="page-width group section">
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ViiV Healthcare ULC (“ViiV”) is committed to the protection of the personal information of individuals with whom it comes into contact. Accordingly, ViiV adheres to the principles set out below (the “Privacy Principles”). The Privacy Principles are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada). “Personal Information”, as used in this Code, means information about an identifiable individual, but does not include the name, title or business address or telephone of an employee of an organization.

<ol>
	<li>PRINCIPLE 1 - ACCOUNTABILITY ViiV is responsible for the personal information under its control and has designated an individual as its Privacy Officer who shall be accountable for the organization's compliance with the following principles </li>
</ol>

1.1  Accountability rests with the Legal Counsel, Compliance and Chief Privacy Officer of GSK, even though other individuals with the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals may be delegated to act on behalf of the designated individual.

1.2  ViiV shall make known, upon request, the identity, title and contact information of the person designated to oversee ViiV 's compliance with its policy.

1.3  ViiV is responsible for personal information in its possession or control. As such, GSK will use appropriate means to ensure that all existing and future contracts ensure a level of privacy protection equal to ViiV 's policies when information is being processed by third parties.

1.4  ViiV shall implement policies and practices to give effect to these principles, including:

(a)  the implementation of procedures to protect personal information;

(b)  the establishment of procedures to quickly receive and respond to complaints and inquiries;

(c)  training and communicating to staff about ViiV 's policies and practices; and

(d)  developing information to explain ViiV 's policies and practices.

<ol>
	<li>PRINCIPLE 2 - IDENTIFYING PURPOSES ViiV shall identify the purposes for which personal information is collected at or before the time the information is collected.  </li>
</ol>

2.1  Accountability rests with the Legal Counsel, Compliance and Chief Privacy Officer of GSK, even though other individuals with the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals may be delegated to act on behalf of the designated individual.

<ul>
	<li>Maintaining a record of medical queries, requests for information, complaints and adverse event reports relating to ViiV products and reporting these to relevant regulatory bodies, related companies or other companies which market the same product as may be required or prudent;</li>
</ul>

<ul>
	<li>Administering disease awareness/management programs or other similar programs organized by ViiV;</li>
</ul>

<ul>
	<li>Notifying you of matters that ViiV may be required by law to notify you of (eg., product recalls);</li>
</ul>

<ul>
	<li>Developing, implementing, marketing and managing ViiV 's products;</li>
</ul>

<ul>
	<li>In the case of Healthcare Professionals:
	<ul>
		<li>
		<ul>
			<li>Sending you material on and contacting you regarding ViiV 's activities and products or developments in pharmaceutical treatments which may be of interest to you and tailoring marketing services to suit your needs;</li>
		</ul>

<ul>
			<li>Supplying you with clinical evaluation packages of ViiV products;</li>
		</ul>

<ul>
			<li>Administering clinical trials or other research organized by ViiV and which you agree to participate in or be involved with;</li>
		</ul>

<ul>
			<li>Identifying, developing and administering continuing education programs, conferences, symposia, expert panels, seminars or other meetings or events organized by ViiV;</li>
		</ul>

<ul>
			<li>Establishing and maintaining customer relationships, including: managing, planning and arranging meetings between you and ViiV sales representatives;</li>
		</ul>
		</li>
	</ul>
	</li>
	<li>Monitoring and reviewing ViiV 's compliance with relevant codes of conduct in its dealings with you.</li>
</ul>

2.2  If we plan to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.

2.3  ViiV will make reasonable efforts to specify the identified purpose, orally or in writing, to the individual from whom the information is collected either at the time of collection or after collection but before use.

<ol>
	<li>PRINCIPLE 3 – CONSENT The knowledge and consent of the individual are required for the collection, use and disclosure of personal information, except where inappropriate. </li>
</ol>

3.1  The way in which we seek consent, including whether it is express or implied consent, may vary depending on the sensitivity of the information and the reasonable expectations of the individual. An individual may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice.

3.2  ViiV will typically seek consent for the use or disclosure of personal information at the time of collection, but in certain circumstances consent may be sought after collection but before use.

3.3  ViiV will only ask individuals to consent to the collection, use or disclosure of personal information as a condition of the supply or purchase of a product, if such use, collection or disclosure is required to fulfill an identified purpose.

3.4  In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge and consent of the individual. These circumstances include: Personal Information which is subject to solicitor-client privilege or is publicly available as defined by regulation; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a time way; to investigate a breach of agreement of a contravention of the law; to act in respect to an emergency that threatens the life, health or security of an individual; for debt collection; or to comply with a subpoena, warrant or court order.

<ol>
	<li>PRINCIPLE 4 - LIMITING COLLECTION</li>
</ol>

ViiV will limit the amount and type of Personal Information collected to that which is necessary for the purposes identified by ViiV. We will only collect Personal Information by fair and lawful means.

<ol>
	<li>PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION</li>
</ol>

ViiV shall not use or disclose personal information for purposes other than those for which it was collected, except with consent of the individual or as required by law. Personal information shall be retained only as long as is necessary for the fulfillment of those purposes.

5.1  ViiV will not disclose personal information about you to any person except in the following circumstances, and then only that information which is necessary.

<ul>
	<li>Third parties we use in the ordinary course of our business, such as for conference organizing, marketing, data processing and associated printing and mailing;</li>
</ul>

<ul>
	<li>Companies related to ViiV for the same kinds of purposes as listed above;</li>
</ul>

<ul>
	<li>Such third parties as otherwise permitted or required by law.</li>
</ul>

5.2  ViiV shall retain personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. In some circumstances where personal information has been utilized to make a decision about an individual, ViiV shall retain that personal information for a period of time that is reasonably sufficient to allow for access by the individual.

5.3  Personal information that is no longer required to fulfill an identified purpose shall be erased, destroyed or made anonymous.

<ol>
	<li>PRINCIPLE 6 - ACCURACY OF PERSONAL INFORMATION ViiV will use its best effort to ensure that Personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.  </li>
</ol>

6.1  Personal information used by ViiV shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual.

6.2  ViiV shall not routinely update personal information about individuals, but only as and when necessary to fulfill identified purposes.

<ol>
	<li>PRINCIPLE 7 – SAFEGUARDS ViiV will protect personal information by security safeguards appropriate to the sensitivity of the information.  </li>
</ol>

7.1  ViiV shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. ViiV shall protect personal information regardless of the format in which it was held.

7.2  Nature of the safeguards taken:

(a)  physical measures - building security, lock boxes, etc.;

(b)  organizational measures - “need to know” basis; and

(c)  technological measures - use of encryption and passwords

7.3  ViiV shall make its employees aware of the importance of maintaining the confidentiality of personal information by signing a Secrecy Document as a precondition of employment.

<ol>
	<li>PRINCIPLE 8 – OPENNESS ViiV will make readily available to individuals specific information about its policies and practices relating to the management of personal information.  </li>
</ol>

8.1  ViiV shall make information regarding its policies and practices available in a form that is generally understandable, including:

(a)  how to gain access to personal information held by ViiV;

(b)  the type of personal information held by ViiV, including a general account of its use;

(c)  personal information available to related organizations (affiliates); and

(d)  how to contact our Privacy Officer.

<ol>
	<li>PRINCIPLE 9 - INDIVIDUAL ACCESS Upon written request, ViiV will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that information. An individual can challenge the accuracy and completeness of the information and have it amended as appropriate. </li>
</ol>

9.1  ViiV will respond to an individual's written request for information within a reasonable period of time. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of Personal Information. This information shall be provided in an understandable, timely and low-cost manner from the perspective of the individual.

9.2  Should an individual successfully demonstrate any inaccuracy or incompleteness in the records, ViiV will make the appropriate amendments to the information. When a challenge is not resolved to the satisfaction of the individual, a statement of disagreement shall be attached to the individual's records. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question.

9.3  In certain situations, ViiV may not be able to provide access to all the personal information it holds about an individual. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. The reasons for denying access shall be provided by ViiV upon request.

<ol>
	<li>PRINCIPLE 10 - CHALLENGING COMPLIANCE An individual can address a challenge concerning compliance with the above principles to the designated person accountable for ViiV 's compliance with the policy.  </li>
</ol>

10.1  ViiV will investigate all complaints. If a complaint is found to be justified, ViiV will take appropriate measures, including, if necessary, amending its policies and practices.

How to contact the Privacy Officer:

Access request, inquiries or complaints should be addressed in writing to:

Privacy Officer 
GlaxoSmithKline Inc. 
7333 Mississauga Road 
Mississauga, Ontario 
L5N 6L4
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</div><pd4ml-page-break><div class="container_title"><h1>Terms of Use</h1></div><div class="container_content">Healthcare information 
  
This website may provide information about medical conditions and their treatment.  ViiV Healthcare ULC makes no representation that material in the site is appropriate or available for use outside of the territory of the intended audience. Those who choose to access this site from other locations do so on their own initiative and are responsible for compliance with local laws, if and to the extent that local laws are applicable.  In addition, nothing on this website should be construed as providing any kind of medical advice or recommendation, and should not be relied on as the basis for any decision or action. Specific medical advice should always be sought from a qualified medical practitioner. 
  
ViiV Healthcare ULC uses reasonable efforts to update this website, but some information may become out of date over time. Except as specifically stated, ViiV Healthcare ULC makes no claims or warranties as to the accuracy, completeness or use of the information contained on this website.  
  
This website may contain a specific section for members of the public, a specific section for patients and a specific section for healthcare professionals. “Healthcare professional” refers to an individual who in the course of their professional activities may prescribe, supply or administer a medicine or medical devices. 
  
The section for the public, where applicable, has been designed as a library resource to provide reference information relating to ViiV Healthcare ULC medicines, including but not limited to, prescription only medicines, to the public within Canada. Within the public section there are specific patient-only pages for those who have been prescribed the medicine relating to those pages. These pages will remain hidden from site navigation and can only be accessed once a member of the public has confirmed they are a patient that has been prescribed a particular medicine. 
  
Further, in the event that this website contains specific pages for healthcare professionals only, those pages will remain hidden from site navigation and can only be accessed once an individual has confirmed they are a healthcare professional under applicable law. 
  
FOR HEALTHCARE PROFESSIONALS ONLY: Please note that approved prescribing information must guide the appropriate use of all medicines. Before prescribing any medicine, healthcare professionals should consult the approved prescribing information for that medicine in their country. 
  
  
Hypertext links 
  
This website may link you to other websites on the Internet, including the websites for ViiV Healthcare ULC affiliates in other countries.  Please ensure that you read the legal and privacy policy sections of any other ViiV Healthcare ULC or third-party site to which you link.  ViiV Healthcare ULC is not responsible for, does not recommend and accepts no liability for any information or opinion contained in any third-party website. 
  
  
Intellectual Property 
  
All intellectual property rights in the material on this site are owned by the ViiV Healthcare group of companies, or they have been granted permission to use such material except where specifically stated otherwise. Reproduction of part or all of the contents in any form is prohibited other than in accordance with the following permissions. 
  
You may read, view, print, download and copy the material on this website for your personal and non-commercial use, but only if you acknowledge the website as the source of the material and include the copyright statement “© ViiV Healthcare group of companies, all rights reserved”.  Unless specifically indicated, no other use of the material is permitted. 
  
Nothing contained in this website should be construed as conferring any licence or right under any intellectual property (including patents, trade marks and copyright) of the ViiV Healthcare group of companies or any third party. 
  
ViiV Healthcare ULC claims no ownership in, nor any affiliation with, any third-party trademarks appearing on this website. Such third-party trademarks are used only to identify the products and services of their respective owners, and no sponsorship or endorsement on the part of ViiV Healthcare ULC should be inferred from the use of these marks. 
  
 
Use of Information 
  
Communications from users or other material sent through the internet, posted on a ViiV Healthcare ULC website or otherwise (other than those containing personal and/or health-related information, which fall within ViiV Healthcare ULC’s Privacy Statement (see link below)) are deemed to be non-confidential and non-proprietary, and ViiV Healthcare ULC shall have no obligation of any kind with respect to such information.  ViiV Healthcare ULC shall be free to use this information for any purpose it deems appropriate, including reproduction and publication, and may use any ideas, concepts, know-how or techniques contained in such information for any purpose whatsoever, including commercial purposes, without paying users for the right to do so. 
  
  
Privacy 
  
ViiV Healthcare ULC respects the privacy of its website visitors. Please refer to ViiV Healthcare ULC’s Privacy Statement (see link below) for an explanation of your rights and responsibilities with respect to the information that is disclosed on this website. 
  
 
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</div><pd4ml-page-break><div class="container_title"><h1>Privacy Statement</h1></div><div class="container_content"> 
Updated:  1 July 2015 
 
This Privacy Statement sets out how ViiV Healthcare ULC uses and protects any information that you give to us.  We respect your privacy and are committed to protecting your personal information.  This Privacy Statement explains how we collect, transfer, process, use and disclose your data and sets out our security practices. 
By providing us with your personal information, you agree and consent to its transfer, processing, use and disclosure as outlined in this Privacy Statement. 
Information about the operator of websites or mobile applications (and ViiV Healthcare ULC entity controlling any PII that is collected) can be found on the footer and/or contact page of websites and in the licensing agreement of mobile applications. 
What we collect 
We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual.  We only do this when you have agreed to our request for that information.  This PII may include your:
<ul>
	<li>name</li>
	<li>address</li>
	<li>telephone number</li>
	<li>e-mail address</li>
</ul>
How we use your PII 
By providing your PII, you agree that, where it is permitted by local law or where you have agreed to receiving these communications from us, we may use the information:

<ul>
	<li>to respond to your requests</li>
	<li>to improve our level of service</li>
	<li>to improve the content of our communications</li>
	<li>to provide you with tips, helpful information, product news and updates</li>
	<li>to notify you of our new products and services</li>
	<li>to seek your views on our products and services</li>
	<li>to consider your application for employment</li>
	<li>for our own administrative and quality assurance purposes</li>
	<li>for other purposes that may be detailed on the website or mobile application</li>
</ul>
Website and mobile application usage information 
We also automatically collect information about your computer browser type and operating system, websites you visited before and after visiting our websites, standard server log information, Internet Protocol (IP) addresses, GPS location data, mobile phone service provider, and mobile phone operating system.  We aggregate this information to understand how our visitors use our websites and mobile applications so that we can improve them and the services we offer.  GPS location data does not typically identify individual users.  We may also share this aggregated information with other companies within the ViiV Healthcare ULC group and with other third parties.  This information includes:

<ul>
	<li>the total number of visits to our websites and mobile applications</li>
	<li>the number of visitors to each page of our websites and mobile applications</li>
	<li>the domain names of our visitors' internet service providers.</li>
</ul>
How we protect your PII 
ViiV Healthcare ULC will take appropriate legal, organizational, and technical measures to protect your personal information consistent with applicable privacy and data security laws.  When ViiV Healthcare ULC uses a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information.  We use a variety of security technologies and procedures to help protect your PII from unauthorised access, use or disclosure.  Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure.  Although we will do our best to protect your PII, we cannot guarantee the security of the PII you transmit to our websites or mobile applications:  any transmission is at your own risk.  While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to prevent such unfortunate occurrences. 
Sharing PII with third parties 
We may share your PII with our affiliates, contractors and agents in the normal course of business for delivery of the activities to which you have agreed.  Unless otherwise specified in the website or mobile application, we will not sell or rent PII to other third parties, except that your PII may be transfered to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred.  Sometimes we use selected third parties to provide support services in connection with our websites, mobile applications or in the normal course of business.  These parties may, from time to time, have access to your information to enable them to provide those services to us.  We require all companies providing such support services to meet the same standards of data protection as our own.  They are prohibited from using the information for their own purposes.  In particular, we do not allow service providers to use your PII for their own marketing activities. 
When we may disclose your PII to others 
ViiV Healthcare ULC reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law.  In certain special cases where permitted by local law, we may disclose your PII:

<ul>
	<li>when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with ViiV Healthcare ULC's rights, property or operations, other users of this website or mobile application or anyone else who could be harmed by such activities</li>
	<li>when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation</li>
	<li>in connection with a substantial corporate transaction, such as the sale of a product line or division, a merger, consolidation, asset sale or in the unlikely event of bankruptcy.</li>
</ul>
PII collected may be transferred to, stored and processed in your country of residence or any other country in which ViiV Healthcare ULC (including its affiliates), subcontractors or agents maintain facilities, including the United States and countries outside the European Economic Area (EEA).  This means that your information may be processed in countries with lower data protection standards than your country of residence.  By using our websites and mobile applications, you consent to any transfer, processing or storing of information outside of your country of residence and outside the EEA.  We will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this Privacy Statement. 
Use of IP addresses 
An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organisation's local area network (LAN) or wide area network (WAN).  Web servers automatically identify your computer by the IP address assigned to it during your session online. 
ViiV Healthcare ULC, or third party companies acting on our behalf, may collect IP addresses for the purposes of systems administration and to audit the use of our websites.  We also may use IP addresses to identify users of our websites when we feel it is necessary to enforce compliance with the websites’ terms of use or to protect our service, websites or other users. 
Cookies 
Our websites and mobile applications may use technology called "cookies."  A cookie is a small text file that is placed on your hard disk by a server.  Cookies allow our websites and mobile applications to respond to you as an individual.  The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.  For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to a website. 
You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer.  Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences. 
If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit.  For additional information regarding our use of cookies, review our global Cookie Policy (see link below) 
Information from outside sources 
Where permitted by local law, we may also collect legally obtained information from third parties to add to our existing user databases.  Some of this information may be PII.  We do this to better target information offerings and promotional campaigns in which we think you would be interested.  Such PII will only be collected and used by us in accordance with the basis on which it was originally provided by the subject, or as otherwise permitted by local law. 
Access 
We will retain your information only for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.  You may contact us in writing to request the updating, correcting or removal of PII that you have provided to us at any time using the contact information provided at the end of this Privacy Statement.  Your local laws may also give you the right to access information that you have provided to us.  In some countries, you may need to pay a reasonable fee to meet our costs in providing you with this information. 
Links to other websites 
Our websites and mobile applications may from time to time provide links to or embed third party websites.  This Privacy Statement does not apply to those websites.  If you choose to enter such a linked site, you agree that we are not responsible for the availability of such websites and do not review or endorse and shall not be liable, directly or indirectly, for:

<ul>
	<li>how these websites treat your PII</li>
	<li>the content of such websites</li>
	<li>the use that others make of these websites.</li>
</ul>
Please ensure you check the legal and privacy statements posted on each website or mobile application you access before entering any PII. 
Use of our websites and mobile applications by children 
Unless otherwise explicitly stated, websites and mobile applications on which this Privacy Statement appears are not intended or designed to attract children under the age of 13.  We do not knowingly collect PII from visitors in that age group via these websites or mobile applications.  On those websites or mobile applications that are intended for use by children under the age of 13, we only collect PII with the explicit consent of a parent or guardian. 
Changes 
We may occasionally update this Privacy Statement.  If the changes we make are material, we also may post a notice regarding the changes on our websites or mobile applications and related licensing agreements.  We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the PII we collect.  Your continued use of our websites and mobile applications constitutes your agreement to the Privacy Statement and any updates.  Subsequent changes in this Privacy Statement will not apply to data that were collected before the change is made. 
This Privacy Statement was last updated on 1 July 2015. 
Contact us                                                                                                                                                                
Please address any questions, comments and requests regarding this Privacy Statement in writing to: 
Privacy Officer 
GlaxoSmithKline Inc., 
7333 Mississauga Road, 
Mississauga, Ontario L5N 6L4 
If you contact us, please note the name of the websites you have visited, as well as how we may contact you. 
 </div><pd4ml-page-break><div class="container_title"><h1>Cookie Policy</h1></div><div class="container_content"><div>
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<div>Updated 1 July 2015 
ViiV Healthcare ULC uses cookies to improve the experience for visitors to our websites, including websites that can be accessed through our mobile applications, and has published this Cookie Policy.  It explains what cookies are and how we use them on our websites.  If you don’t want to receive cookies while browsing our website, you can modify your browser and/or mobile device settings so that it notifies you when receiving cookies or you can choose to restrict or block cookies. 
 
Cookies are tiny files, composed of a string of letters and numbers, placed on your computer by web page servers. They enable the website owner to distinguish you from other users of the website.  Cookies cannot be executed as code or used to deliver viruses and they cannot enable us to access your hard drive. We cannot read any information on your hard drive even if we store cookies there.   
 
The data generated through cookies on ViiV Healthcare ULC websites can be used for various purposes including the following: 
 
Strictly necessary 
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website and saving items to a shopping basket. 
 
Performance 
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often and if they receive error messages. They are used to improve how a website works in future versions. 
 
Functionality 
These cookies allow the website to remember choices you make such as user name, language or region you are in and provide a more enhanced personal experience.    
 
Targeting or advertising 
These cookies are used to deliver content more relevant to you and your interests. 
 
We don’t permit any third parties to advertise on our website but we cannot control advertisers that are allowed by internet service providers to advertise whilst you are browsing on the internet. 
 
ViiV Healthcare ULC is required by law to obtain your consent for all types of cookies that we place other than those that are “strictly necessary”.  
 
You can learn more about how to manage your cookies by visiting the Help function of your browser, the settings of your mobile device or you can visit <a href="http://www.aboutcookies.org/">www.aboutcookies.org</a> which provides detailed information on managing cookies on popular browsers.  Please be aware that parts of our websites may not function correctly if you disable cookies. 
  
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