This policy sets out what is stored on a visitor’s device by builtbywinters.ie. It should be read together with the Privacy Policy, which describes how personal data is handled more generally.
1. Cookies
This website sets no cookies of its own. Cookies are set by two measurement services, and only after the notice at the foot of the page has been accepted. Nothing is set before that, and nothing is set if the notice is declined.
The services are Google Analytics and Google Ads conversion measurement, both provided by Google Ireland Limited. They tell us how many people visit, which pages they read, and which advertisement led to an enquiry. The cookies they set are:
| Name | Purpose | Expires |
|---|---|---|
_ga | Distinguishes one visitor from another | 2 years |
_ga_<id> | Holds the state of the current visit | 2 years |
_gcl_au | Records which advertisement led to an enquiry | 90 days |
These are set on the basis of consent under Article 6(1)(a) GDPR and Regulation 5 of S.I. No. 336 of 2011, and are not set at all in its absence. Advertising personalisation is switched off. Consent can be withdrawn at any time using the control further down this page, which stops the counting and applies from the moment it is used.
Google Ireland Limited processes this data as a controller in its own right for these services, and may transfer it outside the European Economic Area under the standard contractual clauses and the EU–US Data Privacy Framework. Its own terms govern what it does with it.
Visitor measurement is provided by Vercel Web Analytics (Vercel Inc.) and is carried out only where the visitor has accepted it in the notice at the foot of the page. It is withheld entirely until that acceptance is given, and it stops if the acceptance is withdrawn. It records page views. It writes nothing to the device — no cookie, no local-storage entry, no session-storage entry — and reads nothing from the device. It is therefore incapable of recognising a returning visitor from anything held on the device.
The visitor’s IP address and browser type are processed in transit by the provider to derive a hash that changes daily, which is what distinguishes one visitor from another within a single day. That hash is not retained as an identifier and is not linked to any other data held. The page address and the referring address are transmitted with each page view, with every query-string parameter stripped before transmission other than utm_source, utm_medium and utm_campaign.
It is carried out on the basis of consent under Article 6(1)(a) GDPR, and is not performed at all in its absence.
Conversion measurement tells us that an enquiry followed an advertisement. It is not used to build a profile of the visitor, and no session-replay or heat-map tooling is used.
Where a third-party service is embedded in a page — a map, a video player or similar — that service may set cookies in its own context. No such embed is present on this site at the date of this policy. Web fonts are requested from a third-party font service, which receives the visitor’s IP address in order to serve the font files and does not set cookies in doing so.
Information is instead stored using the browser’s own local storage and session storage. Regulation 5 of the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336 of 2011) applies to storing or accessing information on a device whether or not a cookie is used, so what is stored is described below with the basis on which it is stored.
2. What is stored
Separately from the cookies above, two things are stored by the browser itself. Nothing is stored at all unless the notice at the foot of the page is answered or the chat window is opened.
The choice made about page-view counting.When the notice is answered, one entry is written to local storage recording the choice, the version of this policy at the time, and when it was made. Local storage persists until it is cleared. It is not sent anywhere and is not used to identify or measure visitors. It is strictly necessary to provide a service explicitly requested by the user — remembering the answer given, so the question is not put again — and is exempt from the consent requirement under Regulation 5(5). Clearing it does not turn counting on. A cleared choice is treated as no choice, so the notice is asked again and nothing is counted until it is answered.
The chat conversation, if the chat window is used. Session storage holds the messages exchanged, the point the conversation has reached, any contact details entered so that a part-completed enquiry is not lost, and whether the opening message and the chat notice have already been shown. Session storage is confined to the browser tab it was created in and is erased by the browser when that tab is closed. Contact details entered into the chat window are personal data; the rest is not. These entries are strictly necessary to provide the chat conversation the user has opened, and are exempt from the consent requirement under Regulation 5(5).
The precise names and contents of these entries are available on request to the address at the foot of this page.
Your current choice about page-view counting: Loading.
3. How to remove what is stored
Everything held by the chat window is erased automatically when the browser tab is closed. Nothing further is required to clear it.
The cookies listed in section 1 are removed by declining the notice, by using the control above to withdraw consent, or by clearing site data in the browser. They are not set again unless the notice is accepted again.
The entry recording the choice about page-view counting persists until site data is cleared. On a phone or a computer, open the browser settings, find the site settings or privacy section, select builtbywinters.ie, and choose to clear or delete the data stored for it. The notice will then be asked again on the next visit, and nothing is counted in the meantime. Using a private or incognito window has the same effect, as nothing is retained after the window is closed.
4. Changes
If advertising, or any storage or measurement not described above, is added to this site, this page and the notice at the foot of the site will be updated before it takes effect.
Data Controller: Ciarán Winters trading as Built by Winters (sole trader), Co. Wicklow, Ireland. ciaran@builtbywinters.ie.