Privacy Policy
  1. Consent. The GDPR sets forth very strict rules on obtaining consent from “data subjects” (e.g., online users, customers).  We are no longer able to rely on default consent or disclaimers stating “by using our services and/or using our website you are accepting the terms of this Privacy Policy and consenting to the terms and conditions herein.” Accordingly, I recommend the Joslyn website include an affirmative consent mechanism (ideally something that would include the link to the Privacy Policy) requiring consent before anyone may enter any Personal Data (such as their name, email address, or contact information) into the website. The consent box could state the following:

You are about to provide us with your personal information. Please review our Privacy Policy here on how we collect, use, and retain personal information. By clicking “Accept,” you (1) agree to the manner in which we process your personal information, as described in our Privacy Policy, and (2) confirm that you are at least eighteen years (18) of age.

  1. Cookies. If the Joslyn website collects cookie information, then I recommend (similar to above) that it includes an automatic pop-up notifying visitors that the site is using cookies and/or other automated data collection technologies; the pop-up should include a link to the Privacy Policy (which has a section on cookies), and require the user to accept its use. The cookie notification can read something similar to the following:

We use cookies to help our website work more effectively and efficiently, and to align our services and advertisements to your needs. You can read has we collect and retain cookie information in our Privacy Policy here. By clicking “Accept,” you agree to us using cookies in the manner described in our Privacy Policy.

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