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Cookies

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  1. APPLICABLE REGULATIONS

Article 22, section two, of Law 34/2002 of July 11, on Information Society Services and Electronic Commerce (hereinafter, LSSI-CE), establishes the following:

Service providers may use data storage and retrieval devices on recipients’ terminal equipment, provided that the recipients have given their consent after being provided with clear and complete information on their use, in particular, regarding the purposes of the data processing, in accordance with the provisions of Organic Law 15/1999 of December 13, on the Protection of Personal Data.

Where technically possible and effective, the recipient’s consent to accept the processing of data may be provided through the appropriate settings of the browser or other applications, provided that the recipient must configure them during installation or updating through an express action for that purpose.

The above shall not prevent possible storage or access of a technical nature for the sole purpose of carrying out the transmission of a communication over an electronic communications network or, to the extent strictly necessary, for the provision of an information society service expressly requested by the recipient.

According to the “Guide on the Use of Cookies,” published by the Spanish Data Protection Agency (hereinafter, AEPD) in 2013, the LSSI-CE applies to any type of file or device that is downloaded to a user’s terminal equipment for the purpose of storing data that may be updated and retrieved by the entity responsible for its installation. Cookies are one of these commonly used devices; therefore, from now on we will generically refer to these devices as cookies.

The following types of cookies are exempt from complying with the obligations set out in Article 22.2 of the LSSI-CE:

  • Cookies that only allow communication between the user’s device and the network.

  • Cookies that are strictly necessary to provide a service expressly requested by the user.

  1. TYPES OF COOKIES ACCORDING TO THEIR PURPOSE

A cookie is a file that is downloaded to your device when you access certain web pages. Among other things, cookies allow a website to store and retrieve information about a user's or device’s browsing habits and, depending on the information they contain and how the device is used, can be used to recognize the user.

As stated in the AEPD’s “Guide on the Use of Cookies,” depending on the purpose for which the data obtained through cookies are processed, we can distinguish between:

  • Technical cookies: These allow the user to browse a website, platform, or application and use the different options or services available, such as controlling traffic and data communication, identifying the session, accessing restricted areas, remembering the items in an order, carrying out the purchase process, submitting a registration or participation request for an event, using security elements while browsing, storing content for video or audio playback, or sharing content via social media.

  • Personalization cookies: These allow the user to access the service with certain predefined general features based on a set of criteria on the user’s terminal, such as language, the type of browser used to access the service, regional configuration from which the service is accessed, etc.

  • Analytics cookies: These allow the party responsible for them to track and analyze the behavior of users on the websites to which they are linked. The information collected through this type of cookie is used to measure activity on websites, applications, or platforms and to create browsing profiles of users of said sites, applications, and platforms, in order to introduce improvements based on the analysis of data on how users use the service.

  • Advertising cookies: These allow the most efficient management possible of advertising spaces which, where appropriate, the publisher has included on a webpage, application, or platform from which the requested service is provided, based on criteria such as the published content or the frequency with which the ads are shown.

  • Behavioral advertising cookies: These allow the most efficient management possible of advertising spaces which, where appropriate, the publisher has included on a webpage, application, or platform from which the requested service is provided. These cookies store information about users’ behavior obtained through the continuous observation of their browsing habits, allowing the creation of a specific profile to display advertising based on that profile.

  1. DUTY TO INFORM

In compliance with Article 5 of Organic Law 15/1999 of December 13, on the Protection of Personal Data (hereinafter, LOPD), we expressly, precisely, and unequivocally inform you that the information obtained through the cookies installed on your device will be used for the following purposes:

  • Technical cookies: These allow the user to browse a website, platform, or application and use the different options or services available.

  • Third-party cookies: These allow the party responsible for them to track and analyze the behavior of users on the websites to which they are linked.

The recipients of the information obtained through the cookies installed on your device will be the following entities:

  • The publisher responsible for the website and controller of the processing: B. Penélope Boñar.

  1. PRINCIPLE OF CONSENT

Consent for the installation of cookies will be understood as given by ticking the checkbox relating to the acceptance of the “Cookie Policy” made available for that purpose on our website.

In cases where the user does not expressly state whether they accept the installation of cookies but continues to use the website or application, it will be understood that they have given their consent. Our entity expressly informs you of the possibility of blocking or deleting the cookies installed on your device by configuring the browser options installed on your computer.

  1. OPTIONAL NATURE OF COOKIE INSTALLATION

Although accepting the installation of cookies on your device is optional for you, refusing their installation may mean that the functionality of the website is limited or not possible, which would make it impossible for our entity to provide services through it.

  1. SOCIAL MEDIA

We use social media as a channel of communication and promotion of our products and services. Under no circumstances will we use the data for purposes that are not permitted.

This company is not responsible for the content, comments, opinions, or information — whether its own or from third parties — that users publish on our accounts on Facebook, Twitter, etc.

You may use our content for lawful purposes, provided that you mention its source or author.

Please note that the use of social media is subject to the privacy policies of each platform. To learn more:

  1. DISABLING COOKIES

The user may change cookie settings, block them, or disable them at any time. Below we provide instructions for the main browsers:

As well as for third-party cookies:

B. Penélope Boñar is not responsible for the content or accuracy of third-party cookie policies.

  1. CONSEQUENCES OF DISABLING COOKIES

Changes in cookie usage may cause part or all of the website’s functionalities to stop working.

  1. RIGHTS

As a data subject, you are entitled to exercise the following rights:

– Right of ACCESS to your personal data.
– Right to request the RECTIFICATION of inaccurate data.
– Right to request the ERASURE of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
– In certain circumstances, you may request the RESTRICTION OF PROCESSING of your data, in which case we will only keep them for the exercise or defense of legal claims.
– In certain circumstances and for reasons related to your particular situation, you may exercise your right to OBJECT to the processing of your data. We will stop processing the data unless there are compelling legitimate grounds, or for the exercise or defense of possible claims.
– In certain circumstances and for reasons related to your particular situation, you may request your right to DATA PORTABILITY. This is a complementary right to the right of access, as it allows you to obtain the data you have provided to us in a structured, commonly used, machine-readable format, and to have them transmitted directly to another entity at the request of the data subject.

You may exercise these rights, in addition to the technical solutions described above, by submitting a request by any means that provides proof of its submission and receipt, clearly expressing your intention in this regard and, where appropriate, attaching a copy of your ID card and/or any other document proving your identity. You may address this request to the email address:
manuel.companioni@asereconsulting.com
or by post to:
Avda/ Mesa y López, 46 3D, 35007 – Las Palmas de GC.

Furthermore, if you believe that any of your rights have been violated, as a data subject you are entitled to file a claim with the Spanish Data Protection Agency (AEPD), located at C/ Jorge Juan, 6, 28001 – Madrid https://www.aepd.es/ or through the AEPD’s electronic office: https://sedeagpd.gob.es/sede-electronica-web/.