1. APPLICABLE REGULATION
    The second paragraph of article 22 of Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter, LSSI-CE), establishes the following:1. Service providers may use data storage and retrieval devices in terminal equipment of the recipients, provided that they have given their consent after having been provided with clear and complete information on their use, in particular, on the purposes of data storage, in accordance with the provisions of Law 15/1999, of December 13, 1999, on the Protection of Personal Data. Where technically possible and effective, the consent of the recipient to accept the processing of data may be provided through the use of the appropriate settings of the browser or other applications, provided that the recipient must proceed to its configuration during installation or update by an express action to that effect. The foregoing shall not prevent the 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 a service of the information society 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 is applicable to any type of file or device that is downloaded to the terminal equipment of a user in order to store data that can be updated and retrieved by the entity responsible for its installation. The cookie is one of those devices of generalized use so that, hereinafter, we will generically refer to these devices as cookies.

    Cookies used for any of the following purposes are exempt from compliance with the obligations established in article 22.2 of the LSSI-CE: Statistical and advertising data.

    • Allow only communication between the user’s equipment and the network.
    • Strictly provide a service expressly requested by the user.
  2. TYPES OF COOKIES
    A cookie is a file that is downloaded to your computer when you access certain web pages. Cookies allow a website, among other things, store and retrieve information about browsing habits of a user or your computer and, depending on the information they contain and the way you use your computer, can be used to recognize the user.
    As stated in the “Guide on the use of cookies” of the AEPD, depending on the entity that manages cookies, we can distinguish between:

    • Own cookies: those that are sent to the user’s terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
    • Third-party cookies: are those that are sent to the user’s terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through cookies.

    Also, as stated in the “Guide on the use of cookies” of the AEPD, depending on the purpose for which the data obtained through cookies are processed, we can distinguish between:

    • Technical cookies: Are those that allow the user to navigate through a website, platform or application and the use of the different options or services that exist in it as, for example, control traffic and data communication, identify the session, access restricted access parts, remember the elements that make up an order, make the buying process of an order, make the application for registration or participation in an event, use security features while browsing, store content for broadcast video or sound or share content via social networks.
    • Customization cookies: These cookies allow the user to access the service with some general characteristics predefined according to a series of criteria in the user’s terminal, such as the language, the type of browser through which the user accesses the service, the regional configuration from where the user accesses the service, etc..
    • Analysis cookies: These cookies allow the party responsible for them to monitor and analyze the behavior of users of the websites to which they are linked. The information collected through this type of cookies is used to measure the activity of the websites, application or platform and for the elaboration of browsing profiles of the users of such sites, applications and platforms, in order to introduce improvements based on the analysis of the usage data of the users of the service.
    • Advertising cookies: These cookies allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included on a web page, application or platform from which the requested service is provided based on criteria such as the edited content or the frequency at which the advertisements are shown.
    • Behavioral advertising cookies: These cookies allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the editor has included on a website, application or platform from which the requested service is provided. These cookies store information on user behavior obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on the same.

    Finally, as stated in the “Guide on the use of cookies” of the AEPD, according to the period of time they remain activated, we can distinguish between:

    • Session Cookies: are those designed to collect and store data while the user accesses a web page. They are usually used to store information that is only of interest to keep for the provision of the service requested by the user on a single occasion (for example, a list of products purchased) and disappear at the end of the session.
    • Persistent Cookies: these are those in which the data remain stored in the terminal and can be accessed and processed for a period defined by the person responsible for the cookie, which can range from a few minutes to several years.
  3. TYPES OF COOKIES USED BY ESTRATEGIAS DIGITALES 360
    Third-party cookies for analysis or measurement: They allow the monitoring and analysis of user behavior. The information collected through this type of cookies is used in the measurement of website activity (such as browser usage, number of new visitors and advertising impact), in order to introduce improvements based on the analysis of the use made by users of the site. Such as, Facebook or Google Analytics.
  4. CONSERVATION PERIOD
    The data will be retained for the time necessary to carry out the purposes for which they were collected, unless the user requests its cancellation to Estrategias Digitales 360, opposing or revoking their consent.
  5. PERSON IN CHARGE OF THE TREATMENT
    The person responsible for the file or treatment is Estrategias Digitales 360, with address for notification purposes in San Jose, Costa Rica. You can find all the information about our company in our privacy policies.
  6. PRINCIPLE OF INFORMATION: PURPOSES AND ADDRESSEES
    • PURPOSE OF COOKIES
      In compliance with the provisions of Article 5 of Law 15/1999, of December 13, 1999, on the Protection of Personal Data (hereinafter, LOPD), we inform you expressly, precisely and unequivocally that the information obtained through cookies installed on your computer will be used for the following purposes:

      • Tracking and analysis of user behavior. The information collected through this type of cookies is used in the measurement of website activity (such as browser usage, number of new visitors and advertising impact), in order to make improvements based on the analysis of how users use the site.
    • RECIPIENTS OF COOKIES
      • The editor in charge of the website and responsible for the treatment: Estrategias Digitales 360
      • If applicable, the entities directly related to the editor responsible for the website that are expressly listed below: Advertising portals and social networks.
  7. INFORMATION ABOUT ACCEPTING OR DELETING COOKIES
    • ACTIVATION OF COOKIES
      PIn order to activate the cookies it will be necessary to accept or configure them at the beginning of your session on the website.
      While the acceptance of the installation of cookies on your computer is optional for you, the refusal to install them may mean that the functionality of the website is limited or not possible, which would prevent the provision of services by our entity through the same
    • DISABLING COOKIES
      The user can at any time change the configuration of cookies, block or disable them. To do this we provide the way in the main browsers.CHROME: Disable cookies in Chrome EXPLORER: Disable cookies in Explorer FIREFOX: Disable cookies in FirefoxSAFARI: Disable cookies in Safari
      As well as cookies to third parties Google Ads: Cookies Google Ads

      Estrategias Digitales 360 is not responsible for the content and accuracy of the cookie policies of third parties.

  8. PRINCIPLE OF CONSENT
    The consent for the installation of cookies will be understood to be given through the marking of the box relating to the acceptance of the “Cookies Policy” provided for this purpose on our website. In cases where the user does not expressly state whether or not to accept the installation of cookies, but continue to use the website or the application it will be understood that he has given his consent, expressly informing our entity of the possibility of blocking or deleting cookies installed on your computer by configuring the browser options installed on your computer.
  9. COOKIE CONSENT CANCELLATION
    You may, at any time, cancel the consent given in relation to the use of cookies that you authorize us to make, for which you must delete the cookies stored on your computer or mobile device through the settings and configurations of your Internet browser. However, please note that, in most cases, deleting or disabling cookies may affect the functionality of our website and limit your access to certain areas or services offered through it.
  10. DATA SECURITY PRINCIPLE
    Estrategias Digitales 360 is committed to fulfilling its obligation of secrecy regarding personal data and its duty to protect them and take all necessary technical and organizational measures to ensure the security of personal data and avoid its alteration, loss, or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed, whether from human action or from the physical or natural environment, developed in Title VIII of Royal Decree 1720/2007, of December 21, approving the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data.
  11. USER RIGHTS
    In compliance with the provisions of the LOPD and Royal Decree 1720/2007, of December 21, approving the Regulation implementing the same, the recipient of the service may exercise, at any time, their rights of access, rectification, cancellation and opposition to the controller of the file or treatment, attaching a photocopy of your ID.Right of access. Pursuant to Article 15 RGPD, the right, to the extent indicated therein, to obtain information about the personal data concerning you that we process.Right of rectification. Pursuant to Article 16 GDPR, the right to obtain without undue delay the rectification or completion of personal data concerning you.Right of erasure or right to be forgotten. Pursuant to Article 17 RGPD, the right to obtain the deletion of personal data concerning him/her, provided that the processing is not necessary:To exercise the right to freedom of expression and information,
    To comply with a legal obligation,
    For reasons of public interest, or
    For the formulation, exercise or defense of claims.
    Right to limitation of processing. Pursuant to Article 18 RGPD, the right to obtain the limitation of the processing of your data when:

    The data subject contests the accuracy of the data,
    The processing is unlawful and you object to the deletion of the data,
    We no longer need the data, but you need them for the formulation, exercise or defense of claims, or
    You have objected to the processing pursuant to Article 21 RGPD.
    Right to object. Pursuant to Article 21 RGPD you have the right to object to the processing of personal data concerning you.

    Right to data portability. Pursuant to Article 20 RGPD, the right to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, or to request that it be transferred to another controller.

    Right to lodge a complaint with a supervisory authority. Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority. As a general rule, you can address your complaint to the supervisory authority of your usual place of residence or work or of our company’s head office.

    To exercise these rights, the user may contact Estrategias Digitales 360 by clicking on the unsubscribe link available in each commercial communication sent by Estrategias Digitales 360, or by email to [email protected]

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