COOKIES POLICY

[***INTERNAL NOTE. Two types of policies are set out in this document. The first one corresponds to technical cookies, i.e. when the website only hosts cookies that are strictly necessary for the operation of the website, as well as to preserve the preferences[1] expressed by users and that do not collect personal data, which may be own or third parties cookies.

In this context, the Authorities interpret the following cookies as strictly necessary:

    – “User login” cookies[2].

    – User authentication or identification cookies[3].

    – User security cookies[4].

    – Media player session cookies.

    – Session cookies for load balancing.

    – User interface customisation cookies.

– Certain plug-in cookies for social content sharing[5].

Thus, the Authorities provide that these cookies may be understood to be excluded from the scope of application of article 22.2 of the LSSI, and, therefore, it would not be necessary to inform or obtain consent for their use. Therefore, for reasons of transparency, it is recommended that information be provided, at least on a generic basis, on those cookies excluded from the scope of application of Article 22.2 of the LSSI.

In any case, it should be noted that the same cookie may have more than one purpose (multi-purpose cookies), so there is a possibility that a cookie may be exempted from the scope of application of article 22.2 of the LSSI for one or more of its purposes and not for others, the latter being subject to the scope of application of said provision. In relation to cookie management or configuration systems, when multi-purpose cookies are used for two or more purposes not exempted from the scope of application of article 22.2 LSSI, it must be guaranteed that these cookies are only used if all the purposes they group together are accepted, unless the management system used allows the different purposes to be treated differently, so that if the user accepts one of its purposes and not others, the cookie will only operate for the accepted purpose.

On the other hand, a policy is set out for when the web portal has implemented necessary cookies, referred to above, and non-necessary cookies (for example, analytical, statistical, etc.), which may also be own or third-party cookies. With regard to non-necessary cookies, it should be noted that they are included within the scope of application of article 22.2 LSSI. For these purposes, in order to use this type of cookies and, therefore, to be able to store and retrieve data, it will be necessary to obtain the consent of the users, after having provided them with clear and complete information on their use, in particular, on the purposes of data processing, in accordance with the provisions of the personal data protection regulations.

Taking into account all the above information, a choice will have to be made between one policy and another, depending on the cookies actually installed on the website in question.

[1] in order for these cookies to be considered exempt, their use must be limited to what is necessary for their purpose, and the information that can be derived from the user’s selection may not be used for other purposes (e.g. for personalisation of advertising content) or for user profiling.

[2] Session and user login cookies are typically used to track user actions when filling in online forms on various pages, or as a shopping basket to keep track of the items the user has selected by clicking a button.

[3] Session only.

[4] For example, cookies used to detect repeated and erroneous attempts to connect to a website.

[5] The exception only applies to users who have chosen to keep the session open.