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:
Service providers may use data storage and retrieval devices on recipients’ terminal equipment, provided that the recipients have given their consent after having been provided with clear and complete information on their use, in particular, on the purposes of data processing, in accordance with the provisions of Organic 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 with their configuration during their installation or update through 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 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 is applicable 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. The cookie is one of those devices of generalized use so, from now on, 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:
TYPES OF COOKIES AND THEIR PURPOSE
A cookie is a file that is downloaded to your computer, which allows a website, among other things, to store and retrieve information about the browsing habits of a user or their equipment 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 Spanish Data Protection Agency, depending on the purpose for which the data obtained through cookies are processed, there are different types:
Technical Cookies: These are those that allow the user to navigate through a website, platform or application and the use of the different options or services it exist as, for example, control traffic and data communication, identify the session, access parts of restricted access, 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.
Personalization Cookies: These are those that 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 you access the service, the locale from which you access the service, etc..
Analysis Cookies: These are those that allow the person responsible for them, monitoring and analyzing 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 data on the use made by the users of the service.
Advertising Cookies: These are those that allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the publisher has included on a website, application or platform from which it provides the requested service based on criteria such as the edited content or the frequency at which the ads are displayed.
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 web page, 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.
INFORMATION PRINCIPLE
The information obtained through the cookies installed on your computer will be used for the following purposes:
To guarantee the quality, safety and improvement of the services offered.
The recipients of the information obtained through the cookies installed on your computer will be the following entities:
Our entity as the publisher responsible for the website and responsible for the treatment.
The following entities, directly related to our entity (if applicable): GOOGLE (we use Google Adwords or Google Analytics).
PRINCIPLE OF CONSENT
Your consent to the installation of cookies is made by checking the “ACCEPT” box included in our pop-up window and extended information about Cookies is shown in this Cookie Policy.
INSTALLATION OF COOKIES
Although the acceptance of the installation of cookies on your computer is your decision, the refusal to install them may mean that the functionality of the website is limited or not possible, which would make it impossible for our company to provide services through it.
DISABLING COOKIES
You can at any time block, disable or change the configuration of cookies installed on your computer. For this purpose, we provide you with the way to do it in the main browsers:
CHROME: https://support.google.com/chrome/answer/95647?hl=es
EXPLORER: http://windows.microsoft.com/es-es/windows-vista/Block-or-allow-cookies
FIREFOX: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we
SAFARI: http://www.apple.com/es/privacy/use-of-cookies/
As well as cookies to third parties Google AdWords:
Our entity is not responsible for the content and accuracy of the cookie policies of the above third parties.
SECURITY OF YOUR DATA
We will protect your data with effective security measures based on the risks associated with the use of your information.
To this end, our entity has approved a Data Protection Policy and annual controls and audits are carried out to verify that your personal data is secure at all times.
WHERE CAN YOU FILE A COMPLAINT?
Did you know that we have a data protection officer to whom you can send all your complaints, doubts and suggestions about the use of your personal information?
Contact telephone number: 651 826 636
Contact e-mail address: info@zenitclinic.com
Website: https://zenitclinic.com
Spanish Data Protection Agency
C/ Jorge Juan, 6
28001-Madrid
By telephone:
Tel. 901 100 099
Tel. 91 266 35 17
Filing a complaint with the Spanish Data Protection Agency does not entail any cost and the assistance of a lawyer or solicitor is not required.