Cookies Policy

1. WHAT ARE COOKIES?

Cookies and similar technologies are “data storage and retrieval devices” that can be installed or accessed on the user’s terminal equipment when navigating a website. They allow the website to recognize the user on subsequent visits, remember preferences, and collect information about browsing behavior. In particular, cookies are online identifiers that can be associated with a person and leave “traces” which, when combined with other data, can be used to create profiles and identify natural persons.

2. WEBSITE OWNER AND DATA CONTROLLER

• Corporate name: VITTORITO GROUP, S.L.

• NIF/CIF: B-88352596

• Registered office: Via de las Dos Castillas 33 Ática – Edificio 7 -1ª planta 28224 Pozuelo de Alarcón (Madrid)

• Registry registration: Registered in the Commercial Registry of Madrid, Volume 39061, Folio 47, Sheet M-693991.

• Contact email: info@bindtec.eu

• Contact telephone: 0034650839925

• Website: bindtec.eu

• Data Protection Officer: Ugo de Benedictis

• Data Protection Officer contact: info@bindtec.eu

3. LAYERED INFORMATION

Information about the use of cookies is provided through a “layered information” system, providing basic initial information and simple and immediate access to the expanded information. The controller complies with the duty of information by providing the user with basic information and indicating a means to access the remaining information easily and immediately.

• First layer: notice or banner that appears on the first visit to the website.

• Second layer: this Cookies Policy, accessible from the banner and from the footer of the website at all times.

4. TYPES OF COOKIES: CLASSIFICATION

4.1. By the entity that manages them

• First-party cookies: Sent to the user’s equipment from the domain managed by the website owner themselves.

• Third-party cookies: Sent from a computer or domain managed by a third party that processes the data obtained.

4.2. By the conservation period

• Session cookies: They are stored during the visit and deleted when the browser is closed.

• Loss or persistent cookies: The data remains stored for the period necessary for the purposes of the processing, which must be informed to the user.

4.3. By their purpose

• a) Strictly necessary or technical cookies: The use of cookies of a “technical nature” is permitted without the user’s consent when they are strictly necessary to (i) transmit a communication over an electronic communications network or (ii) provide an information society service expressly requested by the user. These cookies are essential for the operation of the website and cannot be deactivated.

• b) Preference or personalization cookies: They allow remembering information that personalizes the browsing experience (such as the language or selected region).

• c) Analytical or measurement cookies: They allow quantifying the number of users and analyzing their behavior for statistical purposes, to improve the website. The processing derived from these cookies must be transparent, with explicit purposes and conservation periods limited to what is necessary.

• d) Behavioral advertising cookies: They store information on user browsing habits to show them personalized advertising.

5. LEGAL BASIS FOR PROCESSING

The processing of personal data associated with the use of cookies will only be lawful if a legal basis concurs among those provided for in Article 6 of the GDPR, including the consent of the data subject or the legitimate interest of the controller.

• User consent (art. 6.1.a GDPR): Consent must be given through a clear, free, specific, informed, and unambiguous affirmative act; silence, pre-ticked boxes, or mere inaction do not constitute consent. This legal basis applies to analysis, preference, and behavioral advertising cookies.

• Legitimate interest of the controller (art. 6.1.f GDPR): Applicable to strictly necessary or technical cookies, the use of which is covered by the provisions of Article 22.2 of the LSSI-CE.

When cookies involve the processing of personal data and are not strictly necessary, their installation and use must be based on the user’s consent, understood as a free, specific, informed, and unambiguous expression of will, through a declaration or clear affirmative action.

If consent is requested for a plurality of purposes, it must be specifically and unambiguously stated that it is granted for all of them.

6. CONDITIONS OF CONSENT

The controller must be able to demonstrate that the data subject consented to the processing of their personal data. If consent is given in the context of a written declaration that also refers to other matters, the request for consent shall be presented in a manner that clearly distinguishes it from the other matters, in an intelligible and easily accessible form, using clear and plain language.

The data subject shall have the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof.

The execution of a contract may not be subordinated to the user consenting to processing for purposes that are not related to the maintenance, development, or control of the contractual relationship.

7. INTERNATIONAL DATA TRANSFERS

If the use of third-party cookies PT involves transfers to third countries or international organizations, the intention to carry out such transfer and the existence or absence of an adequacy decision by the European Commission, or the applicable safeguards and how to obtain a copy of them, must be informed.

In the specific case of tools such as Google Analytics, whose provider —Google LLC— is established in the United States, the transfer is covered by the EU-U.S. Data Privacy Framework, adopted by means of an Adequacy Decision of the European Commission. For other providers established outside the European Economic Area, the appropriate safeguards provided for in the GDPR (in particular, Standard Contractual Clauses) will apply.

8. HOW TO MANAGE OR DEACTIVATE COOKIES?

8.1. Through the Web preferences panel

The user can manage the use of cookies through the consent mechanism implemented on the site, based on clear and complete information, with the possibility of acceptance or denial by purposes. The user can access the cookie configuration panel at any time by clicking on the “Configure cookies” link available in the footer.

8.2. Through the browser configuration

When technically possible and effective, the user can manage consent through the browser configuration or other applications.

Below are the help links for the main browsers:

• Google Chrome: https://support.google.com/chrome/answer/95647

• Mozilla Firefox: https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias

• Safari: https://support.apple.com/es-es/guide/safari/sfri11471/mac

• Microsoft Edge: https://support.microsoft.com/es-es/microsoft-edge/eliminar-las-cookies-en-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

8.3. Google Analytics Opt-out Tool

To specifically object to Google Analytics tracking, the user can install the opt-out add-on available at: https://tools.google.com/dlpage/gaoptout.

9. USER RIGHTS

Users have the right to exercise the rights of access, rectification, erasure, objection, restriction of processing, and portability of their personal data.

The controller must inform about the means available to exercise the rights; such means must be easily accessible and the exercise cannot be denied because the user chooses a means other than the one indicated. The attention to requests for the exercise of rights will be free of charge, except for the exceptions provided for in the GDPR.

These rights can be exercised directly or through a legal or voluntary representative.

Additionally, the user has the right to withdraw their consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

To exercise any of the above rights, the user can contact:

• Email: info@bindtec.eu

• Postal address: Calle Gerardo Diego 6, Pozuelo de Alarcón, 28223, Madrid.

Likewise, the user has the right to file a complaint with the Spanish Data Protection Agency (AEPD), the competent supervisory authority: www.aepd.es.

10. MINORS

If the processing is based on consent and affects minors, it can only be founded on the minor’s consent when they are over 14 years old. In the case of minors under 14 years old, processing based on consent will only be lawful if the consent of the holder of parental authority or guardianship is obtained.

This website is not directed to minors under 14 years of age. In the event of becoming aware that a minor has provided personal data without the mandatory parental consent, it will be immediately deleted.

11. PROFILING

If cookies are used for profiling, this circumstance must be informed in the basic information provided to the user, as well as the right to object to automated individual decisions when they produce legal effects or significantly affect the user in a similar way.

In the event that this website uses cookies for behavioral advertising or profiling purposes, it will be expressly indicated and the user may object to such processing through the cookie configuration panel.

12. SECURITY

The controller applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including, where appropriate, pseudonymization and encryption of personal data, the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of systems, and the regular evaluation and verification of the effectiveness of the measures adopted.

13. UPDATES TO THIS POLICY

Information about cookies will be provided in a concise, transparent, intelligible, easily accessible form, and with clear and plain language. The website owner reserves the right to modify this Cookies Policy at any time, in particular when the cookies used, the purposes of processing, or the applicable regulations change.

When relevant changes occur, the user will be notified by means of a prominent notice on the website. It is recommended to periodically review this Policy.

14.  COOKIES USED IN THIS WEBSITE