This Cookie Policy is an integral part of the legal texts and the Privacy Policy of the website www.weset.io y www.weset.app (hereinafter, respectively the “Website“) owned by Weset Corporation (hereinafter “WESET“) with C.I.F. B-16989006, with registered office at British Virgin Islands and e-mail address ([email protected]) for privacy purposes.

Accessing and browsing the Website, as well as the acceptance of the banner corresponding to the cookies and their configuration imply acceptance of the terms and conditions set out in this Cookies Policy. 

In order to facilitate browsing the Website, WESET uses cookies or other files with similar functionality (hereinafter, “Cookies”).

In any case, we inform you that WESET is responsible for these Cookies and the processing of the data obtained through them, deciding on the purpose, content and use of the processing of the information collected. Furthermore, the Website does not install our Cookies on Users’ devices until they have accepted their installation.

1. What is a Cookie?

Cookies are files containing small amounts of information that are downloaded to the user’s device when visiting a website, associated only with an anonymous user and their device, and sometimes provide evidence that allows access to the user’s personal data.

Cookies are essential for the functioning of the Internet, their main purpose is to recognise the user each time they access the Website, allowing, in addition to improving the quality, to offer a better use of both environments, personalising the services offered therein and offering the User information that is of interest to him/her or that may be of interest to him/her, according to the use they make of them. In any case, the User may access the configuration of their browser to modify and/or block the installation of the Cookies sent from the Website, without this preventing access to the contents.

1. Use of Cookies by WESET

Users expressly authorise the use of this information for the purposes indicated, through the channels provided for this purpose on the Website, without prejudice to their right to reject, disable or configure the use of Cookies. If Cookies are deactivated or rejected, browsing the Website may not be optimal and some of the available utilities may not work correctly.

Specifically, WESET is using Cookies for the purposes set out below. If in the future WESET uses other Cookies for the purpose of providing more and better services, the user will be informed of this.

The installation of these Cookies in the user’s device will always take place after the collection of consent and/or configuration of these.

This Cookies Policy provides general information on all the Cookies used on the Website. However, for information purposes for the User, Cookies that are necessary for the operation of the Website will be enabled by default, and may be, where appropriate, disabled and rejected by the user, always in compliance with current regulations.

1. Types and purposes of the cookies used

The Website uses its own and third-party cookies. Depending on the entity that manages the data obtained through the cookies, they are grouped as follows: 

• Own: Those that are sent to the manager providing the service requested by the user.

• Third-party: These are not managed by the manager, but by a third party that manages the data obtained through the Cookies.

Depending on their permanence:

• Session cookies: theseremain during access and browsing on the site and are deleted once the user leaves the website.

• Permanent: They remain stored in the terminal and can be accessed and processed for a period of time defined by the controller of the Cookies.

1. Cookies used on the website 

The cookies used by WESET are own and third party cookies. 

1. Necessary Cookies

These cookies are considered essential for browsing in both environments, as they enable the user to use their features or tools, such as, for example, identifying the session, accessing restricted access areas, guaranteeing browsing security. Without these cookies, the aforementioned functions would be disabled. 

In this sense, WESET. uses these own cookies for the following purposes: 

• Identify the user’s session in order to keep it active during browsing.
• Identify the user’s session to prevent possible attacks and request forgery.
• Identify the user’s cookie settings.
• Identify the server used by the user.
• Web firewall security settings.
• Verify the connection with the servers (in these cases these cookies may be from third parties, but they will always have the purpose described).
• Optimise web response time with the cache function.

The necessary cookies used by WESET are as follows:

COOKIES	HOLDER	PURPOSE	EXPIRY DATE
Active Campaign (marketing automation)	www.weset.io	Allows the User to register and access the Website, in a secure manner, through their own Google account.	2-5 years

4.2 Analytical cookies

These cookies are used to analyse the user’s browsing of the Website, as well as to keep an account of these. Some of these cookies identify the user, while others only use aggregate data.

WESET, through the Website, uses third-party Cookies for the security of both environments and at an analytical level. Specifically, these Cookies are:

COOKIES	HOLDER	PURPOSE	EXPIRY DATE
_ga	Google Analytics	It records a unique identifier for each visitor to the website. This identifier is used to obtain statistical data on the visitor’s use of the website.	2 years
_gat	Google Analytics	Used by Google Analytics to accelerate the rate of requests on the website.	1 day
_gid	Google Analytics	It records a unique identifier for each visitor to the website. This identifier is used to obtain statistical data on the visitor’s use of the website.	1 day

4.3 Marketing cookies

Marketing cookies are used to track users browsing websites. The intention is to display advertisements that are relevant to users and therefore more valuable to third party advertisers.

COOKIES	HOLDER	PURPOSE	EXPIRY DATE
_fbp	Facebook	Used by Facebook to deliver advertising content and other information from third-party advertisers, in real time, that may be relevant to Users.	3 months
NID	Facebook	Records a unique ID that identifies a returning user’s device. The ID is used for personalised advertisements.	6 months
oauth2_cs	Google	Unclassified	Session
tr	Facebook	Used by Facebook to deliver advertising content and other information from third-party advertisers, in real time, that may be relevant to Users.	Session

1. User settings to prevent Cookies

In compliance with current regulations, the user can configure the installation of Cookies on the Website or on the specifically enabled channels. By means of this tool, the User can accept all Cookies, reject all of them (if applicable, those that are not necessary for the operation of the website) or gradually configure them. 

Similarly, WESET makes available to users of the Website the information that allows them to configure their Internet browser/browsers to maintain their privacy and security in relation to Cookies. Therefore, information and links to the official support sites of the main browsers are provided so that each user can decide whether or not to accept the use of Cookies.

Thus, it is possible to block Cookies through the configuration tools of the browser, or each user can configure their browser to warn them when a server wants to save a Cookie:

• If you use Microsoft Internet Explorer, you will find the option in the menu Tools > Internet Options > Privacy > Settings. To find out more visit this link: http://windows.microsoft.com/es-es/windows-vista/block-or-allow-Cookies and http://windows.microsoft.com/es-es/windows7/how-to-manage-Cookies-in-internet-explorer-9.

• If you use Firefox, you will find the option in the menu Tools > Options > Privacy > Cookies. To find out more visit this link: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-Cookies-que-los-sitios-we.

• If you use Chrome, in the Options > Advanced Options> Privacy. To learn more visit this link: https://support.google.com/accounts/answer/61416?hl=es

• If you use Opera, in the Security and Privacy option, you can configure the browser. To find out more visit: this link: http://help.opera.com/Windows/11.50/es-ES/cookies.html

• If you use Safari you will find the option in the Preferences/Privacy menu. To find out more visit: this link: http://support.apple.com/kb/HT1677?viewlocale=es_ES

• If you use Microsoft Edge, under Settings & More > Settings > Privacy, search and services. To learn more visit this link: https://support.microsoft.com/search/results?query=cookies+Microsoft+Edge&isEnrichedQuery=true

6.- Information in relation to your data 

In order to exercise any of your data protection rights, as well as to know the (i) Purposes of the processing and legal basis of the processing; (ii) Recipients or categories of recipients of the personal data; (iii) International transfers; (iv) Storage; (v) Rights of the data subjects; (vi) Existence of automated decisions, including profiling, you can access WESET’s Privacy Policy.

7.- Modifications to the Cookies Policy

This Cookies Policy may be modified according to legislative or regulatory requirements, or in order to adapt this policy to the instructions issued by the Spanish Data Protection Agency. Therefore, users are advised to visit it periodically. When significant changes are made to this Cookies Policy, they will be communicated to users by e-mail.

2022 © All rights reserved. WESET

Last updated: 06 September 2022.

PRESENTATION OF COOKIES POLICY

A banner should be presented containing the Cookies Notice and also the option to configure them, that is, to allow their acceptance or rejection separately. This banner must be visible on the user’s screen, even if the user scrolls, or navigates in different sections of the website itself.

It is advisable that the information is provided in layers, including summary information in a first layer and more detailed information in a second layer, all in accordance with the recommendations of the Spanish Data Protection Agency (“AEPD“) set out both in its new Guide on the use of Cookies, published this 28 July 2020, and in its Guide for compliance with the duty to inform.

Taking into account the above, in the first layer (the cookie banner), the following should be detailed:

1. First layer (Cookie Notice)

1. The identity of the controller;
2. A reference to the use of third party cookies if any;
3. The purpose of the cookies (specifically stating whether profiling is carried out based on user browsing and the purpose of this profiling, for example, in the case of offering personalised advertising);
4. A link to access the second layer of information, (“COOKIES POLICY”), where the rest of the information can be consulted;
5. An opt-in mechanism to close the cookie notice by implementing an “ACCEPT” button; and
6. A mechanism in which the User can configure cookies, choosing in a granular way which ones to authorise (a link to a settings panel should be included, with a text similar to the following: ” Configure or reject the use of Cookies HERE “).

Here is what the banner text should look like:

“We use our own and third-party cookies for analytical purposes and to show you advertising related to your preferences, based on a profile of your browsing habits. Click HERE for more information. You can accept all cookies by clicking the “Accept” button or configure them or refuse their use by clicking HERE“.

ACCEPT

Regarding this first layer example, it is therefore important to take into consideration that (i) it must be added as a fixed banneron the website and that (ii) cookies cannot be loaded until the user expressly accepts (by clicking on the “Accept” button ). In addition, (iii) the user must be able to withdraw their consent at any time, by accessing the Settings panel enabled in “You can accept all cookies by clicking the “Accept” button or configure them or refuse their use by clicking HERE“.

In addition, in this configuration panel, the user must be able to separately accept the enabling of cookies by category/purpose (for example, the user must be able to choose to accept analytical cookies and not behavioural advertising cookies), for example by implementing YES/NO checkboxes.

However, the maximum degree of granularity (cookie a cookie selection) should be avoided, as too much information makes decision-making difficult.

Finally, in relation to third party cookies, it is sufficient to identify them by name or by the brand name by which they are identified to the public, without including the full company name.

1. Settings Panel

The settings panel should be offered through a link inserted in the Cookies Notice or first layer of information, so that a pop-up window appears in a table (so that it is more visual) so that the user can proceed to accept / reject separately enabling groups of cookies in a granular manner depending on the different categories that you use on the platform (except for session / technical cookies (in this case they are called “necessary”), which are exempt from this duty of consent, but it is advisable to inform of their existence, as indicated in the Cookies Policy).

This should include information on the expiry of the cookie, the developer, etc., and should include a button on the panel that allows the user to reject all cookies, to respect the requirement that it should be as easy to withdraw consent as it is to give it.

For these purposes, for example, this requirement will be considered satisfied if the settings panel includes a button to save the choice of cookies made by the user, expressly specifying in the new AEPD Guide on the use of cookies that, if the user saves their choice without having selected any cookie, it will be equivalent to the rejection of all cookies.

Taking into account the above, we indicate below how the text should be included in the Settings Panel, in the case of the button to save the user’s choice of cookies:

“When you click “Save settings”, the cookie selection you have made will be saved. If you have not selected any options, pressing this button will be equivalent to rejecting all cookies”.

SAVE SETTINGS

El second layer, i.e. the text of the Cookies Policy, should detail the following:

1. Second Layer (Cookies Policy)

In the Cookies Notice banner, in addition to the settings panel specified above, a link should also be included in the “Click HERE for more information” that redirects the User to the full text of the Política de Cookies that we have included in this Dossier.