Privacy and cookies policy

PRIVACY POLICY

Visiting our website does not imply that the user is obliged to provide any personal information. If the user provides any personal information, the data collected on this website will be used in compliance with Regulation (EU) 2019 / 679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and on the free movement (European Data Protection Regulation) and Organic Law 3 / 2018, of December 5th, regarding the protection of Personal Data Protection and Digital Rights Guarantee.

Data provided by users will be incorporated into the personal files for which SALUSEX is responsible, being kept in Spanish territory by Salusex.

Users who provide personal data, unambiguously consent their incorporation to the files, which contain data of this nature, for which SALUSEX is responsible, as well as the automated or partially automated processing thereof in order to may be used by SALUSEX, in order to manage relationships with our associates or any other third person. SALUSEX will keep people’s data, initially and once the entire relationship with the user is finished, in the case that it is determined by the Law while the conservation obligation lasts and during the limitation period of the corresponding actions.

SALUSEX is authorized by users to make use of their personal data and to carry out with them the necessary treatment for the development of their commercial activities, reserving the right to cancel all data belonging to users who do not meet the criteria for the development of its institutional and corporate activities.

If the data collected were going to be treated used for different purposes to those established initially, the person in charge will inform the interested party of such end and again people prior consent will be also required.

Data collected will not be transferred unless people’s consent is previously obtained.

SALUSEX has adopted the necessary technical and organizational measures to guarantee the security and integrity of the data, as well as to prevent their alteration, loss, treatment or unauthorized access.

Users may revoke their consent at any time (although without retroactive effects). Likewise, they can freely exercise their rights to access, rectify, cancel and oppose to their data. As well as the right of limitation of the processing and portability of their data, in accordance to the Regulation (EU) 2019 / 679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and on the free movement (European Data Protection Regulation) and Organic Law 3 / 2018, of December 5th, on Personal Data Protection and Digital Rights Guarantee.

People may exercise these rights contacting with SALUSEX at the following address Calle de L’amistat nº 5, 46021 Valencia by postal mail, with a copy of their ID or by digitally signed email, in order to prove people identity, addressed to salusex@uji.es

When data will be collected, the voluntary or mandatory nature of the responses will be indicated. The refusal to provide mandatory data will mean the non-provision of the requested service or information. Likewise, data may be provided voluntarily in order to provide the requested service or the requested information in the best way possible.

If website users have to provide their email address in order to access to some of the services or information requested, they can manifest that they do not want to receive any type of communication from SALUSEX. SALUSEX will make available to users who have previously registered to the web page the steps for unsubscribing.

 

COOKIES POLICY

As a result of the reform operated in the article 22 of Law 34 / 2002, of July 11th by Royal Decree-Law 13 / 2012, of March 30th, every information society service provider must inform visitors to the website about Cookies policy:

  • Information that should be provided.

The second section of article 22 of Law 34 / 2002 on services of the information society and electronic commerce (LSSICE) establishes that users should be provided with clear and complete information on the data storage use and retrieval devices and, in particular, on the purposes of data processing, according to the Law 3 / 2018, of December 5th, on Personal Data Protection and Digital Rights Guarantee.

Therefore, the information on cookies provided at the time of consent requesting must be enough to allow users to understand the purpose for which they were installed and to know the uses that will be given to them.

In the case of being obtained consent to use cookies, users may withdraw any previously granted consent at any time. For this purpose, the information on how to withdraw consent and remove cookies must be available for them in an accessible and permanent way.

In addition to providing the necessary information to obtain a valid consent, it is advisable to keep that information visible in the web page at any moment, and particularly the one related to the way in which cookies can be managed.

  • How that information should be displayed.

The Working Group of the 29 Article has established in its 15/2011 Resolution, two requirements, with the aim of providing suitable information. One of them related to the information quality and, the other to the accessibility and visibility of that information.

Firstly, related to the quality of the information provided, it is recommended:

Taking into account the users to which this web page is directed, and adapting the language and content to their technical level. The lower the user’s technical level of the website, the simpler the language used (avoiding understandable technical terminology) and the more complete the information offered must be, based on the most basic aspects of what cookies are and how they work. In any case, this low technical level should not be an impediment for providing the clearest information, avoiding to charge the information with unnecessary details that make its reading difficult.

Contrarily, if users have a good Internet knowledge level, it is not necessary to give them basic information about cookies and how they work. However, detailed information should be included about the type of cookies used and their goal.

Currently, it may be assumed that the user’s cookies knowledge level is very low.

It should be taken into account the web design and its mechanism. The better the information offered about cookies fits with the other website contents and its operating mechanism, the more likely this information will be read by users.

Secondly, cookies information about accessibility and visibility can be enhanced in the following ways:

Through the link format: For instance, increasing the information link size or using a different source that can differentiate that link from the website normal text and other links.

Through the link position: The link location at areas that catch user’s attention can help to ensure accessibility and visibility.

Through a descriptive and intuitive link designation use: The explanatory expression use, such as “Cookies Policy”, instead of a more general expression (such as “Privacy Policy”) to improve the message’s accessibility and visibility.

Using other techniques that could help to highlight the importance of that informative link, such as framing or underlining the link, displaying a warning when the mouse pointer passes over the link or using an image or icon that can be clicked on, encouraging people to look for more information.

Informing and obtaining users consent is not something new on the Internet. Most websites know what methods have to use to attract user’s attention to that information they want to highlight, such as promotions, offers or satisfaction surveys, and to obtain user’s consent, even though it is in different contexts (terms and use conditions changes, purchase confirmation or minimum age verification). The way in which information is given to users, and how user’s consent is obtained should take advantage of the acquired experience through these methods.

Anyway, the mandatory information may be offered through multiple systems. As we will see later, generally with these methods not only the necessary information will be provided, but also user’s consent for devices installation can be requested. Among the most common methods it should be highlighted:

a.- The information supply through a header bar or footer, visible enough.

b.- For starting a service, or before downloading it, both information and privacy policy may be provided, or in the terms and conditions of the service use.

With the aim of maintaining cookies information visible, this information should be featured and separated (using a different hyperlink, for instance) from the rest of term’s and condition’s information, as well as privacy policy.

If the user’s cookies installation consent is required when they have already been registered in the service,

In case it would be necessary to obtain the user’s cookies installation consent (that is, usera that are already registered in the service), they must be informed about the changes made in relation to the cookies treatment and, if they continue using the service, it will be understood that they consent their installation.

In both cases it will also be possible to provide the information and to obtain the consent through conventional (off-line) methods, as long as it is recorded that users have been individually informed and they have provided their consent.

c.- Layered information: this system displays the main information in a first layer, when accessing the page or application, and completing it in a second layer through a page in which additional information about cookies is offered.

1.- The below information should be provided in the first layer:

  • Warning about of non-excepted cookies use, which are installed when browsing this page or when using the requested service.
  • Goals Identification of the installed cookies. Information on whether the installation and cookies use will be only from the website responsible editor, or also from third parties associated with it.
  • If a certain action is performed, it will be understood that the user accepts the cookies use.
  • A link to a second layer that includes more detailed information.

This information will be provided through a format that would be visible to users and should be maintained until users perform the action required to obtain the consent.

EXAMPLE:

We use our own and third party cookies in order to improve our services and show you advertising related to your preferences, using your own browsing habits. If you continue surfing on the web, you are accepting the cookies. You can change your settings or getting more information here. As can be seen, this example shows user’s and third party’s information about publicity. Cookies should be analyzed in that form, in order to adapt information to a particular situation.

2.- The below information should be provided in the second layer:

  • Cookies definition and function

EXAMPLE:

What are cookies? Cookies are files that are downloaded to the user’s computer when accessing certain web pages. Cookies allow the website to save and retrieve information about browsing habits. Depending on the information or how the computer use it, cookies can be used to user’s recognition.

  • Information using a box or list about the cookies used by the website and its purpose.

EXAMPLE:

What type of cookies use this webpage?

  • Analysis cookies: used by our self or third party. They allow us to quantify the user’s number, in order to analyze the user’s use about the offered service. People’s web browsing is analyzed with the aim of improving the products or services offered by us.
  • Advertising cookies: used by our self or third party. They allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included in a web page, adapting the advertisement content to the requested service content, or the website use made. People’s web browsing habits are analyzed with the aim of showing related advertising to users browsing profile.
  • Information on how to deactivate or eliminate the enunciated cookies through the functionalities provided by the editor, the tools provided by the browser or terminal or through common platforms that may exist to this aim, as well as the way to withdraw the consent already given.

EXAMPLE:

You can allow, block or delete the cookies installed on your computer by configuring the options of your Internet browser.

You can block or delate the cookies in your browser:

Identification information about who is using cookies, that is, if the information obtained by cookies is treated only by the editor and / or also by third parties, with whom the editor has contracted the provision of a service for which the use of cookies is required, with identification of this third party.