SIROKO TV COOKIE POLICY

1. General Information on the Use of Cookies

1.1. What are cookies

Cookies are small text files that websites and applications download to the user’s device (computer, smartphone, tablet, smart TV, or other) when the user accesses them. They allow the site or application to recognize the device, remember the user’s preferences, facilitate navigation, and, in certain cases, analyze user behavior or display personalized advertising.

In addition to cookies in the strict sense, there are other similar technologies, such as pixels, tags, web beacons, device identifiers, or local storage (localStorage and sessionStorage). For the purposes of this Policy, all of these are collectively referred to as “cookies,” in accordance with the broad interpretation applied by the Spanish Data Protection Agency.

1.2. Where cookies are stored

Cookies are stored on the user’s own device, in the browser’s or operating system’s memory. From there, they can be read by the website or application that installed them (first-party cookies) or by third-party sites or services (third-party cookies), when so provided.

1.3. Types of cookies

A) By purpose

  • Technical cookies. These enable navigation and the proper functioning of the website or application. They manage the session, traffic, user identification, access to restricted areas, form recall, payment processing, fraud prevention, video and audio playback, and other essential features.
  • Preference or personalization cookies. These allow the site to remember information that personalizes the user experience, such as language, content layout, the region from which the site is accessed, or the preferred display format.
  • Analytics or measurement cookies. These allow us to count the number of users, analyze how they use the service, and compile statistics to improve the Platform.
  • Behavioral advertising cookies. These allow us to manage advertising spaces on the site or app and display personalized ads based on user behavior.

B) By the entity that manages them

  • First-party cookies. These are sent to the user’s device from a server or domain managed by Siroko Solutions, S.L. itself.
  • Third-party cookies. These are sent to the user’s device from a server or domain managed by a third party that processes the information obtained through the cookies.

C) By duration

  • Session cookies. They collect and store data while the user accesses the service and are deleted at the end of the session.
  • Persistent cookies. The data remains stored on the device for a specific period, determined by the party responsible for the cookie.

2. Applicable regulatory framework

The use of cookies on Siroko TV is subject, in particular, to the following regulations:

  • Article 22.2 of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE), which requires the user’s informed consent for the storage and retrieval of information on their terminal equipment, except for strictly necessary cookies.
  • Regulation (EU) 2016/679 (GDPR), in particular Articles 6 and 7.
  • Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD).
  • Guidelines on the use of cookies from the Spanish Data Protection Agency, in their current version as of July 2023.

3. Cookies Used by Siroko TV

Siroko TV uses first-party and third-party cookies for the purposes described in section 1.3. The complete and updated list of cookies actually installed, including the owner, purpose, legal basis, and retention period, is provided in Annex I.

Consent management tool. Siroko TV uses, as its Consent Management Platform, [• pending confirmation: OneTrust, Cookiebot, Didomi, CookieFirst, proprietary, or another], which allows the user to accept, reject, or configure cookies at any time and maintain a record of the decision made.

4. How Siroko TV Requests Consent

Upon first accessing the Platform, Siroko TV displays a cookie banner to the user that clearly and concisely describes the purposes of the different categories of cookies used and the available options.

In accordance with the Spanish Data Protection Agency’s Guidelines, the banner presents three options with equal visibility and accessibility:

  • Accept all cookies. Authorizes the installation of all categories described in this Policy.
  • Reject all cookies. This denies the installation of categories that are not strictly necessary. Technical cookies will continue to be installed as they are essential.
  • Configure cookies. Allows the user to individually select which categories to accept or reject.

Refusal to consent will not restrict access to the Platform’s essential features. Siroko TV does not use cookie walls or make access conditional on the acceptance of non-essential cookies.

Renewal of consent. In accordance with the AEPD Guidelines of July 2023, Siroko TV will request renewal of consent every twenty-four (24) months from the last expression of consent, as well as when there are significant changes to the purposes of processing or the cookies used.

Proof of consent. In accordance with Article 7.1 of the GDPR, Siroko TV maintains a technical record of the consent provided by each user, indicating the accepted categories, date, time, and version of the banner.

5. Management and withdrawal of consent

The user may modify or revoke their consent at any time, without this affecting the lawfulness of the prior processing. To do so, Siroko TV provides:

5.1. Private Browsing

Most browsers allow you to enable a private or incognito mode, in which cookies are automatically deleted when you close the session. This mode may limit the functionality of the Platform and does not replace active consent management.

6. Siroko TV’s Commitment

Siroko Solutions, S.L. is committed to providing users with clear, complete, and accessible information about the use of cookies, as well as effective tools to manage their consent.

Likewise, it adopts the necessary technical and organizational measures to ensure the security of the information obtained through cookies and the complete preservation of proof of consent.

7. Modifications

Siroko Solutions, S.L. may modify this Policy when required by regulatory changes, new technologies, the addition of providers, or changes in the purposes. Substantial modifications will be communicated to the user via a banner requesting renewal of consent.

8. Related Documents

This Policy is supplemented, in matters not expressly regulated herein, by:

  • Legal Notice.
  • Terms and Conditions of Use.
  • Privacy Policy.

9. Contact

  • Siroko Solutions, S.L., Plaza 6 de Agosto No. 6, 2nd Floor, 33203 Gijón (Asturias).
  • Email: gdpr@siroko.com.
  • Data Protection Officer: Mr. Martín López Escartiín, gdpr@siroko.com.

Appendix I. List of Cookies

This Annex identifies the cookies that Siroko TV installs on the user’s device

Siroko Solutions, S.L. · N.I.F. B33950338 · Plaza 6 de Agosto nº 6, 2º · 33203 Gijón (Asturias) · gdpr@siroko.com