COOKIE POLICY
1. Purpose and Scope
This Cookie Policy is intended to provide clear, complete and transparent information regarding the cookies and similar technologies that may be used when browsing ja2e.com (hereinafter, the “Website”), operated under the name JA2E Consulting.
This Policy should be read together with the Privacy Policy and, where applicable, the Website’s Legal Notice.
For the purposes of this document, the term “cookies” shall also include, where appropriate, other technologies capable of storing information on a user’s terminal device or accessing information already stored on that device.
2. What Are Cookies?
Cookies are small files or pieces of information that a website may store in a user’s browser or device while they browse the website and retrieve at a later time.
These technologies may perform a variety of functions, including enabling the proper technical operation of the Website, maintaining certain settings, remembering preferences, carrying out statistical measurements regarding Website usage, analysing performance or, where applicable, conducting advertising and campaign measurement activities.
In addition to traditional cookies, other storage or access technologies may exist, including browser local storage (localStorage), session storage (sessionStorage), pixels, tags, identifiers, scripts, SDKs or other mechanisms of an equivalent nature.
The mere loading of a technical resource, a network request or a connection to an external provider does not necessarily, in itself, entail the installation of a cookie or the storage of information on the user’s device.
3. Classification of Cookies
Cookies may be classified according to different criteria.
3.1. According to the Entity Managing Them
First-party cookies: cookies managed from the domain or service of the Website operator itself.
Third-party cookies: cookies managed by an entity other than the Website operator, either because they are installed from a different domain or because the information obtained through them is processed by a third party.
3.2. According to How Long They Remain Active
Session cookies: cookies designed to collect and store information while the user accesses a website and which, as a general rule, cease to be available once the browsing session has ended.
Persistent cookies: cookies that remain stored on the device for a period determined by the party responsible for the cookie. This period may range from a few minutes to longer periods depending on the purpose for which the cookie has been configured.
3.3. According to Their Purpose
Technical or strictly necessary cookies: cookies that enable browsing and the use of essential Website functionalities or that are necessary to provide a service expressly requested by the user.
Preference or personalisation cookies: cookies that make it possible to remember certain choices or settings made by the user.
Analytics or measurement cookies: cookies that make it possible to quantify users and statistically analyse the use and performance of a website.
Advertising cookies: cookies that make it possible to manage, as effectively as possible, any advertising spaces that may be included on a website.
Behavioural advertising or profiling cookies: cookies that make it possible to obtain information about users’ browsing habits for the purpose of creating profiles, personalising content or displaying advertising related to their interests.
4. Technologies Currently Used by JA2E
The Website has been developed and is hosted using the Framer technology platform, provided by Framer B.V.
According to the configuration currently implemented on the Website, no non-essential cookies have been identified as being installed under the ja2e.com domain which, at present, would require the user’s prior consent.
The Website may use the statistical functionalities integrated into Framer Analytics.
Framer Analytics is an audience measurement system designed to provide aggregated statistical information regarding the operation and use of websites developed using the platform.
According to Framer’s current technical documentation, its integrated analytics tool:
does not install cookies in the user’s browser;
does not generate persistent identifiers;
does not use a cookie to recognise the same visitor over extended periods;
measures unique visitors within a daily time window; and
uses technical mechanisms intended to prevent the creation of persistent identifiers across different days.
Accordingly, Framer Analytics does not currently constitute an analytics cookie installed on the user’s terminal device.
Current Inventory
Technology
Provider
Purpose
Nature
Retention
Consent
Framer Analytics
Framer B.V.
Collection of aggregated statistics regarding visitors, page views, traffic sources and general use of the Website
Cookie-free analytics without persistent identifiers
Does not install a persistent cookie on the device. Statistical visitor identification is limited to a daily time window
Consent for the installation of cookies is not required for this technology, as it does not install cookies or persistent identifiers
Non-essential first-party cookies belonging to ja2e.com
—
—
None identified in the current configuration
—
Not applicable
The foregoing information reflects the technical configuration of the Website as at the date of the latest update of this Policy.
JA2E will review this inventory whenever new functionalities, integrations or technology providers are introduced.
5. Cookies Belonging to the Framer Domain
JA2E uses Framer as a technology provider for the development and hosting of the Website. This must be distinguished from the direct use of websites and services belonging to Framer itself.
When browsing services or websites belonging directly to Framer, particularly under the framer.com domain, cookies belonging to that provider may be used.
Cookies specifically configured for the .framer.com domain do not, by that fact alone, constitute cookies belonging to ja2e.com, nor should they be confused with technologies used by JA2E on the Website.
For this reason, cookies associated with the .framer.com domain, including those named FPID, __ps_fva, __ps_lu, __ps_r, _ttp, cookie_consent or visitor_id, are not included in the inventory above as first-party cookies belonging to JA2E.
Their use in services provided directly by Framer is subject to Framer’s own cookie policy and information.
6. Applicable Legal Basis
In Spain, the use of data storage and retrieval devices on recipients’ terminal equipment is primarily governed by Article 22.2 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, in conjunction with Article 5(3) of Directive 2002/58/EC.
As a general rule, where a cookie or similar technology is not strictly necessary, its use will be subject to the user having previously received clear and complete information concerning its use and having validly provided consent.
Technologies whose use is necessary to transmit a communication over an electronic communications network or to provide an information society service expressly requested by the user may be exempt from this requirement, provided the legally established conditions are met.
Where the use of cookies or similar technologies also involves the processing of personal data, such processing will additionally be subject to Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR) and any other applicable data protection legislation.
Information relating to the processing of personal data in connection with the use of the Website is set out in the JA2E Privacy Policy.
7. Consent
Under the technological configuration described in this Policy, no non-essential first-party cookies belonging to ja2e.com have currently been identified that would require the user’s prior consent before installation.
For this reason, the mere use of the integrated Framer Analytics functionalities described above does not, in itself, make it necessary to deploy a cookie consent mechanism.
However, should JA2E introduce non-essential cookies or technologies subject to consent in the future, such technologies will not be installed or activated until the user has made a valid choice, where required under applicable law.
In such circumstances, users will be provided with a mechanism that clearly and accessibly enables them to:
accept non-essential cookies;
reject non-essential cookies; and
individually configure the available categories where appropriate.
The consent mechanism shall be configured so that rejecting cookies does not entail greater complexity or burden than accepting them.
8. Withdrawal and Modification of Consent
Where a particular cookie or technology relies on the user’s consent, the user may withdraw or modify such consent at any time.
Withdrawal shall be possible with substantially the same level of ease as that used to provide consent.
If JA2E introduces technologies subject to consent, the Website will maintain a permanent and accessible mechanism enabling users to review or modify their previously selected preferences.
Withdrawal of consent shall not affect the lawfulness of any processing carried out before such consent was withdrawn.
9. Duration of Cookies
Any cookies that may be introduced on the Website will be retained only for the period necessary and proportionate to fulfil the purpose for which they were configured.
The specific duration of each cookie will be identified in the inventory included in this Policy whenever technologies are introduced that effectively store cookies on the user’s device.
Under the current configuration, Framer Analytics does not install a persistent cookie on the device, and therefore there is no retention period for a Framer analytics cookie in the browser that needs to be specified.
Where new persistent cookies are introduced, JA2E will seek to ensure that their retention period is proportionate to their purpose and will periodically review whether their continued use remains necessary.
10. Managing and Deleting Cookies Through the Browser
Irrespective of any mechanisms that JA2E may make available, users may view, allow, block or delete cookies and other website data through their browser settings.
Such tools generally allow users to:
view stored cookies;
delete individual cookies;
delete all cookies associated with a particular website;
block third-party cookies;
prevent the storage of certain categories of cookies; and
delete browsing data and local storage.
Users should be aware that disabling or deleting certain strictly necessary technologies may affect the proper operation of some website functionalities.
11. Third-Party Services
JA2E uses Framer B.V. as the provider of the technological infrastructure used for the development and hosting of the Website.
If third-party services using cookies or similar technologies are introduced on the Website in the future —including, by way of example only, external analytics tools, CRM systems, video players, booking services, chat tools, advertising pixels, social networks or commercial automation solutions— JA2E will analyse their operation in advance and update this Policy where necessary.
Where such technologies require consent, their installation or activation will be prevented until the user has provided a valid indication of their wishes.
12. International Transfers of Personal Data
The mere use of a cookie does not necessarily entail an international transfer of personal data.
However, where a cookie or technology used by the Website involves the disclosure or making available of personal data to an entity located outside the European Economic Area, JA2E will assess the applicable legal transfer mechanism and provide the corresponding information in the Privacy Policy or, where appropriate, in this Cookie Policy.
If new providers involving international transfers in connection with tracking or measurement technologies are introduced in the future, the corresponding information will be updated before or at the time such technologies are used, in accordance with applicable law.
13. Protection of Personal Data
Information relating to personal data processed through the Website —including categories of data, purposes, legal bases, recipients, providers, retention periods, international transfers and data subject rights— is set out in the JA2E Privacy Policy.
14. Users in the European Economic Area
Where a user is subject to the laws of the European Economic Area, JA2E will apply the relevant provisions of Directive 2002/58/EC, the national legislation implementing it, the GDPR and any other applicable legislation.
Where a technology cannot rely on a statutory exemption from the consent requirement, it will remain disabled until a valid indication of the user’s wishes has been obtained.
15. Users in the United Kingdom
Where United Kingdom law applies, the use of cookies and other storage or access technologies will be subject to the Privacy and Electronic Communications Regulations (PECR), the UK GDPR and any other applicable legislation.
JA2E will adapt its information, consent and management mechanisms where required by the technologies used or the territorial scope of its services.
16. Users in Other Jurisdictions
The regulation of cookies, tracking technologies, targeted advertising and opt-out mechanisms is not uniform internationally.
Accordingly, where JA2E directs its services to users subject to legal systems establishing specific rights or requirements regarding online tracking, targeted advertising, profiling, sale or sharing of information or universal opt-out mechanisms, JA2E will implement any additional measures required by applicable law.
This Policy is not intended to replace specific obligations that may apply in a particular jurisdiction where such jurisdiction establishes a different or more specific legal framework.
17. Links to Third-Party Websites
The Website may contain links enabling users to access websites or services operated by third parties.
When a user leaves ja2e.com and voluntarily accesses a domain belonging to a third party, the cookies and technologies used by that third party on its own website will be subject to the relevant third party’s privacy and cookie policies.
JA2E does not control cookies that may be installed directly by third parties once the user has left the Website.
18. Amendments to the Cookie Policy
JA2E may amend this Policy where necessary in order to adapt it to:
changes in the configuration or technical architecture of the Website;
the introduction, replacement or removal of providers;
new functionalities or integrations;
changes to the purposes of the technologies used;
legislative or regulatory changes;
new case law or criteria issued by supervisory authorities; or
recommendations or best practices relating to privacy and tracking technologies.
Where an amendment entails the introduction of new technologies subject to consent or a substantial change to the purposes for which consent was previously obtained, JA2E will seek a new choice from the user where legally required.
The date stated at the beginning of this Policy identifies the version currently in force.
19. Contact
For any queries relating to this Cookie Policy, the technologies used by the Website or the exercise of privacy rights, you may contact JA2E at:
jatue@ja2e.com
You may also consult the Privacy Policy and Legal Notice of JA2E for further information regarding the processing of personal data and the ownership and legal terms governing the Website.