Privacy Policy

This Privacy Policy describes what personal data is collected by the Company when visiting and using the Site, for what purpose and on what legal basis they are processed, how they are protected, as well as the rights of Users in relation to their personal data. The Policy has been developed in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection legislation.

Definitions: In this Policy, "personal data" means any information related to an identified or identifiable natural person (data subject), such as: name, email address, telephone number, online identifiers (IP address, cookies, etc.), as well as other information that allows the User to be directly or indirectly identified. "Processing" means any actions with personal data - collection, recording, storage, use, transfer, deletion, etc.

Data Controller: The Controller (operator) of the Users’ personal data is Jurisprudential Consulting Group SL, NIF (Número de Identificación Fiscal): B75756304, registered and operating in Spain. For communication regarding data protection matters, the contact details provided in section 2.10 below can be used.

1.1. Collection of personal data

We collect and process personal data of Users only to the minimum extent necessary, corresponding to clearly defined purposes. Data collection may occur in the following ways:

• Data provided by the User: You may directly provide us with information about yourself, for example, when filling out a feedback form, sending an email request, registering for an event or subscribing to a newsletter. Such data may include your first name, last name, position, organization name, contact phone number, email address, postal address, as well as the content of the message or other information that you choose to provide to us. We ask you to provide only the information that is necessary for the relevant purpose (for example, for feedback it is sufficient to provide your name and contact information).
• Data collected automatically: Each time you visit the Site, certain technical data is automatically sent to our systems. This data includes: the IP address of the User’s device, information about the browser and type of operating system, interface language, date and time of access, address of the requested pages, cookies and other unique identifiers. This data is collected by our server logs, as well as through cookies and pixel tags (for details, see Section 3 on cookies). Automatically collected data does not generally allow you to be identified without combining it with additional information, but it may be considered personal data (for example, the IP address and cookie ID are considered personal data in the EU, since they can be associated with a specific user).
• Data from third-party sources: We generally obtain information directly from you. In some cases, we may receive certain data from publicly available sources or from third parties – for example, if you interact with us via the company’s social media pages or through external services (e.g., submitting a request via a professional social network), or if you have been referred to us by a partner organization. In such cases, we will ensure that we have a legal basis for processing such data and will inform you accordingly.

Please note that our Site is not intended to collect and process special categories of personal data (such as information about health, racial or ethnic origin, political views, religious beliefs, criminal record, etc.). Please do not provide us with such data through the Site forms or in any other way. The Company does not knowingly collect data about children under 16 years of age; if we learn that we have accidentally received personal data from a child without parental consent (where such consent is required), we will take steps to delete such information.

1.2. Purpose of processing personal data

We use the personal data we collect in a strictly limited manner – only for the purposes for which the data was provided or collected and other compatible purposes. The main purposes for processing your data include:

• Provision of services and information: Processing of requests and inquiries from Users. For example, if you contact us via the contact form on the Site or by e-mail with a request for our consulting services, we will use the contact details you provide and the content of your request to respond to you, provide the requested information or take the necessary actions to conclude a contract for the provision of services.
• Functioning and improving the Site: Ensuring the correct operation of the Site and the convenience of its use. We process technical data (IP addresses, cookies, etc.) to load Site pages, adapt content to your device, remember your preferences (e.g., language selection), and to maintain Site security (e.g., to protect against fraudulent requests and cyberattacks). Analytical data on traffic (collected through cookies) is used to understand which sections of the Site are most in demand, how Users interact with the content. This helps us optimize the structure and content of the Site, correct errors, and improve the quality of the materials and services provided.
• Marketing and newsletters: With your separate consent, we may use contact details (e.g. e-mail) to send you news, reviews, newsletters, invitations to our events or other marketing materials related to the Company's activities. You can always unsubscribe from such mailings by following the instructions in the email or by contacting us (see section 2.8 on the right to withdraw consent). In addition, the Site may use marketing tools (e.g. social media pixels) to personalize advertising: for example, we may show you an advertisement for our services on other platforms, taking into account that you have visited our Site. Such tools also operate on the basis of cookies and require your consent (more details in section 3).
• Fulfilment of legal obligations: In certain cases, we need to process personal data to comply with legal requirements. For example, accounting and tax regulations may require us to keep contracts and invoices with personal customer data, and anti-money laundering legislation may require us to verify and store certain customer data. Although the Site itself may not collect such data, if you become our customer, further processing will be governed by the terms of the contract and the law. In relation to the operation of the Site itself, we may retain certain log files and technical information for the period required by electronic communications and data protection laws.
• Protection of rights and interests: If necessary, we may process personal data to establish, exercise or defend the Company's legal claims (for example, in the event of disputes involving you or the need to prevent illegal actions, attempts at unauthorized access to the Site, to defend against a lawsuit, etc.). This includes the use and, if necessary, the transfer of data to competent authorities if this is required to investigate incidents, fulfill law enforcement requests or enforce court orders.

We ensure that the data is not processed in a manner incompatible with the purposes described above. If we need to use personal data for a new purpose not initially specified, we will notify you of this and, where necessary, request additional consent.

1.3. Legal basis for processing

The Company processes Users' personal data only if there is a proper legal basis, as provided for in Article 6 of the GDPR (and relevant national legislation). Depending on the specific type of data and purposes, such grounds may be:

• Consent of the data subject. We ask for your consent to the processing where required by law. In particular, we rely on consent for the use of optional cookies and similar technologies (e.g. analytics or marketing cookies set by Google Analytics, Meta Pixel, etc.). Your voluntary, unambiguous consent will also be the legal basis for sending you marketing materials (e.g. newsletters by e-mail) – you give such consent, for example, by ticking a box or otherwise expressing your consent when subscribing. You have the right to revoke your consent at any time by contacting us or using technical options (see section 2.8), while the lawfulness of the processing before the revocation will remain valid.
• Necessity for the performance of a contract or for taking steps at the request of the subject prior to the conclusion of a contract. If you are our client or intend to become one, we process your data necessary to provide you with services in accordance with the contract. For example, when you request a consultation via the Site, the processing of your contact details and request details is necessary to take steps on your request prior to the conclusion of the contract. If the Company and you have concluded a contract for the provision of consulting services, the processing of your data within the framework of the performance of such contract (communication, provision of work results, invoicing, etc.) is carried out on this legal basis.
• Legitimate interests of the Company. We may process certain data based on our legitimate interests, provided that such interests do not prevail over the fundamental rights and freedoms of the User. For example, our legitimate interest is to ensure the security of the Site and prevent fraud - for this purpose, we process log data, IP addresses, etc. without separate consent. Legitimate interest may also be to improve the performance of the Site and analyze the audience - however, in terms of the use of cookies and similar identifiers for analytics and marketing, we rely on consent in accordance with the ePrivacy requirements, as stated above. However, we may use aggregated non-personalized analytics based on legitimate interest for internal reporting. Another example is to protect our rights in the event of a dispute (processing data within the framework of legal claims). In all cases, when relying on this legal basis, we carry out a balancing test to ensure that we do not violate your rights. The user has the right to object to processing carried out on the basis of our legitimate interest (see section 2.8).
• Fulfilment of a legal obligation. Some data operations are required to comply with legal requirements. For example, tax legislation requires us to store documents with personal data of customers (names, addresses, payment amounts) for a certain period. EU data protection legislation may also require storing your requests to exercise data subject rights and our correspondence on this matter. In such cases, the legal basis is the fulfilment of a legal obligation, and your data will be processed only to the extent required to comply with the law.
• Other grounds. In rare cases, it may be necessary to process data to protect the vital interests of the data subject or another person (e.g. in the event of an emergency) or to perform a task carried out in the public interest. However, the activities of our Company, as a private consulting business, do not usually require such grounds, so they are mentioned only for the sake of completeness and, as a rule, are not used by us.

In summary: We always ensure that there is one or more legal grounds under the GDPR for each processing of your personal data. If there is none, the data will not be collected or processed.

1.4. Disclosure of Personal Data to Third Parties

The Company respects the privacy of your data and generally does not transfer Users' personal data to third parties, except in cases expressly stated below, or if you yourself have requested or permitted such transfer.

The categories of third parties to whom information may be disclosed include:

• Authorized employees and contractors of the Company. Only those employees, consultants and outsourced specialists of the Company who need it in the course of performing their job responsibilities (the “need-to-know” principle) have access to personal data. All such persons are bound by confidentiality obligations. For example, your request with personal data may be processed by an employee of the business development department or a specific consultant competent in the subject of the request.
• Service providers (processors). We may engage external companies to perform certain functions on our behalf and at our request – for example, for hosting and technical support of the Site, for traffic analysis, for organizing mailings, for making payments and accounting, etc. When granting such processors access to personal data, we conclude agreements with them obliging them to process the data strictly according to our instructions, to ensure their protection and confidentiality in accordance with the GDPR and this Policy. For example, the hosting provider stores Site data on its server equipment; the web analytics service (Google Analytics) receives data on the use of the Site; the payment processor processes payment details if the Site provides for online payment for services. In each such case, the volume of data transferred is limited to the necessary minimum (for example, technical data on the visit is transferred to the analytics service, and data for executing the transaction is transferred to the payment service).
• Affiliated and partner organizations. The company may exchange data with affiliated entities (for example, if Jurisprudential Consulting Group SL is part of a group of companies or has branches, it may theoretically be necessary to transfer data within the group). At the moment, there is no such transfer, since all operations are concentrated in one legal structure. However, if in the future we have associated companies or we interact with a partner consulting firm within the framework of a project, we will inform you and request consent, if necessary, before transferring your data to the partner.
• Third parties with the User's consent. In certain situations, you may ask us to share information with a third party or expressly agree to such transfer. For example, you may ask us to introduce you to our legal partner and provide them with your contact information - this will only be done with your consent.
• Government bodies and other persons based on the law. The Company may disclose personal data if required by law, on the basis of an official request, order or court decision, or if the disclosure is necessary to protect the rights, property or safety of the Company, our employees, Users or the public. In particular, we will provide the necessary data to competent authorities as part of an investigation of illegal activities (e.g. fraud, cybercrime) or at the request of a data protection supervisory authority (e.g. in response to a complaint filed by a User). We always check the legality of each request for data disclosure and provide information strictly to the extent required by law.

It is important to emphasize that we do not sell or transfer personal data to third parties for their own marketing purposes without your explicit consent. Any statistical information that we may share publicly (for example, in marketing materials about the number of visitors to the Site, general trends) does not contain identifiable data about individual Users.

1.5. Cross-border data transfer

We process personal data primarily within the European Union. However, some of our third-party service partners may be located outside the EEA (European Economic Area) or store data on servers in other jurisdictions. In particular, some recipients of data are located in the United States or other countries outside the EEA. For example, Google and Meta (Facebook), which provide us with analytics and advertising tools, are based in the United States, which involves the transfer of technical data (such as IP address, cookie ID, site interaction data) to servers in the United States.

Where personal data is transferred outside the EEA, we will ensure that appropriate measures are taken to protect your data in accordance with Chapter V of the GDPR. Such measures may include:

• Transfer of data to countries recognized by the European Commission as providing an adequate level of protection of personal data (Article 45 GDPR).
• The use of the European Commission's Standard Contractual Clauses (SCCs) in contracts with data importers, supplemented where necessary by additional security measures, which obliges the recipient of the data to ensure a level of protection equivalent to the European one.
• Engaging companies certified under EU-approved mechanisms (e.g. the existing EU-US Privacy Shield or new cross-border data transfer frameworks if they come into force).

We closely monitor legal developments in the field of cross-border data transfer. If there is a risk that the legislation of a third country does not provide adequate protection, we carry out an assessment (Transfer Impact Assessment) and, if necessary, suspend the transfer or require additional guarantees from the partner. Your rights and protections provided by the GDPR remain unchanged regardless of the place where the data is actually stored or processed.

At the User’s request (see section 2.10 for contact details), we are ready to provide additional information on the cross-border transfer mechanisms applicable to his/her data.

1.6. Personal data storage periods

We store Users' personal data no longer than is necessary for the purposes for which they were collected or for the period prescribed by law. The criteria for determining the storage period depend on the data category and the purposes of processing. Below are indicative storage principles:

• Inquiry and correspondence data. We store the information you provide when contacting us (e.g. via the contact form or by email) for as long as necessary to process your request and further communication. Correspondence on general issues is usually stored for 1-2 years for the record, unless long-term obligations arise from it. If the correspondence or inquiry leads to the conclusion of a service contract, the corresponding data may be stored as part of the project documentation (see next point).
• Customer data (as part of the provision of services). If you become our customer, your data (e.g. contract details, work results, invoices) will be stored for the duration of the contract and for a certain period after its termination – as a rule, until the expiration of the limitation period for possible disputes or until the expiration of the statutory storage periods (e.g. accounting documentation is stored for at least 5-6 years in accordance with Spanish tax requirements). Such data is stored separately from data collected through the open Site and is governed not only by this Policy, but also by the terms of the specific contract with you.
• Technical and analytical data. Web server log files containing IP addresses and visitor information are stored for a limited time (usually 1-3 months), unless longer storage is required for security purposes. Analytical data collected using Google Analytics and other cookies is usually aggregated and stored statistically. Google Analytics, for example, allows you to customize the storage period for user and event data – we adhere to the minimum necessary period (e.g. 14 months), after which the data is deleted automatically. Anonymized aggregate statistics may be stored indefinitely, as they are not personal data. Information on the specific storage periods for each cookie is provided in the Cookie Policy (section 3).
• Marketing data. If you have given consent to receive a newsletter, we will store your email address and associated preferences until you unsubscribe from the newsletter or withdraw your consent and request deletion of the data. After withdrawal of consent, your email will be placed on an opt-out list (to ensure that you do not receive further emails) or deleted completely, unless this conflicts with our obligations (e.g. storing evidence of your consent/revocation for a certain period).
• Legal and other mandatory periods. Certain data may be stored longer if this is necessary in the context of legal or administrative proceedings (e.g. until the end of a dispute, investigation) or if a mandatory storage period is established by law. At the end of such a period, the data will be securely deleted or anonymized.

At the end of the storage period, we either completely delete personal data or anonymize it so that identification of the user is no longer possible. If deletion of data is not immediately possible for technical reasons (e.g. data is stored in backup archives), we will ensure that it is isolated and inaccessible for further processing until final deletion.

1.7. Data Subject Rights

In accordance with the GDPR and other applicable laws, the User (as a data subject) has a number of important rights in relation to their personal data. We respect these rights and provide detailed information about each of them:

• Right of access (Article 15 GDPR): You have the right to request confirmation as to whether we process your personal data and, if so, to receive a copy of your personal data held by us, as well as information about the purposes of the processing, categories of data, categories of recipients, retention periods and other aspects of the processing. We will provide this information free of charge (first request), in a structured form that is understandable to you.
• Right to rectification (Article 16 GDPR): If you find that any of your personal data held by us is inaccurate or incomplete, you have the right to request that it be corrected (changed, updated). We will promptly make the necessary adjustments, having ensured that they are justified.
• Right to erasure of data (“right to be forgotten”, Article 17 GDPR): In certain cases, you may request that we erase your personal data. For example, if the data is no longer necessary for the purposes for which it was collected, if you have withdrawn your consent (and we have no other legal basis), if you have objected to the processing and we have no legal basis to continue, or if the data was processed unlawfully. However, this right is not absolute – there are exceptions. We will not be able to erase data that we are required to retain by law (e.g. data from mandatory accounting records until the statutory deadline has expired) or data that is necessary to establish, exercise or defend our legal claims. In response to your request, we will indicate which data may and may not be erased, with a reference to the grounds.
• Right to restriction of processing (Article 18 GDPR): You have the right to request a temporary restriction of the processing of your data (i.e. storage only) if: you have contested the accuracy of the data (for the duration of the review); the processing is unlawful, but you request restriction instead of erasure; we no longer need the data, but you need it to establish or defend legal claims; or you are awaiting a decision on your objection to processing (see below). Under restriction mode, we stop actively processing the data, but leave it stored. We will also notify you when the restriction is lifted.
• Right to data portability (Article 20 GDPR): With regard to data that you have provided to us and that is processed automatically on the basis of your consent or a contract with you, you have the right to receive this data in a structured, commonly used and machine-readable format and (if technically feasible) to transmit it to another data controller. For example, you can request from us the contact details you have provided and a description of the requests in order to transmit them to another consultant. At your request, where possible, we can ourselves forward such data directly to the new person, but only if this does not adversely affect the rights of other persons (e.g. if the data contains information about third parties - their personal data must not be disclosed without their consent).
• Right to object (Article 21 GDPR): You have the right to object at any time to the processing of your personal data, which is carried out on the basis of our legitimate interests (Article 6(1)(f) GDPR) or for reasons of public interest (Article 6(1)(e)), where there are grounds for doing so relating to your particular situation. If you object, we will cease to process the data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims. Important: if your data is used for direct marketing, you have an unconditional right to object at any time and we will stop using the data for this purpose. For example, you can object to your email being used to send you marketing materials – and we will stop sending them immediately (similar to withdrawing consent for a newsletter).
• Right not to be subject to an automated decision (Article 22 GDPR): You have the right not to be subject to a decision based solely on automated processing (including profiling), where such decision produces legal effects concerning you or otherwise significantly affects you. Simply put, in cases where an important decision is taken solely by an algorithm without human intervention, you can request a review with human intervention. We do not carry out fully automated decisions on our Site that produce significant effects for Users. Any profiling is limited in nature (e.g. interest analysis for advertising purposes) and does not produce any legal effects for you.
• Right to withdraw consent: If the processing is based on your consent, you have the right to withdraw that consent at any time (as easily as you gave it). Withdrawal of consent does not affect the lawfulness of the processing before the withdrawal. For example, you can refuse cookies (see section 3.4) or newsletter subscriptions, and we will stop the relevant processing.
• Right to lodge a complaint with a supervisory authority: If you believe that your data protection rights have been violated, you can lodge a complaint with the competent national data protection authority. We hope that any questions can be resolved by contacting us first (we take your privacy seriously and will try to satisfy your requests). However, you have the right to contact the supervisory authority directly. In Spain, this is the Agencia Española de Protección de Datos (AEPD) – the Spanish Data Protection Agency. You can also lodge a complaint with the data protection authority of your country of residence or location (for EU citizens/residents). Contact details for European authorities are available on the official website of the European Data Protection Board (EDPB).

We undertake to promptly comply with your requests and respect your rights. We usually respond to requests within 1 month from the date of receipt of the request. If necessary, given the complexity or number of requests, this period may be extended by a maximum of 2 months, but in this case we will inform you of the reasons for the delay. To exercise your rights, we may need to verify your identity (to prevent unauthorized access by someone else to your data). This may include a request for additional identification information.

Most rights are free to exercise. We may charge a reasonable fee or refuse to comply with requests that are clearly unfounded or excessive (repetitive) – but always in a reasonable manner and in accordance with the law.

1.8. Protection of personal data (security measures)

The Company takes the necessary technical and organizational measures to ensure the security of personal data and protect it from unauthorized access, modification, disclosure or destruction. We recognize the importance of data protection, especially in the online environment, and take the following measures:

• Technical measures: Our Site operates via the secure HTTPS protocol using encryption (SSL/TLS), which ensures secure data transfer from your browser to our server. Data is stored on servers equipped with modern security measures (firewalls, intrusion detection systems, anti-virus protection, backup mechanisms). We regularly update software, apply security patches, use encryption for sensitive data (e.g. encryption of backups or databases, where appropriate). When transferring data to third-party processors (e.g. data exchange with payment gateways or analytics services), we also rely on encrypted communication channels (API with authentication, HTTPS, etc.).
• Organizational measures: We have an internal access restriction policy – ​​only those employees and contractors who need to know the data have access to it. Each such employee is trained in the basics of information security and confidentiality and is obliged to observe the confidentiality regime. We conduct periodic reviews and audits of data processing processes. Incident response procedures are in place, including an action plan in the event of a data leak. If, despite all measures, a data security breach occurs that poses a risk to the rights of users (e.g. a leak of personal data), we act in accordance with the GDPR: we will notify the supervisory authority (within 72 hours) and, in the case of a high risk, the affected users themselves without undue delay.
• Data minimization: We collect only the personal data that is necessary for specific purposes and store it for no longer than necessary (see section 2.6). The less data, the lower the risks – this is a key principle to which we adhere.
• Trusted Partners: When selecting third-party services and processors, we evaluate their reputation and security level. Each processor has a Data Processing Agreement that ensures compliance with GDPR requirements. We strive to cooperate with companies that have security certifications (e.g. ISO 27001) or have undergone an independent assessment.

However, please remember that no method of data transmission over the Internet or method of electronic storage guarantees 100% security. We cannot absolutely guarantee the absence of any threats (for example, new types of complex attacks). The User must also pay attention to security on his/her part: use up-to-date antivirus software, do not provide confidential data in unencrypted form, beware of phishing messages allegedly coming from the Company (our official correspondence is conducted from a domain address, and we will never ask for your password or payment details via email).

If you have reason to believe that your interaction with us is no longer secure (for example, you have discovered a vulnerability on the Site or noticed unauthorized use of your data), please notify us immediately (contacts – section 2.10). We value responsible disclosure of security issues and respond promptly to such reports.

1.9 Cookies and similar technologies

Since the use of cookies is described in detail in a separate Cookie Policy (section 3 below), here we will only provide a general explanation: The Site uses cookies and similar tracking technologies (pixels, local browser storage, etc.) to provide functionality, analyze traffic and (with your consent) for marketing purposes. Some cookies are absolutely necessary to provide our services (e.g. session cookies when filling out a form) and we use them on the legitimate basis of necessity. Other cookies (analytics, advertising) are used only with your prior consent, which you give via the cookie banner when you first visit the site or by managing cookie settings. More detailed information is available in section 3 of this document.

1.10. Contact details

For questions regarding this Privacy Policy, the processing of your personal data, and to exercise your rights, you can contact us as follows:

• Administrator (company): Jurisprudential Consulting Group SL
• Postal address: Calle Mayor de Sarrià, 12 - P. 1 PTA. 2, 08017, Barcelona, ​​Spain 
• Email: office@jurisprudential.eu

Please indicate in your request that your request concerns data protection issues. This will enable us to forward it to the responsible person more quickly.

We will try to answer all your questions and resolve any problems that may arise. Our goal is to ensure maximum transparency and user control over their personal data.

1.11. Changes to the Privacy Policy

This Policy may be updated by the Company as necessary – for example, when our data processing practices change, new services appear on the Site, legislation or regulatory requirements change. We will not limit your rights under this Policy without your express consent. All changes will be published in this section of the Site under the updated effective date.

If the changes are material, we will make reasonable efforts to notify you (for example, by placing a prominent notice on the home page of the Site, or by sending you an email if we have your mailing address). We encourage you to periodically review this page to review any changes. Your continued use of the Site following the posting of an updated Policy will constitute your acceptance of it.

2. Cookie Policy

This section explains what cookies are, what types of cookies are used on our Site, what purposes they are intended for, and how the User can manage cookie settings in accordance with applicable law (including the requirements of the GDPR and the ePrivacy Directive).

2.1. What is a cookie: A cookie is a small text file that is saved on the User's device (computer, smartphone, tablet) when visiting a website. Cookies allow the User's device to be recognized on repeat visits, remember their actions and preferences (e.g. interface language, login parameters), and collect technical information about the visit session. In addition to cookies, there are similar tracking technologies, such as pixel tags (small invisible images or code fragments downloaded when visiting a page, which record the fact of the visit or certain actions of the User), Browser Local Storage, SDK in mobile applications, etc. For the sake of simplicity, in this Policy all these technologies are referred to as “cookies”, although we are talking about a broader range of tools.

Cookies may be set directly by us (such cookies are called “first-party cookies”) or by third-party services that we cooperate with (“third-party cookies”). An example of a first-party cookie is a cookie that stores your choice of language on our Site. An example of a third-party cookie is the Google Analytics cookie, which Google sets on our behalf to collect visitor statistics.

2.2. How we use cookies: We strive to make work with our Site convenient and efficient, as well as to offer content that is relevant to Users. For this purpose, the Site uses several categories of cookies:

• Essential cookies: These cookies are required for the Site to function properly and enable basic functions. Without them, the Site cannot function properly. For example, such cookies allow you to navigate between pages, remember data entered in forms during a session. Strictly necessary cookies do not require the User's consent - we use them based on our legitimate interest in providing you with the online service you requested. Examples: cookies that store the user's session ID, cookies for server load balancing (so that the site remains available), cookies necessary for security (for example, to verify the token in the form and prevent CSRF attacks). These cookies are usually first-party cookies and can be temporary (session cookies, deleted after closing the browser).
• Functional (preference) cookies: These cookies allow the Site to remember the choices you make (e.g. interface language, region) and provide enhanced features that are more personalized for you. Functional cookies may also include those required for media playback (e.g. if a video is embedded on the site) or for third-party plugins that you use. Although consent may also be required by law for such cookies (if they are not strictly technical), their use is generally considered less invasive. Example: lang cookie – remembers the preferred language so that the site is displayed in Russian on your next visit.
• Analytics cookies: These cookies collect information about how visitors use our Site – which pages they visit, how long they spend there, what devices and browsers they use, whether there were any errors while browsing, etc. We use this data to analyze traffic and user behavior, which helps us improve the structure, navigation, and content of the Site. Important: We aim to collect aggregated and anonymized data where possible. For example, we can configure the web analytics service so that IP addresses are anonymized (cut off) and not saved in full. The main analytics tool we use is Google Analytics from Google (USA). Google Analytics uses cookies to collect information (such as your IP, browser data, pages viewed) and generates reports on how our Site is used. These reports do not allow us to personally identify any of the users; we need them solely for statistics. However, since the Google Analytics cookie stores a unique identifier on your device, this identifier can theoretically be linked to you (for example, if you are logged into your Google account on the same device). Analytics cookies are therefore considered by law to require consent. We only use Google Analytics with your consent via the cookie banner. Google acts as our data processor in accordance with our instructions. Google Analytics data may be transferred to and stored on Google servers in the US, but Google is committed to European data protection standards and uses standard contractual clauses for the transfer of data (for more information, see Google's privacy policy). You can opt out of analytics at any time - the options are described in Section 3.4 below.
• Advertising and Marketing Cookies: These cookies are used for marketing purposes, namely to track the User’s actions on the Website in order to provide personalized advertising and promotional materials on third-party platforms, as well as to measure the effectiveness of such advertising campaigns. Our Website may set cookies associated with advertising networks or social media platforms that we use to promote our services. In particular, we use Meta Pixel (formerly known as Facebook Pixel) – a tool from Meta Platforms (the owner of social networks Facebook and Instagram), which places a small piece of code on the pages of our Website. This code sets a cookie/pixel that allows us to associate your visit to our Website with your Facebook/Instagram account (if you have one and are logged in), and also to record certain of your actions on the Website (for example, visiting the Services page or sending a contact form). As a result, when you visit Facebook or Instagram, you may be shown a targeted advertisement from our Company (“remarketing”), or your visit may be counted for the purpose of ad conversion analysis (we will be able to see aggregated statistics on how many users came to the Site from our advertisement and what they did). The Meta Pixel cookie and similar third-party marketing cookies are also used only with your explicit consent. Without your permission, these files are not activated. We emphasize that such cookies may collect and transfer to third parties (e.g. Meta) certain data about your device and visits (including IP, pixel ID, action information). These third parties act not only as our processors, but also as independent controllers using the data for their own purposes (e.g. for ad targeting within their platform). You can find out more about how Meta uses pixel data in the Facebook/Meta Data Policy on their official website. We recommend that you familiarize yourself with these policies, as they are outside the control of the Company.
• Other third-party cookies: Depending on the functionality of the Site, other third-party tools may be used that set cookies. For example, if the Site embeds a YouTube video, a Google Maps map, social media share buttons or callback/chat widgets from external services, they may all set cookies. Such cookies also generally require consent unless they fall into the necessary category. We do not list every possible provider in this Policy, but we do ensure that we either ask for your consent to use them or disable them by default until consent is obtained. In Section 5 below (Third-party services), we provide general information about which third-party services we may use and under what conditions.

2.3. List of cookies used: Below is information about specific cookies that may be used on our Site, indicating their name, purpose and expiration date:

• Cookies required for the operation of the Site:
  • PHPSESSID (or similar session identifier) ​​– stores the user session identifier so that the Site recognizes requests from the same user when switching between pages. Validity: for the duration of the current session (deleted when the browser is closed).
  • cookie_consent – ​​records the fact that the User has seen the cookie banner and made a choice (agreed or configured them). Thanks to this file, the Site will not show the notification again each time you visit. Validity period: for example, 6 months.
• Analytical cookies (third parties):
  • _ga – the main Google Analytics cookie, used to distinguish users by assigning a unique random identifier. Duration: 14 months (with the possibility of renewal with each visit).
  • _gid – Google Analytics auxiliary cookie, used to distinguish users within one day. Duration: 24 hours.
  • _gat – cookie to limit the frequency of requests to the Google Analytics service (to avoid overload). Duration: 1 minute.

(Note: In newer versions of Google Analytics 4, other cookies are used, such as _ga_ , different logic of identifiers; we adapt to their use also within the limits of agreement.)

• Marketing cookies (third parties):
  • fr – Facebook cookie (Meta) for delivering, measuring and improving the relevance of advertising. It contains an encrypted browser and Facebook user ID. Duration: 90 days.
  • _fbp – Facebook cookie, used to identify browsers for the purpose of providing analytical services and advertising. Duration: 90 days.

(Note: The Meta Pixel cookie set may change; Meta may add other identifiers.)

• Functional/preference cookies:
  • lang – remembers the interface language selected by the user (for example, ru for Russian). Duration: 1 year.
  • [name]_cookie – any other cookies related to user settings (e.g. font scale, display mode), if such functions are implemented. Duration: from a session to several months.

(The list may be updated as the set of cookies used changes. We strive to keep this table up to date, but minor deviations are possible. In any case, no optional cookies will be used without your consent.)

2.4 Obtaining consent to use cookies:

In accordance with EU law, explicit prior consent from the user is required for the storage/reading of cookies that are not strictly necessary. When you first visit our Site, you will see a banner (notification) about the use of cookies. In this banner, you are asked to agree to the use of cookies (e.g. the "Accept all cookies" button) or to set your preferences (e.g. enable only certain categories of cookies). Until you have expressed your choice, no non-essential cookies will be installed on your device (only strictly technically necessary cookies will work).

We try to provide you with sufficient information directly in the banner interface – briefly explaining which categories of cookies are used and providing a link to this Policy for details. Your choice (consent or refusal of certain categories of cookies) will be recorded and remembered for a certain period (usually 6-12 months, after which the banner may appear again to update your choice due to possible changes or as required by law).

You can change your cookie settings at any time. For this purpose, the Site provides a link "Cookie settings" (or similar), accessible in the footer (bottom of the page) or in the profile settings (if applicable). By clicking it, you can open the cookie control panel and revoke the previously given consent or give consent if you initially refused. In addition, you can always revoke consent by clearing cookies through your browser settings - after which the banner with the choice will appear again the next time you visit the Site.

2.5. Managing cookies via browser settings:

In addition to our consent mechanism, you have the ability to control cookies at the level of your web browser. Most browsers are set to accept cookies by default, but you can change your settings so that your browser blocks third-party cookies or notifies you when a server attempts to set a cookie. You can also delete cookies that have already been saved at any time. Please note that disabling all cookies may affect the functionality of many websites (including ours): for example, some preferences will not be saved, authorization on websites may not work, etc.

Here are links to instructions on how to manage cookies for popular browsers:

• Google Chrome – (Settings -> Privacy and security -> Cookies and other site data).
• Mozilla Firefox – (Tools -> Settings -> Privacy -> Cookies).
• safari – (Settings -> Privacy -> Manage website data).
• Microsoft Edge – (Settings -> Cookies and site permissions).
• Opera – (Settings -> Advanced -> Privacy and Security -> Site Settings -> Cookies).

2.6 Disabling Google Analytics and Advertising:

If you want to prevent data collection by Google Analytics in addition to cookie settings, Google provides an optional browser add-on – Google Analytics Opt Out. By installing it, you will prevent the transmission of visitor data to Google Analytics from all sites, not just ours.

To manage personalized advertising displayed on social networks and advertising networks:

• Facebook/Instagram Ad Preferences (Meta) settings allow you to opt out of ads based on activity outside of these platforms (see the Ad Preferences section of your Facebook account). You can also visit Facebook's Personalized Ads Opt-Out Page for instructions.
• Many large ad networks participate in self-regulatory programs where you can opt out of behavioral advertising centrally. For example, on sites like YourOnlineChoices EU or Network Advertising Initiative a list of companies is provided – you can disable or enable targeting for each of them. Please note that this opt-out is cookie-based – if you delete the cookie, the opt-out companies will not be able to recognize you and the ads will become personalized again, so you may have to repeat the procedure.

2.7. Consequences of disabling cookies:

You have the right to disagree with the use of cookies (except for essential ones), but you should understand that in this case some of the Site's functions may be unavailable or limited. For example, disabling functional cookies will mean that you will have to re-select the interface language each time you visit; disabling analytical cookies will leave us without usage statistics, but this will not noticeably affect your experience; and disabling marketing cookies simply means that you will see less relevant advertising on other resources (but the volume of advertising will remain the same).

We do not restrict access to the Site for users who have refused optional cookies – you will still be able to view content and use basic services. Our cookie banner provides the option to “Opt out of all optional” or not to consent at all (simply close the notification without consenting), and we will not force you to consent.

2.8 Cookie Policy Updates:

Any changes to the cookies we use will be reflected in this section of the Policy. If we start using new categories of cookies or new services that require consent, we will update the information and ask for your consent again when you visit the Site. The date of the last update of the Policy is indicated at the beginning of the document.

3. Conditions for processing personal data

This section supplements and to a certain extent summarizes the provisions of the Privacy Policy, focusing on the legal terms of processing the personal data of Users and the User's consent to such terms. It serves as a kind of agreement on the processing of personal data between the User and the Company.

3.1 Lawfulness and fairness of processing

The Company processes the personal data of Users strictly in accordance with the current data protection legislation, in particular the GDPR, the Spanish Organic Law on Data Protection (LOPDGDD) and other applicable regulations. We adhere to the principles of lawfulness, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality (Article 5 of the GDPR). Processing is carried out on the legal grounds described in Section 2.3 above (consent, necessity for a contract, legitimate interest, etc.) and does not go beyond the stated purposes (Section 2.2).

By using our Site and/or providing the Company with their personal data (e.g., filling out forms, sending requests), the User confirms that they have read these Rules, including the Privacy Policy, and agrees to the processing of their personal data in accordance with the stated terms. In cases where the law requires separate explicit consent (e.g., to install marketing cookies, to receive advertising mailings), we request it through specific actions by the User (clicking "Accept", checking a checkbox, etc.).

3.2. Scope of the User's consent

By agreeing to these terms, the User gives the Company permission to perform all necessary actions with his/her personal data described in the Privacy Policy, namely: collection, systematization, storage, use, transfer to third parties under the terms of Section 2.4, depersonalization, blocking or deletion - depending on the applicable situation. Such consent covers both automated processing and non-automated processes (for example, maintaining a paper archive of contracts with clients, if this is the case).

The User agrees that in order to achieve the processing purposes, the Company may combine personal data obtained in various ways (for example, compare information provided through the feedback form with technical data on visiting the Site in order to better understand the User's needs). At the same time, the adoption of automated decisions that generate legal consequences for the User is not carried out without additional notification and consent of the User.

In addition, the User understands that the data provided by him/her must be current and accurate, and undertakes to update it, if necessary, by sending the Company correct information. The Company shall not be liable for damages arising from receiving inaccurate, unreliable or outdated information directly from the User.

3.3. Privacy and security

The Company undertakes to maintain the confidentiality of the Users' personal data and to process them strictly in accordance with the procedure provided for in this document. The Parties acknowledge that the User's personal data is confidential information. The Company has implemented all organizational and technical measures sufficient to protect such data (as set out in Section 2.8). Personal data will not be disclosed or transferred to third parties without legal grounds. All employees who have access to personal data are bound by confidentiality obligations.

As part of providing access to the Site, the User also undertakes not to attempt to obtain personal data of other Users, not to violate security measures, not to bypass access restrictions. If a leak or threat of leakage of their personal data is detected, the User has the right to notify the Company about this and receive information about the measures taken.

3.4 Withdrawal of consent and termination of processing

As stated in Section 2.7, the User has the right to revoke their consent to the processing of personal data at any time (in cases where the processing is based on consent). The revocation can be implemented by sending a corresponding request (see contacts in Section 2.10) or by performing certain actions provided on the Site (for example, changing cookie settings, unsubscribing from mailings).

In case of withdrawal of consent, the Company will stop processing the User's personal data related to the purposes for which consent was withdrawn, with the exception of processing that may be carried out on another legal basis (for example, storing some data in connection with a legal obligation or legitimate interest, despite the withdrawal of consent for marketing). Please note that withdrawal of consent for processing may result in the impossibility of providing some services - for example, if you withdraw consent to the processing of contact information before the completion of the consideration of your request, we will not be able to respond to you and communication will be terminated.

The User may also exercise the right to delete data, as described above. If one of the grounds provided by law occurs, the Company, at your request (or on its own initiative, when the goal has been achieved), will delete or anonymize your personal data, ceasing to process it.

3.5 Inclusion of new purposes or types of processing

If the Company decides to use personal data for new purposes not specified in the original Privacy Policy, or to begin processing already collected data in a different way that changes the terms, then before starting such processing, we will either update this document and notify Users (if necessary, requesting new consent), or, if required by law, obtain your express consent for additional purposes.

However, in general, the structure of these Rules is such that it provides for the main possible processing scenarios with sufficient flexibility to cover new instruments without fundamentally changing the conditions. For more details, see Section 7 below.

3.6. Additional agreements

In the event that the User enters into more formal relations with the Company (for example, concludes a separate agreement for the provision of services), issues of personal data processing may be additionally regulated by the provisions of such an agreement and a separate Policy or Consent signed upon conclusion of the agreement. These Rules, in the part that does not contradict a specific agreement, continue to apply to the processing of personal data when using the Site.

Also, if certain services on the Site require separate consent (for example, the “I agree to the processing of personal data” checkbox under the webinar registration form), the text of such consent may provide more detailed conditions that should be read together with these Rules. The Company strives to avoid duplication, so we usually refer to this Policy in such cases to avoid contradictions.

3.7. Other conditions

These terms of personal data processing constitute an integral part of the User Agreement. Their violation by the User (for example, providing false personal data, using third party data without reason) is considered a violation of the terms of use of the Site. The Company, for its part, is responsible for the processing of Users' personal data in accordance with applicable law and these Rules. In the event that the User suffers damage due to the illegal processing of his data, he has the right to demand compensation for damage in the manner prescribed by law (Article 82 of the GDPR, etc.), however, the Company may be held liable only if its guilt or violation of requirements is proven.

4. Notices about the use of third-party services

Our Site integrates or interacts with a number of third-party services and platforms that help provide functionality, analysis and other features. In this section, we notify Users of such use of third-party services, provide examples and explain the related terms.

4.1. General provisions

Some functions of the Site are implemented using external services, which may mean the transfer of certain data to these third parties or their interaction with your device. In some cases, such services collect and process data about Users for their own purposes (e.g., statistical or advertising). The Company carefully selects third-party services, giving preference to well-known and reliable providers, and concludes the necessary data protection agreements with them. However, it is important to understand that each such service operates according to its own rules and policies, which we recommend that you familiarize yourself with. Below are the main third-party services used on the Site and key notices about them:

• Google Analytics: (Mentioned earlier in the Cookie Policy, we will repeat briefly.) This is a web analytics service from Google that we use to collect anonymous statistical data about the use of the Site. Google Analytics sets cookies and collects data (such as IP address, browser information, page actions) to compile reports. Google acts as a processor, acting on our behalf, but Google may use aggregated data to improve its services or develop new ones. We do not share any personally identifiable data (such as names or contacts) with Google, and IP anonymization is enabled in our settings. However, Google may have access to some of the data (including your shortened IP and cookie ID) for its internal work. Google is certified to security standards and (at the time of writing) declares compliance with the GDPR. You can read Google's privacy policy hereIf you do not want to participate in analytics, you can disable it as described in section 4.4.
• Meta Pixel (Facebook Pixel): As stated, we use the Facebook/Meta social network pixel for advertising analytics and remarketing purposes. This means that information about your visit to our Site (e.g. a specific page view, conversion) will be reported to Meta Platforms, who may associate this data with your Facebook/Instagram account and use it to show you ads or improve the ad serving system. Meta may set a cookie (_fbp, fr, etc.) on your device or use existing Facebook application identifiers. We do not receive personal data about individual users from Meta - we only see aggregated reports (e.g. "N users visited our site, X% of whom completed the target action"). However, Meta acts as an independent controller when processing pixel data, so the data they actually collect is governed by Meta's Data Policy. This data includes: HTTP headers (IP, browser, page information), pixel data (ID, event type, time), and possibly demographic or other information if you are logged in to them. Meta stores this data for typically 90 days, after which it is anonymized. If you do not want Meta to receive data about your visits, please opt out of marketing cookies on our Site (we will not activate the pixel without your consent). If you have agreed but have changed your mind, you can change your settings (see 3.4) or disable personalized advertising through your Facebook account. We inform you that Meta Platforms, Inc. is located in the United States and pixel data may be transferred there under standard contractual clauses.
• Payment services (example: Revolut, PayPal, etc.): If the Site offers the ability to pay for services online (e.g. paying for a consultation or booking a seminar), we may engage third-party payment providers to process transactions. The question provides the example of "Revalut", which likely refers to the Revolut service, a fintech platform that provides payment services. If Revolut (or a similar service) is integrated on the Site, when the User clicks the payment button, they may be redirected to the payment system page or an external widget. Any financial data (card numbers, accounts) entered during payment are sent directly to the payment system (e.g. Revolut, Stripe, PayPal) and are not stored on our Site (except for marking the fact of payment). We only receive information about the payment status (success/failure) and, possibly, a unique transaction identifier from the payment provider. In the case of Revolut, this company is licensed as a banking/payment institution and will independently control the personal data associated with the payment (e.g. your payment details, cardholder name). Revolut applies its own Privacy Policy and security rules. Other systems, such as PayPal, work similarly. We inform you that by using the online payment option, you automatically agree to the processing of your data by the selected payment service under the terms of this service. If you do not agree, you can choose an alternative payment method (e.g. manual invoicing).
• Other external tools: The site may contain elements and libraries loaded from external CDNs or sources (e.g. Google Fonts, library scripts). Such connections could theoretically reveal your IP address to a third-party host (e.g. Google Fonts server when loading a font). We use them to optimize display speed and quality. Google has stated that using Google Fonts locally or via API does not collect or store personal user data (after a well-known case, we may host critical fonts locally to avoid data transfer).

Also, if the Site embeds YouTube videos, Google Maps or social media widgets (e.g. the Facebook Like button), please note that these elements may set cookies and collect interaction data even without a click (especially social buttons). We try to implement them in a “two-click” mode (i.e. disabled by default until you explicitly click). When interacting with such embedded elements, you are actually using a third-party service and are subject to the terms of use and privacy policies of the relevant third-party providers (YouTube/Google, Facebook/Meta, etc.). The Company is not responsible for how these providers process your data, but we are ready to provide information and assistance if you have any questions (as far as this concerns data passing through our Site).

• Communication tools: If the Site has an online support chat or a callback form via a third-party service (e.g. Tawk.to, Zendesk Chat, JivoSite, etc.), when you interact with such a service, certain data (text of the conversation, specified contact information, technical parameters) will be transferred to the chat provider. We select services that comply with the GDPR and enter into data processing agreements with them. But it is important to know that your messages may be stored on their servers (usually in the EU or the US) for some time. Such services usually act as processors on our behalf, not using your data for their own purposes. However, please read the brief information they usually provide when you open a chat (e.g. “By clicking start chat, you agree to…”).

4.2. Limitation of liability for third-party services:

The Company is not responsible for the functioning and actions of third-party services, as it does not directly manage them. We act as a user of these services on an equal basis with you. Despite our efforts to select reliable partners, we cannot guarantee their absolute uninterrupted operation or compliance with the User's expectations. Any claims arising from the use of functionality provided by a third-party service should also be addressed to this third party. For example, if there is a failure in online payment due to the fault of the payment gateway, the Company will try to facilitate a solution, but the primary responsibility lies with the payment provider in accordance with its terms of service.

4.3. Consent to interaction with third-party services:

By using the Site and its individual functions, you automatically agree that external services integrated into the Site may interact with your device and process your data as described above. This is an integral part of providing our service. Otherwise, we would not be able to provide, for example, online payment or viewing a map of the office location. If you do not want any data to be transferred to third parties, you can limit the use of the relevant functions (for example, do not use the map on the site, but open the address specified in text in your preferred application; do not use the online chat form, but call / write to us directly, etc.). At the same time, we assure you that all integrations are implemented in accordance with legal requirements - either on the basis of your consent (as with cookies and pixels) or on the basis of necessity (as with payments upon your request).

4.4. List of main third-party services used by the Company:

For convenience, let us repeat/summarize the key services:

• Analytics: Google Analytics.
• Marketing: Meta (Facebook/Instagram) Pixel, possibly LinkedIn Insight Tag (if used – similarly, for LinkedIn advertising), Google Ads Conversion Tracking (if we use Google contextual advertising – cookie from Google Ads).
• Payments: for example, Revolut, Stripe, PayPal – for online payment of services.
• Maps: Google Maps (embed office map).
• Multimedia: YouTube/Vimeo (video presentations).
• Support chat: (if any, please specify, or absence).
• Fonts/libraries: Google Fonts CDN, Cloudflare CDN (to speed up content delivery).

Each of the listed providers has its own terms and policies. If you have any questions, we are ready to tell you where to find them and how they may affect your data.

Let us repeat: by accepting these Rules, you are notified of the use of the listed services and agree that their use is part of the functionality of the Site. The Company takes measures to ensure that any interaction with them occurs within the legal framework and is safe for users.

5. Automatic consent of users when visiting the Site

In order to ensure transparency, we explain how exactly the user's consent to these Rules and their individual sections is recorded when visiting and using the Site.

5.1. Acceptance of the Terms of Use: When visiting the Site for the first time, the User has access to a link to these Rules (usually in the footer of the site under the title "Rules of Use", "User Agreement" or similar). By continuing to use the Site - viewing pages, clicking on links, filling out forms - the User automatically confirms his/her consent to the terms of the User Agreement (section 1) and all other rules set forth in this document. In other words, the fact of using the site indicates the conclusion of the Agreement on the stated terms by the user's implicit actions.

If you do not agree with these terms in whole or in part, you must immediately leave the Site and refrain from further use of its materials and services.

5.2. Consent to the privacy policy: By using the Site and providing any personal data through it, the User thereby expresses consent to the collection and processing of this data in accordance with Section 2 (Privacy Policy) and Section 4 (Terms of Data Processing). On some pages of the Site (e.g., the feedback form, registration for an event), we may also place a short notice of the following type: "By submitting your data, you agree to the privacy policy." Submitting data in this case is a clear confirmation of consent. If the User does not accept the terms of personal data processing, he/she should not provide it through the Site.

5.3. Cookie and Tracker Consent: As detailed in Section 3, when entering the Site, the User is shown a banner asking for consent to the use of certain types of cookies. By clicking the “Accept” button in this notification (or continuing to use the Site after the notification appears, in the case of the “by continuing to use, you agree” mechanism), the User consents to the storage of cookies on their device and the collection of data through them in accordance with the Cookie Policy. This is considered automatic consent, since it is expressed by performing an action (continued navigation or explicit confirmation on the banner). If the banner refuses (if the User clicks “Decline” or selects the settings, disabling all non-functional cookies), it is considered that consent has not been provided, and the corresponding cookies do not work. In the future, if the User wants to change the choice, he/she can do so (described earlier).

5.4. Automatic consent to updated terms: As stated, the Company may periodically make changes to these Rules. After the publication of a new version on the Site, the User's continued use of the Site will be interpreted as tacit consent to the updated terms. If the User does not agree with the changes made, he/she must stop using the Site and, if desired, can contact us to clarify the disagreement. We value our Users and are open to discussing the terms, but we do not practice forcing consent - you can always refuse to use our web resource if the terms do not suit you.

5.5. Consent recording: The Site's technical logs and databases may store records confirming your consent: for example, a timestamp and IP address when the User Agreement was accepted, or a note about which buttons you clicked in the cookie banner. This information is stored for evidentiary purposes (GDPR requires the ability to demonstrate the consent received). We guarantee that such records will only be used to confirm the fact of consent and manage settings, and will not be used for other purposes.

5.6. Preliminary familiarization: We proceed from the presumption that each User has read these Rules before using the Site. We have made them accessible and tried to present them in understandable language. Ignorance of the terms does not relieve the User from liability for their failure to comply. In particular, if the User continues to use the Site without reading this document, it will still be considered that he/she has agreed to the terms and bears the obligations associated with it. Therefore, we strongly recommend that you take the time to read the legal documents on the sites, especially when it comes to personal data.

In summary: whenever you visit and interact with this Site, you confirm by your actions that you accept the current "Terms of Use" in their entirety, including the User Agreement, Privacy Policy, Cookie Policy and other sections. This automatic consent is valid as long as you use the Site. If you do not agree, you have the right to revoke it by leaving the resource and ceasing to use it.

6. Implementation of new tools and services (changes without modification of conditions)

This section sets out the legal and technical guidelines and principles that the Company follows when adding new features, tools or integrations with services to the Site, in order to avoid the need to change the terms and conditions and re-obtain consents in each case, without sacrificing transparency and legality.

6.1. Universality of these Rules

These Terms of Use of the Site are initially formulated to cover a wide range of possible scenarios for data processing and use of services. We have deliberately described the categories of services (analytics, advertising, payments, etc.) and types of personal data (contact, technical, etc.) in a generalized form. This means that if in the future the Company decides to connect a new service similar to those already described, or to expand the functionality of the Site, but within the framework of the already outlined purposes and categories of data, then no additional changes to the text of the Rules may be required.

For example, if we currently use Google Analytics for analytics, and later switch to another web analytics tool (say, Matomo or Yandex.Metrica), the goals will remain the same (traffic analysis), the data categories will remain the same (technical data, cookies), and the user consent for analytics obtained earlier will also cover the new tool. Of course, we will update the Cookie Policy, indicating the name of the new tool, but your previously made choice (consent or refusal of analytical cookies) will remain in effect. Thus, the new service will fit within the framework of the existing conditions.

Another example: we have now stated that we can use the Meta pixel for advertising. If in a year a new social network appears where we want to place advertising (for example, the conditional “X” or LinkedIn), and we implement their pixel - it will also be covered by the general category of “marketing cookies and pixels”, which requires your consent. We will simply add it to the list of those used, and if you have consent to cookie marketing enabled, it will be activated; if disabled, it will not work. You will not need to separately consent to the “new pixel”, because you have either already given general consent to all marketing trackers, or have refused them all.

Conclusion: The consent structure we have organised (by categories) and the broad formulation of the purposes of data processing allow us to flexibly incorporate technological innovations without changing the legal basis.

6.2. Evaluation of legal consequences in new integrations

Before connecting a new tool or service, the Company conducts a legal analysis: whether the new data processing scenario relates to the already described purposes and grounds, or it introduces a qualitatively new purpose/category. If the new introduction does not change the essence of the processing (for example, replacing one service with another, adding a similar function), we believe that the current consents of users are sufficient. If a new purpose is planned (for example, to start collecting new types of personal data, to use them for new purposes not provided for in the Policy), then we will make changes to the Privacy Policy and other sections, and, if necessary, request consent from users.

Example: Let's say we decide to launch personalized push notifications via the browser. This is a new interaction channel that requires collecting user browser tokens and their explicit permission to send notifications. This feature is not described directly in the current Policy. Before implementation, we will add a corresponding description (purpose - informing users about updates, data - push token, reason - consent) and implement a consent request for subscription. This is a significant innovation that users will learn about and give separate permission.

Another example: we are introducing a new type of content – ​​for example, a forum for users. This means that users will be able to post messages, and we will store and display their content. This is also a new situation (previously the site was static). In this case, we will develop Rules for the forum and introduce them either as part of the Agreement or as a separate document, and we will ask users to accept these rules before using the forum (for example, via a checkbox when registering on the forum).

6.3 Technical measures for easy integration

From a technical point of view, we are building the Site so that the integration of a new service does not require a global reworking of the consent system. For example, we use a tag manager (Google Tag Manager or similar) for centralized management of third-party service scripts. This allows:

• Add/remove scripts (pixels, analytics) without changing the Site code, but through the GTM interface, where triggers are configured that take into account user consent.
• Flexible configuration of which scripts are launched at which consent status. So, if we add a new analytics script, we simply mark it as “analytics” category – and it will automatically obey the previously given consent (i.e. launch only for those who have agreed to analytics). Same for marketing.

This approach ensures technical compatibility of new services with the existing consent system without changing the user interface.

In addition, we try to choose universal libraries. For example, if we use a graph display library, we choose one that does not send data outside and does not require additional notification. This will not require changes to the Policy.

6.4. Informing without renewing consent

If a new tool significantly affects data processing but still fits into general categories, the Company may consider it necessary to inform users without asking for new consent. For example, if we start using a new analytics option, we may notify you via a news item on the site or update the Policy with a note. This will be done for the sake of transparency, although the old consent will formally cover the new tool. Users who disagree with such an innovation will be able to revoke their consent (as described above).

6.5 Regular compliance audit

The Company periodically (at least once a year, as well as with each major update of the Site) conducts an internal audit: checks whether all technologies and services used on the Site are taken into account in the legal documentation, and vice versa - whether there are any outdated references in the documentation. This allows us to keep the Rules up to date. This approach ensures that "without the need to modify the terms" does not mean "never modify the terms", but means that the terms are general enough to cover minor changes, and at the same time we keep them in good shape and do not allow them to become outdated.

6.6. Reserve coverage for new cases

In case any new situation is not expressly described in these Rules, the following general reservations apply:

• These Rules are interpreted in favor of maximum protection of the User's rights and in light of applicable EU legislation. The absence of a direct reference to any tool does not mean that the Company is exempt from the obligation to comply with the law when using it. We will still act in accordance with the GDPR and obtain the necessary consents.
• No new data will be used for purposes incompatible with the original purposes of data collection without the user's explicit consent.
• In the event of any legal ambiguity or dispute regarding the new tool, the user's rights and the spirit of the law shall prevail. The Company will clarify the rules in its and your favor at the earliest opportunity.

In other words, we aim to lay the groundwork for future changes in advance, and when they occur, act responsibly and either quietly integrate them into existing categories (if harmless and intended) or transparently update documents and obtain consent (if significant).

6.7. Example scenario – implementation of a new tracker:

Let's say that after some time we decide to implement a user experience tracking tool on the site - for example, a screen recording service for visits (like Hotjar or Yandex.Metrica with scroll maps) to better understand how users scroll the page. Such a tool collects behavioral data, can record keystrokes (with anonymization). This can be attributed to analytical processing, but it is more invasive than regular metrics, and users should know. We, analyzing, will decide: 1) whether it is included in the existing goal of "improving the site" - yes, quite; 2) whether it is necessary to update the Policy - most likely yes, it is worth explicitly mentioning the new type of collection (session recording) so that users are informed; 3) technically - we will put the script in the analytics category, which means that the current consents for analytics will cover it - no need for everyone to click again. But, perhaps, for reasons of openness, when launching a new thing, we will show a short notification: "We are starting to use a tool for studying the interface. The data is anonymized. More details are in the updated policy." The user can click "OK" or close - this is just information. And/or we will describe in the Policy, and on the cookie banner in the analytics list we will add "including behavior visualization tools". Thus, compliance is achieved without requiring new actions from the user.

6.8. Benefit for the User:

By supporting this approach (general rules + rare updates), we save the User from having to read and agree to tons of new legal text with every small innovation. The rules are written as comprehensively as possible from the very beginning, covering all the “what ifs”. This saves your time and nerves, and also maintains the continuity of your consent. Of course, we will highlight major changes and bring them to your attention, but you will not have to tick new boxes every couple of months for every little thing - we made sure that your initial consent was sufficiently broad and informed, but does not violate the law.

6.9. Your actions if you do not agree with the new:

If, despite our efforts to include a new service under the old consent, you still find that a specific new feature is unacceptable to you, you can always withdraw your consent (for example, by disabling the relevant category of cookies if it is something tracking, or asking us not to use your data in the new feature, or stop using the site). We are open to feedback: if you think a new tool violates privacy, you can write to us, and we will consider your point of view. We try to use only those new technologies that comply with the principles of Privacy by Design.

In conclusion, we note: the Company's priority is to respect the rights of users and laws, so no new tools and services will be introduced at the cost of violating these rights. These Rules are a living document, and our approach "without the need to modify the terms" will never mean "without considering the legal consequences." It is more about the convenience of users: you do not need to sign a new agreement every time - we tried to include everything that may be needed at once, and we will keep this document up to date so that it remains a sufficient cover over all the innovations of the Site.

Thank you for taking the time to study the "Rules for using the Jurisprudential Consulting Group SL website". If you have any additional questions or concerns about any of the sections, please contact us through the specified contacts. We value the trust of our Users and are ready to clarify any unclear points.

By using this Site, you confirm that you understand and accept all of the above terms and conditions.