Tradilex

Cookie policy

1. General information

1.1 This Cookie Policy governs the use of cookies and equivalent technologies on the Tradilex platform, in compliance with Section 22.2 of the Act 34/2002, Spanish Information Society Services and Electronic Commerce Act (LSSI-CE), of Regulation (EU) 2016/679 (GDPR) and the Spanish Data Protection Agency’s Guide on the Use of Cookies.

  • Data controller: Universidad Nacional de Educación a Distancia (UNED), Spanish Tax Identification Number (NIF) Q2818016D, calle Bravo Murillo, 38, 28015 Madrid, through its TRADIT Research Group
  • Data Protection Officer: dpd@adm.uned.es

1.2 The information provided in this Cookie Policy is supplemented by the platform’s Privacy Policy, which is available at https://www.tradilex.es/en/politica-privacidad-en.

1.3 This Policy supersedes any previous version; In particular, it renders null and void any references to “tacit” or “by use” acceptance of cookies and to “abandoning browsing” as the sole alternative, as these practices are incompatible with the applicable legislation.

2. What are cookies?

2.1 Cookies are small files that websites store on a user’s device (computer, tablet, or phone) when they visit their pages. They enable the website to function, remember preferences, analyze how the website is used and, where applicable, manage content or advertising.

2.2 For the purposes of this Policy, the term “cookies” includes other equivalent technologies used to store and retrieve information from a user’s device, such as browser local storage (HTML Local Storage) or integrated databases (IndexedDB).

3. Types of cookies

3.1 Cookies may be classified according to the following criteria:

  • a) According to who manages them: first-party cookies (managed by UNED through the tradilex.es domain) and third-party cookies (managed by entities other than UNED, in particular Google LLC in connection with embedded YouTube videos).
  • b) According to their duration: session cookies (deleted when the browser is closed) and persistent cookies (which remain for the period specified in the cookie inventory).
  • c) According to their purpose: strictly necessary (technical) cookies, preference cookies, analytics or statistical cookies, and marketing or advertising cookies.

4. Cookie inventory

4.1 The cookies used by the platform are listed below, based on the automated scan performed using the Cookiebot tool, together with their name, provider, purpose, duration, technology, and category:

5. Legal basis and obtaining consent

5.1 Strictly necessary cookies are installed without prior consent, under the exception set out in the final provision of Section 22.2 of the LSSI-CE, as they are essential for providing the service expressly requested by the user.

5.2 All other cookies, including preference, analytics, and marketing cookies, as well as third-party cookies loaded by YouTube, require the user’s prior, freely given, specific, informed, and unambiguous consent, in accordance with Articles 4(11) and 7 of the GDPR and Section 22.2 of the LSSI-CE.

5.3 Consent is obtained through the cookie banner displayed upon the user’s first visit, which provides the options to accept all cookies, reject all non-essential cookies, or manage consent granularly by cookie category, with all options presented with equal visibility and accessibility. The option to reject non-essential cookies is therefore as accessible as the option to accept them.

5.4 Continued browsing, scrolling through the page, or simply remaining on the website does not constitute valid consent. Non-essential cookies, including those associated with the embedded video, are neither installed nor loaded before the user’s consent has been obtained.

6. Information language

6.1 Both this Policy and the consent management panel are provided in the active interface language (Spanish or English), ensuring equivalent information across both versions, in accordance with the transparency principle set out in Article 12(1) of the GDPR and the Spanish Data Protection Agency (AEPD) Guidelines on the Use of Cookies.

7. Third-party embedded content (YouTube)

7.1 The platform incorporates videos from YouTube (Google LLC). Such content, together with any associated cookies, is only loaded after the user has given their consent. Until consent is provided, a notice or placeholder is displayed instead of the video.

7.2 Where technically feasible, the video is served using YouTube’s enhanced privacy mode (youtube-nocookie.com domain). Further information on the processing of personal data by Google LLC can be found at: https://policies.google.com/privacy.

8. Consent management, modification and withdrawal

8.1 Users may modify or withdraw their consent at any time through the persistent consent management icon displayed on the platform, which provides access to the granular settings panel by cookie category, or through their browser settings (see Section 10).

8.2 Withdrawal of consent takes effect prospectively and does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. It may result in the loss of functionalities associated with the blocked cookies, such as the playback of embedded videos.

9. International data transfers

9.1 Acceptance of analytics and marketing cookies loaded from youtube.com involves the disclosure of user data (including IP addresses, technical identifiers, and player interaction data) to Google LLC, based in the United States, which constitutes an international transfer of personal data outside the European Economic Area.

9.2 Where applicable, this transfer is based on the EU-U.S. Data Privacy Framework adequacy decision (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023), insofar as Google LLC is certified under that framework, or, alternatively, on the Standard Contractual Clauses pursuant to Article 46(2)(c) of the GDPR. If these cookies are not accepted, no such transfer takes place.

10. Browser settings

10.1 Users may also restrict, block, or delete cookies through their browser settings, in accordance with the official instructions provided by each browser manufacturer:

10.2 Blocking cookies at the browser level may affect the proper functioning of certain features of the platform.

11. Proof of consent

11.1 In accordance with the principle of accountability set out in Article 5(2) of the GDPR, the controller retains, through Cookiebot, evidence of the consent given by each user and for each session, including the Consent ID, the date and time consent was provided, and the version of the information presented. This evidence is retained for the duration of the consent and thereafter for the periods required for evidentiary purposes.

12. Data subject rights

12.1 Users may exercise their rights of access, rectification, erasure, objection, restriction, and data portability, as well as withdraw their consent, by contacting the Data Protection Officer at dpd@adm.uned.es or through the UNED’s online portal. You may also file a complaint with the Spanish Data Protection Agency (www.aepd.es; Calle Jorge Juan, 6, 28001 Madrid).

13. Updates to the Cookie Policy

13.1 This Policy may be updated to reflect regulatory, judicial, or technical developments, as well as the addition, modification, or removal of cookies. The current version of the Policy will be the one published on the website, together with the date of the latest update.

13.2 Effective as of the date of publication.