Cookie policy

1. Introduction

This Cookie Policy (the "Policy") describes how Golova Europe SL (Tax ID B70717004, EU VAT ESB70717004, registered office at Calle l'Hospital 95, Planta 1, Puerta 2, 08001 Barcelona, Spain; the "Controller", "Puntavia", "we") uses cookies and similar technologies on the website https://puntavia.com and in the Puntavia control panel (the "Services").

This Policy complements our Privacy Policy and is published in compliance with Article 22.2 of Spanish Law 34/2002 (LSSI-CE), Article 5.3 of Directive 2002/58/EC (ePrivacy Directive), Regulation (EU) 2016/679 (GDPR) and the Guidance on the use of cookies issued by the Spanish Data Protection Agency (AEPD).

The desktop program that records working time uses no cookies: it communicates directly with our servers. What that program collects is described in the Legal Notice and in the Privacy Policy.

2. What cookies are

Cookies are small text files that a website places on your device (computer, tablet or phone) when you visit it. They allow the site to recognise your browser on later visits, keep you logged in, remember your preferences and keep forms secure.

This Policy also covers similar technologies that serve comparable purposes, in particular the browser's local storage (localStorage). For convenience, all of these are referred to below as "cookies", with the actual nature of each one stated in every case.

3. Categories of cookies we use

Cookies are classified by who sets them (first-party or third-party), by their duration (session or persistent) and by their purpose (strictly necessary, functional, analytics or advertising).

Every cookie in the Services is first-party: it is set by Puntavia, and no third party sets cookies through our website.

3.1. Strictly necessary cookies. These are indispensable for the Services to work: they keep you logged in to the control panel, they protect forms against request forgery, and, while the private beta is running, they remember that the visitor holds a valid access key. Without them you cannot log in or submit forms. They are exempt from the prior consent requirement under Article 22.2 LSSI-CE.

3.2. Functional or preference cookies. These remember a choice you have expressly made about the interface language. They are not indispensable, but they save you from choosing the language on every visit. Because the value is set by a direct user action, we treat it under the AEPD exception for a "service expressly requested by the user".

3.3. Analytics cookies. We use none. We do not measure visitor behaviour with cookies, whether our own or anyone else's.

3.4. Advertising or marketing cookies. We use none. We do no behavioural advertising, cross-site profiling or retargeting, and we embed no pixels, web beacons or advertising-network SDKs. If this ever changed, we would update this Policy and ask for your prior consent before setting any such cookie.

4. Specific cookies in use

The list below is complete: these are all the cookies the Services can place in your browser.

• session: first-party cookie of the Puntavia control panel. Purpose: keep the session and the authentication state. Category: strictly necessary. Duration: session cookie, it expires when you log out or close the browser.
• CSRF token: not a separate cookie, it is stored inside the session cookie. Purpose: protect forms against cross-site request forgery. Category: strictly necessary. Duration: the lifetime of the session.
• tl_lang: first-party cookie. Purpose: remember the language the visitor has chosen. Category: functional. Duration: 1 year.
• tl_gate: first-party cookie, used only while the private beta is running. Purpose: store the fingerprint of the access key so that it is not requested on every visit. Category: strictly necessary for the duration of the beta. Duration: 180 days.

The colour theme (light or dark) is not stored in a cookie but in the browser's local storage (localStorage). That value stays on your device and is never sent to our servers.

This list is reviewed whenever the Services change, and the version in force is always available at https://puntavia.com, with the date shown at the top of the document.

5. Your consent and how to manage cookies

5.1. Puntavia shows no cookie consent banner, and it does not need one. Every cookie listed in section 4 is either strictly necessary to provide the service you asked for, or remembers the language you chose by a direct action. Article 22.2 LSSI-CE exempts from prior consent those cookies used solely to carry out the transmission of a communication or to provide a service expressly requested by the user. We set no cookie that falls outside that exemption.

5.2. This can only change if we add analytics or advertising cookies. In that case, before setting them, we would publish the updated Policy and ask for your prior consent, with accept and reject options equally visible and requiring the same number of clicks, in line with the AEPD Cookie Guidance.

5.3. Even without a banner, you stay in control: you can inspect, block and delete cookies from puntavia.com at any time in your browser settings.

• Google Chrome: Settings, Privacy and security, Cookies and other site data;
• Mozilla Firefox: Settings, Privacy and security, Cookies and site data;
• Microsoft Edge: Settings, Cookies and site permissions;
• Safari: Settings, Privacy, Manage website data;
• Opera: Settings, Privacy and security, Cookies.

5.4. Be aware of the consequences: deleting or blocking the session cookie logs you out and you will have to log in again; deleting tl_lang means the site no longer remembers your language and falls back to the default; deleting tl_gate during the private beta means the access key is requested again. None of this affects the working-time data already recorded.

6. International transfers

The cookies described in section 4 are first-party, and their content is processed on our servers, hosted in a data centre located in Finland (European Union). Using these cookies does not in itself involve any international transfer of data.

We embed no cookies, pixels or SDKs from providers established outside the European Economic Area. The only provider outside the European Union involved in the service is Anthropic PBC (United States), which analyses the activity data in order to generate the daily sentence; that transfer does not happen through cookies and is described, together with the applicable safeguards, in the Privacy Policy.

7. Updates to this Policy

We update this Policy whenever the cookies in use change, for example when the private beta ends and the tl_gate cookie is no longer set. The date of the last update is shown at the top of the document.

If we ever add a cookie that is not exempt from consent, we will not rely on any earlier acceptance: we will ask for your consent before setting it.

8. Language of this Policy

This Policy is published in Spanish and in English. The Spanish version is the reference version and prevails in the event of any discrepancy between language versions. The English version is provided for the convenience of users who do not read Spanish.

9. Contact and complaints

Questions about this Policy may be addressed to privacy@puntavia.com. For legal matters, legal@puntavia.com; for help with the product, support@puntavia.com. You can also write to Golova Europe SL, Calle l'Hospital 95, Planta 1, Puerta 2, 08001 Barcelona, Spain, or call +34 672 390 777.

You also have the right to lodge a complaint with a supervisory authority. As Golova Europe SL is established in Spain, the lead supervisory authority is the Spanish Data Protection Agency (AEPD, www.aepd.es). Under the one-stop-shop mechanism (Article 56 GDPR), you may also lodge your complaint with the supervisory authority of your habitual residence in the European Union or the European Economic Area.