Cookies Policy

NOTICE:

This Policy explains the use of cookies, tags, pixels, local storage, device identifiers, and comparable technologies, collectively referred to as the “Technologies.” A visitor’s choice concerning non-essential Technologies is referred to as the “Consent Preference.”

Necessary Technologies may operate for:

• security;
• session management;
• load balancing;
• preservation of a choice.

Analytics Technologies, non-essential Functional Technologies, and Advertising Technologies will remain blocked until a valid Consent Preference is obtained when required by applicable law.

Controls That Must Be Visible in the First Layer

Reject Non-Essential Cookies · Cookie Settings · Accept All

Accepting and rejecting must be equally accessible. Closing the banner does not constitute acceptance. Optional Technologies remain blocked until a valid choice is made. Permanent center: Cookie Settings link in the website footer.

This Policy describes the Technologies used on umwrecordingsinc.com, public forms, and, when applicable, UMW Core.

Not every Technology is loaded on every page.

The inventory displayed in the second layer of the consent management platform must identify the Service that is actually active on the URL being visited.

‍FIRST.— DATA CONTROLLER.

UMW RECORDINGS, INC. S.A.S.
RUC 0993391921001
Av. Francisco de Orellana
Guayaquil 090512
Ecuador

‍SECOND.— TECHNOLOGIES COVERED.

In addition to cookies, the website may use:

• local or session storage;
• pixels;
• tags;
• identifiers;
• SDKs;
• scripts;
• iframes;
• server logs;
• URL parameters.

Even when a request does not create a cookie, it may communicate:

• IP address;
• browser information;
• device information;
• URL;
• time.

‍THIRD.— CONSENT MANAGEMENT PLATFORM.

UMW uses a consent management platform to:

• display categories;
• record the Consent Preference;
• allow the Consent Preference to be changed.

The consent management platform must:

• load before optional Technologies;
• offer Reject Non-Essential Cookies, Cookie Settings, and Accept All;
• provide equal access to accepting and rejecting;
• save the choice;
• allow the choice to be changed;
• prevent new optional Technologies from loading after consent is withdrawn;
• refrain from treating closure of the banner as acceptance.

When UMW changes its settings ID or provider, it will update the second layer and this Policy.

‍FOURTH.— CATEGORIES.

4.1. NECESSARY TECHNOLOGIES.

Necessary Technologies enable:

• security;
• session management;
• load balancing;
• basic abuse prevention;
• preservation of the Consent Preference;
• requested functionality.

They are not used for behavioral advertising.

4.2. FUNCTIONAL TECHNOLOGIES.

Functional Technologies enable chat, scheduling, embedded content, or preferences that are not essential to display the basic webpage.

4.3. ANALYTICS.

Analytics Technologies measure navigation, errors, and use to improve the website.

They must not load before the applicable choice is made.

4.4. ADVERTISING AND SOCIAL MEDIA.

Advertising and Social Media Technologies may:

• measure campaigns;
• create audiences;
• attribute conversions;
• load social content.

They require a prior choice when required by law.

‍FIFTH.— OPERATIONAL INVENTORY.

The audit identified the following Technologies or configurations. Inclusion in this table does not mean that a Technology may load before consent.

1. Immediate Load / Essentials (Necessary)

• Webflow : Runs when the website opens. Hosts the public site.
• Usercentrics : Runs before any other option. Manages consent.
• Firebase Authentication : Runs at login. Protects accounts.

2. Conditional Loading by Function (Forms and Containers)

• Google Tag Manager : Loads with the website, but blocks optional tags.
• Google reCAPTCHA : It is only activated when the user uses a protected form.

3. On-Demand Loading / User Interaction (Functional)

• Calendly : Loads after accepting functional cookies or clicking on the calendar.
• Tidio : Loads after accepting cookies or manually starting the chat.

4. Post-Consent Loading / Optional (Advertising and Metrics)

• Google Ads : It only runs after accepting advertising cookies.
• Meta Pixel : Only runs after accepting advertising cookies.
• X/Twitter : Loads as functional or advertising, depending on the user's choice.

When a Service is no longer used, it will be removed from:

• the website;
• the consent management platform;
• this table.

When a new Service is added, it will be classified before activation.

‍SIXTH.— GOOGLE TAG MANAGER.

Google Tag Manager must not be treated as a Necessary Technology when it is capable of triggering Advertising, Analytics, or pixels.

Each tag must have:

• an owner;
• a purpose;
• a category;
• a trigger;
• a legal basis;
• evidence of blocking;
• a review date.

An All Pages rule must not circumvent the visitor’s choice.

‍SEVENTH.— EMBEDDED CONTENT.

Calendly, X/Twitter, videos, chats, and other iframes may disclose the visit to the applicable provider.

When consent has not been provided, UMW will display a local placeholder:

This content is provided by [Service]. By loading it, the provider may receive data from your device. Review its information and choose whether you wish to activate it.

The button activates only:

• the specific content;
• or the corresponding category.

‍EIGHTH.— RECAPTCHA.

UMW uses reCAPTCHA only on forms requiring protection against abuse.

The page must:

• disclose its use;
• link to Google’s applicable documents.

UMW will not load reCAPTCHA on pages without a protected form and will review less intrusive alternatives.

‍NINTH.— UMW CORE.

UMW Core may require Technologies for:

• session management;
• authentication;
• CSRF protection;
• preferences;
• security;
• activity logging;
• continuity of an upload.

These Technologies are limited to operating and protecting the Account.

Analytics or marketing within the dashboard will be classified separately.

‍TENTH.— DURATION.

For each Technology, the second layer of the consent management platform will display:

• name;
• provider;
• purpose;
• duration.

UMW will not use indefinite expressions such as “for as long as necessary” when the provider publishes a specific duration.

A persistent cookie will be deleted or renewed in accordance with:

• its applicable duration;
• the Consent Preference.

‍ELEVENTH.— HOW TO MAKE A CHOICE.

During the first visit, the User may:

• reject all optional Technologies;
• accept all optional Technologies;
• choose by category.

Essential functions remain available after rejection.

A requested external function may require activation of the specific provider.

The first layer will use the following text:

Your Privacy, Your Choice

We use Necessary Technologies to operate and protect this website. With your permission, we may also activate external content, Analytics, and Advertising. You may choose now and change your decision later.

Buttons, with equivalent size and contrast:

Reject Non-Essential Cookies · Cookie Settings · Accept All

Text displayed below the rejection option:

You will continue to use the website with the Technologies strictly necessary for security, session management, requested preferences, and basic functionality. We will not activate Analytics, Advertising, or optional personalization.

‍TWELFTH.— HOW TO CHANGE OR WITHDRAW YOUR CHOICE.

The Cookie Settings link must reopen the preference center from every page.

Withdrawal:

• is free of charge;
• does not require the User to manually clear the browser;
• prevents new optional Technologies from loading;
• is recorded with the date and version.

UMW cannot delete a cookie that is already controlled exclusively by a third party.

UMW must, however:

• stop calling the third party;
• explain how to delete the local data.

After a rejection is saved, the following confirmation will appear:

Preferences Saved

Non-essential Technologies remain disabled. You may change this choice through Cookie Settings, available in the website footer.

‍THIRTEENTH.— BROWSER SIGNALS.

UMW will apply browser signals when legally required and will document the applicable configuration.

A general Do Not Track signal will be addressed according to:

• available technical capabilities;
• applicable law.

UMW will not claim compatibility when the feature has not been implemented.

‍FOURTEENTH.— MINORS.

UMW does not use optional cookies to deliberately profile minors.

Ordinary Accounts are intended for persons who are at least eighteen (18) years old.

‍FIFTEENTH.— INTERNATIONAL TRANSFERS.

Some providers may process personal data outside Ecuador.

UMW documents the applicable:

• entity;
• country;
• role;
• transfer mechanism;

in the Provider Registry and the Privacy Policy.

Acceptance of cookies does not replace international data transfer obligations.

‍SIXTEENTH.— CONSENT RECORDS.

UMW retains:

• the choice identifier;
• date and time;
• domain;
• banner version;
• categories;
• action: acceptance, rejection, change, or withdrawal;
• language;
• evidence of change or withdrawal.

The record is not used for Advertising. It is retained for the period necessary to demonstrate compliance. The existence of a record does not convert a defective choice into valid consent.

UMW must be able to demonstrate that:

• information was presented before the action;
• accepting and rejecting were equally accessible;
• no optional category was preselected.

An authenticated User may review the record in UMW Core through:

Account → Privacy and Security → Privacy and Acceptance History

The visible history will display:

• date;
• document or preference;
• version;
• action;
• current status;
• downloadable copy.

It will not display a complete IP address or security information.

‍SEVENTEENTH.— TECHNICAL VERIFICATION.

UMW tests:

1. a clean browser before any choice;
2. closing the banner without making a choice;
3. rejection;
4. acceptance of Functional Technologies;
5. acceptance of Analytics without Advertising;
6. acceptance of Advertising;
7. complete acceptance;
8. a version change;
9. withdrawal.

Testing is repeated on pages containing:

• forms;
• chat;
• scheduling;
• embedded content;
• marketing;
• UMW Core.

For each test, UMW will retain:

• date;
• environment;
• URL;
• browser and device;
• consent management platform version;
• categories;
• inventory before and after;
• screenshot;
• network file or equivalent evidence;
• result;
• incident;
• responsible person.

UMW will display the Verified Consent Controls seal only after production testing has passed.

The seal will indicate:

• the date;
• the scope.

It will not be presented as certification by the SPDP.

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