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Cookie Policy

1. Nature of tracking technologies

The web platform operated by Toledo les 360 SL uses cookies and similar technologies that store and retrieve information during your browsing. These tools allow the user to be recognized, obtain data about the usage habits of the application, and customize the content displayed. The user can reject non-essential cookies without in any case preventing the use of the booking platform or the management of the deposit; only the blocking of strictly necessary technical cookies could affect essential functions of the site.

2. Technical classification

The tracking files are divided according to their duration, ownership, and functional purpose.

Temporary classification

  • Session cookies. They collect data exclusively while the user is browsing and expire when the browser is closed, keeping the session active during the autonomous navigation.
  • Persistent cookies. They store information on the device for a predefined period to remember the traveler's preferences without the need to reconfigure them.

Classification by property

  • Own cookies. Managed directly from the Toledo domain, the 360 SL is used to support the technical infrastructure.
  • Third-party cookies. Deployed by external entities to perform analytical or advertising metrics audits.

Classification by purpose

  • Technical cookies. They guarantee navigation, session identification, traffic control, and the stability of the web application.
  • Preferences cookies. They memorize specific user settings to speed up recurring access.
  • Analytical cookies. They quantify the pseudonymized behavior of the devices to evaluate the volume of visits and the performance of the servers.
  • Advertising cookies. They store navigation data to optimize the reach of their advertising campaigns.

3. Technologies implemented in LEMS 360

The system displays the following files. The inventory has been verified using live technical scanning with the CookieYes tool (44 pages tracked); the elements still pending verification are explicitly indicated in each block.

Own / Technical (Necessary) Cookies

  • cookieyes-*. Generated by the CookieYes consent manager to register and remember the cookie preferences selected by the user. Domain: lems360.com. Duration: 1 year.
  • Path progress identifier. Cookie generated by LEMS 360 to associate the progress of the route (stop reached, current/completed state) with an unregistered device, thus allowing geolocated guidance. Does not require consent as it is strictly necessary (Article 22.2 of the LSSI).
  • wordpress_logged_in_. Generated by WordPress when the user logs in with their account or PIN, to keep the session authenticated. Applies only to registered users.
  • trp_language. Generated by the site’s language selector (TranslatePress plugin) to remember the language chosen by the visitor.

Own / functional cookies

  • activechatyWidgets. Set up by the Chaty plugin to collect information about user interaction with the live chat widget on the site. Domain: lems360.com. Duration: Not expired.
  • maz-resolved-color-mode. Remember the user's preference regarding the site's display mode (clear/dark). Domain: lems360.com. Duration: 1 year.

Booking and payment platform (third parties required)

  • Bókun. External platform through which the reservation, availability and issuance process of the locator is managed. Bókun can deploy its own cookies strictly necessary to maintain the reservation status during the purchase process.
  • Stripe. Payment gateway that may deploy technical cookies necessary for fraud prevention and the secure validation of the transaction during the payment process.

These cookies from Bókun and Stripe are necessary to complete the reservation and payment, so they do not require prior consent (Article 22.2 of the LSSI), without prejudice to the fact that both providers may deploy additional analytical or other purposes-specific cookies, which will be subject to the consent banner in case they are detected.

Analytics and measurement

  • sbjs_migrations, sbjs_current_add, sbjs_first_add, sbjs_current, sbjs_first, sbjs_udata. Set by Sourcebuster to identify the source of the visit and store information about the user's action, in order to improve the visitor's experience on the website. Domain: .lems360.com. Duration: Session.
  • sbjs_session. Established by Sourcebuster for the same purpose as the previous ones. Domain: .lems360.com. Duration: 1 hour.
  • tk_or, tk_lr. Set by Jetpack as referral cookies on sites with store functionality, to analyze the behavior of visitors. Domain: .lems360.com. Duration: tk_or, 1 year, 1 month and 4 days; tk_lr, 1 year.
  • tk_r3d. Established by Jetpack to collect internal metrics of user activity and improve their experience. Domain: .lems360.com. Duration: 3 days.
  • tk_ai. Set up by Jetpack to store an anonymous identifier generated randomly, used for general analytical tracking purposes. Domain: lems360.com. Duration: 1 year.
  • _ga. Set up by Google Analytics 4 (through the Google Site Kit plugin) to identify devices using a pseudonymous identifier and analyze browsing trends. Expiry set to 2 years.
  • _gid. Distinguishes devices by pseudonymous identifiers during an active 24-hour session.
  • _gat. Limits the request rate to the server to stabilize performance within a 1-minute margin.

Advertising tracking

Currently LEMS 360 does not deploy advertising or remarketing cookies (Google Ads or others). If a campaign requiring them is activated in the future, this section will be updated in advance of its implementation, indicating the exact name, owner, purpose, and duration of each cookie, and this category will be included as a configurable option in the consent banner.

4. Mechanisms of consent, revocation and control

Consent management is performed through the CookieYes tool, integrated into the web platform. The consent banner allows, on the first layer and with equal prominence, to accept all cookies, reject all non-essential ones, or configure them for specific purposes. The non-essential cookies remain blocked by the CookieYes auto-blocking system until consent is obtained, which is recorded as evidence. The user can withdraw or modify their consent at any time, with the same ease with which they granted it, through the permanent link «Set cookies» available at the footer. Additionally, the privacy settings of browsers allow for global blocking, as a complementary mechanism to the platform’s configuration panel:

  • Google Chrome: Settings > Privacy and security > Delete browsing data.
  • Firefox: Options > Privacy and security > History > Custom settings.
  • Microsoft Edge: Settings > Site cookies and permissions > Manage and delete cookies.
  • Safari: Preferences > Privacy.

5. International data transfers

The deployment of Google’s analytical and marketing services involves operational transfers to servers located in the United States. The contractual entity in the European Economic Area is Google Ireland Limited, although the processing may involve Google LLC (USA) as a sub-processor. This transfer is based on Google LLC’s certification under the EU-US Data Privacy Framework (Data Privacy Framework), an adequacy decision pursuant to Article 45.1 of the GDPR, as well as, subsidiarily, on the Standard Contractual Clauses approved by the European Commission.

6. Segmentation and profiling

LEMS 360 does not currently perform advertising segmentation or profiling for marketing purposes. If tools such as Google Ads are activated in the future, they will be able to consolidate pseudonymized profiles—which are considered personal data—based on previous interaction with the web platform, for the sole purpose of optimizing the technical effectiveness of the campaigns. In no case will automated decisions be executed that have binding legal effects on the traveler. In such cases, the user may neutralize this advertising personalization from the web panel or through the ad settings of the provider company; this section will be updated before the service is activated.

7. Exercise of normative rights

The legal framework provides guarantees regarding access, rectification, deletion, objection, portability and limitation of processing. The exercise of these rights is carried out by submitting a documented request to Toledo les 360 SL. Postal address: Carretera de Fuencarral N.º 44, edificio 5, loft 43, 28108, Alcobendas, Madrid. Privacy contact email: info@lems360.com.

8. Destruction of information

When the life cycle stipulated in the technical expiration of each temporary or persistent cookie has expired, the code automatically executes its removal from the user's terminal memory.

9. Legal updates

Toledo will modify this regulatory document in the event of functional changes to the platform or to comply with mandatory requirements issued by the Spanish Data Protection Agency (AEPD).

Date of entry into force: 01/10/2026.