Cookies Policy

Last Updated: April 28, 2026

This Cookies Policy explains what cookies are, how luisenriquebernal.com (the “Website”) uses cookies, the types of cookies we use, your rights regarding cookies, and how to manage your cookie preferences. This policy applies to all users, regardless of their location, and complies with international privacy regulations including LFPDPPP 2025 (Mexico), GDPR (European Union), CCPA (California), LGPD (Brazil), PIPEDA (Canada), and equivalent privacy laws in other jurisdictions.

Please read this policy carefully. By using this Website, you consent to the use of cookies as described herein, subject to your ability to opt-out.

1. What Are Cookies?

Cookies are small text files that are stored on your device (computer, tablet, mobile phone) when you visit a website. Cookies contain information about your browsing activity and user preferences. They are created by the website you’re visiting and by third-party services that the website uses.

Key characteristics of cookies:

• They are typically very small (a few kilobytes at most)
• They are stored locally on your device, not on our servers
• They have an expiration date (session cookies expire when you close your browser; persistent cookies can last for months or years)
• They can contain any information the website chooses to store (user ID, preferences, tracking data, etc.)
• They can only be read by the website that created them (or third parties the website has authorized)

2. Mexico LFPDPPP 2025 Compliance Statement

This Website operates in full compliance with Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), effective March 21, 2025.

Regulatory Authority: The Secretariat of Anti-Corruption and Good Governance (Secretaría de Anticorrupción y Buen Gobierno, or SABG) is the authority responsible for enforcing and overseeing LFPDPPP compliance, replacing the dissolved National Institute for Transparency, Access to Information, and Protection of Personal Data (INAI).

Your ARCO Rights Under LFPDPPP 2025:

To exercise any ARCO right, contact: lebz.sap@gmail.com with your request clearly stating which right you wish to exercise and providing any necessary identifying information. Response will be provided within 20 business days per LFPDPPP requirements.

3. Types of Cookies We Use

3.1 Essential / Strictly Necessary Cookies

Purpose: These cookies are absolutely necessary for the Website to function properly. They enable core functionality such as page navigation, security, and access to protected areas of the Website.

Examples:

• Session cookies that remember you’re logged in (if applicable)
• Security cookies that detect fraudulent activity
• Load balancing cookies that distribute traffic across servers
• Cookies that remember your language or region preference

Legal Basis: These cookies do NOT require your explicit consent under LFPDPPP, GDPR, CCPA, LGPD, or other privacy laws because they are necessary for the Website to function.

Retention Period: Session cookies are deleted when you close your browser. Persistent essential cookies are retained for up to 1 year.

3.2 Performance & Analytics Cookies

Purpose: These cookies collect information about how you use the Website (pages visited, time spent on each page, links clicked, errors encountered, etc.). This data helps us understand Website performance, identify technical issues, and improve user experience.

Third-Party Services: We use Google Analytics to track Website usage. Google Analytics sets its own cookies on your device to collect this data.

Analytics Providers:

• Google Analytics: Collects data on pages visited, time on site, device type, browser, operating system, and referrer source. Data is processed by Google LLC (USA) and Google Ireland Limited (EU). Google Privacy Policy
• Additional analytics providers may be used as Website services evolve

Legal Basis: Under LFPDPPP, GDPR, CCPA, and LGPD, performance cookies typically require your explicit opt-in consent before data collection begins.

Data Sharing: Analytics data is shared with third-party analytics providers (primarily Google Analytics) but is NOT shared with advertisers or other unrelated third parties.

Retention Period: Analytics cookies typically expire after 2 years. Aggregated analytics data may be retained longer for trend analysis.

3.3 Functional Cookies

Purpose: These cookies remember your preferences and choices to provide a customized experience. For example, they might remember your language preference, font size, or whether you’ve visited the site before.

Examples:

• Cookies remembering your preferred language
• Cookies remembering whether you’ve closed a banner or notification
• Cookies storing your form preferences (if any forms exist on the Website)

Legal Basis: Functional cookies typically require opt-in consent under LFPDPPP, GDPR and LGPD, though some may be considered “necessary” if they’re essential to Website functionality.

Retention Period: Functional cookies typically persist for 1-2 years.

3.4 Marketing & Advertising Cookies

Current Status: The Website currently does NOT use marketing or advertising cookies. We do not track you for advertising purposes, and we do not retarget you with ads across other websites.

Future Use: If marketing cookies are ever implemented in the future, we will update this policy and obtain your explicit consent before any marketing tracking begins.

3.5 Third-Party Cookies

What are third-party cookies? These are cookies set by services external to the Website that you visit. For example, if the Website embeds a YouTube video, YouTube may set cookies on your device.

Third-Party Services Currently Used:

• Google Analytics: Tracks Website usage (see Performance Cookies section above)
• Contact Forms (if applicable): Forms may use cookies to pre-populate fields you’ve entered before
• YouTube (if embedded): YouTube may set cookies if videos are embedded on the Website
• Other Third-Party Services: Additional services (CDN providers, hosting services, security services) may use cookies or similar technologies

Important Note: We are NOT responsible for third-party cookies set by external services. Each third party has their own privacy policy governing how they use cookies. We recommend reviewing their policies directly.

4. Similar Technologies Beyond Cookies

In addition to cookies, the Website may use similar tracking technologies:

• Web Beacons / Tracking Pixels: Invisible 1×1 pixel images embedded in pages to track when a page is loaded
• Local Storage / Session Storage: Browser storage mechanisms that work similarly to cookies but have larger storage capacity
• Device IDs: Unique identifiers assigned to your device (separate from cookies) that may be used to track your activity
• Server Logs: Your IP address, device type, browser type, and pages accessed are automatically logged by the web server

Privacy Note: These technologies are governed by the same privacy principles as cookies. Your consent preferences for cookies generally extend to similar tracking technologies as well.

5. Data Retention & Deletion Schedule (LFPDPPP Compliance)

Under LFPDPPP 2025, data controllers must establish and disclose retention periods for personal data. Here is our retention schedule:

Cookie Type	Retention Period	Deletion Method
Session Cookies (Essential)	Duration of browser session (deleted upon close)	Automatic deletion
Functional Cookies	1-2 years	Automatic deletion after expiration; can be manually cleared
Analytics Cookies	2 years	Automatic deletion after expiration; Google Analytics allows opt-out
Tracking Pixels / Web Beacons	2 years for aggregated data	Automatic deletion; aggregated data may be retained for trend analysis
Server Logs	90 days	Automatic deletion after 90 days; older logs are permanently erased

LFPDPPP Data Blocking & Deletion Process: When personal data retention periods expire, the data is first “blocked” (made inaccessible to regular operations) and then permanently deleted within 30 days per LFPDPPP Article 11 requirements. Complete erasure ensures data cannot be retrieved or reconstructed.

6. Your Rights & Cookie Consent

6.1 Mexico (LFPDPPP 2025)

Your Rights Under LFPDPPP:

• Right to Consent: You have the right to consent to or refuse non-essential cookies before they are used
• ARCO Rights: You can exercise Access, Rectification, Cancellation, and Opposition rights regarding cookies (see Section 2 above)
• Right to Withdraw Consent: You can withdraw your consent at any time
• Right to Opt-Out of Automated Decision-Making: You can object to automated processing that significantly affects your rights or freedoms

Consent Mechanism: When you first visit the Website, a cookie consent banner will appear (if cookies are enabled on your device). You can:

• Accept All: Consent to all cookies (essential + optional)
• Reject All: Refuse all non-essential cookies
• Customize: Choose which types of cookies you consent to

Granular Consent: You can adjust your cookie preferences at any time by accessing your cookie settings through the Website’s cookie preferences tool (accessible via footer or settings menu).

6.2 European Union (GDPR)

Your Rights Under GDPR:

• Right to Consent: You have the right to consent to or refuse non-essential cookies before they are used
• Right to Withdraw Consent: You can withdraw your consent at any time
• Right to Access: You can request what cookies we have stored on your device
• Right to Deletion: You can request that cookies be deleted
• Right to Opt-Out: You can opt-out of specific types of cookies (analytics, functional, etc.)

6.3 California (CCPA)

Your Rights Under CCPA:

• Right to Know: You can request what personal information (including from cookies) we collect about you
• Right to Delete: You can request deletion of cookies and related data
• Right to Opt-Out: You can opt-out of “sale” or “sharing” of personal information
• Right to Non-Discrimination: You cannot be discriminated against for exercising your CCPA rights

Do Not Track (DNT) Signals: If your browser sends a Do Not Track (DNT) signal, the Website will honor your preference by minimizing non-essential cookie use.

6.4 Brazil (LGPD)

Your Rights Under LGPD:

• Right to Consent: You have the right to consent to data collection via cookies
• Right to Access: You can request access to data collected through cookies
• Right to Deletion: You can request deletion of cookie data
• Right to Rectification: You can request correction of inaccurate cookie data
• Right to Portability: You can request your data in a structured, portable format

6.5 Canada (PIPEDA)

Your Rights Under PIPEDA:

• Right to Access: You can access your personal information collected through cookies
• Right to Correction: You can request correction of inaccurate information
• Right to Deletion: You can request deletion of your personal information
• Right to Withdraw Consent: You can withdraw consent for cookie collection at any time

7. How to Manage Your Cookies

7.1 Browser Cookie Controls

Most web browsers allow you to control cookies through browser settings. You can:

Google Chrome: Settings → Privacy and Security → Cookies and Other Site Data → Manage All Site Data and Permissions

Mozilla Firefox: Preferences → Privacy & Security → Cookies and Site Data → Manage Exceptions

Apple Safari: Preferences → Privacy → Cookies and Website Data

Microsoft Edge: Settings → Privacy, Search, and Services → Clear Browsing Data → Cookies and Cached Images and Files

Important Notes:

• Blocking all cookies may prevent the Website from functioning properly
• Essential cookies should NOT be blocked as the Website requires them to operate
• You can typically allow essential cookies while blocking optional cookies
• Some websites may not work correctly if you disable all cookies

7.2 Website Cookie Preferences

You can manage your cookie preferences directly on this Website using the cookie preferences tool, typically accessible via:

• Cookie consent banner (displayed on first visit)
• Footer cookie settings link
• Privacy settings page (if available)

Your preferences are saved in an essential cookie, so your choices are remembered across future visits.

7.3 Opt-Out Tools

Google Analytics Opt-Out: You can opt-out of Google Analytics tracking by:

• Installing the Google Analytics Opt-Out Browser Add-on
• Using your browser’s Do Not Track (DNT) settings
• Adjusting your cookie preferences on the Website

8. Data Transfer & International Compliance

8.1 Where Your Data Is Processed

Cookies and related data are processed in the following locations:

• Website Server: Hosted in Mexico (or regional data centers)
• Google Analytics: Data is processed by Google in the United States and European Union data centers
• Content Delivery Network (CDN): If used, data may be processed across multiple global locations
• Third-Party Services: Additional third-party services may process data in their respective locations

8.2 Data Transfer Compliance (LFPDPPP, GDPR)

For users in Mexico and the European Union: Data transfers are protected through appropriate legal mechanisms including Standard Contractual Clauses (SCCs), Privacy Shield / Adequacy Decisions, and other derogations where necessary.

If you have concerns about international data transfers, you can contact us to request additional safeguards.

9. Security of Cookie Data

Security Measures: The Website implements industry-standard security practices to protect cookies and related data:

• HTTPS encryption for all Website traffic (all data in transit is encrypted)
• Secure cookie flags (HttpOnly, Secure, SameSite) to prevent unauthorized access
• Regular security audits and vulnerability assessments
• Firewalls and intrusion detection systems
• Limited access to cookie data (only authorized personnel)

Limitation: While we implement reasonable security measures, no system is 100% secure. We cannot guarantee absolute protection against all security threats.

10. Changes to This Cookies Policy

Luis Enrique Bernal reserves the right to update this Cookies Policy at any time to reflect changes in technology, legal requirements, or Website functionality. If we make material changes, we will notify you by:

• Posting the updated policy on this page with a new “Last Updated” date
• Displaying a notification banner on the Website (if required by law)
• Requesting renewed consent (if your previous consent no longer applies)

It is your responsibility to review this policy periodically for changes. Continued use of the Website following any updates constitutes your acceptance of the updated Cookies Policy.

11. Contact Information for ARCO Rights Requests & Questions

12. Additional Resources

Learn More About Cookies & Data Protection:

• All About Cookies – Educational resource on cookies
• GDPR Info – GDPR guidance and resources
• California CCPA – CCPA official information
• LGPD (Portuguese) – Brazilian data protection law
• PIPEDA (Canada) – Canadian privacy commissioner
• SABG Mexico – Secretariat of Anti-Corruption & Good Governance (Spanish)

13. Summary of Cookie Types & Consent Required

Cookie Type	Purpose	Consent Required?	Retention	LFPDPPP Compliant?
Essential/Necessary	Website functionality	❌ No (legal basis: necessity)	Session / 1 year	✅ Yes
Analytics	Website performance tracking	✅ Yes (GDPR, LGPD, CCPA, LFPDPPP)	2 years	✅ Yes
Functional	User preferences	✅ Yes (most jurisdictions)	1-2 years	✅ Yes
Marketing	Advertising tracking	✅ Yes (all jurisdictions)	Varies	Not currently used
Third-Party	External services	✅ Yes (depends on purpose)	Varies	✅ Yes (with consent)

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This Cookies Policy is provided in English and Spanish (available upon request) and may be translated into other languages for accessibility. In case of discrepancy between the English version and any translation, the English version shall prevail.

LFPDPPP 2025 Compliance: This Website and this Cookies Policy comply with Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), effective March 21, 2025, as enforced by the Secretariat of Anti-Corruption and Good Governance (SABG).

Last Updated: April 28, 2026