Cookies Policy
1. What Are Cookies?
Cookies are small files that are downloaded onto the User's device (computer, smartphone, tablet, etc.) when they access certain web pages. These cookies allow a website, among other things, to store and retrieve information about the User's browsing habits or device, and to recognize them in order to improve their browsing experience and offer personalized content.
Cookies cannot harm your device, and many of them are essential for the proper functioning of the website.
Depending on their nature, cookies may collect various types of information, such as:
- Pages visited,
- Time spent in each section,
- Links clicked,
- Language preferences or technical settings,
- Anonymized IP address, among others.
The use of cookies is regulated by applicable data protection law. When cookies allow identification of the User, the GDPR (Regulation (EU) 2016/679) applies.
2. What Types of Cookies Exist?
Cookies can be classified into different categories based on various criteria:
a) Based on the entity that manages them:
First-party cookies: Those sent to the User's device from a domain managed by ElenPAY, such as https://elenpay.tech, from which the requested service is provided.
Third-party cookies: Those sent from a domain or server managed by an entity other than ElenPAY, such as analytics tools, social networks, or external advertising services.
b) Based on their purpose:
Technical or necessary cookies: Allow the User to browse the website and use its basic features, such as accessing secure areas, maintaining sessions, or managing cookie preferences. Consent is not required.
Personalization cookies: Allow the website to remember information to personalize the User's experience (language, region, browser type). Consent may be required if not strictly necessary.
Analytics or measurement cookies: Collect statistical and aggregated information about User behavior in order to improve website performance. Their use requires prior consent.
Behavioral advertising cookies: Store information about the User's browsing habits to display personalized ads based on their interests. Express consent is required.
c) Based on how long they remain active:
Session cookies: Automatically deleted when the browser is closed or the website is exited.
Persistent cookies: Remain stored on the device for a specific period (defined by each cookie) and allow information to be reused on subsequent visits.
3. What Cookies Does ElenPAY Use?
The ElenPAY Website uses first-party and third-party cookies for technical, analytics, and personalization purposes. The categories of cookies used are detailed below, with common examples. The list will be automatically updated as new features or tools are enabled:
| Cookie Name | Type / Purpose | Owner | Duration | Description / Use |
|---|---|---|---|---|
| cookieConsent | Technical (essential) | First-party | 1 year | Stores the User's consent status for cookie usage. |
| _ga | Analytics | Google Analytics | 2 years | Used to distinguish users anonymously (visit measurement). |
| _gat | Analytics | Google Analytics | 1 minute | Limits analytics requests to prevent server overload. |
| _gid | Analytics | Google Analytics | 24 hours | Distinguishes users across different sessions. |
| intercom-id-* | Personalization / Support | Intercom | 9 months | Identifies users to provide contextual support. |
| pll_language | Personalization (language) | First-party | 1 year | Saves the User's preferred language. |
ElenPAY does not use advertising or advanced tracking cookies without prior consent. If implemented in the future, express authorization will be requested.
4. Who Uses the Information Collected by Cookies?
Information collected through cookies used on the ElenPAY Website may be processed by:
a) ElenPAY (Paidly Interactive LTD)
As publisher and owner of the website, ElenPAY uses first-party cookies to ensure the technical operation of the page, remember User preferences, and obtain internal usage and performance metrics for the site.
b) Authorized Third-Party Providers
Some cookies may be managed by third parties that provide services to ElenPAY, such as web analytics tools (e.g., Google Analytics), customer support solutions, or User experience personalization services.
In such cases, these third parties may process data for their own purposes, always within legally permitted limits and subject to contracts ensuring confidentiality, regulatory compliance, and purpose limitation.
The identity of these third parties and the details of the cookies they manage are available in the previous section ("What Cookies Does ElenPAY Use?") and may be updated as technology or services contracted by ElenPAY evolve.
The User may obtain more detailed information about third-party privacy policies on their respective platforms, accessible from the cookie settings panel or the links provided in this Policy.
5. How Can the User Configure or Disable Cookies?
The User may manage their cookie preferences at any time through two complementary mechanisms:
a) Through the Privacy Preference Center provided by ElenPAY
The Website includes a Privacy Preference Center, accessible from the initial cookie banner and permanently from the footer, where the User may:
- Accept or reject all cookies.
- Accept only certain categories (analytics, personalization, etc.).
- Withdraw previously granted consent.
This panel meets the granularity and revocation requirements under applicable law and allows the User's choices to be respected and recorded through a technical cookie.
b) Through browser settings
The User may also configure their browser to restrict, block, or delete installed cookies. The procedure varies depending on the browser used. Links to the official help pages of the main browsers are provided below:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471
- Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406
Disabling cookies may affect Website functionality, and in some cases may prevent the use of certain features or personalized services.
6. Cookies Exempt from Consent
In accordance with applicable data protection legislation, certain cookies are exempt from the requirement to obtain prior User consent, as they are deemed technically necessary for the proper functioning of the Website.
These cookies are:
Technical cookies: Those enabling the User to browse the website and use its various options or services, such as controlling traffic, identifying the session, accessing restricted areas, remembering form elements, or using security features during browsing.
Personalization cookies (limited): Those allowing the Website to remember User preferences (such as language or browser type), provided they are selected by the User and not used for additional purposes.
These cookies are installed by default upon accessing the Website and do not require the User's express consent, although their existence and purpose must be clearly communicated, as done in this Cookies Policy.
Any other cookie that does not meet these criteria (such as analytics, advertising, or performance measurement cookies) will require prior and informed consent, managed through the corresponding settings panel.
7. Retention of Data Collected by Cookies
Personal data obtained through the use of cookies on the ElenPAY Website will be retained for a proportionate and limited period, in accordance with the following guidelines:
a) Duration of the cookie on the User's device
Each cookie installed in the browser has a specific lifespan, which may be:
- Session: automatically deleted when the browser is closed.
- Persistent: remain on the device for a specific period, defined by the cookie's publisher or provider.
The complete list of cookies and their duration is available in the "What Cookies Does ElenPAY Use?" section and in the settings panel.
b) Retention period for personal data derived from cookie use
Personal data processed through cookies (such as browsing data, preferences, or analytics) will be retained only for the time strictly necessary to fulfill the purpose for which they were collected, and never for a period exceeding 24 months, unless required by law or a legitimate retention obligation.
Once the purpose is fulfilled or the retention period has expired, data will be anonymized or securely deleted, unless the User grants new consent enabling its further use.
ElenPAY applies an active data minimization policy, avoiding unnecessary or disproportionate collection of personal data through cookies and ensuring their use in accordance with the principles of the GDPR.
8. International Transfers Arising from Cookie Use
Some cookies used on the ElenPAY Website may be managed by providers located outside the European Economic Area (EEA) or hosting their servers in third countries, which may involve an international transfer of personal data.
In such cases, ElenPAY ensures that the transfer is carried out with full legal guarantees and in compliance with Chapter V of the General Data Protection Regulation (GDPR). In particular, the following safeguards apply:
- An adequacy decision by the European Commission regarding the destination country (Art. 45 GDPR);
- Execution of standard contractual clauses adopted by the European Commission (Art. 46.2.c GDPR);
- Additional contractual commitments and privacy risk assessments, in compliance with Schrems II jurisprudence.
The third-party providers responsible for these cookies are trusted technology companies, such as Google LLC, Meta Platforms, Inc., Intercom, and other analytics or technical support tools that ElenPAY may use, whose privacy policies are available from the cookie settings panel.
At any time, the User may find out whether a cookie involves an international transfer and review the applicable legal basis or safeguards from the "What Cookies Do We Use?" section or by contacting info@paidlyinteractive.com.
9. Acceptance, Configuration, and Withdrawal of Consent
The use of non-essential cookies on the ElenPAY Website requires the User's express, informed, and verifiable consent, in accordance with applicable law.
a) Initial acceptance and configuration
When first accessing the Website, the User will see a cookie banner that:
- Clearly informs about the existence and purpose of cookies.
- Provides access to a granular settings panel.
- Allows accepting all cookies, rejecting all, or configuring by category.
Acceptance will only be valid if the User has taken a clear affirmative action, such as clicking the "Accept" button or selecting the desired categories in the panel.
b) Managing preferences at any time
The User may modify or withdraw consent at any time through the Cookie Preference Center, permanently accessible from the website's footer.
This panel allows the User to:
- View active cookies.
- Change authorized categories.
- Withdraw granted consent.
c) Browser-level configuration
Additionally, the User may manage cookies directly through their browser, including the option to delete or block them entirely. The procedure is described in the "How Can the User Configure or Disable Cookies?" section.
Withdrawal of consent does not affect the lawfulness of processing based on prior consent, nor does it prevent the use of technical cookies necessary for the operation of the site.
10. Updates to the Cookies Policy
ElenPAY reserves the right to modify, update, or revise this Cookies Policy at any time, whether for legal, technical, operational reasons, or due to changes in the cookies used on this website.
When significant changes occur that affect consent or the purposes of processing, the User will be informed through:
- An update of the content on this page,
- A new request for consent, if necessary,
- And/or a clear notification in the cookie banner or through the usual means.
Users are encouraged to periodically review this policy to stay informed about ElenPAY's use of cookies and similar technologies.
This Cookies Policy was last reviewed in: June 2025.