Cookie Policy
How The Holiday Doctor uses cookies and equivalent technologies on theholidaydoctor.com, in compliance with Article 22.2 of the LSSICE and the AEPD Guide on the use of cookies. Strictly necessary cookies are always installed. Analytics cookies (PostHog, EU-hosted) are installed only with your consent. Your consultation is never tracked by analytics.
In compliance with Article 22.2 of Ley 34/2002, de 11 de julio, de Servicios de la Sociedad de la Información y de Comercio Electrónico (the LSSICE), the Guide on the use of cookies of the Agencia Española de Protección de Datos (the AEPD) in its current version, Regulation (EU) 2016/679 (the GDPR) and Spanish Ley Orgánica 3/2018, de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD), Doctor Abbs SL provides the user with the following information on the use of cookies and equivalent technologies on the website theholidaydoctor.com.
Basic information on cookies
| Controller | Doctor Abbs SL, NIF B42734350, registered office at Calle Hermosilla 48, 1 Dcha, 28001 Madrid. Full detail in the Privacy Policy. |
|---|---|
| Purpose | To enable technical operation of the website and ensure its security (strictly necessary cookies, always installed) and, with the user's express consent, to understand aggregated site traffic through privacy-respecting analytics (PostHog, EU-hosted). The consultation form is operated by Jotform and is not tracked by the site's analytics. Behavioural-advertising cookies are not used. |
| Legal basis | Article 22.2 LSSICE: technical necessity for the service for strictly necessary cookies; express user consent for analytics cookies and any other cookie that is not strictly necessary. |
| Retention period | Variable by cookie. Detail in the inventory in Section 4. |
| Recipients | Processors named in Section 6 of the Privacy Policy. |
| User rights | To withdraw consent at any time, to configure cookie preferences and to exercise the other rights provided by the GDPR. |
| How to manage cookies | Through the consent banner shown on the user's first visit, or at any time afterwards by clicking the Cookie preferences link in the site footer. Browser-level settings are also available, as set out in Section 5. |
1. What are cookies
A cookie is a small file that a website sends to the user’s device (computer, mobile phone or tablet) and that is stored in the user’s browser. Cookies allow the site to remember information about the user’s visit, such as preferred language, logged-in session or aggregated information about how the site is used.
For the purposes of this policy, the term “cookies” is used broadly and also covers equivalent technologies that perform the same function, such as local storage, session storage, pixel tags, web beacons and similar, in line with the express position of the AEPD in its Guide on the use of cookies.
2. Types of cookies used
The website theholidaydoctor.com uses cookies that may be classified by the following criteria:
By the entity that manages them:
- First-party cookies: cookies sent to the user’s device from a device or domain managed by Doctor Abbs SL.
- Third-party cookies: cookies sent to the user’s device from a device or domain not managed by Doctor Abbs SL but by a third party that processes data obtained through the cookie as a processor or as an independent controller, as the case may be.
By the period during which they remain active:
- Session cookies: automatically deleted when the browser is closed.
- Persistent cookies: stored on the user’s device for a period defined by the party responsible for the cookie.
By purpose:
- Technical cookies or strictly necessary cookies: allow the user to navigate the website and to use the various options or services available. They do not require user consent under Article 22.2 LSSICE.
- Analytics or measurement cookies: allow the controller to monitor and analyse the aggregated behaviour of the user on the site. theholidaydoctor.com uses one analytics provider (PostHog, EU-hosted) installed only with the user's express consent. The provider is configured to create profiles only for identified users; anonymous visitors are not profiled. The consultation form (Jotform) is on a separate domain and is not part of the analytics scope.
- Behavioural advertising cookies: not used on theholidaydoctor.com. Doctor Abbs SL does not engage in behavioural advertising and accordingly does not install cookies for this purpose.
3. Cookies installed only with consent
In accordance with Article 22.2 LSSICE, cookies that are not strictly necessary are installed only when the user gives express consent, in line with the concept of consent in Article 4.11 GDPR. theholidaydoctor.com presents a consent banner on the user's first visit, before any non-strictly-necessary cookie is installed. The banner offers two equally prominent options on the first layer:
- Accept all: the user authorises the installation of analytics cookies as described in Section 4.2.
- Reject all: only strictly necessary cookies (Section 4.1) are installed. No analytics cookies are installed under any circumstance.
The user's decision is recorded in the user's own browser (local storage of the user's device, key thd_cookie_consent) and is honoured on all subsequent visits to the same browser. The banner does not reappear once a decision has been recorded.
The user can revoke or change consent at any time by clicking the Cookie preferences link in the footer of any page of the site, which re-opens the banner. Where the user revokes a previous acceptance, the analytics provider is instructed to stop capturing further events within the current session, and no analytics cookies are installed on subsequent visits.
Rejection or revocation of analytics consent does not affect strictly necessary cookies, which are installed in any case under the exemption of Article 22.2 LSSICE, and does not affect the user's ability to use the site, including the consultation form at /start-a-request.
4. Inventory of cookies used on theholidaydoctor.com
The cookies used on the site as of the date of the last update shown at the top of the document are identified below. The inventory is reviewed periodically and updated when the technical configuration of the site changes.
4.1 Strictly necessary cookies
| Provider | Purpose | Category | Type | Expiry |
|---|---|---|---|---|
| Cloudflare, Inc. | Technical operation of the website (static hosting, content delivery network, request integrity, load balancing) and security (request origin identification, bot mitigation, attack mitigation). | Technical / security | Third-party | Session / up to 30 days depending on sub-component. |
| Jotform Inc. (EU plan) | Technical operation of the consultation form embedded at /start-a-request: form integrity, anti-bot protection, progress persistence. Installed only when the user accesses /start-a-request. | Technical | Third-party | Session / up to 30 days depending on sub-component. |
These cookies are installed under the exemption of Article 22.2 LSSICE and do not require user consent.
4.2 Analytics cookies
The analytics provider listed below is installed only after the user has given express consent through the banner described in Section 3. If consent is not given, or has been revoked, this provider is not loaded and no analytics cookies are installed.
| Provider | Purpose | Category | Type | Expiry |
|---|---|---|---|---|
| PostHog Inc. (EU instance, hosted in Frankfurt, eu.i.posthog.com) | Aggregated site analytics: page views, navigation patterns, session duration, device and browser type. Configured in "identified_only" person-profile mode, which means anonymous visitors are not profiled. The provider does not receive content of the consultation form (which is operated by Jotform on a separate domain) and is not used for behavioural advertising or marketing-list building. | Analytics | Third-party | Persistent cookies up to 365 days; events retained per the provider's standard retention. |
Analytics consent is recorded as a single value in the user's local storage (key thd_cookie_consent, value accepted or rejected) and is not transmitted to any third party. The local-storage entry is itself classified as strictly necessary (it is the technical record of the user's choice required to honour that choice on subsequent visits) and is installed regardless of the analytics decision.
4.3 Behavioural advertising cookies
Doctor Abbs SL does not install behavioural advertising cookies on theholidaydoctor.com. No advertising tracking technologies are used, no cookie-based retargeting campaigns are run, and user data is not shared with advertising networks.
5. How to manage cookies
The user can manage cookie use in two ways:
Through the site's consent banner. On the user's first visit, the banner appears at the foot of the page with two equally prominent options: Reject all and Accept all. After a decision has been recorded, the banner can be re-opened at any time by clicking the Cookie preferences link in the footer of any page. The banner allows the user to change a previous decision (for example, from accepted to rejected, or vice versa). Where the user revokes a previous acceptance, the analytics provider is instructed to stop capturing further events within the current session.
Through browser settings. Each browser provides its own mechanisms for managing, deleting and blocking cookies. The official links are provided below:
Blocking strictly necessary cookies through browser settings may affect the functioning of the website. Blocking analytics cookies in this way has no effect on site functionality and is equivalent in effect to clicking Reject all on the banner.
6. International data transfers associated with cookies
Some of the providers identified in Section 4 are established outside the European Economic Area. The position is as follows:
- Cloudflare, Inc. is established in the United States.
- Jotform Inc. is incorporated in the United States, although Doctor Abbs SL contracts its EU plan and the infrastructure of the form is hosted in Europe.
- PostHog Inc. is incorporated in the United States, but theholidaydoctor.com uses the provider's EU instance (eu.i.posthog.com), which hosts and processes event data in Frankfurt, Germany. Event data does not leave the European Economic Area in the normal course of processing.
Where international transfers to the United States are involved (for example, where the provider's parent entity provides support or sub-processing from a US location), those transfers are made under the EU-US Data Privacy Framework, recognised by the European Commission's Adequacy Decision of 10 July 2023, where the provider is certified under that framework. Failing that, transfers are made under the Standard Contractual Clauses approved by the European Commission under Decision (EU) 2021/914, complemented by such supplementary measures as may be appropriate under European Data Protection Board Recommendations 01/2020.
The complete detail of the international transfer regime is set out in Section 8 of the Privacy Policy.
7. Period of retention of consent
Where, in future, consent is requested for the installation of cookies that are not strictly necessary, that consent will be renewed, in line with the AEPD’s position, after a maximum of 24 months from being given, or earlier if there is a substantive change to this Cookie Policy or to the technical configuration of the site.
Where the user has withdrawn consent or has set granular preferences, information about that consent is retained for the reasonable period necessary to evidence the user’s choice and to ensure that the choice is respected.
8. Modifications to the policy
Doctor Abbs SL reserves the right to modify this Cookie Policy to adapt it to new legislation, operational changes to the service, the introduction or removal of providers in the site’s technical stack, or recommendations of the competent authorities.
Substantive modifications (introduction or removal of cookies, changes of purpose, changes of provider, changes of retention period) are reflected in an update of the inventory in Section 4 and, where appropriate, in a new consent request to the user.
The date of the last update is shown at the start and end of the document.