Cookie and Tracking Technologies Policy

Last updated: September 1, 2026
Effective date: September 1, 2026

1. IDENTIFICATION OF THE DATA CONTROLLER

The controller of personal data that may be collected through cookies and similar technologies on ancestrina.com is:

Hereinafter, ANCESTRINA.

2. PURPOSE OF THIS POLICY

This Policy explains what cookies and similar technologies are, which categories ANCESTRINA may use, the purposes for which they may be used, when consent is required, how a person may accept, reject or configure non-essential technologies, and how preferences may later be changed.

This Policy should be read together with ANCESTRINA’s Personal Data Processing and Privacy Policy.

3. GENERAL LEGAL FRAMEWORK

In Colombia, when a cookie, identifier or similar technology allows information linked or linkable to an identified or identifiable natural person to be collected, its processing may be subject to the personal-data protection regime, including the principles of purpose, freedom, transparency, restricted access, security and confidentiality.

ANCESTRINA will apply this Policy in accordance with Law 1581 of 2012, Decree 1074 of 2015 and the applicable rules, instructions and criteria of the Superintendencia de Industria y Comercio.

Authorization for personal-data processing must be prior and informed when legally required. Silence will not be treated as consent.

4. WHAT COOKIES ARE

Cookies are small files or identifiers that a website may store or read in a browser or device to remember information, maintain site functions, recognize certain preferences, measure website use or, depending on the technology used, support personalization, analytics or advertising activities.

Not every cookie necessarily contains personal data. However, certain identifiers, combinations of data or browsing information may become linked or associated with a person and, in that case, will be processed under the applicable personal-data protection regime.

5. SIMILAR TECHNOLOGIES

This Policy also applies, where relevant, to technologies similar to cookies, such as:

  • local storage and session storage;
  • pixels and tags;
  • device or browser identifiers;
  • measurement scripts;
  • SDKs or equivalent technologies in integrated services;
  • technologies used by embedded video players;
  • campaign attribution and measurement mechanisms;
  • other technologies that allow information about use to be stored, read, recognized or associated.

6. CATEGORIES OF COOKIES AND TECHNOLOGIES

6.1 Strictly necessary cookies

These are necessary for the site to function, maintain security, remember an action requested by the user or provide an essential feature. They may be used, for example, for:

  • security and fraud prevention;
  • session management;
  • cart and checkout operation where ecommerce exists;
  • load balancing or technical operation;
  • cookie-consent preferences;
  • form protection and anti-spam mechanisms;
  • other essential functions requested by the user.

These technologies may be activated without consent when they are strictly necessary to provide the requested functionality or fulfill an essential technical purpose, without prejudice to the applicable duties of information and data protection.

6.2 Functional cookies

These allow certain choices to be remembered or improve functions that are not strictly essential, for example language, display preferences or certain integrations. When these technologies involve personal-data processing or are not necessary to provide the requested service, ANCESTRINA will request the corresponding consent before activating them.

6.3 Analytics or measurement cookies

These make it possible to understand, in aggregate or at an individualized level depending on the tool used, how people reach the site, which pages they visit, which devices they use and which interactions they perform. They may be used to:

  • measure traffic and acquisition sources;
  • identify errors and navigation problems;
  • evaluate content performance;
  • understand journeys between pages;
  • measure non-sensitive conversions;
  • improve design, speed and user experience.

Non-essential analytics technologies must remain blocked until the user grants the corresponding consent when such consent is required.

6.4 Advertising, attribution or marketing cookies

Depending on the platforms actually contracted and ANCESTRINA’s configuration, these may be used to measure campaigns, limit frequency, attribute conversions, build audiences or personalize advertising.

These technologies must not load before consent when they are non-essential and require authorization. ANCESTRINA will not use sensitive information obtained through therapeutic forms to build advertising audiences and will not send advertising platforms the text of requests for individual or couple therapeutic accompaniment.

6.5 External-content cookies

Certain third-party integrations, such as video players, maps, calendars, course platforms or widgets, may place or read their own cookies. When an integration is not strictly necessary and may activate third-party technologies before the user has made a choice, prior blocking or a consent-respecting mode should be used.

7. FIRST-PARTY AND THIRD-PARTY COOKIES

Cookies may be first-party, when managed directly by ANCESTRINA or infrastructure acting under its control, or third-party, when placed or read by external providers.

ANCESTRINA must maintain an up-to-date technical inventory of the cookies and technologies actually used. A generic list that includes non-existent tools, or an incomplete list that omits active technologies, will not be considered valid.

8. COOKIE INVENTORY

Within the cookie-settings panel, the site should provide an accessible and current inventory that allows users to know, for each identified cookie or technology, at least:

  • cookie or identifier name;
  • provider or domain;
  • category;
  • purpose;
  • duration or expiration, where applicable;
  • whether it is first-party or third-party;
  • a link to provider information where relevant.

The inventory must be based on a real technical audit of the site and reviewed whenever services, plugins, pixels, analytics platforms, players or integrations are added or removed.

9. CONSENT

When a cookie or technology is not strictly necessary and processing requires authorization, ANCESTRINA must request the user’s decision in advance.

The consent mechanism must allow users to:

  • accept all non-essential categories;
  • reject all non-essential categories;
  • configure preferences by category;
  • save a selection;
  • later change or withdraw the decision easily.

Accept and reject options must have comparable accessibility and clarity. Pre-selected boxes will not be used for non-essential technologies.

10. REJECTING NON-ESSENTIAL COOKIES MUST NOT BLOCK THE SITE

Rejecting non-essential cookies must not prevent general access to ancestrina.com or to information that can be provided without those technologies.

Certain third-party functions may be unavailable if they technically depend on a rejected category. In that case, the site should explain which function requires authorization and allow the user to activate it voluntarily.

11. WITHDRAWING OR CHANGING CONSENT

The user may change preferences at any time through a permanent link such as “Cookie settings” or “Cookie preferences”, available from the footer.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal when that processing was valid.

12. RECORD OF THE USER’S DECISION

ANCESTRINA must retain reasonable technical evidence of the user’s decision when necessary to demonstrate consent or the preferences applied. Depending on the tool used, the record may include:

  • date and time;
  • banner or policy version;
  • categories accepted or rejected;
  • technical consent identifier;
  • information strictly necessary to demonstrate the selection.

The consent record must not be used for purposes other than managing or demonstrating preferences unless another lawful basis and duly disclosed purpose apply.

13. DURATION OF CONSENT

The consent platform should request a new decision when there is a material change in purposes or technologies, when the configured preference-renewal period expires, or when legal or technical reasons make a new decision necessary.

A new decision should not be forced on every visit while a valid saved preference exists, unless necessary.

14. BROWSER AND DEVICE CONTROLS

Users may also manage or delete cookies through their browser or device settings. Deleting browser cookies may cause ANCESTRINA to stop recognizing a previously saved preference and request a new decision.

15. ANALYTICS

ANCESTRINA may use analytics tools only to the extent they are actually installed and configured. The consent tool must prevent non-essential analytics scripts from running before the corresponding authorization.

Analytics events must not include text written by users in open fields of therapeutic forms, health data, sexual information, narratives of violence, diagnoses or other intimate information.

16. ADVERTISING AND CAMPAIGN MEASUREMENT

When ANCESTRINA uses advertising or attribution technologies, they must be correctly categorized and made subject to the corresponding consent before loading when they are not essential.

Commercial measurement may record events such as a visit, click, form start or successful submission, provided that the private content of the form or sensitive attributes of the person are not transferred to the advertising platform.

17. VIDEO AND EMBEDDED CONTENT

The site may embed external content, for example videos. Those providers may use their own technologies. Where technically possible, ANCESTRINA should use enhanced-privacy settings, deferred loading or prior-blocking mechanisms that prevent non-essential technologies from being activated before the user’s decision.

18. ECOMMERCE

Cookies necessary to maintain a cart, shopping session, checkout, security or fraud prevention may be considered technically necessary to provide the requested functionality.

This does not automatically make advertising, analytics or profiling technologies integrated into ecommerce necessary.

19. THERAPEUTIC FORMS

Individual Therapeutic Accompaniment, Couple Therapy and therapeutic-guidance forms require an enhanced level of privacy. On these pages:

  • pixels must not capture form content;
  • sensitive field values must not be sent to analytics or advertising tools;
  • session-replay tools must not record text entered into sensitive fields;
  • the reason for consultation must not be used to create advertising segments;
  • measurement must be limited to non-sensitive events such as form start or submission.

20. SESSION REPLAY, HEATMAPS AND EXPERIENCE TOOLS

If ANCESTRINA uses session-recording, heatmap or experience-analysis tools, they must be configured to exclude form fields, personal information and sensitive pages.

Therapeutic-request text, payment data, passwords and other information that is unnecessary for the analysis purpose must not be recorded.

21. INTERNATIONAL TRANSFERS AND PROVIDERS

Some providers of cookies or similar technologies may process information outside Colombia. Where processing involves personal data, ANCESTRINA will apply the international-transfer or transmission rules set out in Colombian law and in its Personal Data Processing and Privacy Policy.

22. CHILDREN AND ADOLESCENTS

ANCESTRINA will not deliberately use behavioral-advertising technologies to profile minors based on information collected through therapeutic forms or services.

When a page is specifically aimed at children or adolescents, a separate review of cookies, consent and enhanced protection must be completed before publication.

23. DO NOT TRACK AND BROWSER SIGNALS

The response to technical signals such as Do Not Track, Global Privacy Control or others will depend on the capabilities of the tools implemented and the applicable legal framework. ANCESTRINA will not claim technical support for a signal that the site has not actually verified.

24. UPDATES TO THIS POLICY

This Policy may be updated when the technologies used, providers, purposes, regulations or site architecture change.

The last-updated date must appear at the beginning of the document. When a change requires renewed authorization, the consent platform must request it before activating the affected technologies.

25. RIGHTS OF DATA SUBJECTS

When cookies or similar technologies involve personal-data processing, people may exercise the rights recognized in the Personal Data Processing and Privacy Policy, including the right to know, update and rectify data, request information about its use, withdraw authorizations or request deletion where applicable.

Privacy channel: privacidad@ancestrina.com

26. CONTACT

27. RELATED DOCUMENTS