Cookie policy

The binding version of this policy is the Spanish one. This English text is provided for convenience.

1. What are cookies?

Cookies are small files or storage devices that may be installed or used on the user’s device when visiting a website or using certain digital services.

Cookies and similar technologies make it possible, among other functions, to remember certain preferences, keep sessions open, ensure the security of a service, obtain information about how it works or analyse how it is used.

This Policy explains the use of cookies and similar technologies on the website and, where applicable, on the ALIVIO platform.

2. Who uses the cookies?

The party responsible for the website and the cookies used for its own purposes is:

• ALIVIO Asset Management, S.L.
• NIF: [pending]
• Registered office: [pending]
• Email: hola@alivioasset.com

Hereinafter, “ALIVIO”. Certain cookies or technologies may be managed by third parties when ALIVIO uses external services.

3. Where may they be used?

This Policy applies to cookies and similar technologies used, where applicable, on:

• ALIVIO’s website;
• web access to the ALIVIO Platform;
• and other digital environments managed by ALIVIO that reference this Policy.

Mobile apps, where they exist, may use storage or identification technologies other than traditional cookies. Where such technologies require information or consent, principles equivalent to those set out in this Policy will apply.

4. What types of cookies may we use?

Depending on the technical configuration in place at any given time, ALIVIO may use the following categories.

4.1. Technical or necessary cookies

These are necessary to enable the operation of the website or Platform. They may be used, for example, to:

• keep a session open;
• authenticate a User;
• manage security;
• remember certain technical settings;
• balance loads;
• prevent fraudulent use;
• enable functionalities requested by the User;
• preserve privacy preferences.

These cookies may be necessary to provide the service requested by the User. Where strictly necessary, they do not require consent, without prejudice to the duty to inform about their use.

4.2. Preference or personalisation cookies

They allow certain features chosen by the User to be remembered, such as language, display preferences, interface settings or other customised options.

Where these cookies are installed as a direct result of a choice made by the User and are necessary to provide the requested service, they may be exempt from consent in the cases legally provided. In other cases, consent will be requested where appropriate.

4.3. Analytics or measurement cookies

They allow analysis of how Users use the website or Platform, such as number of visits, pages or screens viewed, functionalities used, approximate session duration, errors, performance and aggregate usage patterns.

Where these cookies are not strictly necessary and are subject to consent, they will not be installed until the User has authorised them.

4.4. Advertising cookies

They allow advertising spaces to be managed or advertising campaigns to be measured. If used, they will be disabled by default until consent is obtained where legally required.

4.5. Behavioural advertising cookies

These technologies allow profiles derived from browsing habits to be created or used in order to display personalised advertising. ALIVIO does not envisage using this type of cookie in the professional Platform unless expressly disclosed and the required prior consent is obtained.

5. First-party and third-party cookies

• First-party cookies: managed directly from domains or systems controlled by ALIVIO.
• Third-party cookies: managed by external providers whose services are integrated into the website or Platform.

Where third-party cookies are used, the relevant information will be included in the cookie inventory available in this Policy or in the settings panel.

6. What do we use cookies for?

Depending on the technologies ultimately implemented, ALIVIO may use cookies to enable the technical operation of the site, manage sessions, authenticate Users, maintain security, remember preferences, detect errors, analyse performance, understand in aggregate how certain functionalities are used and improve the User experience.

We will not use cookies subject to consent for purposes other than those authorised by the User.

7. Legal basis

The use of cookies strictly necessary to provide a service requested by the User may be carried out without obtaining consent in the cases legally provided.

Where a cookie or similar technology requires consent, the legal basis for its use will be the User’s consent. The User may withdraw that consent later as easily as it was given.

8. Cookie settings panel

Where ALIVIO uses cookies subject to consent, the User will have a mechanism enabling them to accept the cookies, reject them, or configure the categories they wish to authorise.

Non-necessary cookies will remain disabled until the User makes a valid choice. The choice made can be changed later via the “Cookie settings” link or mechanism available on the website.

9. Rejecting cookies

Rejecting non-necessary cookies will not prevent access to the basic functionalities of the website or Platform.

However, certain optional functionalities related to the rejected category may not be available.

Strictly necessary cookies cannot be disabled via the panel where they are essential to provide the requested functionality.

10. Withdrawal of consent

The User may change or withdraw consent at any time via the cookie settings panel.

Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

11. Cookie duration

• Session: deleted when the session ends or the browser is closed, depending on its configuration.
• Persistent: stored for a set period.

ALIVIO will limit cookie duration to the time reasonably necessary for its purpose. The specific duration of each cookie will be indicated in the relevant inventory.

12. International transfers

Where cookie or similar-technology providers are used that may involve transfers of data outside the European Economic Area, ALIVIO will inform of this and apply the safeguards required by data protection law. Specific information will be added to the inventory where applicable.

13. Cookies and personal data

Certain cookies may involve the processing of information that qualifies as personal data.

Such data will be processed in accordance with this Policy and ALIVIO’s Privacy Policy. Where applicable, the User may exercise the rights recognised by data protection law in accordance with the procedure described in that Policy.

14. Browser settings

The User can also configure their browser to allow, block or delete cookies. How to do so depends on the browser and device used.

Deleting technical or authentication cookies may require signing in again or reconfiguring certain preferences.

15. Updates to this Policy

ALIVIO may update this Policy as a result of regulatory changes, the addition or removal of technologies, new providers, changes to functionalities or changes to the purposes of the cookies.

Where changes affect previously given consent such that new consent is required, it will be requested again from the User. The current version will be permanently accessible from the website.

Annex I — Cookie inventory

This section will be completed before final publication, following a technical review of the cookies and technologies actually used. For each cookie, at least the following will be documented: cookie/technology, owner, purpose, category (necessary / preferences / analytics / advertising), duration and first- or third-party nature. Where applicable, the relevant third party and information on possible international transfers will be identified.

Cookie / technology	Owner	Purpose	Category	Duration	First/third-party
[pending]	[pending]	[pending]	[pending]	[pending]	[pending]

ALIVIO Asset Management, S.L. · NIF: [pending] · Address: [pending] · Email: hola@alivioasset.com · Version: August 2026.