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Cookie Policy

DRAFT — pending review by qualified Spanish/EU counsel. Bracketed [PLACEHOLDERS] must be completed before this document is relied upon in production. The English version governs; other languages are provided for convenience only.

Effective date: [EFFECTIVE DATE] Last updated: [EFFECTIVE DATE]

This Cookie Policy explains how the SleepyCuddle service ("SleepyCuddle", "we", "us", "our") uses cookies and similar technologies on our website, sleepycuddle.com, and how you can control them. It is provided in accordance with Article 22.2 of the Spanish Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE), the ePrivacy rules, and the cookie guidance issued by the Spanish Data Protection Agency (AEPD).

Scope. This Cookie Policy covers sleepycuddle.com only. If you use our mobile app, on-device storage (such as the data the app keeps to remember your session or preferences on your phone) is described in our Privacy Policy rather than here. SleepyCuddle is an AI family bedtime-storytelling service operated by an individual self-employed professional ("autónomo") established in Spain. This policy should be read together with our Privacy Policy and our Terms of Service, which explain in more detail how we handle your personal data.

Who operates SleepyCuddle

  • Operator: [OPERATOR FULL NAME] (autónomo — a natural person)
  • NIF: [NIF]
  • Address: Av. de les Corts Valencianes 26, 46015 Valencia, Spain
  • Contact e-mail: [CONTACT EMAIL]

Table of contents

  1. What are cookies and similar technologies?
  2. Our approach in short
  3. Strictly necessary cookies (used without consent)
  4. Functional cookies (language preference)
  5. Non-essential cookies (analytics / measurement)
  6. We do not use advertising cookies
  7. Cookie category table
  8. Third-party contexts (payment checkout and social sign-in)
  9. How to manage or withdraw your consent
  10. Controlling cookies through your browser
  11. Cookies and your personal data
  12. Changes to this Cookie Policy
  13. Contact and complaints

1. What are cookies and similar technologies?

A cookie is a small text file that a website places on your device (computer, tablet or phone) when you visit it. Cookies allow the website to recognise your device, remember your choices, and function correctly. Cookies are passive data files, not executable programs.

By "similar technologies" we mean other methods that store or read information on your device for comparable purposes, such as:

  • Local storage and session storage — small amounts of data kept by your browser to remember, for example, that you are logged in or which language you prefer.
  • Pixels and tags — small pieces of code that can perform functions similar to cookies.

Throughout this policy, when we say "cookies" we mean cookies and these similar technologies used in the browser on sleepycuddle.com. On-device storage inside our mobile app is addressed in our Privacy Policy.

Cookies can be described in several ways:

  • By who sets them: first-party cookies are set by SleepyCuddle; third-party cookies are set by another organisation whose service appears on our pages (for example, our payment provider).
  • By how long they last: session cookies are deleted when you close your browser; persistent cookies remain for a set period or until you delete them.
  • By purpose: strictly necessary cookies are essential to provide a service you have requested; functional cookies remember choices you make; non-essential cookies (such as analytics) are not essential and require your prior consent.

2. Our approach in short

We keep our use of cookies deliberately minimal. In practice:

  • We use strictly necessary cookies to keep the site secure, keep you signed in and balance server load. These do not require your consent.
  • We may set a functional cookie to remember your chosen interface language after you actively select it. Depending on how long that preference is stored, this may require your consent (see Section 4).
  • We do not show ads and we do not use any advertising, profiling or cross-site tracking cookies — ever.
  • Any non-essential cookie (for example, analytics or audience measurement) is loaded only after you have given prior, freely-given consent through our cookie banner, and you can refuse or withdraw that consent at any time, just as easily as you gave it.

Under Article 22.2 LSSI-CE and AEPD guidance, cookies that are strictly necessary to provide a service you have expressly requested are exempt from the consent requirement. These are always active because the website cannot work properly without them; you cannot switch them off through our banner, but you can still block them via your browser settings (this may break parts of the site).

We use strictly necessary cookies for the following purposes:

  • Session management — to maintain your session as you move between pages.
  • Authentication — to recognise you when you sign in and keep you securely logged in to your account (only adults hold accounts; children never sign in).
  • Security and fraud prevention — to protect your account and our service against abuse, and to support the integrity of the checkout process.
  • Load balancing — to distribute traffic across our servers so the site stays available and responsive.

4. Functional cookies (language preference)

If you actively choose an interface language (English, Ukrainian, Spanish or German are provided as interface languages only), we may store that choice so you do not have to select it again.

  • Where this preference is kept only for the current visit (a session-scoped cookie set as a direct result of your explicit selection), AEPD and EDPB guidance treat it as consent-exempt, and we set it on that basis.
  • Where we remember your language for a longer, persistent period so it survives across visits, that persistent functional cookie is not strictly necessary. In that case we set it only with your prior consent, offered through the same controls described in Section 9, and you can withdraw that consent at any time.

We do not use language or preference cookies for any purpose beyond remembering your interface choice.

5. Non-essential cookies (analytics / measurement)

Current position: SleepyCuddle does not currently use any analytics, audience-measurement or statistics cookies. At the time this policy takes effect, no non-essential cookies are loaded on sleepycuddle.com.

If, in the future, we decide to use analytics or measurement cookies to understand how our website is used and to improve it, we will:

  1. Load them only after you have given prior opt-in consent through the cookie banner — never by default and never before you choose;
  2. Keep the choice to accept and to reject equally prominent and equally easy (rejecting will be no harder than accepting, and there will be no pre-ticked boxes);
  3. Allow you to withdraw your consent at any time, as easily as you gave it, through the "Cookie settings" control described in Section 9;
  4. Update the table in Section 7 and this policy before such cookies are activated, so you always know exactly what is running.

Until then, the representative analytics row shown in the table below is marked as a [PLACEHOLDER] and is not active.

6. We do not use advertising cookies

SleepyCuddle contains no advertising and shows no ads. We do not use advertising, marketing, retargeting, behavioural-profiling or cross-site tracking cookies, and we do not disclose your data to third parties for advertising purposes. This is a fundamental part of how the service is designed: it exists to help a parent play personalised bedtime stories to their own children, not to profile anyone.

The table below describes the cookies and similar technologies we use. Where a specific technical cookie name or duration is not yet fixed, we show a [PLACEHOLDER] that will be completed once our final cookie inventory is confirmed. Third-party cookies listed here are set only in specific contexts (see Section 8) — for example, on pages where payment is available or when you choose social sign-in.

Name / ProviderPurposeCategoryType & storageDurationConsent
[PLACEHOLDER — session cookie] (SleepyCuddle, first-party)Maintains your browsing sessionStrictly necessaryHTTP cookieSession (deleted on browser close)Not required
[PLACEHOLDER — auth token] (SleepyCuddle, first-party)Keeps you securely signed in to your accountStrictly necessaryHTTP cookie / local storageSession or up to [PLACEHOLDER — max auth duration]Not required
[PLACEHOLDER — security/CSRF token] (SleepyCuddle, first-party)Protects against cross-site request forgery and abuseStrictly necessaryHTTP cookieSessionNot required
[PLACEHOLDER — load-balancing cookie] (SleepyCuddle / hosting, first-party)Routes your requests to a healthy serverStrictly necessaryHTTP cookieSessionNot required
[PLACEHOLDER — locale cookie] (SleepyCuddle, first-party)Remembers the interface language you selectFunctionalHTTP cookie / local storageSession, or persistent up to [PLACEHOLDER — e.g. 12 months] if you consentSession: not required · Persistent: prior consent
Payment checkout cookies (our payment provider's checkout, third-party)Payment processing, checkout security and fraud prevention within the payment featureStrictly necessary (for the payment feature)HTTP cookieSession / as set by the payment provider — see the payment provider's own privacy policyNecessary for the feature you requested; any additional cookies set by the payment provider are governed by that provider's own policies
Social sign-in cookies (social sign-in provider, third-party)Authenticates you if you choose social sign-inStrictly necessary (for the sign-in feature)HTTP cookieAs set by the sign-in provider — see the sign-in provider's own privacy policyNecessary for the feature you requested; any additional cookies set by the sign-in provider are governed by that provider's own policies
[PLACEHOLDER — analytics cookie] ([PLACEHOLDER — provider], first/third-party)Not currently used. Would measure aggregate website usageAnalytics / measurement[PLACEHOLDER][PLACEHOLDER]Prior opt-in required

Cookie durations and behaviour set by third parties are controlled by those providers and may change; please consult their policies (referred to above and in Section 8) for the most current and authoritative details.

8. Third-party contexts (payment checkout and social sign-in)

Some cookies are set by trusted third parties, but only within a specific feature you have chosen to use, not for advertising across our general browsing pages:

  • Payment checkout (payments). When you subscribe or buy a story-time top-up, payment is processed by our payment provider through its checkout on our site. Because the payment provider's payment and fraud-prevention technology is loaded on the pages where the payment feature is available, the payment provider may set cookies on those pages, not only at the moment you click to pay. Within this feature, these cookies are used to process the payment securely and to prevent fraud. We never store your full card number. The payment provider may also set other cookies for its own purposes; those are governed by that provider's own policies, and we do not control every cookie a third party may set. The payment provider's policies are authoritative on how it classifies its cookies — see the payment provider's own privacy and cookie policies.

  • Social sign-in (authentication). If you choose to sign in through a social sign-in provider, that provider may set cookies to authenticate you. This happens only if you use that sign-in option. The provider may also set additional cookies for its own account, functional or measurement purposes; those are governed by the provider's own policies, which are authoritative on how it classifies them — see the sign-in provider's own privacy and cookies policies.

These third parties process data under their own policies and, where personal data leaves the EU/EEA, under appropriate safeguards (such as EU Standard Contractual Clauses, and, where a provider relies on it, the EU–US Data Privacy Framework). Our Privacy Policy lists our processors and the specific safeguards in full.

Because we currently use only strictly necessary and (where you select a language) functional cookies, there is at present no analytics or advertising cookie to accept or reject. Where consent applies — that is, for a persistent language preference (Section 4) or for any non-essential (analytics/measurement) cookie we might introduce — you will be able to manage it as follows:

  • Cookie banner. On your first visit (and again after the interval described below, or after any material change), a banner will let you accept or reject cookies that require consent. Rejecting is exactly as easy as accepting. No such cookie is set before you choose to accept.
  • "Cookie settings" control. A persistent "Cookie settings" (or "Manage cookies") link is available on our website so you can review your choices and withdraw or change consent at any time, with the same ease you gave it. Withdrawing consent does not affect the lawfulness of any processing that took place before withdrawal.
  • Consent refresh and record. In line with AEPD guidance, we record the consent you give and re-request it after a defined period (we intend [PLACEHOLDER — e.g. 24 months]) and whenever there is a material change, so your choices stay current.

Withdrawing consent to cookies that require it will not affect your ability to use the core service, since those cookies are, by definition, not essential.

10. Controlling cookies through your browser

Independently of our banner, you can control or delete cookies through your browser settings, including strictly necessary ones. Please note that blocking strictly necessary cookies may stop parts of sleepycuddle.com from working (for example, you may be unable to stay signed in or complete a payment).

Most browsers let you view, block and delete cookies. Instructions are available here:

You can also usually set your browser to notify you when a cookie is being set, or to use private/incognito browsing.

11. Cookies and your personal data

Cookies operate on two legal layers, which we keep separate:

  • Storing or reading the cookie on your device. Whether a cookie may be stored on, or read from, your device is governed by Article 22.2 LSSI-CE (implementing the ePrivacy rules). Strictly necessary cookies rely on the exemption for a service you have expressly requested; cookies that are not strictly necessary (a persistent language preference, or any analytics cookie) are stored only with your prior consent.
  • Processing any personal data obtained through the cookie. Where a cookie then processes personal data, we rely under the EU General Data Protection Regulation (GDPR) on the performance of our contract with you (for example, keeping you signed in and processing your payment) and/or our legitimate interest in operating a secure, functioning website; for non-essential cookies the basis is your consent, which you may withdraw at any time.

Cookies do not process biometric data. Your voice recording and the derived voice clone — which are special-category biometric data under GDPR Article 9 and are handled only on your separate explicit consent under Article 9(2)(a) — are managed within your account, not through cookies, and can be deleted from your account at any time. How we handle that data, your rights, international transfers and our processors are all described in our Privacy Policy.

We may update this Cookie Policy from time to time, for example if we change the technologies we use or introduce a new cookie category. When we make a material change — such as adding any non-essential cookie — we will update this page, revise the "Last updated" date, and, where required, ask for your consent again through the banner before the new cookies are activated. We encourage you to review this policy periodically.

13. Contact and complaints

If you have any questions about this Cookie Policy or about how we use cookies, please contact us:

  • Operator: [OPERATOR FULL NAME] (autónomo)
  • NIF: [NIF]
  • Address: Av. de les Corts Valencianes 26, 46015 Valencia, Spain
  • E-mail: [CONTACT EMAIL]

If you believe we have not handled your personal data or your cookie choices correctly, you have the right to lodge a complaint with the Spanish Data Protection Agency:

Agencia Española de Protección de Datos (AEPD) C/ Jorge Juan 6, 28001 Madrid, Spain Website: www.aepd.es

This Cookie Policy is governed by Spanish law.