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Cookie & Tracking Policy

Effective Date: [EFFECTIVE DATE]

This Cookie & Tracking Policy explains how [ONSAVO LEGAL ENTITY] ("Onsavo," "we," "us," or "our") uses cookies and similar tracking technologies on onsavo.com and our related online services (the "Site"). Onsavo is a self-pay telemedicine platform that connects patients with independent, state-licensed providers. This policy describes what these technologies are, the categories we use, the choices you have to control them, and—importantly—how we limit the use of health information in tracking.

This policy should be read together with our Privacy Policy and our Notice of Privacy Practices.

1. What Cookies, SDKs, and Pixels Are

Cookies and similar technologies are small files or pieces of code placed on your device or within our applications that help a website or service function, remember your preferences, and understand how the Site is used. The most common technologies are described below.

  • Cookies. Small text files stored in your browser by the websites you visit. "First-party" cookies are set by Onsavo; "third-party" cookies are set by other companies whose tools we use. "Session" cookies expire when you close your browser; "persistent" cookies remain until they expire or you delete them.
  • Pixels (also called web beacons or tags). Tiny, often invisible graphics or snippets of code embedded in a web page or email that can record whether a page was viewed or an email was opened, and that may set or read cookies.
  • Software development kits (SDKs). Blocks of code that may be integrated into mobile or web applications to provide functionality such as analytics or error reporting.
  • Local storage and similar technologies. Mechanisms such as browser local storage and device identifiers that store information on your device for similar purposes.

In this policy, we refer to all of these collectively as "cookies" or "tracking technologies."

2. Categories of Cookies We Use

We group the cookies and tracking technologies on our Site into the following categories. Specific tools may change over time; the categories below describe the purposes for which we use them.

Strictly Necessary

These cookies are required for the Site to function and cannot be switched off in our systems. They are typically set in response to actions you take, such as logging in, completing an intake form, maintaining a secure session, or processing a payment. Examples include session-management cookies, security and fraud-prevention cookies, load-balancing cookies, and cookies that remember items during checkout. Because the Site cannot work properly without these, they do not require consent where consent would otherwise be needed.

Functional

These cookies allow the Site to remember choices you make and provide enhanced, more personalized features. Examples include cookies that remember your language or display preferences, that keep you signed in, or that support live-chat or customer-support features.

Analytics

These cookies help us understand how visitors interact with the Site so we can measure and improve performance—for example, which pages are visited, how long pages take to load, and where errors occur. The information is used in aggregate to improve usability and reliability. Examples include page-view and event-measurement cookies and performance-monitoring tools.

Advertising

These cookies may be used to measure the effectiveness of our marketing and, where applicable, to show you relevant advertising on other websites. Examples include conversion-measurement pixels and audience-measurement tools provided by advertising partners. Subject to Section 3 below, any advertising activity is strictly limited so that it never relies on your health information.

3. We Do Not Use Health Information for Advertising or Targeting

We treat the health information you provide to Onsavo with heightened care. Specifically:

  • We do not use protected health information (PHI), health-questionnaire responses, diagnoses, symptoms, medications, lab results, or other sensitive health-condition data for third-party advertising, audience-building, or ad targeting.
  • We do not share your health-questionnaire content, intake responses, clinical records, BMI/height/weight, or lab results with advertising networks, social-media platforms, or data brokers for their own advertising purposes.
  • We do not place advertising or third-party marketing pixels on pages where we collect health information—such as medical intake, clinical questionnaire, lab-result, or patient-portal pages—in a manner that would transmit that health information to advertising partners.

Where we use measurement or advertising tools at all, they are configured to exclude health-condition and PHI signals. Our handling of health information is governed by HIPAA and described in our Notice of Privacy Practices.

4. Third-Party Tools We Use

We use a limited set of third-party services that may set cookies or use similar technologies on our Site. The categories and representative providers are listed below. This list is illustrative and may be updated as our tools change; for the current list, contact us using the details in Section 8.

  • Analytics / performance: [e.g., web analytics provider]
  • Error and reliability monitoring: [e.g., application monitoring provider]
  • Customer support / live chat: [e.g., support-chat provider]
  • Payment processing: [e.g., payment processor]
  • Advertising / conversion measurement (subject to Section 3): [e.g., advertising/measurement provider]

Each third-party provider's use of information it collects is governed by that provider's own privacy policy. We do not control, and are not responsible for, the privacy practices of these third parties.

5. How to Control Cookies

You have several ways to control or limit cookies and tracking technologies.

  • Consent banner. Where required, we present a cookie consent banner or preference center when you first visit the Site. You can use it to accept or decline non-essential categories (functional, analytics, and advertising) and to change your choices later. Strictly necessary cookies cannot be declined because the Site relies on them to function.
  • Browser settings. Most browsers let you view, block, or delete cookies through their settings menu. You can usually choose to block all cookies, block third-party cookies only, or delete existing cookies. If you block strictly necessary cookies, parts of the Site may not work properly.
  • Mobile settings. Your device settings may let you limit ad tracking or reset device identifiers.
  • Opt-out and industry tools. Some advertising and analytics providers offer their own opt-out mechanisms, which you can typically find in the provider's privacy disclosures.

6. Do Not Track and Global Privacy Control

Some browsers offer a "Do Not Track" (DNT) signal. Because there is no common industry standard for how DNT signals should be interpreted, our Site does not currently respond to DNT signals.

We do honor recognized opt-out preference signals, including the Global Privacy Control (GPC), where required by applicable law. When you visit the Site with a browser or extension that transmits a GPC signal, we treat it as a request to opt out of the sale or sharing of personal information and of targeted advertising, to the extent these apply to you under applicable privacy laws. Because such a signal is tied to the specific browser and device you are using, you should enable it on each browser and device you wish to cover.

7. Related Policies

For more information about how we collect, use, and protect your information, please review:

  • [Privacy Policy](/privacy) — how we handle personal information across our services.
  • [Notice of Privacy Practices](/hipaa-notice) — how we handle protected health information (PHI) under HIPAA.

8. Changes to This Policy and Contact Information

We may update this Cookie & Tracking Policy from time to time to reflect changes in the technologies we use or in applicable law. When we make material changes, we will update the Effective Date above and, where appropriate, provide additional notice.

If you have questions about this policy or our use of cookies and tracking technologies, contact us at:

  • Email: [PRIVACY EMAIL]
  • Mailing address: [BUSINESS MAILING ADDRESS]

This is a template for [ONSAVO LEGAL ENTITY]; have qualified counsel review before publishing.