Cookie Policy – Doceree Spark

Introduction

Doceree Inc. (“Doceree,” “we,” “our,” or “us”) is committed to protecting your privacy and ensuring transparency regarding the use of tracking technologies. This Cookie Policy explains how Cookies and similar technologies are used on the Doceree Spark Platform portal (the “Spark Platform Portal”), which provides publishers and authorized users with access to Spark configuration tools, reporting features, and administrative functions.

This Policy applies only to the web-based Spark Platform Portal. It does not apply to the delivery of Spark Messages within electronic health record (“EHR”) systems or health-system environments, where Cookies and similar tracking technologies are not used..

This Policy describes what Cookies are, how and why we use them within the Spark Platform Portal, and the choices available to you for managing their use. For more information about how we process personal information more broadly, please refer to our Privacy Policy.

What Are Cookies?

Cookies are small text files that websites or applications place on your browser or device to store information. Within the Spark Platform Portal, Cookies help maintain secure login sessions, remember your preferences, support performance and analytics, and enable certain portal features to function correctly.

We may also use technologies that operate in a similar manner, such as tags, local storage, SDKs, and device identifiers, to support essential platform functions and analytics. For ease of reference, this Cookie Policy refers to all such technologies collectively as “Cookies.”

These technologies are used only within the Spark Platform Portal and are not used to deliver or trigger Spark Messages inside EHR or health-system workflows. Spark Messages rely on de-identified contextual workflow signals, not Cookies, pixels, trackers, or device identifiers.

Legal Basis and Consent

Here required by applicable law, including but not limited to the California Privacy Rights Act (CPRA), the Washington My Health My Data Act (MHMDA), the EU General Data Protection Regulation (GDPR), the UK GDPR, and other international privacy regulations, we obtain your consent before using any non-essential Cookies within the Spark Platform Portal. Non-essential Cookies may include optional analytics technologies that help us understand how authorized users interact with portal features, improve platform performance, or enhance user experience.

Consent is not required for Cookies that are strictly necessary to operate the Spark Platform Portal, including those used for authentication, security, session integrity, and core functionality. These essential Cookies enable the portal to function and cannot be disabled.

This consent framework applies only to the Spark Platform Portal. Cookies and similar tracking technologies are not used to deliver Spark Messages within EHR or health-system environments, and Spark Message delivery does not rely on personal information, device identifiers, or cookie-based tracking.

You may manage, modify, or withdraw your consent to non-essential Cookies at any time using the Cookie Preferences tool available within the Spark Platform Portal. Any changes to your consent will apply prospectively and will not affect the lawfulness of processing that occurred before such changes were made.

How We Use Cookies on the Spark Platform

Cookies and similar technologies are used only within the Spark Platform Portal, not within EHR or health-system environments where Spark Messages are delivered. These technologies help ensure secure access, support essential functionality, and enable performance improvements for users interacting with Spark Platform Portal. We use Cookies for the following purposes:

Operate and Maintain the Spark Platform Portal: : Cookies support essential functions such as secure login sessions, authenticated access, navigation between portal features, maintaining session integrity, and enabling tools used to configure Spark integrations or view reporting dashboards. These Cookies are necessary for the proper functioning of the Spark Platform Portal.

Secure the Spark Platform Portal and Prevent Fraud: Cookies help detect unauthorized access attempts, identify unusual or suspicious activity, enforce authentication and session controls, and maintain overall platform security. These Cookies are essential for protecting user accounts and maintaining system integrity.

Personalize and Enhance Your Experience: Cookies allow the Spark Platform Portal to remember your preferences—such as saved filters, reporting configurations, interface settings, or display options, and provide a consistent, streamlined user experience across sessions

Analyze Usage and Improve Functionality: Collect aggregated, non-identifiable usage data to understand how users engage with the platform, identify issues, refine features, and optimize overall performance.

Support Advertising Analytics and Reporting: We may use Cookies to collect aggregated, de-identified usage information to understand how users engage with portal tools, identify technical issues, improve navigation, enhance portal performance, and guide product development.

Support Cross-Browser and Cross-Device Continuity: Cookies may help recognize returning users on the Spark Portal to maintain saved preferences or dashboard settings. These Cookies do not support cross-device tracking in clinical environments and do not identify EHR users.

Note: Cookies are not used to deliver or trigger Spark Messages within EHR or health-system workflows. Spark Message delivery is powered exclusively by workflow-based, de-identified contextual signals generated within the Publisher’s environment, and does not rely on Cookies, pixels, device identifiers, or any browser-based tracking technologies. We do not use Cookies to collect or associate sensitive personal information or any personal health information (PHI). Cookies used on the Spark Platform Portal are limited solely to what is necessary for functionality, security, and optional portal analytics.

Categories of Cookies Used on the Spark Platform

The Spark Platform uses a limited set of Cookies and similar technologies only within the Spark Platform Portal to support secure access, functionality, and performance. These technologies are not used to deliver or trigger Spark Messages in EHR or health-system environments.

Strictly Necessary Cookies: : These Cookies are required for the fundamental operation and security of the Spark Platform Portal. They support functions such as authenticated logins, maintaining secure sessions, enabling navigation across portal tools, and ensuring system stability. These Cookies are essential and cannot be disabled without impairing portal functionality.

Functional Cookies: Functional Cookies help the Spark Platform Portal remember your preferences and enhance usability. They support features such as customized dashboard layouts, saved reporting filters, preferred display options, and other user-selected configurations that streamline your portal experience.

Performance and Analytics Cookies: These Cookies collect aggregated, de-identified information about how authorized users interact with the Spark Platform Portal. This includes understanding which tools are accessed most frequently, identifying technical issues or slow-loading features, and measuring overall system performance. This information is used solely to improve portal functionality and user experience and does not reflect or track activity within EHR workflows.

Third-Party Cookies: Certain third-party services integrated into the Spark Platform Portal, such as analytics tools, hosting providers, or performance-monitoring solutions, may set their own Cookies to deliver their contracted services. These Cookies are used only to support portal operations, diagnostics, and functionality enhancements and are governed by the privacy policies of the respective providers.

Do we Sell or Share your Cookie Data?

The Spark Platform Portal uses only functional, security, and performance-related Cookies. These Cookies are used exclusively to operate the portal, maintain secure sessions, support user preferences, and improve portal performance. Cookies are not used to deliver or trigger Spark Messages within EHR or health-system workflows, and no Cookie data is used for advertising, behavioral tracking, or cross-site profiling.

Under certain privacy laws, such as the CPRA, MHMDA, GDPR, and other state or international regulations, some uses of analytics or performance Cookies may be classified as “sharing” or, in limited contexts, a “sale” of personal information, even where no monetary exchange occurs. Doceree does not sell personal information for monetary gain and does not use Cookies for advertising, targeted marketing, or audience profiling.

Any Cookie-related data processed through the Spark Platform Portal may be disclosed only to third-party service providers who support platform security, analytics, hosting, or performance monitoring, and only for the purpose of delivering those contracted services. These providers are bound by contractual obligations and are not permitted to use Cookie data for their own independent purposes.

Where required by law, we provide you with the ability to opt out of non-essential Cookies that may be considered “sharing” under applicable regulations. You can manage your preferences or withdraw consent at any time through the Your Privacy Choices section or via the Cookie Preferences tool available on the Spark Platform Portal.

Retention of Cookie and Tracking Data

The Spark Platform Portal retains Cookie and tracking data only for as long as necessary to support the operational, functional, security, or performance purposes for which such data was collected. Retention periods vary based on the category of Cookie, such as strictly necessary, functional, or analytics Cookies, and are limited to what is required to maintain portal functionality, ensure platform security, support user preferences, and improve system performance. Cookies are not used to support the delivery of Spark Messages within EHR or health-system environments, and no Cookie data is retained for advertising, behavioral tracking, or marketing purposes

We apply global privacy and data-protection principles such as lawful purpose, data minimization, and proportionality when determining retention periods, and we comply with applicable legal requirements in the jurisdictions in which the Spark Platform Portal operates. Cookie and tracking data is not stored longer than necessary, and our retention practices are regularly reviewed to ensure ongoing compliance and operational relevance.

Third-Party Services and Tracking Technologies

The Spark Platform Portal may incorporate certain third-party services, such as hosting providers, performance-monitoring tools, analytics platforms, or security-enhancement technologies, that may use their own Cookies or similar tracking mechanisms. These technologies are employed solely to support portal performance, diagnostics, security, and functionality. They do not support, enable, or measure Spark Message delivery within EHR or health-system workflows.

These third-party service providers may collect limited device, session, or interaction information directly from your use of the Spark Platform Portal, in accordance with their own privacy policies and subject to their contractual obligations to Doceree. Doceree does not control or assume responsibility for the independent data practices of such third parties, and any data collected is used exclusively to provide the contracted services necessary for operating and improving the Spark Platform Portal.

We encourage you to review the privacy policies of any third-party services integrated with the Spark Platform Portal to understand how your information may be collected, used, or processed outside of Doceree’s environment.

How You Can Manage Your Cookie Preferences

You have control over how Cookies and similar technologies are used when accessing the Spark Platform Portal. The options below allow you to manage non-essential Cookies while maintaining full access to required platform functionality. Here are the ways you can manage your preferences:

Cookie Preference Manager: You may review and modify your preferences for non-essential Cookies, such as Functional or Analytics Cookies, through the Cookie Preferences tool available within the Spark Platform Portal. Essential Cookies used for security, authentication, and system operation cannot be disabled, as they are required for the Portal to function properly.

Browser Controls: Most modern web browsers allow you to block, delete, or restrict Cookies, receive alerts when Cookies are set, or manage site-specific privacy settings. Adjusting these settings may limit certain features or reduce the performance of the Spark Platform Portal.

Mobile Device Settings: Depending on your device or operating system, you may have additional options for limiting certain types of browser-based storage or tracking technologies. These controls apply only to your use of the Spark Platform Portal and do not affect the delivery of Spark Messages within EHR or health-system environments

Do Not Track (DNT) Signals: Some browsers offer a Do Not Track feature; however, because no consistent industry standard currently exists, the Spark Platform Portal does not respond to DNT signals. You may instead use the Cookie Preferences tool or browser controls to manage your choices.

Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our use of Cookies and similar technologies within the Spark Platform Portal, updates to applicable privacy or data-protection laws, or modifications to the features, functionality, or security of the Spark Platform. The “Last Updated” date at the top of this Policy indicates the most recent revision. Where required by law, or where a change materially affects how non-essential Cookies operate, we may provide additional notice, such as an in-platform notification or email communication, to inform you of the update..