HCEsquared Cookie and Tracking Technologies Policy

Effective Date: 10/6/2026

1.1  Scope and purpose 

This Cookie and Tracking Technologies Policy explains how HCEsquared uses cookies and similar technologies on its U.S.-only accredited continuing medical education platform for clinicians (the “Platform”). It applies to cookies and similar technologies used on the Platform, in our mobile applications, and in electronic communications that link to this Policy. Read this Policy with the Privacy Policy and the Terms of Use, including Terms of Use §§ 7.5, 7.8, and 7.14. The Privacy Policy provides additional information about California rights, data sales and sharing, and retention. 

1.2  Default settings and consent 

We do not condition access to the Platform on consent to non-essential tracking. When you visit the Platform, functional, analytics, and advertising technologies may load, and you may turn them off at any time through Cookie Settings or the Do Not Sell or Share My Personal Information link. HOWEVER, IF YOU ACCESS THE PLATFORM FROM CALIFORNIA OR FLORIDA, NON-ESSENTIAL COOKIES AND SIMILAR TECHNOLOGIES DO NOT LOAD UNTIL YOU AFFIRMATIVELY CONSENT THROUGH THE COOKIE BANNER OR PREFERENCE CENTER. This includes non-essential cookies, tracking pixels, web beacons, SDKs, session analytics, session-replay tools, and third-party technologies capable of intercepting communications.  References in this Policy to technologies that load only after consent apply to visitors from California and Florida.  

Strictly necessary cookies and similar technologies may load without consent because they are required to provide the Platform, authenticate users, maintain security, remember your cookie choice, and perform load balancing. For visitors from California and Florida, functional, analytics, and advertising technologies load only after consent to the applicable category. 

Strictly necessary cookies cannot be turned off through Cookie Settings because sign-in, security, consent management, and core Platform functions depend on them. 

1.3  Categories 

1.4  Technology types 

1.4.1  Session cookies. Session cookies remain on your browser only during a browsing session and generally expire when you close the browser. 

1.4.2  Persistent cookies. Persistent cookies remain on your device until they expire or you delete them. Their retention depends on the purpose and is described in the inventory in § 1.5. 

1.4.3  First-party and third-party cookies. First-party cookies are set by HCEsquared or at our direction. Third-party cookies are set or accessed by another service provider or platform. Third parties may use their own cookies and similar technologies under their own policies. 

1.4.4  Tracking pixels and web beacons. Tracking pixels and web beacons are small electronic images or code that can report activity to a server, such as pages viewed, email opens, link clicks, or the time and date of an interaction. Non-essential pixels and beacons load only after consent. 

1.4.5  Tags and tag managers. Tags are code elements that perform functions such as analytics, advertising, or video measurement. A tag manager helps deploy tags, but it does not override your consent choice; non-essential tags remain disabled until consent. 

1.4.6  SDKs in mobile applications. Software development kits may allow an application to provide security, video, analytics, advertising, or other functionality. Non-essential SDKs load only after consent to the applicable category. 

1.4.7  Local storage. Local storage and similar browser storage may retain preferences or identifiers on your device. We treat local storage used for non-essential tracking in the same way as non-essential cookies. 

1.4.8  Server-side event collection. Some events are collected on our servers rather than directly in your browser. Server-side collection must respect the same consent choice as the equivalent browser technology, including an opt-out of cookie-based sale or sharing. 

1.4.9  Email pixels. We may use pixels in emails to measure opens or link clicks. Where consent is required, email pixels and related tracking load only after consent to the applicable category; disabling images in your email client prevents most pixel tracking. 

1.4.10  Device and browser fingerprinting. We do not use device or browser fingerprinting to circumvent your cookie choices or to recreate tracking that you have declined. 

1.4.11  Session replay. We do not use session-replay tools that record keystrokes or form inputs. If we use session analytics, those tools load only after consent and mask form fields. 

1.4.12  Identity matching and cross-device association. We may use hashed identifiers, such as a hashed email address, to match activity or audiences and may associate activity across devices. These functions load or operate only after consent when used for non-essential analytics, advertising, audience matching, or measurement. 

1.5  Current inventory 

2.1  California and Florida communications tracking notice 

FOR VISITORS ACCESSING THE PLATFORM FROM CALIFORNIA OR FLORIDA, HCESQUARED REQUIRES YOUR EXPRESS PRIOR CONSENT BEFORE THESE TECHNOLOGIES LOAD. 

2.2  Express consent to communications tracking 

By selecting “Accept” or enabling a category in Cookie Settings, you expressly consent, on your own behalf, to HCEsquared and the third parties identified by category in § 1.5 recording, intercepting, receiving, and using your communications with and activity on the Platform for the purposes described in this Policy, and you acknowledge that this consent is given before any such technology loads. HCEsquared and each applicable third-party provider are each a party to this consent for the technology and purposes identified by category. 

2.3  Chat, live chat, and chatbot features 

If HCEsquared offers chat, live chat, or chatbot features, chat transcripts are recorded and stored by HCEsquared and its chat service provider and may be processed by automated systems, including artificial intelligence. A notice and consent prompt appears before the chat session begins. Chat is not for protected health information; do not submit patient information or other protected health information. Terms of Use § 5.6 and the Privacy Policy provisions addressing protected health information apply. Our chat providers are prohibited by contract from using transcripts for their own purposes or to train their models. 

2.4  Email tracking, server-side collection, and cross-device association 

Email pixels and related link tracking are used only after consent to the applicable category where consent is required. Server-side events are not used to continue analytics, advertising, audience matching, or sale or sharing transfers after you decline or withdraw the relevant consent. If you sign in on more than one device, we may associate those devices for account, security, or CME functions; we associate devices for non-essential analytics, advertising, audience matching, or measurement only after consent. 

2.5  Tracking controls 

Browser settings can block or delete cookies, although blocking all cookies may affect sign-in or other Platform functions. Industry opt-out tools are available at optout.aboutads.info and optout.networkadvertising.org, and mobile devices provide advertising and tracking controls. These tools are cookie- or device-based and may not preserve a choice after cookies or device identifiers are cleared. Cookie Settings and the Do Not Sell or Share My Personal Information link provide the Platform controls described in this Policy. 

3.1  Categories of personal information collected through cookies 

Cookies and similar technologies may collect identifiers, including online identifiers, IP address, device identifiers, cookie and pixel identifiers, and hashed email; internet or electronic network activity, including browsing history, search history, pages viewed, URLs, clicks, and interactions with the Platform; approximate geolocation derived from IP address; inferences, including professional interests and audience segments; and professional information when matched to an account. The Privacy Policy provides the broader categories and purposes of personal information processing. 

3.2  Sale and sharing of cookie information 

Disclosing information through third-party advertising cookies and pixels may constitute a “sale” or “sharing” for cross-context behavioral advertising under the CCPA. HCEsquared treats those disclosures as a sale or sharing and provides the opt-out described below. See the Terms of Use §§ 7.5, 7.8, and 7.14 and the Privacy Policy for the broader disclosure of data sales, sharing, recipients, and California rights. 

3.3  Right to opt out of sale and sharing 

You may opt out at any time through the “Do Not Sell or Share My Personal Information” link and through Cookie Settings. The choice turns off advertising cookies and pixels and also applies to cookie-based transfers made server-side. We honor Global Privacy Control and other recognized opt-out preference signals as an opt-out of sale and sharing for the browser that sends the signal and, when you are signed in, for the signed-in account. The Platform displays whether the signal has been processed. An opt-out is available without registration and is never tied to whether you register for or use the Platform. 

3.4  No discrimination 

We will not discriminate against you for exercising a privacy right or changing a cookie choice. Exercising a choice will not change the price or quality of the Platform or the continuing education services you receive. 

4.1  Cookie banner 

If you access the Platform from California or Florida, on your first  the cookie banner presents equally prominent “Accept,” “Reject non-essential,” and “Manage preferences” options. Non-essential technologies remain disabled until you make a choice, except that a strictly necessary consent-management technology may operate to record and enforce that choice. 

4.2  Preference center 

The preference center is accessible through the “Cookie Settings” link in the footer of every page. You may withdraw or update consent at any time by changing the categories enabled there. Withdrawal takes effect prospectively and does not affect the lawfulness of processing based on consent before withdrawal. 

4.3  Consent records and renewal 

We record your consent choices with the date and time of the choice. We request consent again when we add a new category, materially change our tracking practices, or at least every twelve (12) months. A change to a category does not activate that category until you provide the required consent. 

5.1  Third-party categories 

Third parties used in connection with the Platform may include web analytics providers; advertising networks and demand-side platforms; HCP identity-resolution and audience-matching providers; our consent management platform; video hosting and streaming providers; the learning management system and learning record store used for CME credit reporting; email delivery and marketing automation providers; event registration and virtual-event platforms; and chat providers. 

5.2  Third-party policies 

We do not control third-party cookies or similar technologies. Their collection and use are governed by the applicable third party’s privacy policy and terms. Consent to a category permits the identified category of technology to load for the purposes described in this Policy, but it does not change the third party’s separate legal obligations. 

6.1  Changes to this Policy 

We may change this Policy when our tracking practices, Platform features, legal requirements, or third-party technologies change. We will post the revised Policy with a new effective date and provide notice through the Platform or by email when the change is material. We review this Policy at least every twelve (12) months. 

7.1  Contact 

Questions about this Policy or cookie and tracking choices may be sent to privacy@hcesquared.com. 

8.1  Governing law 

This Policy is governed by the laws of the State of South Carolina, without regard to its conflict-of-laws rules. The dispute-resolution provisions in the Terms of Use apply to disputes relating to this Policy to the extent applicable.