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HPLY COOKIE POLICY

Effective Date: August 10, 2026

1. Purpose and Scope

This Cookie Policy explains how HPLY Inc. (“HPLY,” “we,” “us,” or “our”) uses cookies and similar technologies in connection with HPLY’s websites, nonprofit portals, administrative interfaces, and other digital services, and, if made available, HPLY mobile applications and other digital features (collectively, the “Services”).

Cookies and similar technologies may be used to provide and secure the Services, authenticate users, maintain sessions, remember preferences, prevent fraud, support functionality, maintain performance and reliability, and perform other purposes described in this Cookie Policy.

This Cookie Policy also explains the choices and controls that may be available concerning these technologies.

Not every technology, feature, or category described in this Cookie Policy is necessarily used in every Service or at all times. HPLY’s use of cookies and similar technologies may vary depending on the Service, feature, device, jurisdiction, user choices, and technologies made available by HPLY or its service providers.

2. Relationship to Other HPLY Policies

This Cookie Policy supplements the HPLY Privacy Policy and, for California residents, the HPLY California Privacy Notice. Those documents provide additional information about HPLY’s collection, use, disclosure, retention, and other Processing of Personal Information and the privacy rights that may apply.

Use of the Services is also subject to the HPLY Terms of Service and, where applicable, other HPLY agreements and policies, including the HPLY Acceptable Use Policy, HPLY Donation & Refund Policy, HPLY Nonprofit Organization Participation Agreement, and HPLY Community Guidelines.

This Cookie Policy focuses specifically on cookies and similar technologies and the choices that may apply to them. Where information collected through cookies or similar technologies constitutes Personal Information, HPLY Processes that information in accordance with the HPLY Privacy Policy, the HPLY California Privacy Notice where applicable, and applicable law.

Capitalized terms not defined in this Cookie Policy have the meanings given in the HPLY Privacy Policy or other applicable HPLY agreement.

3. What Are Cookies?

Cookies are small text files or similar data files that websites may place or store on a browser or device. Cookies can enable a website or service to recognize a browser or device, maintain a secure session, remember preferences, and support technical and operational functions.

Cookies may be either session cookies or persistent cookies.

Session cookies generally remain active only for the duration of a browser session and expire or become inactive after the browser is closed or the session otherwise ends.

Persistent cookies may remain on a browser or device after a session ends until they expire, are replaced, are deleted by the user, or are otherwise removed.

The duration of a particular cookie or similar technology depends on its purpose, configuration, provider, applicable legal requirements, and other relevant circumstances.

4. Similar Technologies

HPLY and its service providers may use technologies that perform functions similar to or related to cookies.

Depending on the Services and features involved, these technologies may include pixels, web beacons, tags, local storage, secure storage, software development kits (“SDKs”), device identifiers, push-notification tokens, APIs, server logs, authentication technologies, fraud signals, and comparable technologies.

For convenience, references to “cookies” or “cookies and similar technologies” in this Cookie Policy generally include these technologies where appropriate unless the context requires otherwise.

These technologies may operate differently from traditional browser cookies and may be controlled through different mechanisms, including HPLY privacy or cookie controls, browser settings, device settings, operating-system permissions, or other legally required mechanisms.

5. Categories of Cookies and Similar Technologies

HPLY may use different categories of cookies and similar technologies depending on the functionality being provided. The legal treatment of a particular technology may vary by jurisdiction, purpose, configuration, and manner of use.

5.1 Strictly Necessary and Essential Technologies

Strictly Necessary or Essential technologies support functions necessary to provide requested Services or operate essential features.

These technologies may support account authentication, session management, load balancing, network management, security, fraud prevention, transaction integrity, preference management necessary to honor privacy choices, and other essential functionality.

Where permitted by applicable law or where consent is not required, these technologies may operate without prior consent and may not be capable of being disabled through HPLY’s cookie preference tools.

Blocking these technologies through browser or device settings may prevent portions of the Services from functioning correctly or may prevent a user from accessing certain features.

5.2 Security and Fraud-Prevention Technologies

HPLY may use cookies and similar technologies to authenticate users, identify suspicious activity, detect compromised accounts, prevent fraudulent transactions, maintain secure sessions, investigate abuse, protect payment activity, enforce security controls, and protect the integrity of the Services.

Security and fraud-prevention technologies may remain active when a user declines other non-essential technologies where their use without consent is permitted by applicable law or otherwise necessary to provide a secure service requested by the user.

5.3 Functional and Preference Technologies

Functional or Preference technologies may remember choices or settings selected by a user, such as language, accessibility preferences, login convenience, interface settings, nonprofit browsing preferences, and similar features.

These technologies may allow HPLY to provide a more consistent user experience without necessarily being required for the basic operation of the Services.

Where applicable law requires consent for these technologies, HPLY will obtain the required consent before activating them.

5.4 Analytics and Performance Technologies

HPLY does not currently use non-essential Analytics or Performance technologies.

If HPLY introduces Analytics or Performance technologies in the future, they may be used to understand how the Services are used, evaluate aggregate usage patterns, measure feature adoption, diagnose errors, identify performance issues, improve navigation, assess system reliability, and improve the Services.

If HPLY engages an analytics provider, the provider may receive technical, device, usage, or interaction information as described in the HPLY Privacy Policy.

Where applicable law requires prior consent for Analytics or Performance technologies, HPLY will not activate the applicable technologies until the required consent has been obtained.

Depending on their implementation, certain analytics technologies or disclosures may constitute a “sale” or “sharing” of Personal Information under California law even when no money is exchanged. Any such activity is subject to Section 15 of this Cookie Policy and the HPLY California Privacy Notice.

5.5 Advertising and Personalization Technologies

If HPLY uses advertising, remarketing, interest-based advertising, cross-context behavioral advertising, personalized promotional technologies, or similar technologies, those technologies may be used to measure advertising effectiveness, personalize promotional content, understand interactions across services, or support related advertising functions.

HPLY does not represent through this Cookie Policy that these technologies are currently deployed.

If HPLY uses Advertising or Personalization technologies, HPLY will provide any notices, consent mechanisms, opt-out rights, or other choices required by applicable law.

Where applicable law requires prior consent, HPLY will not activate applicable non-essential Advertising or Personalization technologies until the required consent has been obtained.

Where the use or disclosure of Personal Information through these technologies constitutes a “sale” or “sharing” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and implementing regulations (collectively, the “CCPA”), HPLY will provide the legally required opt-out rights and mechanisms.

6. Purposes for Which HPLY Uses These Technologies

Depending on the Services and features involved, HPLY may use cookies and similar technologies to:

(a) authenticate users and maintain secure sessions;

(b) provide requested features and Services;

(c) remember user preferences and settings;

(d) preserve privacy and cookie choices;

(e) improve accessibility and user experience;

(f) detect, prevent, investigate, and respond to fraud, abuse, security threats, and unauthorized activity;

(g) diagnose technical errors and maintain platform reliability;

(h) where applicable, understand how users interact with particular features of the Services;

(i) where applicable, measure feature adoption and performance;

(j) support payment authorization, transaction security, and fraud prevention;

(k) provide or improve recommendations or personalization where applicable;

(l) support embedded content or third-party integrations where available;

(m) comply with legal, regulatory, security, and recordkeeping requirements; and

(n) perform other purposes described in the HPLY Privacy Policy or disclosed at the time of collection as permitted by applicable law.

HPLY does not use cookies or similar technologies for purposes materially inconsistent with this Cookie Policy, the HPLY Privacy Policy, or applicable law without providing any notice or obtaining any consent required by law.

7. Third-Party Technologies

HPLY may engage third-party providers in connection with cloud infrastructure, authentication, customer support, content delivery, security, fraud prevention, payment processing, embedded content, communications, and other Services.

These providers may use cookies or similar technologies in connection with the services they provide.

If HPLY later engages analytics providers, their use of cookies or similar technologies will be subject to this Cookie Policy and applicable law.

Depending on the arrangement and applicable law, a third-party provider may Process information on HPLY’s behalf, may independently control certain Processing, or may perform different legal roles for different Processing activities.

Third-party technologies may be governed by the provider’s own privacy notices or policies where the provider independently determines the purposes or means of applicable Processing.

HPLY does not control every technology independently deployed or operated by a third party. This does not limit any responsibility HPLY has under applicable law for HPLY’s selection, configuration, authorization, or use of third-party technologies.

Where applicable law requires HPLY to provide notice, obtain consent, offer an opt-out, enter into contractual restrictions, or otherwise regulate the use of a third-party technology, HPLY will comply with those requirements.

8. Payment-Processing Technologies

Donation payments are currently processed by Stripe through Stripe Connect.

If HPLY offers other payment-based Services in the future, including merchandise or other commercial transactions, those payments may be processed by Stripe or another payment processor or commerce provider designated by HPLY. For purposes of this Cookie Policy, a provider processing an applicable payment is a “Payment Processor.”

A Payment Processor may use cookies, device identifiers, authentication technologies, fraud signals, risk-scoring tools, local storage, server-side technologies, or comparable tools in connection with payment authorization, security, fraud prevention, regulatory compliance, transaction processing, and related functions.

A Payment Processor may independently determine certain technologies necessary to provide its services and may Process information under its own privacy terms where legally applicable.

HPLY does not control every technology independently deployed by a Payment Processor.

Information collected or Processed in connection with Donations remains subject to the applicable HPLY privacy framework and the HPLY Donation & Refund Policy.

Nothing in this Cookie Policy expands the donor information that participating Nonprofit Organizations receive.

HPLY does not provide donor names, email addresses, telephone numbers, mailing addresses, or other donor contact information to participating Nonprofit Organizations for their independent fundraising, marketing, advertising, donor acquisition, or unrelated solicitation.

9. Social Media and Embedded Content

If HPLY makes social sharing, social authentication, videos, maps, widgets, embedded media, or other third-party content available through the Services, the third-party provider may use cookies or similar technologies when a user interacts with that content.

Depending on the technology, provider, and configuration, information may be transmitted to the third party when the content loads or when the user interacts with it.

Where applicable law requires consent or another choice before such a technology may be activated, HPLY will provide the required mechanism.

Third-party providers may Process information under their own privacy notices where they independently control the relevant Processing.

10. Mobile Applications and Device Technologies

If HPLY makes mobile applications available, those applications may use SDKs, device identifiers, push-notification tokens, application permissions, local storage, secure storage, APIs, or comparable technologies rather than traditional browser cookies.

These technologies may support authentication, security, fraud prevention, notifications, preferences, application performance, and other functions described in this Cookie Policy.

If HPLY later introduces mobile analytics technologies, their use will be subject to applicable notice, consent, opt-out, and other legal requirements.

Applicable privacy choices may be available through HPLY controls, device settings, operating-system permissions, application settings, or other legally required mechanisms.

Users may be able to control permissions for features such as notifications, location, camera, photos, or other device functionality through their device or operating-system settings. Disabling a permission may prevent the corresponding feature from operating.

Nothing in this Section represents that a particular mobile application, SDK, permission, or mobile feature is currently available.

11. Consent

HPLY uses consent for cookies and similar technologies where consent is required by applicable law.

Where applicable law requires prior consent, HPLY will not activate the applicable non-essential technologies until the required consent has been obtained.

HPLY may use technologies without consent where applicable law permits such use, including where technologies are necessary to provide a service requested by the user, maintain security, prevent fraud, preserve privacy choices, or perform another function for which consent is not legally required.

Where HPLY provides a cookie banner, preference center, privacy settings, or another consent mechanism, users may be able to accept, reject, or manage categories of non-essential technologies.

A user who has provided consent may withdraw or modify that consent through the available cookie or privacy preference tools where applicable.

Withdrawal of consent applies prospectively and does not affect the lawfulness of Processing performed before withdrawal.

A change in preferences may not immediately remove technologies already stored on a device. Users may use browser or device controls to remove stored cookies or comparable information where technically appropriate.

12. Cookie and Privacy Preference Controls

HPLY may provide cookie or privacy preference controls that allow users to manage non-essential technologies or other privacy choices where required or appropriate.

Available controls may vary according to jurisdiction, device, browser, Service, technology, and applicable law.

Where applicable law requires a particular consent or opt-out mechanism, HPLY will provide or recognize that mechanism as required.

Choices made through one browser or device may not automatically apply to another browser or device unless HPLY is legally required and technically able to associate the choice with the same consumer or account.

Strictly Necessary, Essential, Security, or Fraud-Prevention technologies may not be subject to the same preference controls where applicable law permits their use without consent or opt-out.

13. Browser and Device Controls

Most browsers provide controls that allow users to view, delete, block, or restrict cookies.

Devices and operating systems may also provide privacy controls for identifiers, permissions, application storage, and related technologies.

The availability and operation of these controls are determined by the browser, device, or operating-system provider.

Blocking or deleting cookies may affect account authentication, security, saved preferences, payment functionality, accessibility settings, or other portions of the Services.

Deleting a cookie that records a privacy preference may also require the user to make that choice again unless HPLY can preserve the preference through another mechanism.

14. Opt-Out Preference Signals

HPLY will recognize and process legally valid opt-out preference signals as required by the CCPA and applicable regulations.

Where an opt-out preference signal applies to a browser, device, consumer, or other recognized context, HPLY will treat the signal in accordance with applicable California law and any legally required technical specifications.

Where cookie, pixel, SDK, advertising, analytics, social-integration, or similar activity constitutes a “sale” or “sharing” of Personal Information under the CCPA, HPLY will provide the legally required opt-out mechanism and honor qualifying opt-out preference signals.

An opt-out preference signal recognized under applicable law is distinct from a traditional browser “Do Not Track” signal described in Section 16.

Additional information regarding California privacy rights and opt-out preference signals is available in the HPLY California Privacy Notice.

15. California Sale and Sharing

HPLY does not sell Personal Information for monetary consideration.

HPLY does not currently use non-essential analytics or advertising technologies and does not currently represent that cookies or similar technologies used by HPLY constitute a “sale” or “sharing” of Personal Information under the CCPA.

Certain disclosures or Processing involving analytics, cookies, pixels, SDKs, social integrations, advertising technologies, or similar technologies could constitute a “sale” or “sharing” of Personal Information under the CCPA depending on the particular implementation, even where HPLY does not receive monetary consideration.

To the extent HPLY later engages in an activity that constitutes a sale or sharing under the CCPA, HPLY will provide any notice and right to opt out required by applicable law, including a clear and conspicuous opt-out mechanism and recognition of legally valid opt-out preference signals where required.

Disclosures to Service Providers or Contractors that satisfy applicable CCPA requirements are treated in accordance with the CCPA.

HPLY does not knowingly sell or share the Personal Information of consumers under sixteen years of age without the affirmative authorization required by applicable law.

For additional information concerning HPLY’s California privacy practices, see the HPLY California Privacy Notice.

16. Do Not Track

Some browsers offer a “Do Not Track” (“DNT”) setting intended to communicate a user’s preference concerning certain forms of online tracking.

Traditional DNT signals have not historically been governed by a single uniform legal or technical standard, and HPLY may not respond uniformly to traditional DNT signals except where applicable law requires a particular response.

This Section does not limit HPLY’s separate obligation to recognize and process legally valid opt-out preference signals, including signals required by the CCPA and applicable regulations.

HPLY will honor those signals as required by applicable law, regardless of whether a traditional DNT signal is separately recognized.

17. Aggregate Information and Future Analytics

HPLY may use aggregated or de-identified information for security, research, service improvement, reporting, and other purposes permitted by applicable law.

HPLY does not currently use non-essential analytics technologies.

If HPLY introduces analytics technologies in the future, HPLY may use them to understand aggregate or statistical patterns concerning use of the Services, identify errors, evaluate feature adoption, assess reliability, improve navigation, and support product and service development.

Analytics information, if collected in the future, may include device, browser, network, session, interaction, performance, and similar technical information.

Where HPLY maintains information as de-identified information under applicable law, HPLY will handle it in accordance with applicable legal requirements concerning de-identified information.

Any future use of analytics technologies will remain subject to the consent, opt-out, disclosure, and other requirements described in this Cookie Policy and applicable law.

18. Donor Information and Cookie-Derived Data

Cookies and similar technologies used in connection with Donation-related portions of the Services may generate technical, device, session, security, fraud-prevention, and transaction-related information.

HPLY may Process that information as described in this Cookie Policy, the HPLY Privacy Policy, the HPLY California Privacy Notice where applicable, and the HPLY Donation & Refund Policy.

HPLY does not provide donor names, email addresses, telephone numbers, mailing addresses, or other donor contact information to participating Nonprofit Organizations for their independent fundraising, marketing, advertising, donor acquisition, or unrelated solicitation.

Participating Nonprofit Organizations receive only donor and transaction information that HPLY determines is reasonably necessary for payment processing, reconciliation, legal compliance, Donation administration, or fulfillment of accepted donor restrictions, subject to the HPLY Privacy Policy, HPLY Donation & Refund Policy, and HPLY Nonprofit Organization Participation Agreement.

Nothing in this Cookie Policy expands the categories of donor information made available to participating Nonprofit Organizations.

19. Retention

The retention period for cookies and information derived from cookies or similar technologies varies depending on the technology, purpose, configuration, provider settings, legal requirements, security needs, and applicable user choices.

Session technologies generally expire or become inactive after the relevant browsing or application session ends.

Persistent technologies may remain for a longer period until they expire, are replaced, are deleted, or are otherwise removed.

HPLY retains cookie-derived Personal Information only for as long as reasonably necessary and proportionate for the relevant purpose, subject to applicable legal, security, fraud-prevention, recordkeeping, transaction, dispute, and enforcement requirements.

Third-party providers may maintain their own retention periods for information they Process, subject to applicable contractual and legal requirements.

Where technically appropriate, users may delete stored cookies through browser or device settings.

Deleting stored technologies may affect preferences or functionality and may require users to make privacy choices again.

Additional information regarding HPLY’s retention practices is available in the HPLY Privacy Policy and, for California residents, the HPLY California Privacy Notice.

20. International Processing

Cookies and similar technologies may involve Processing of Personal Information in countries other than the country in which the user is located, including where HPLY or its service providers operate infrastructure, provide support, or Process information.

Where international Processing or transfers of Personal Information are subject to legal transfer requirements, HPLY will use legally required safeguards or transfer mechanisms as applicable.

Additional information regarding international Processing and transfers is available in the HPLY Privacy Policy.

21. Children and Minors

HPLY does not knowingly use cookies or similar technologies in violation of applicable laws governing children or minors.

HPLY does not knowingly sell or share the Personal Information of consumers under sixteen years of age where prohibited by applicable law without the authorization required by law.

Where HPLY knows that additional protections apply to information concerning a child or minor, HPLY will Process the information in accordance with applicable law and the protections described in the HPLY Privacy Policy and HPLY California Privacy Notice.

Nothing in this Cookie Policy expands eligibility to use HPLY Services.

Age and eligibility requirements remain governed by the HPLY Terms of Service and other applicable HPLY agreements.

22. Privacy Rights

Information collected through cookies and similar technologies may constitute Personal Information under applicable privacy laws.

Depending on where a user resides and the law that applies, the user may have rights concerning that Personal Information, including rights relating to access, correction, deletion, portability, consent, objection, restriction, or opt-out.

HPLY’s Privacy Policy explains applicable privacy rights and methods for exercising them.

California residents should also review the HPLY California Privacy Notice for information concerning rights under the CCPA, including rights concerning sale, sharing, Sensitive Personal Information, and opt-out preference signals.

This Cookie Policy does not limit any privacy right that cannot lawfully be waived.

23. Legal Compliance

HPLY uses cookies and similar technologies in accordance with applicable privacy, consumer-protection, electronic-communications, security, and other laws.

Legal requirements concerning cookies and similar technologies differ by jurisdiction.

A technology that may operate without consent in one jurisdiction may require consent or another choice in another jurisdiction.

HPLY may adjust the technologies it uses, the manner in which they operate, or the choices made available to users based on applicable law, the Service involved, and the user’s jurisdiction.

Nothing in this Cookie Policy limits any right or obligation that cannot lawfully be limited.

24. Accessibility

HPLY intends to make cookie notices and privacy preference mechanisms reasonably accessible as required by applicable law.

Individuals who have difficulty accessing or using a cookie or privacy preference mechanism may contact HPLY using the information in Section 27.

HPLY may provide an alternative method for exercising an applicable privacy choice where required by law.

25. Future and Evolving Technologies

Technology used to provide digital services evolves over time.

HPLY may adopt additional security, authentication, analytics, storage, device, application, personalization, or other technologies that perform functions similar to those described in this Cookie Policy.

HPLY may also discontinue or replace technologies as its Services evolve.

If a new technology materially changes HPLY’s Processing practices, HPLY will provide any notice, consent mechanism, opt-out right, or other choice required by applicable law and will update this Cookie Policy where appropriate.

Nothing in this Section represents that a particular future technology or feature will be made available.

26. Changes to This Cookie Policy

HPLY may update this Cookie Policy from time to time to reflect changes in the Services, technologies, legal requirements, privacy practices, or other relevant circumstances.

When HPLY makes changes, HPLY may revise the Effective Date at the beginning of this Cookie Policy or otherwise identify when the updated Cookie Policy becomes effective.

Where applicable law requires advance notice, renewed consent, or another action before a change becomes effective, HPLY will provide the required notice or obtain the required consent.

Continued use of the Services following an update does not constitute consent to a change where applicable law requires a different form of consent.

27. Contact Information

Questions regarding this Cookie Policy or HPLY’s use of cookies and similar technologies may be directed to:

HPLY Inc. 3517 Camino del Río South Suite 215, Mailbox #83 San Diego, CA 92108 United States

Email: support@hply.org

HPLY

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