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Cookie Notice

Onflay LLC Last updated: [INSERT: Effective Date]

1. What This Notice Covers

This Cookie Notice explains what cookies and similar technologies Onflay LLC uses on the Platform, why we use them, and how you can manage them.

This notice applies to the Onflay website (onflay.com), the creator dashboard, the checkout experience, and any other Onflay web properties.

2. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, or mobile) when you visit a website. They allow the website to recognize your device and store certain information about your preferences or activity.

Similar technologies include local storage, session storage, pixels, and device fingerprinting. This notice covers all such technologies used by Onflay.

3. Cookies We Use

3.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. Without them, you cannot log in, access your account, or complete a purchase. Because they are necessary, they are set without requiring your consent.

| Cookie | Provider | Purpose | Duration | Type | |---|---|---|---|---| | Auth access token | Onflay | Maintains your authenticated session. Required for Platform access after login. | ~15 minutes (auto-refreshed) | HttpOnly, Secure — not accessible by JavaScript | | Auth refresh token | Onflay | Allows renewal of your session without logging in again. | 7 days | HttpOnly, Secure | | NEXT_LOCALE | Onflay | Stores your preferred language (English or Spanish) for Platform display and communications. | Session / persistent per browser setting | First-party |

3.2 Analytics Cookies

These cookies help us understand how users interact with the Platform, identify issues, and improve the user experience. They are set by our analytics provider, PostHog.

| Cookie | Provider | Purpose | Duration | Type | |---|---|---|---|---| | ph_* (PostHog session and device identifiers) | PostHog, Inc. (US) | Tracks page views, click events, session activity, and session recordings. Input fields in payment-adjacent areas are masked and not captured. | Up to 1 year | Third-party |

Session recordings: PostHog may record your browsing session on the Platform to help Onflay identify usability issues. All form input fields — especially in checkout and payment flows — are masked so their content is never captured.

[PLACEHOLDER: Confirm exact PostHog cookie names and durations by inspecting the live Platform. Update this table before publication.]

4. Consent Requirements by Jurisdiction

Cookie consent requirements vary by jurisdiction. Here is how Onflay approaches this by region:

4.1 Dominican Republic and LATAM Users

Under the Dominican Republic's Ley No. 172-13 (LPDP) and equivalent LATAM data protection laws, tracking technologies that collect personal data require disclosure and, depending on the jurisdiction and use case, user consent. Onflay discloses its use of analytics cookies in this notice.

[PLACEHOLDER: Until a cookie consent management platform (CMP) is implemented, analytics cookies are set on all users. Before EU/UK launch and before implementing behavioral advertising, implement a CMP so that non-essential cookies are only set after consent is obtained from users in jurisdictions where consent is required. Confirm LATAM consent obligations with DR and LATAM counsel.]

4.2 European Union and EEA Users

Under the EU ePrivacy Directive (as implemented by EU member states), non-essential cookies require prior, freely given, specific, informed, and unambiguous consent. Analytics cookies (PostHog) are non-essential and must not be set for EU users without consent.

[PUBLICATION BLOCKER for EU/EEA launch]: A cookie consent management platform (CMP) must be implemented and a cookie consent banner presented to EU users before non-essential cookies are set. This has not yet been implemented in the Platform codebase. Onflay's Privacy Policy §7 also contains a placeholder for this requirement.

4.3 United Kingdom Users

Under the UK Privacy and Electronic Communications Regulations (PECR), non-essential cookies require prior consent. The same CMP requirement noted for EU users applies to UK users.

4.4 United States Users (CCPA/CPRA)

Under the California Consumer Privacy Act (CCPA/CPRA), Onflay must disclose cookies used to "share" personal data for cross-context behavioral advertising. Onflay does not currently use cookies for behavioral advertising purposes.

Analytics cookies may still trigger disclosure obligations under CCPA depending on how PostHog data is used. Onflay does not sell personal data collected via cookies.

5. How to Manage Cookies

5.1 Browser Settings

You can control cookies through your browser's settings. Most browsers allow you to:

  • View and delete existing cookies.
  • Block cookies from specific websites.
  • Block all third-party cookies.
  • Set preferences for future cookie acceptance.

Note: disabling strictly necessary cookies (authentication tokens) will prevent you from logging into the Platform.

Instructions for common browsers:

  • Chrome: Settings → Privacy and security → Cookies and other site data
  • Safari: Settings → Privacy → Manage Website Data
  • Firefox: Settings → Privacy & Security → Cookies and Site Data
  • Edge: Settings → Cookies and site permissions

5.2 Opting Out of Analytics

To opt out of PostHog analytics tracking, you may adjust your browser settings to block the ph_* cookies. You can also consult PostHog's opt-out documentation at posthog.com/docs/privacy.

[PLACEHOLDER: Once a CMP is implemented, update this section with instructions for using the CMP to manage consent preferences directly on the Platform.]

6. Third-Party Links and Embeds

The Platform may contain links to third-party websites. Onflay is not responsible for the cookie practices of those websites. Please review their privacy and cookie notices separately.

7. Changes to This Notice

Onflay may update this Cookie Notice at any time. Changes will be posted with an updated effective date. Material changes will be communicated through the Platform or by email.

8. Contact

For questions about this Cookie Notice:

Onflay LLC 1021 E Lincolnway, Suite 10028 Cheyenne, Wyoming 82001 United States Email: privacy@onflay.com