# RoundPenny Cookie Policy

**Last Updated: May 30, 2026**

This Cookie Policy explains how RoundPenny Advisors LLC ("RoundPenny," "we," "us," or "our") uses cookies and similar technologies when you visit our website or use our Service. This policy is part of our Privacy Policy and should be read in conjunction with it.

**TEMPLATE DISCLAIMER:** This document is a template for informational purposes only and does not constitute legal advice. You should have it reviewed by qualified legal counsel.

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## 1. What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, or mobile) by your web browser when you visit a website. They help websites function properly, remember your preferences, and collect information about how you use the site.

## 2. Cookies We Use

RoundPenny uses a minimal set of cookies. We do not use advertising, tracking, or third-party marketing cookies.

### 2.1 Essential Cookies (Strictly Necessary)

These cookies are required for the Service to function and cannot be disabled in our systems. They are set in response to actions you take, such as logging in, completing forms, or setting privacy preferences.

| Cookie Name | Purpose | Duration |
|-------------|---------|----------|
| `session` | Maintains your authenticated session across page requests | Session (deleted when browser is closed) |
| `csrf_token` | Prevents cross-site request forgery attacks | Session |
| `auth_mfa` | Tracks MFA authentication status during a session | Session |

**Legal Basis:** These cookies are necessary for the provision of the Service (performance of contract) and are exempt from consent requirements under applicable law.

### 2.2 Analytics Cookies (Optional)

With your consent, we use analytics cookies to understand how users interact with our Service. These cookies help us improve functionality and user experience.

| Cookie Name | Purpose | Duration |
|-------------|---------|----------|
| `_rp_analytics` | Tracks page views and feature usage (anonymized) | 24 hours |
| `_rp_session_count` | Counts unique sessions for usage analytics | 30 minutes |

**Legal Basis:** Consent (you may opt in or out at any time).

**Note:** Our analytics are self-hosted. Data is not shared with third-party analytics providers (e.g., Google Analytics).

### 2.3 Cookies We Do NOT Use

We do not use the following types of cookies or similar technologies:

- Advertising or retargeting cookies
- Social media pixels (e.g., Meta Pixel, LinkedIn Insight Tag)
- Cross-site tracking cookies
- Third-party marketing cookies
- Fingerprinting or device identification technologies (beyond what is described above)

## 3. How to Manage Cookies

### 3.1 Cookie Consent Banner

When you first visit our website, a cookie consent banner will appear asking you to accept or decline analytics cookies. Essential cookies are set regardless of your choice, as they are necessary for the Service to function.

You may change your cookie preferences at any time by clicking the "Cookie Preferences" link in the website footer.

### 3.2 Browser Settings

You can control and manage cookies through your browser settings. Most browsers allow you to:

- View cookies stored on your device;
- Delete individual or all cookies;
- Block cookies from specific websites;
- Block all cookies;
- Set preferences for third-party cookies.

**Please note:** If you disable essential cookies, the Service may not function properly, and you may be unable to log in or access key features.

#### Instructions by Browser:

- **Google Chrome:** Settings → Privacy and Security → Cookies and other site data
- **Mozilla Firefox:** Options → Privacy & Security → Cookies and Site Data
- **Safari:** Preferences → Privacy → Cookies and website data
- **Microsoft Edge:** Settings → Site permissions → Cookies and site data

### 3.3 Do Not Track

Our Service does not currently respond to "Do Not Track" (DNT) browser signals, as there is no consistent industry standard for DNT interpretation. We do not track you across third-party websites regardless of DNT settings.

## 4. Updates to This Policy

We may update this Cookie Policy from time to time. If we make material changes, we will notify you via email and through our website. The "Last Updated" date at the top of this page indicates when the policy was last revised.

## 5. Contact

If you have questions about our use of cookies, please contact us:

- **Email:** privacy@roundpenny.com
- **Subject Line:** "Cookie Inquiry"

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*This document is a template and does not constitute legal advice. You should consult with qualified legal counsel before implementing this policy.*