Cookie Policy

1. What is a cookie?

Cookies are small data files that may be saved on your device through your browser when you visit a website.

Cookies may be used to manage user sessions, remember preferences, apply security checks and support certain website functions.

The browser's local storage and other technical identifiers may also be used for similar purposes.

These technologies do not always identify you directly. However, because they can be linked to IP addresses, online identifiers and usage records, they may be subject to personal data processing activities.

2. Which categories of cookies do we use?

2.1. Necessary cookies

These are cookies needed for our website and patient portal to perform their core functions.

Their purposes may include the following:

• Maintaining user sessions.
• Secure login and authentication.
• Supporting the core technical functions of application forms.
• Reducing unauthorised access and security risks.
• Providing the core service requested by the user.

Strictly necessary cookies may be used without separate cookie consent where the relevant legislation permits.

Classifying a cookie as necessary depends on it being genuinely necessary for the relevant service, not merely on it making the user experience easier.

2.2. Preference and functionality cookies

These cookies may help remember user preferences and provide certain personalised functions on the website.

For example, language selection, interface preferences and certain helper features requested by the user may fall within this category.

Where required for such cookies, separate permission is obtained from the user.

2.3. Analytics and performance cookies

Cuba Health Assist may use analytics technologies such as Google Analytics to evaluate the performance of the website and to understand how visitors interact with its pages.

The following information may be processed through these systems:

• Pages visited.
• Numbers of page views and interactions.
• Types of device and browser used.
• General traffic sources.
• Certain page and button interactions.
• Measurements of site performance.

Analytics systems are not used to transfer patients' diagnoses or medical documents to advertising and analytics providers.

Analytics cookies are activated after the user's approval where the relevant legislation requires it.

2.4. Advertising and conversion measurement technologies

Advertising platforms such as Google Ads may be used to measure the effectiveness of advertisements and to produce statistical results about certain actions users take after interacting with advertisements.

These technologies may process online identifiers or ad click information.

Health files, diagnostic information and the contents of medical reports are not used for advertising targeting.

Non-essential cookies for advertising and marketing purposes are not activated unless the valid legal conditions are met and, where required, the user's approval has been obtained.

2.5. Chat and communication tools

Our website may include WhatsApp links or other user support tools. When Cubi · AI-powered Digital Patient Coordinator becomes available on our website, the cookies and browser storage it uses will be added to the table below.

When these tools are used, the session and technical information needed for the relevant service to work may be processed.

Where an external chat or communication service uses its own cookies, those cookies are assessed according to their function.

A cookie being associated with a chat service does not mean that it is automatically treated as necessary.

3. First-party and third-party cookies

First-party cookies are cookies created directly by the website you are visiting.

Third-party cookies are cookies that may be placed through the technologies of external service providers used on the website.

The technologies used by Cuba Health Assist may be connected with third-party systems such as Google Analytics, Google Ads or the relevant communication services.

The data processing activities of third parties may also be subject to their own privacy terms and the relevant data protection legislation.

4. How long are cookies kept?

The retention period of cookies varies according to their purpose and technical configuration.

Session cookies: Usually expire when the relevant session ends.

Persistent cookies: May remain on the device for a defined period to remember preferences or support certain functions.

Analytics and advertising identifiers: Are subject to the service configuration of the relevant provider and its set retention policies.

The retention period of ad click information kept in the browser is controlled by the limits set in the relevant system configuration.

The current overview of the types of cookies and browser records used is set out below:

5. How can you manage your cookie preferences?

Where your permission is required for the use of non-essential cookies, you can make your choices through the cookie preferences interface on the website.

This interface is configured to offer the user the following options:

Accept all: You agree to the use of the cookie categories that require permission.

Reject all: You reject non-essential cookies. The core functions of the website can continue to be used.

Manage preferences: You can make separate choices about analytics, advertising and other optional cookie categories.

Not giving cookie consent does not prevent you from using the core services of the website.

Open cookie preferences

6. Withdrawing your cookie permission

You can later change or withdraw the permission you have given for non-essential cookies through the cookie preferences interface or the "Cookie preferences" link at the bottom of every page.

Withdrawing permission does not invalidate operations lawfully carried out before the withdrawal.

After permission is withdrawn, new permission-based cookie operations are stopped and the relevant identifiers are cleared from your browser.

You can also delete or block cookies through your browser settings.

7. Browser storage and form drafts

Some website functions may use the browser's local storage technologies in addition to conventional cookies.

Language preferences, application drafts or certain session information may be kept in these areas.

Where sensitive health data would be kept in browser storage areas, the relevant security and data minimisation requirements are assessed separately.

When using shared or public devices, users are advised to log out of their accounts securely and to clear browser data where necessary.

8. Protection of health data

The medical documents that Cuba Health Assist collects for healthcare coordination are not used as a data source for advertising and behavioural targeting activities.

Patient file numbers, diagnoses, laboratory reports and other special categories of health information are not included in analytics or advertising tracking parameters.

Technical controls are applied in the analytics and advertising systems used to prevent such data from being transferred.

9. International data transfers

Some cookie and analytics providers may be located abroad.

Personal data shared with these providers is subject to the relevant rules on data transfers abroad.

Cookie consent does not mean that it automatically replaces other mechanisms that may be legally required for transferring personal data abroad.

For detailed information on the processing of personal data and the conditions for international transfers, please see the Privacy and Personal Data Protection notice.

10. Changes to the policy

Cuba Health Assist may change the cookies, service providers or technical infrastructure it uses.

The Cookie Policy and the related cookie inventory are updated in line with these changes.

If separate consent is required for a new data processing purpose, the necessary information and permission procedures are applied.

11. Contact

You can send any questions about cookies, your personal data and the tracking technologies used on our website to the address below.

This policy should be read together with the Privacy and Personal Data Protection notice.