Cookies Policy
OFFICE OF NATIONAL EXCELLENCE, LLC
COOKIE AND TRACKING TECHNOLOGIES POLICY
Effective Date: September 16, 2026
Last Revised: September 16, 2026
Contracting Entity: Office of National Excellence, LLC
Organization: ONE
Network: ON | ONE Network
Official Domain: ONEUSA.us
ARTICLE I
PURPOSE; SCOPE; APPLICABILITY
§ 1.01 Purpose.
This Cookie and Tracking Technologies Policy ("Cookie Policy") describes the use of Cookies, pixels, tags, web beacons, scripts, software development kits, local storage, session storage, device identifiers, authentication technologies, analytics technologies, advertising technologies, and other Tracking Technologies by Office of National Excellence, LLC, a Michigan limited liability company ("ONE," "Company," "we," "us," or "our").
§ 1.02 Scope.
This Cookie Policy applies to Cookies and Tracking Technologies deployed, accessed, controlled, received, or otherwise processed by or on behalf of ONE in connection with Services to which this Cookie Policy is posted, linked, incorporated, or otherwise expressly made applicable.
Applicable Services may include:
(a) ONEUSA.us;
(b) ONE;
(c) ON;
(d) the ONE Network;
(e) ONE Membership;
(f) ONE ID;
(g) ONE Card;
(h) the Excellence Identity Registry;
(i) ONE Standard;
(j) ONE Recognition;
(k) ONE Awards;
(l) ONE Accounts;
(m) websites;
(n) applications;
(o) directories;
(p) bulletin boards;
(q) Listings;
(r) search and discovery functions;
(s) Bookings and Appointments;
(t) marketplace functionality;
(u) P2P functionality;
(v) Provider functionality;
(w) consulting services;
(x) Virtual Brand services;
(y) governmental, educational, nonprofit, religious, business, and community bulletin functionality; and
(z) other ONE Services expressly subject to this Cookie Policy.
§ 1.03 Supplemental Notices.
Certain Services may be subject to additional notices, disclosures, authorizations, consents, or preference mechanisms concerning Cookies or Tracking Technologies.
A supplemental notice shall control concerning the specific processing expressly governed by that notice to the extent of an irreconcilable conflict.
§ 1.04 Relationship to Privacy Policy.
This Cookie Policy supplements the ONE Master Privacy Policy.
The Master Privacy Policy governs ONE's broader collection, receipt, use, processing, retention, disclosure, protection, and deletion of Personal Information.
This Cookie Policy specifically governs disclosures concerning Cookies and Tracking Technologies.
§ 1.05 Applicable Law.
ONE shall deploy and process Cookies and Tracking Technologies subject to Applicable Law.
Nothing in this Cookie Policy shall be construed to waive, eliminate, restrict, or supersede any legally applicable consent requirement, opt-out right, disclosure requirement, data-protection obligation, or other mandatory requirement.
ARTICLE II
DEFINITIONS
§ 2.01 "Applicable Law."
"Applicable Law" means any applicable federal, state, local, territorial, tribal, foreign, or other constitution, statute, law, ordinance, regulation, rule, order, binding governmental requirement, or other legally enforceable requirement.
§ 2.02 "Cookie."
"Cookie" means a data file, text file, identifier, token, or substantially similar technology stored on or associated with a browser, device, application, or computing environment and used to recognize, authenticate, remember, measure, secure, analyze, personalize, or otherwise facilitate digital activity.
§ 2.03 "First-Party Cookie."
"First-Party Cookie" means a Cookie deployed or controlled through the domain or Service with which a User directly interacts, subject to the technical and legal classification applicable to the particular technology.
§ 2.04 "Third-Party Cookie."
"Third-Party Cookie" means a Cookie or substantially similar technology deployed, accessed, controlled, or otherwise processed by a Third Party through or in connection with a ONE Service.
§ 2.05 "Session Cookie."
"Session Cookie" means a Cookie generally configured to remain active for a browser or application session and expire, terminate, or become inaccessible following termination of that session.
§ 2.06 "Persistent Cookie."
"Persistent Cookie" means a Cookie configured to remain stored beyond a single session until expiration, deletion, replacement, withdrawal of applicable authorization, or other applicable termination.
§ 2.07 "Tracking Technologies."
"Tracking Technologies" means Cookies and technologies capable of collecting, receiving, accessing, storing, reading, transmitting, measuring, recognizing, associating, or otherwise processing information concerning a browser, device, User, Account, session, interaction, activity, Transaction, or other digital event.
Tracking Technologies may include:
(a) Cookies;
(b) pixels;
(c) tracking pixels;
(d) web beacons;
(e) tags;
(f) scripts;
(g) software development kits;
(h) local storage;
(i) session storage;
(j) browser storage;
(k) device identifiers;
(l) advertising identifiers;
(m) authentication tokens;
(n) embedded technologies;
(o) analytics technologies;
(p) attribution technologies;
(q) conversion technologies;
(r) application programming interfaces; and
(s) substantially similar technologies.
§ 2.08 "Essential Technologies."
"Essential Technologies" means Cookies or Tracking Technologies reasonably necessary to provide, secure, authenticate, administer, maintain, or deliver a Service requested by a User or otherwise deployed as permitted by Applicable Law.
§ 2.09 "Functional Technologies."
"Functional Technologies" means Cookies or Tracking Technologies used to remember User selections, preferences, configurations, or settings or to provide enhanced functionality.
§ 2.10 "Analytics Technologies."
"Analytics Technologies" means Cookies or Tracking Technologies used to measure, understand, evaluate, analyze, maintain, or improve Service use, performance, functionality, traffic, engagement, reliability, security, or operation.
§ 2.11 "Advertising Technologies."
"Advertising Technologies" means Cookies or Tracking Technologies used for advertising, audience measurement, campaign measurement, attribution, conversion measurement, personalization, targeted advertising, cross-context behavioral advertising, or substantially similar advertising activities.
§ 2.12 "Personal Information."
"Personal Information" means information defined as personal information, personal data, personally identifiable information, or substantially equivalent terminology under Applicable Law.
§ 2.13 "Sensitive Personal Information."
"Sensitive Personal Information" means information classified as sensitive personal information, sensitive data, special-category information, or substantially equivalent terminology under Applicable Law.
§ 2.14 "User."
"User" means any natural person accessing or using a ONE Service subject to this Cookie Policy.
§ 2.15 "Third Party."
"Third Party" means a person or entity other than ONE, subject to distinctions imposed by Applicable Law.
§ 2.16 "Service Provider."
"Service Provider" means a person or entity processing information for or on behalf of ONE pursuant to an applicable contractual or legal relationship.
ARTICLE III
CATEGORIES OF COOKIES AND TRACKING TECHNOLOGIES
§ 3.01 Categories.
Subject to the applicable Service, ONE may deploy or permit the deployment of:
(a) Strictly Necessary Cookies;
(b) Authentication Cookies;
(c) Security Cookies;
(d) Functional Cookies;
(e) Preference Cookies;
(f) Analytics Cookies;
(g) Performance Cookies;
(h) Personalization Cookies;
(i) Advertising Cookies;
(j) Attribution Cookies;
(k) Fraud-Prevention Technologies;
(l) Consent-Management Technologies; and
(m) other legally permissible Tracking Technologies.
§ 3.02 Classification.
Classification of a Cookie or Tracking Technology shall depend upon its actual purpose, functionality, data processing, configuration, and Applicable Law.
A technology shall not be classified as "necessary" solely because its deployment is commercially advantageous.
ARTICLE IV
STRICTLY NECESSARY TECHNOLOGIES
§ 4.01 Purposes.
ONE may use Essential Technologies reasonably necessary to:
(a) provide requested Services;
(b) maintain User sessions;
(c) authenticate Accounts;
(d) authenticate ONE ID;
(e) administer Membership;
(f) process Transactions;
(g) maintain Booking sessions;
(h) maintain security;
(i) detect fraud;
(j) prevent abuse;
(k) protect Accounts;
(l) maintain network integrity;
(m) balance network traffic;
(n) remember privacy preferences;
(o) maintain consent choices;
(p) provide accessibility functionality; and
(q) maintain essential Service functionality.
§ 4.02 Consent.
Where Applicable Law permits Essential Technologies to be deployed without prior consent, ONE may deploy such technologies without obtaining prior consent.
Where Applicable Law requires consent notwithstanding the asserted necessity of the technology, ONE shall obtain the legally required consent.
§ 4.03 Blocking.
Blocking Essential Technologies may prevent or materially impair:
(a) Account access;
(b) authentication;
(c) ONE ID functionality;
(d) ONE Membership functionality;
(e) Transactions;
(f) Bookings;
(g) security;
(h) saved privacy preferences; or
(i) other Service functionality.
ARTICLE V
FUNCTIONAL AND PREFERENCE TECHNOLOGIES
§ 5.01 Purposes.
ONE may use Functional Technologies to remember:
(a) language;
(b) region;
(c) display preferences;
(d) accessibility settings;
(e) Account preferences;
(f) Membership preferences;
(g) search preferences;
(h) saved selections;
(i) location preferences;
(j) communication preferences; and
(k) other permitted settings.
§ 5.02 Consent.
Where Applicable Law requires consent before deployment of Functional Technologies, ONE shall obtain such consent.
§ 5.03 Withdrawal.
Where processing is based upon consent, a User may withdraw consent as provided by Applicable Law.
ARTICLE VI
ANALYTICS AND PERFORMANCE TECHNOLOGIES
§ 6.01 Analytics.
ONE may use Analytics Technologies to understand and evaluate use and performance of ONE Services.
§ 6.02 Information.
Analytics Technologies may process information concerning:
(a) pages viewed;
(b) screens viewed;
(c) links selected;
(d) searches;
(e) session duration;
(f) navigation paths;
(g) referring pages;
(h) browser type;
(i) operating system;
(j) device type;
(k) IP address;
(l) approximate location;
(m) timestamps;
(n) errors;
(o) crashes;
(p) loading performance;
(q) feature interaction;
(r) network performance; and
(s) other usage information.
§ 6.03 Purposes.
ONE may use analytics information to:
(a) measure Service traffic;
(b) identify technical problems;
(c) measure performance;
(d) understand navigation;
(e) understand feature use;
(f) improve functionality;
(g) improve accessibility;
(h) prevent fraud;
(i) detect abnormal activity;
(j) conduct statistical analysis; and
(k) develop or improve Services.
§ 6.04 Third-Party Analytics.
ONE may engage Third-Party analytics providers.
Such providers may process information subject to applicable contracts, privacy notices, consent requirements, and Applicable Law.
ARTICLE VII
ADVERTISING AND MARKETING TECHNOLOGIES
§ 7.01 Advertising.
Subject to Applicable Law and ONE's actual practices, ONE may use Advertising Technologies to:
(a) measure advertising;
(b) measure campaign performance;
(c) attribute conversions;
(d) understand marketing performance;
(e) limit advertisement frequency;
(f) prevent advertising fraud;
(g) create advertising audiences where lawful;
(h) personalize advertising where lawful;
(i) deliver targeted advertising where lawful; and
(j) perform other disclosed lawful advertising functions.
§ 7.02 Sale and Sharing.
Transfers of Personal Information through Cookies, pixels, SDKs, advertising technologies, or other Tracking Technologies may constitute "sale," "sharing," "targeted advertising," "cross-context behavioral advertising," or substantially equivalent regulated processing under certain Applicable Laws.
The absence of monetary consideration shall not independently determine whether a transfer constitutes a regulated sale or sharing.
§ 7.03 Applicable Rights.
Where ONE engages in covered sale, sharing, targeted advertising, or cross-context behavioral advertising, ONE shall provide legally applicable disclosures and opt-out mechanisms.
§ 7.04 No Blanket Representation.
ONE shall not represent that it does not sell or share Personal Information unless such representation accurately reflects ONE's actual data flows, advertising technologies, analytics technologies, vendors, integrations, SDKs, pixels, and commercial practices.
ARTICLE VIII
AUTHENTICATION AND ACCOUNT TECHNOLOGIES
§ 8.01 Authentication.
ONE may use Cookies, tokens, or similar technologies to:
(a) authenticate Users;
(b) recognize authenticated Accounts;
(c) maintain Account sessions;
(d) prevent unauthorized Account access;
(e) protect login credentials;
(f) support multifactor authentication;
(g) prevent session hijacking; and
(h) protect Account integrity.
§ 8.02 ONE ID.
ONE may use authentication technologies in connection with ONE ID.
ONE ID is a private membership identification credential.
§ 8.03 No Governmental Identification.
Use of authentication technologies in connection with ONE ID does not cause ONE ID to constitute governmental identification, governmental authorization, governmental certification, or governmental status.
ARTICLE IX
SECURITY AND FRAUD-PREVENTION TECHNOLOGIES
§ 9.01 Security.
ONE may use Tracking Technologies to:
(a) detect unauthorized access;
(b) detect suspicious activity;
(c) identify automated attacks;
(d) detect credential abuse;
(e) prevent fraud;
(f) prevent impersonation;
(g) prevent Account takeover;
(h) protect ONE ID;
(i) protect Membership;
(j) protect Users;
(k) enforce security controls;
(l) investigate security incidents; and
(m) maintain system integrity.
§ 9.02 Retention.
Security-related information may be retained for periods reasonably necessary for security, fraud prevention, investigation, dispute resolution, legal compliance, and enforcement.
ARTICLE X
ON; ONE NETWORK TECHNOLOGIES
§ 10.01 ON.
ON is the ONE Network.
§ 10.02 Network Functionality.
ONE may use Cookies and Tracking Technologies to support:
(a) search;
(b) discovery;
(c) Listings;
(d) Provider discovery;
(e) saved items;
(f) recommendations;
(g) opportunities;
(h) Events;
(i) Bookings;
(j) Appointments;
(k) communications;
(l) community information;
(m) preferences; and
(n) other ON functionality.
§ 10.03 Personalization.
Where permitted by Applicable Law, ONE may use interaction information to personalize or improve ON.
§ 10.04 Profiling.
Where such processing constitutes regulated profiling, automated decision-making, targeted advertising, or another regulated activity, Applicable Law shall govern.
ARTICLE XI
TRANSACTION, BOOKING, AND APPOINTMENT TECHNOLOGIES
§ 11.01 Transaction Functionality.
ONE may use Cookies or Tracking Technologies to:
(a) maintain Transaction sessions;
(b) maintain Booking sessions;
(c) preserve selected dates;
(d) preserve selected times;
(e) preserve selected Services;
(f) maintain shopping selections;
(g) prevent duplicate Transactions;
(h) authenticate payment sessions;
(i) detect payment fraud;
(j) maintain Transaction security;
(k) maintain checkout progress; and
(l) provide confirmations.
§ 11.02 Payment Providers.
Independent payment processors may deploy technologies necessary to provide payment functionality.
Where an independent payment processor determines the purposes and means of its own processing, its applicable privacy practices may separately govern such processing.
ARTICLE XII
LOCATION TECHNOLOGIES
§ 12.01 Approximate Location.
ONE may derive approximate geographic location from technical information such as IP address where permitted by Applicable Law.
§ 12.02 Precise Geolocation.
ONE may process precise geolocation only in accordance with Applicable Law and applicable authorization requirements.
§ 12.03 Device Permission.
Where required, ONE may request device permission before accessing precise location information.
§ 12.04 Sensitive Information.
Where precise geolocation constitutes Sensitive Personal Information or Sensitive Data, ONE shall provide protections required by Applicable Law.
§ 12.05 User Controls.
Users may control location permissions through applicable browser, operating-system, application, or device settings.
§ 12.06 Effect of Restriction.
Restricting location permissions may impair location-dependent functionality.
ARTICLE XIII
PIXELS, WEB BEACONS, AND TAGS
§ 13.01 Pixels.
ONE may use pixels, web beacons, tags, or substantially similar technologies where legally permissible.
§ 13.02 Functions.
Such technologies may support:
(a) analytics;
(b) conversion measurement;
(c) email measurement;
(d) security;
(e) fraud prevention;
(f) attribution;
(g) advertising where lawful;
(h) Service improvement; and
(i) other disclosed purposes.
§ 13.03 Third-Party Pixels.
Third-Party pixels may result in information being transmitted to an independent Third Party.
ONE shall provide legally required notice, consent, or opt-out mechanisms for such processing.
ARTICLE XIV
SOFTWARE DEVELOPMENT KITS AND APPLICATION TECHNOLOGIES
§ 14.01 SDKs.
ONE applications may contain software development kits or similar technologies.
§ 14.02 Functions.
SDKs may provide:
(a) analytics;
(b) crash reporting;
(c) authentication;
(d) payments;
(e) communications;
(f) mapping;
(g) security;
(h) fraud prevention;
(i) advertising where permitted; and
(j) other application functionality.
§ 14.03 Legal Treatment.
An SDK shall be evaluated according to the information it processes and the purposes for which it is deployed.
ARTICLE XV
LOCAL STORAGE AND SESSION STORAGE
§ 15.01 Storage.
ONE Services may use browser local storage, session storage, application storage, or similar technologies.
§ 15.02 Purposes.
Such storage may maintain:
(a) User preferences;
(b) session information;
(c) authentication information;
(d) saved selections;
(e) temporary Service data;
(f) privacy preferences;
(g) consent preferences; and
(h) other permitted information.
§ 15.03 User Controls.
Browser or device settings may permit deletion of stored information.
ARTICLE XVI
SOCIAL MEDIA AND EMBEDDED CONTENT
§ 16.01 Embedded Content.
ONE Services may include:
(a) videos;
(b) maps;
(c) social-media functionality;
(d) widgets;
(e) embedded Content;
(f) sharing functionality; and
(g) other Third-Party integrations.
§ 16.02 Third-Party Processing.
Third Parties providing embedded functionality may deploy their own Tracking Technologies.
§ 16.03 Independent Third Parties.
Where a Third Party independently determines the purposes and means of processing, such Third Party remains independently responsible for applicable legal obligations.
§ 16.04 User Review.
Users may review applicable Third-Party privacy and Cookie policies concerning independent Third-Party processing.
ARTICLE XVII
INFORMATION PROCESSED THROUGH TRACKING TECHNOLOGIES
§ 17.01 Categories.
Depending upon the technology and Service, ONE or applicable Third Parties may process:
(a) IP address;
(b) browser information;
(c) operating system;
(d) device type;
(e) device identifier;
(f) advertising identifier;
(g) session identifier;
(h) Account identifier;
(i) approximate location;
(j) language;
(k) referring URL;
(l) destination URL;
(m) pages viewed;
(n) screens viewed;
(o) searches;
(p) links selected;
(q) interactions;
(r) timestamps;
(s) session duration;
(t) Transaction events;
(u) conversion events;
(v) technical errors;
(w) performance information;
(x) security events;
(y) privacy preferences;
(z) consent preferences; and
(aa) other information disclosed through an applicable notice.
§ 17.02 Sensitive Personal Information.
Nothing in this Cookie Policy independently authorizes collection or use of Sensitive Personal Information through Tracking Technologies where additional authorization is legally required.
ARTICLE XVIII
PURPOSES OF PROCESSING
§ 18.01 Permitted Purposes.
ONE may process information through Tracking Technologies for purposes including:
(a) Service delivery;
(b) Account administration;
(c) authentication;
(d) Membership administration;
(e) ONE ID administration;
(f) ON functionality;
(g) Transaction processing;
(h) Bookings;
(i) Appointments;
(j) preferences;
(k) security;
(l) fraud prevention;
(m) analytics;
(n) Service improvement;
(o) personalization where lawful;
(p) advertising where lawful;
(q) legal compliance;
(r) privacy compliance;
(s) dispute resolution; and
(t) other disclosed lawful purposes.
ARTICLE XIX
COOKIE DURATION
§ 19.01 Session Cookies.
Certain Cookies may expire when a User closes a browser, application, or applicable session.
§ 19.02 Persistent Cookies.
Persistent Cookies may remain stored until:
(a) expiration;
(b) deletion by the User;
(c) deletion by ONE;
(d) withdrawal of applicable consent;
(e) replacement; or
(f) other applicable termination.
§ 19.03 Duration Criteria.
Cookie duration may depend upon:
(a) purpose;
(b) category;
(c) technical necessity;
(d) User preference;
(e) security requirements;
(f) fraud-prevention requirements;
(g) vendor configuration;
(h) legal requirements; and
(i) contractual requirements.
§ 19.04 Specific Durations.
Where legally required or operationally appropriate, specific Cookie durations shall be identified through ONE's Cookie Preference Center, Cookie register, consent-management platform, or supplemental disclosure.
ARTICLE XX
COOKIE CONSENT
§ 20.01 Consent.
Where Applicable Law requires affirmative consent before a Cookie or Tracking Technology may be deployed, ONE shall obtain the legally required consent before covered deployment.
§ 20.02 Consent Categories.
ONE may permit Users to provide consent by category.
Categories may include:
(a) Strictly Necessary;
(b) Functional;
(c) Analytics;
(d) Performance;
(e) Personalization;
(f) Advertising; and
(g) other applicable categories.
§ 20.03 Granularity.
Where Applicable Law requires granular consent, ONE shall provide legally sufficient granular controls.
§ 20.04 Withdrawal.
Where processing is based upon consent and Applicable Law provides a right to withdraw consent, Users may withdraw such consent through the applicable mechanism.
§ 20.05 Prospective Effect.
Withdrawal ordinarily operates prospectively and does not independently render prior lawful processing unlawful.
§ 20.06 Consent Records.
ONE may retain records concerning:
(a) consent;
(b) refusal;
(c) withdrawal;
(d) date and time;
(e) applicable notice version;
(f) preference selections; and
(g) related compliance information
where reasonably necessary to demonstrate compliance or maintain User preferences.
ARTICLE XXI
COOKIE PREFERENCE CENTER
§ 21.01 Preference Interface.
ONE may provide a Cookie Preference Center or substantially equivalent interface.
§ 21.02 Available Controls.
The interface may permit Users to:
(a) review Cookie categories;
(b) accept applicable Cookies;
(c) reject applicable nonessential Cookies;
(d) modify selections;
(e) withdraw consent;
(f) review applicable vendors;
(g) review purposes;
(h) access privacy information; and
(i) exercise available privacy choices.
§ 21.03 Essential Technologies.
Technologies reasonably necessary for requested functionality and lawfully exempt from consent requirements may not be capable of being disabled through ONE's preference interface.
§ 21.04 Browser Controls.
Users may separately use browser and device controls.
ARTICLE XXII
BROWSER AND DEVICE CONTROLS
§ 22.01 Browser Controls.
Browsers may permit Users to:
(a) inspect Cookies;
(b) delete Cookies;
(c) block Cookies;
(d) restrict Third-Party Cookies;
(e) restrict storage;
(f) receive Cookie notifications; and
(g) modify privacy settings.
§ 22.02 Device Controls.
Devices and operating systems may provide controls concerning:
(a) advertising identifiers;
(b) location;
(c) tracking permissions;
(d) application permissions; and
(e) other privacy settings.
§ 22.03 Consequences.
Blocking or deleting Cookies may:
(a) terminate sessions;
(b) require repeated authentication;
(c) delete preferences;
(d) remove saved selections;
(e) impair Transactions;
(f) impair Bookings;
(g) impair Membership functionality;
(h) impair ONE ID functionality; or
(i) otherwise affect Services.
ARTICLE XXIII
GLOBAL PRIVACY CONTROL AND OPT-OUT PREFERENCE SIGNALS
§ 23.01 Recognition.
Where Applicable Law requires recognition of a qualifying universal opt-out mechanism, opt-out preference signal, Global Privacy Control signal, or substantially equivalent mechanism, ONE shall process such signal as legally required.
§ 23.02 Covered Processing.
A legally qualifying signal may apply to:
(a) sale of Personal Information;
(b) sharing of Personal Information;
(c) targeted advertising;
(d) cross-context behavioral advertising; or
(e) other processing subject to a statutory opt-out preference signal.
§ 23.03 Scope.
The effect of a signal may depend upon:
(a) jurisdiction;
(b) browser;
(c) device;
(d) Account status;
(e) signal configuration;
(f) processing activity; and
(g) Applicable Law.
§ 23.04 Conflicting Preferences.
Where a recognized statutory opt-out signal conflicts with a previously stored preference, ONE shall resolve the conflict as required by Applicable Law.
ARTICLE XXIV
DO NOT TRACK
§ 24.01 Do Not Track Signals.
Certain browsers transmit "Do Not Track" signals.
§ 24.02 Treatment.
ONE shall respond to such signals to the extent required by Applicable Law.
§ 24.03 Distinction.
A general Do Not Track signal may differ legally and technically from a recognized universal opt-out mechanism or Global Privacy Control signal.
Nothing in this Article limits ONE's obligation to recognize a qualifying opt-out preference signal where legally required.
ARTICLE XXV
SALE, SHARING, AND TARGETED ADVERTISING
§ 25.01 Statutory Definitions.
"Sale," "sharing," "targeted advertising," "cross-context behavioral advertising," and substantially equivalent terminology shall possess the meanings prescribed by Applicable Law.
§ 25.02 Applicable Opt-Out Rights.
Where ONE engages in covered processing, eligible Users may possess statutory opt-out rights.
§ 25.03 Privacy Choices.
Where legally required, ONE shall provide an applicable privacy-choice mechanism, which may include:
"Your Privacy Choices"
"Your California Privacy Choices"
"Do Not Sell or Share My Personal Information"
or other legally sufficient language.
§ 25.04 Cookie Consent Distinguished.
A general Cookie banner shall not independently constitute satisfaction of a separate statutory sale, sharing, or targeted-advertising opt-out obligation unless the mechanism satisfies Applicable Law.
ARTICLE XXVI
CHILDREN AND MINORS
§ 26.01 Special Protection.
ONE may restrict Cookies and Tracking Technologies concerning children and Minors.
§ 26.02 COPPA.
Where the Children's Online Privacy Protection Act ("COPPA") applies, ONE shall comply with legally applicable notice, consent, data-minimization, security, retention, and parental-right requirements.
§ 26.03 Persistent Identifiers.
Persistent identifiers may constitute Personal Information under COPPA where the applicable statutory and regulatory conditions are satisfied.
§ 26.04 Advertising.
Nothing in this Cookie Policy constitutes authorization to use children's information for behavioral advertising, profiling, or other processing where separate parental consent is legally required or the processing is prohibited.
§ 26.05 Age Restrictions.
ONE may restrict Tracking Technologies according to age, Service, Account classification, jurisdiction, or Applicable Law.
§ 26.06 Parental Rights.
Where Applicable Law provides parents or legal guardians with rights concerning a child's Personal Information, ONE shall provide applicable mechanisms for exercising those rights.
ARTICLE XXVII
HEALTH INFORMATION AND CONFIDENTIAL CONTEXTS
§ 27.01 Health Information.
Where ONE provides healthcare Provider discovery or Appointment functionality, ONE may use technologies reasonably necessary for administrative scheduling and related functions.
§ 27.02 Protected Information.
ONE shall not construe this Cookie Policy as authorization to disclose protected health information or other legally protected health information to advertising or tracking providers where prohibited by Applicable Law.
§ 27.03 Regulated Roles.
Where ONE acts as a Covered Entity, Business Associate, or other regulated person concerning particular health information, applicable healthcare privacy requirements shall control.
§ 27.04 Confidential Contexts.
ONE shall not construe this Cookie Policy as authorization to use information collected in a legally protected or confidential context for materially different advertising, financial-benefit, profiling, or other purposes where affirmative express consent or other authorization is required by Applicable Law.
ARTICLE XXVIII
EMPLOYMENT AND WORK OPPORTUNITIES
§ 28.01 Employment Context.
Cookies and Tracking Technologies may support job, gig, contractor, volunteer, or other Work Opportunity functionality.
§ 28.02 No Unlawful Processing.
Nothing in this Cookie Policy authorizes unlawful employment discrimination, unlawful profiling, or other prohibited employment-related processing.
§ 28.03 Sensitive Information.
Employment-related Sensitive Personal Information shall receive protections required by Applicable Law.
ARTICLE XXIX
HOUSING AND REAL ESTATE
§ 29.01 Housing Functionality.
Cookies and Tracking Technologies may support housing discovery, Listings, searches, preferences, and related functionality.
§ 29.02 No Unlawful Discrimination.
Nothing in this Cookie Policy authorizes unlawful housing discrimination, discriminatory advertising, or prohibited targeting.
§ 29.03 Location and Sensitive Data.
Housing-related location or Sensitive Personal Information shall receive protections required by Applicable Law.
ARTICLE XXX
GOVERNMENT AND PUBLIC-SECTOR SERVICES
§ 30.01 Government Content.
ONE may use Cookies or Tracking Technologies in connection with governmental or public-sector Content and functionality.
§ 30.02 Private Status.
Government participation in ONE or ON does not transform ONE into a governmental entity.
§ 30.03 No Automatic Government Access.
Government participation does not independently grant a governmental organization unrestricted access to Tracking Technology data or other Personal Information maintained by ONE.
§ 30.04 Legal Process.
ONE may preserve or disclose information pursuant to legally sufficient governmental process or as otherwise required or permitted by Applicable Law.
ARTICLE XXXI
EDUCATIONAL AND SCHOOL SERVICES
§ 31.01 Educational Functionality.
ONE may use Cookies and Tracking Technologies in connection with educational bulletins, school information, Events, activities, and related functionality.
§ 31.02 Protected Student Information.
Where Tracking Technologies process legally protected student information, applicable privacy requirements shall control.
§ 31.03 No General Authorization.
This Cookie Policy does not independently authorize use of protected student information for advertising or unrelated profiling.
ARTICLE XXXII
RELIGIOUS, NONPROFIT, AND COMMUNITY INFORMATION
§ 32.01 Religious Information.
Information concerning religious beliefs, affiliations, or activity may constitute Sensitive Personal Information under Applicable Law.
§ 32.02 Nonprofit and Community Information.
Tracking Technologies may support nonprofit and community Services subject to applicable privacy requirements.
§ 32.03 Sensitive Inferences.
ONE shall provide legally required protections where Tracking Technologies may create sensitive inferences concerning a User.
ARTICLE XXXIII
THIRD-PARTY SERVICE PROVIDERS
§ 33.01 Providers.
ONE may engage Third Parties providing:
(a) hosting;
(b) cloud infrastructure;
(c) content delivery;
(d) security;
(e) fraud prevention;
(f) analytics;
(g) payment processing;
(h) communications;
(i) customer support;
(j) advertising;
(k) mapping;
(l) video;
(m) authentication;
(n) verification; and
(o) other technology services.
§ 33.02 Contractual Requirements.
Where required by Applicable Law, ONE shall maintain applicable contractual requirements governing Service Provider processing.
§ 33.03 Independent Processing.
Certain Third Parties may independently determine the purposes and means of their processing.
Such Third Parties remain independently responsible for their own legal obligations to the extent prescribed by Applicable Law.
§ 33.04 Third-Party Policies.
Where appropriate, Users should review applicable Third-Party privacy and Cookie policies.
ARTICLE XXXIV
DATA MINIMIZATION
§ 34.01 Minimization.
ONE may seek to limit information processed through Tracking Technologies to information reasonably necessary and proportionate to the applicable disclosed purpose.
§ 34.02 Technical Capability.
The technical capability to collect information does not independently establish necessity for its collection.
§ 34.03 Sensitive Information.
ONE may impose additional restrictions concerning Tracking Technologies capable of processing Sensitive Personal Information.
ARTICLE XXXV
PURPOSE LIMITATION
§ 35.01 Disclosed Purposes.
ONE shall process information obtained through Tracking Technologies for disclosed or otherwise legally permissible purposes.
§ 35.02 Materially Different Purposes.
Where Applicable Law requires additional notice, consent, or authorization before information may be processed for a materially different or incompatible purpose, ONE shall provide such notice or obtain such authorization.
ARTICLE XXXVI
RETENTION
§ 36.01 General Standard.
Information processed through Cookies and Tracking Technologies may be retained for periods reasonably necessary for applicable purposes, subject to Applicable Law.
§ 36.02 Retention Factors.
Retention may depend upon:
(a) purpose;
(b) technology type;
(c) Cookie duration;
(d) Account status;
(e) security requirements;
(f) fraud-prevention requirements;
(g) analytics requirements;
(h) consent records;
(i) contractual obligations;
(j) legal obligations;
(k) dispute requirements; and
(l) technical requirements.
§ 36.03 Browser Deletion.
Deletion of a Cookie from a browser does not independently require immediate deletion of server-side information lawfully retained from prior interactions.
§ 36.04 Statutory Rights.
Applicable statutory deletion rights remain unaffected.
ARTICLE XXXVII
SECURITY
§ 37.01 Safeguards.
ONE may maintain administrative, technical, organizational, and physical safeguards appropriate to the nature of information processed through Tracking Technologies.
§ 37.02 No Absolute Security.
NO COOKIE, BROWSER, DEVICE, NETWORK, APPLICATION, SOFTWARE, DATABASE, STORAGE SYSTEM, COMMUNICATION SYSTEM, OR INTERNET-BASED TECHNOLOGY CAN BE WARRANTED AS ABSOLUTELY SECURE.
§ 37.03 Mandatory Obligations.
Nothing in this Article disclaims any data-security obligation directly imposed upon ONE by Applicable Law.
ARTICLE XXXVIII
DEIDENTIFIED AND AGGREGATED INFORMATION
§ 38.01 Permitted Processing.
Where permitted by Applicable Law, ONE may create and process Deidentified Information or Aggregated Information derived from information processed through Tracking Technologies.
§ 38.02 Purposes.
Such information may be used for:
(a) analytics;
(b) statistical analysis;
(c) research;
(d) security;
(e) Service improvement;
(f) business intelligence;
(g) capacity planning; and
(h) other lawful purposes.
§ 38.03 Deidentified Status.
Where Applicable Law requires maintenance of deidentified status, ONE shall comply with applicable requirements.
ARTICLE XXXIX
USER PRIVACY RIGHTS
§ 39.01 Rights.
Depending upon Applicable Law and ONE's processing activities, eligible Users may possess rights concerning Personal Information processed through Tracking Technologies, including:
(a) access;
(b) knowledge;
(c) correction;
(d) deletion;
(e) portability;
(f) withdrawal of consent;
(g) opt-out of sale;
(h) opt-out of sharing;
(i) opt-out of targeted advertising;
(j) limitation of certain uses of Sensitive Personal Information;
(k) appeal; and
(l) non-discrimination.
§ 39.02 Conditions.
Rights remain subject to statutory applicability requirements, verification requirements, exceptions, exemptions, and limitations.
§ 39.03 Exercise.
Applicable rights may be exercised through mechanisms identified in the ONE Master Privacy Policy, Cookie Preference Center, or applicable privacy interface.
ARTICLE XL
CALIFORNIA PRIVACY RIGHTS
§ 40.01 Applicability.
Where ONE is subject to the California Consumer Privacy Act, as amended ("CCPA"), eligible California consumers shall receive applicable statutory rights.
§ 40.02 Sale and Sharing.
Where Cookies or Tracking Technologies result in sale or sharing within the meaning of the CCPA, ONE shall provide applicable opt-out rights.
§ 40.03 Opt-Out Preference Signals.
ONE shall recognize legally qualifying opt-out preference signals to the extent required by Applicable Law.
§ 40.04 Sensitive Personal Information.
Where ONE uses or discloses Sensitive Personal Information in a manner giving rise to an applicable right to limit, ONE shall provide the legally required mechanism.
§ 40.05 Non-Discrimination.
ONE shall not unlawfully discriminate against an eligible consumer for exercising applicable statutory privacy rights.
§ 40.06 Supplemental Notice.
This Article supplements and does not replace applicable California disclosures contained in the ONE Master Privacy Policy.
ARTICLE XLI
CHANGES TO COOKIE PREFERENCES
§ 41.01 Modification.
Users may modify available Cookie preferences through ONE's designated preference mechanism.
§ 41.02 Preference Cookie.
ONE may use a Cookie or similar technology to remember privacy and Cookie preferences.
§ 41.03 Clearing Storage.
If a User deletes Cookies, clears browser storage, changes devices, changes browsers, uses private browsing, or otherwise removes stored preferences, ONE may be unable to recognize prior selections.
§ 41.04 New Selection.
ONE may request a new preference selection where prior preferences cannot reasonably be recognized.
§ 41.05 Account Preferences.
Where legally permissible, ONE may associate applicable privacy preferences with an authenticated Account.
ARTICLE XLII
THIRD-PARTY WEBSITES AND APPLICATIONS
§ 42.01 External Services.
ONE Services may contain links to independent Third-Party websites or applications.
§ 42.02 External Tracking.
ONE does not control Tracking Technologies independently deployed by a Third Party after a User leaves ONE Services and accesses an independent Third-Party property.
§ 42.03 Independent Policies.
Third-Party privacy and Cookie practices are governed by applicable Third-Party policies and Applicable Law.
§ 42.04 ONE's Own Conduct.
Nothing in this Article disclaims responsibility imposed upon ONE by Applicable Law concerning ONE's own selection, configuration, deployment, or disclosure of Third-Party technologies on ONE Services.
ARTICLE XLIII
COOKIE REGISTER
§ 43.01 Register.
ONE may maintain a Cookie and Tracking Technologies Register through a Cookie Preference Center, consent-management platform, or other accessible interface.
§ 43.02 Register Information.
The Register may identify:
(a) technology name;
(b) provider;
(c) domain;
(d) purpose;
(e) category;
(f) duration;
(g) First-Party or Third-Party classification; and
(h) other applicable information.
§ 43.03 Operational Changes.
Individual technologies and vendors may change as ONE Services evolve.
§ 43.04 Disclosure Updates.
Where legally required, ONE shall update applicable disclosures or consent mechanisms to reflect material changes.
ARTICLE XLIV
INTERNATIONAL USERS
§ 44.01 United States Platform.
ONE is principally intended as a United States platform unless expressly stated otherwise.
§ 44.02 International Requirements.
Where additional Cookie, electronic communications, consent, tracking, or privacy requirements of another jurisdiction legally apply to ONE, ONE shall comply with applicable mandatory requirements.
§ 44.03 No Universal Availability.
Access to ONEUSA.us from another jurisdiction does not constitute a representation that every ONE Service is offered in that jurisdiction.
ARTICLE XLV
NO GOVERNMENTAL STATUS
§ 45.01 Private Entity.
Office of National Excellence, LLC is a private Michigan limited liability company.
§ 45.02 ONE.
ONE is the Office of National Excellence.
§ 45.03 ON.
ON is the ONE Network.
§ 45.04 Private Technologies.
ONE's Cookies, Tracking Technologies, ONE ID, ONE Card, Accounts, registries, networks, websites, applications, and systems are private technologies unless expressly identified otherwise concerning a specific Third-Party governmental system.
§ 45.05 Government Participation.
Participation by federal, state, tribal, territorial, county, municipal, school, or other public-sector organizations does not transform ONE or ON into a governmental entity, agency, authority, instrumentality, or public body.
§ 45.06 No Governmental Access by Participation Alone.
Government participation does not independently provide unrestricted access to Tracking Technology information or other Personal Information maintained by ONE.
ARTICLE XLVI
NO ABSOLUTE PRIVACY OR TECHNOLOGY GUARANTEE
§ 46.01 Technical Environment.
Internet technologies, browsers, devices, applications, operating systems, privacy signals, and Third-Party technologies may change.
§ 46.02 No Absolute Guarantee.
ONE does not represent that every browser, device, privacy extension, Tracking Technology, consent-management system, opt-out signal, or technical configuration will operate identically.
§ 46.03 Mandatory Rights.
Nothing in this Article limits a non-waivable duty imposed upon ONE by Applicable Law.
ARTICLE XLVII
CHANGES TO THIS COOKIE POLICY
§ 47.01 Amendments.
ONE may amend this Cookie Policy prospectively to reflect:
(a) changes in ONE Services;
(b) changes in technology;
(c) changes in vendors;
(d) changes in Cookies;
(e) changes in Tracking Technologies;
(f) changes in privacy practices;
(g) changes in Applicable Law; or
(h) other lawful operational changes.
§ 47.02 Last Revised Date.
The revised Cookie Policy shall display an updated "Last Revised" date.
§ 47.03 Material Changes.
Where Applicable Law requires additional notice or consent concerning a material change, ONE shall provide the legally required notice or obtain the legally required consent.
§ 47.04 No Retroactive Authorization.
An amendment to this Cookie Policy shall not independently retroactively authorize processing for which Applicable Law requires additional consent.
ARTICLE XLVIII
MANDATORY-LAW SAVINGS CLAUSE
§ 48.01 Non-Waivable Rights.
NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS COOKIE POLICY, NO PROVISION SHALL BE CONSTRUED TO DISCLAIM, WAIVE, RELEASE, RESTRICT, TRANSFER, ELIMINATE, OR LIMIT ANY PRIVACY RIGHT, CONSENT REQUIREMENT, OPT-OUT RIGHT, DATA-SECURITY OBLIGATION, CHILD-PROTECTION REQUIREMENT, CONSUMER RIGHT, SENSITIVE-DATA PROTECTION, HEALTH-INFORMATION REQUIREMENT, OR OTHER LEGAL RIGHT OR OBLIGATION TO THE EXTENT SUCH TREATMENT IS PROHIBITED BY APPLICABLE LAW.
§ 48.02 Mandatory Law.
Where Applicable Law provides a greater mandatory protection than this Cookie Policy, the mandatory legal requirement shall control to the extent applicable.
§ 48.03 Remaining Provisions.
Any remaining provisions shall continue in effect to the maximum extent permitted by Applicable Law.
ARTICLE XLIX
SEVERABILITY
§ 49.01 Severability.
If any provision of this Cookie Policy is determined by a court or tribunal of competent jurisdiction to be invalid, unlawful, or unenforceable, such provision shall be construed, modified, limited, or severed to the minimum extent necessary where legally permissible.
§ 49.02 Remaining Provisions.
The invalidity or unenforceability of one provision shall not affect the remaining provisions except where Applicable Law requires otherwise.
ARTICLE L
RELATIONSHIP TO OTHER ONE POLICIES AND AGREEMENTS
§ 50.01 Legal Framework.
This Cookie Policy shall be construed together with, as applicable:
(a) ONE Master Terms of Use and Services Agreement;
(b) ONE Master Privacy Policy;
(c) ONE Membership Agreement;
(d) ONE ID Terms;
(e) ONE Card Terms;
(f) ON Network Rules;
(g) Provider Agreement;
(h) Marketplace and Transaction Terms;
(i) Booking and Appointment Terms;
(j) Child and Family Privacy Notice;
(k) Healthcare Privacy Notice;
(l) Employment and Opportunity Rules;
(m) Housing Rules;
(n) Government Bulletin Terms;
(o) Educational Bulletin Terms;
(p) Tax Liability, Reporting, and Withholding Disclaimer;
(q) Acceptable Use Policy;
(r) Electronic Communications Consent; and
(s) other applicable ONE agreements, disclosures, notices, consents, and policies.
§ 50.02 Privacy Policy.
The ONE Master Privacy Policy governs broader processing of Personal Information.
§ 50.03 Cookie Policy.
This Cookie Policy governs disclosures concerning Cookies and Tracking Technologies.
§ 50.04 Master Terms.
The ONE Master Terms of Use and Services Agreement governs contractual use of ONE Services, subject to Applicable Law.
ARTICLE LI
CONTACT INFORMATION
§ 51.01 Privacy Office.
Questions concerning Cookies, Tracking Technologies, privacy preferences, or applicable statutory privacy rights may be directed to:
OFFICE OF NATIONAL EXCELLENCE, LLC
ATTN: PRIVACY OFFICE
Privacy Email:
[PRIVACY EMAIL]
Privacy Request Portal:
[PRIVACY REQUEST URL]
Cookie Preference Center:
[COOKIE PREFERENCE CENTER URL]
Your Privacy Choices:
[PRIVACY CHOICES URL, IF APPLICABLE]
Telephone:
[PRIVACY TELEPHONE, IF REQUIRED]
Mailing Address:
[PRIVACY MAILING ADDRESS]
Official Domain:
ONEUSA.us
ARTICLE LII
FINAL NOTICE AND ACKNOWLEDGMENT
§ 52.01 Notice.
THIS COOKIE POLICY PROVIDES NOTICE CONCERNING THE USE OF COOKIES AND TRACKING TECHNOLOGIES BY OR IN CONNECTION WITH ONE SERVICES AS DESCRIBED HEREIN.
§ 52.02 Consent Where Required.
WHERE APPLICABLE LAW REQUIRES AFFIRMATIVE CONSENT FOR A PARTICULAR COOKIE, TRACKING TECHNOLOGY, OR PROCESSING ACTIVITY, ACCESS TO OR USE OF A ONE SERVICE ALONE SHALL NOT SUBSTITUTE FOR THE LEGALLY REQUIRED CONSENT.
§ 52.03 Opt-Out Rights.
WHERE APPLICABLE LAW PROVIDES AN OPT-OUT RIGHT CONCERNING SALE, SHARING, TARGETED ADVERTISING, CROSS-CONTEXT BEHAVIORAL ADVERTISING, OR OTHER COVERED PROCESSING, NOTHING IN THIS COOKIE POLICY SHALL CONSTITUTE A WAIVER OF SUCH RIGHT.
§ 52.04 Withdrawal of Consent.
WHERE PROCESSING IS BASED UPON CONSENT AND APPLICABLE LAW PROVIDES A RIGHT TO WITHDRAW CONSENT, THE USER MAY EXERCISE SUCH RIGHT THROUGH THE APPLICABLE MECHANISM PROVIDED BY ONE.
§ 52.05 Statutory Privacy Rights.
NO CONTRACTUAL ACCEPTANCE, ACCOUNT REGISTRATION, MEMBERSHIP, ONE ID ISSUANCE, TRANSACTION, OR USE OF ONE SERVICES SHALL CONSTITUTE A WAIVER OF A PRIVACY RIGHT THAT APPLICABLE LAW PROHIBITS FROM BEING WAIVED.
§ 52.06 Controlling Principle.
NOTHING IN THIS COOKIE POLICY AUTHORIZES OFFICE OF NATIONAL EXCELLENCE, LLC, ANY USER, PROVIDER, SERVICE PROVIDER, PROCESSOR, CONTRACTOR, VENDOR, OR THIRD PARTY TO ENGAGE IN PROCESSING PROHIBITED BY APPLICABLE LAW.
OFFICE OF NATIONAL EXCELLENCE, LLC
ONE
ON | ONE NETWORK
Official Domain: ONEUSA.us
COOKIE AND TRACKING TECHNOLOGIES POLICY
Effective Date: September 16, 2026
Last Revised: September 16, 2026
Last Updated
September 16, 2026 at 6:43:15 AM