Cookie & Tracking Policy
This Cookie & Tracking Policy (this “Cookie Policy”) explains how Aspire Advisors LLC d/b/a HeyDrew and its parent, affiliates, and subsidiaries (collectively, “HeyDrew,” “we,” “us,” or “our”) use cookies and similar tracking technologies on our website, mobile application, and digital platform (collectively, our “Platform”).
This Cookie Policy should be read together with our Privacy Policy, available at www.heydrew.com/legal/privacy-policy, which describes how we collect, use, and protect your personal information. Capitalized terms used but not defined in this Cookie Policy have the meanings given to them in our Privacy Policy.
Cookies and similar technologies are small files or pieces of code placed on your device when you visit a website or use an application. They allow us and third parties to recognize your device, remember information about your visit, understand how you interact with our Platform, and, in some cases, serve content or advertisements relevant to you. Some of these technologies are essential to how our Platform works, while others are optional and subject to your preferences.
We believe you should understand which tracking technologies we use, why we use them, and how you can control them. This Cookie Policy is designed to provide that understanding in plain language.
1. Types of Tracking Technologies We Use
We use several types of tracking technologies on our Platform. Understanding what each one does helps clarify how we collect information and how you can manage your preferences.
Cookies. Cookies are small text files that websites place on your device when you visit them. Cookies can be set directly by HeyDrew (“first-party cookies”) or by third parties whose services we use on our Platform (“third-party cookies”). Cookies may be “session cookies,” which expire when you close your browser, or “persistent cookies,” which remain on your device for a set period or until you delete them.
Pixels and web beacons. Pixels are tiny, invisible images or code snippets embedded in web pages or emails. When loaded, they signal to us or a third party that a page was viewed, an email was opened, or a specific action was taken. They are commonly used for analytics and advertising measurement.
Local and session storage. Local and session storage are browser-based technologies that let websites store data directly on your device. Unlike cookies, this data is not automatically sent to a server with every request. Session storage is cleared when you close your browser tab; local storage persists until it is manually cleared or cleared by the application.
Software development kits and device identifiers. In our mobile application, our service providers and we may use software development kits (“SDKs”) — small packages of code embedded in the app — and device identifiers such as Apple’s Identifier for Advertisers (IDFA) or Android’s Advertising ID. These serve functions similar to cookies on websites, allowing us to recognize your device, understand app usage, and measure performance. Your device’s operating system provides controls to limit or reset these identifiers, as described in Section 3.
Other similar technologies. We may use other technologies that function similarly to those described above, including fingerprinting techniques that identify your device based on its characteristics and authentication tokens that keep you securely logged in. When we use such technologies, the same principles described in this Cookie Policy apply.
2. Categories of Cookies and Tracking Technologies
We organize the cookies and tracking technologies used on our Platform into four categories. Where a consent management tool is active on our Platform, these categories will be presented to you directly so you can make informed choices about which technologies to accept.
2.1 Essential / Strictly Necessary
Essential cookies are required for our Platform to function. They enable core features such as secure login, session management, account authentication, page navigation, and platform security. Without these cookies, our Platform cannot operate properly, and the services you have requested cannot be delivered.
Essential cookies cannot be disabled through our cookie preference tool. Because they are strictly necessary to provide the services you have requested, they do not require your consent. They do not collect information used for marketing or analytics purposes.
Examples of what essential cookies do on our Platform include keeping you logged in during your session, remembering items in your account, maintaining your security session, and preventing fraudulent activity.
2.2 Functional / Preference
Functional cookies allow our Platform to remember your choices and provide enhanced, personalized features. They may remember your language preferences, display settings, previously entered information, and other customizations that improve your experience.
These cookies are set by HeyDrew and do not track your activity on other websites. Disabling functional cookies may affect the personalization and convenience features of our Platform, but it will not prevent you from using its core functions.
2.3 Analytics / Performance
Analytics cookies help us understand how visitors and users interact with our Platform. They collect information such as which pages are visited most frequently, how long users spend on specific features, where users come from, and where they encounter errors or drop off. This information is used in aggregate to improve our Platform and services.
Analytics cookies on our Platform may be set by HeyDrew or by third-party analytics providers, including Google Analytics and similar services. These providers may process data on our behalf in accordance with our instructions and their privacy policies. We configure analytics tools to limit the collection of sensitive personal and financial information.
You may opt out of analytics cookies via our cookie preference tool or directly through the applicable third-party provider. Opting out of analytics cookies does not affect your ability to use our Platform.
2.4 Advertising / Marketing
Advertising cookies help measure the effectiveness of HeyDrew’s marketing and advertising efforts and, where applicable, deliver content or advertisements relevant to your interests. These cookies may be set by third-party advertising platforms — such as Meta, Google, or similar services — and may track your activity on our Platform and across other websites to build a profile of your interests.
HeyDrew uses advertising cookies solely to measure and improve our marketing efforts. We do not use advertising cookies to collect sensitive personal or financial information, and we configure our advertising tools to exclude pages where such information is entered.
You may opt out of advertising cookies using our cookie preference tool. You may also opt out directly through participating advertising platforms, including the Digital Advertising Alliance’s opt-out tool at optout.aboutads.info and the Network Advertising Initiative at optout.networkadvertising.org. Note that opting out of advertising cookies does not mean you will stop seeing HeyDrew advertisements — it means those advertisements will not be tailored to your tracked activity.
3. Mobile App Tracking Technologies
Mobile applications do not use cookies in the traditional browser-based sense. Instead, our mobile application may use equivalent technologies that serve similar functions — including software development kits (SDKs), device identifiers, local storage, and in-app analytics tools. These technologies help us recognize your device, understand how the application is used, maintain your session, and measure the performance of our services.
Device identifiers. Our mobile application may use device-level identifiers to recognize your device across sessions. On Apple iOS devices, this may include the Identifier for Advertisers (IDFA). On Android devices, this may include the Android Advertising ID (AAID). You can reset or limit these identifiers through your device’s privacy settings, as described below.
In-app analytics. We use in-app analytics tools to understand how users interact with our mobile application — including which features are used, how often the app is opened, and where users encounter issues. This information is aggregated to improve the application experience. Sensitive personal and financial information is excluded from in-app analytics collection.
Your mobile device’s operating system provides controls that let you limit or reset advertising identifiers and restrict app tracking. We encourage you to use these controls to match your preferences.
Adjusting these device-level settings limits certain tracking in our mobile application. The category-based preferences described in Section 2 apply to our mobile application to the extent technically feasible, and we configure our mobile tools to honor your stated preferences where possible.
4. Third-Party Cookies and Tracking
Some cookies and tracking technologies on our Platform are set and managed by third parties — companies other than HeyDrew. These third parties set their own cookies when you interact with our Platform, in accordance with their privacy and cookie policies. HeyDrew does not control how third-party cookies operate beyond the configurations we apply when integrating their tools into our Platform.
Who sets third-party cookies on our Platform. Third-party cookies on our Platform may be set by analytics providers, advertising platforms, and technology service providers whose tools we use to operate and improve our services. This may include providers such as Google Analytics, Meta, and similar services. The specific third-party cookies present on our Platform at any given time are identified and disclosed through our cookie preference tool.
What third-party cookies collect. Third-party cookies may collect information about your activity on our Platform, your device, your browser, and, in some cases, your activity across other websites and applications. This information is collected directly by the third party and is subject to that party’s privacy policy, not this Cookie Policy. HeyDrew receives aggregated or limited data from these providers — we do not receive the full scope of data they may collect about you.
HeyDrew’s limited control. While we take reasonable steps to configure third-party tools in a manner consistent with this Cookie Policy — including excluding sensitive information from their reach — we cannot fully control or guarantee how third-party technologies operate once deployed. If you have concerns about a specific third party’s data practices, we encourage you to review that party’s privacy policy directly.
You have several options for limiting third-party tracking:
- Use HeyDrew’s cookie preference tool at www.heydrew.com/legal/cookie-policy to manage your consent for third-party cookie categories
- Opt out directly through participating advertising networks, including the Digital Advertising Alliance at optout.aboutads.info and the Network Advertising Initiative at optout.networkadvertising.org
- Adjust your browser settings to block third-party cookies — note that this may affect the functionality of some features on our Platform
- Use your device’s privacy settings to limit mobile tracking as described in Section 3
5. Cookie Consent and Your Preferences
HeyDrew uses a cookie consent management tool to give you control over which categories of cookies and tracking technologies are active when you use our Platform. When you visit our website or open our mobile application for the first time, you will see a consent notice that explains the categories of cookies we use and lets you accept all, reject non-essential cookies, or customize your preferences by category.
How consent works. Your preferences are captured and stored so our Platform can honor your choices on future visits. If you do not interact with the consent notice, only essential cookies will be active until you make a selection. Your consent applies to the device and browser where it was given — if you use a different device or browser, or clear your cookies, you may be asked to set your preferences again.
Geolocation-based preferences. The consent experience you see may vary by your location. Users in states or regions with specific privacy requirements may see enhanced consent options or additional disclosures that comply with applicable law. Regardless of your location, HeyDrew provides meaningful preference controls to all users as part of its privacy standards.
Changing your preferences. You may update your cookie preferences at any time by using the privacy settings link in the footer of our website.
What happens when you opt out. If you reject non-essential cookies or opt out of specific categories, those technologies will not be activated during your visit. Opting out of functional or analytics cookies may affect certain features of our Platform but will not prevent you from accessing core services. Opting out of advertising cookies means HeyDrew’s advertising platforms will not use your activity data for targeting or measurement during that session.
Withdrawing consent. You may withdraw previously given consent at any time by updating your preferences in the cookie preference tool. Withdrawing consent does not affect the lawfulness of any processing that occurred before withdrawal.
6. Do Not Track
Some browsers offer a “Do Not Track” (“DNT”) setting that signals to websites that you do not want your online activity tracked. There is currently no universally accepted standard for how websites should respond to DNT signals, and HeyDrew’s Platform does not currently respond to browser-level DNT signals.
If you wish to limit tracking on our Platform, we encourage you to use the available preference controls — including our cookie preference tool described in Section 5, your browser’s cookie settings, and your device’s privacy controls described in Section 3. These tools provide meaningful, actionable control over how your activity is collected and used, independent of DNT signals.
We will monitor developments in DNT standards and update our practices if a uniform standard is adopted.
7. Sensitive Information and Tracking
HeyDrew’s Platform is designed to handle sensitive personal and financial information with heightened care. Consistent with our Privacy Policy, tracking technologies are not used to collect, transmit, or process sensitive information — including Social Security Numbers, government-issued identification, financial records, tax data, and other categories of information described in Section 3 of our Privacy Policy.
Page-level configuration. Pages and features on our Platform that handle sensitive information are configured to limit the reach of third-party tracking technologies. Analytics tools, advertising pixels, and similar technologies are excluded from these areas to the extent technically feasible.
No sensitive data in advertising tools. Sensitive personal and financial information is never shared with advertising platforms or used for behavioral targeting, audience building, or ad measurement.
AI and derived data. Tracking technologies are not used to feed sensitive information into artificial intelligence models or to generate sensitive inferences that are shared with third parties.
If you have concerns about how your sensitive information is handled in connection with our tracking practices, please contact us at privacy@heydrew.com.
8. Changes to This Policy
HeyDrew may update this Cookie Policy from time to time to reflect changes in the tracking technologies we use, applicable law, or our privacy practices. The current version is always available at www.heydrew.com/legal/cookie-policy, and the “Last Updated” date at the top reflects the most recent revision. When we make changes that materially affect how we use cookies or tracking technologies, we will provide reasonable notice — such as updating the consent notice in our cookie preference tool or posting a notice on our website. Your continued use of our Platform after an update takes effect constitutes your acceptance of the revised Cookie Policy.
9. Contact Us
If you have questions or concerns about this Cookie Policy or our use of cookies and tracking technologies, please contact us by email at privacy@heydrew.com or by mail at HeyDrew, 90 Fort Wade Rd., Ponte Vedra, FL 32081.
For broader privacy questions or requests about your personal information, please refer to our Privacy Policy at www.heydrew.com/legal/privacy-policy or contact us at the same address.
HeyDrew Cookie & Tracking Policy · Confidential