Legal
This Cookie Policy (“Cookie Policy”) explains how ORamaVR SA (“ORamaVR”, “we”, “us”, or “our”) uses cookies and similar technologies on:
This Cookie Policy supplements, and should be read together with, the ORamaVR Privacy Policy. In the event of conflict between this Cookie Policy and the Privacy Policy on matters within the scope of this Cookie Policy, this Cookie Policy prevails.
Cookies. A cookie is a small text file that a website places on your device when you visit it, which the website reads on subsequent visits. Cookies enable a website to recognise your device, remember your preferences, support security and authentication, and analyse how the site is used.
Similar technologies. For the purposes of this Cookie Policy, “cookies” also includes HTML5 local storage and session storage, IndexedDB and Web SQL, pixel tags and web beacons, and device fingerprinting (where used). The same rules apply to these similar technologies unless otherwise stated.
First-party and third-party cookies. First-party cookies are placed by ORamaVR directly. Third-party cookies are placed by service providers we engage. Third-party cookies are subject to the privacy policy of the relevant third party in addition to this Cookie Policy.
Session and persistent cookies. A session cookie is deleted when you close your browser. A persistent cookie remains on your device until it expires or you delete it.
ORamaVR's use of cookies is governed by: the ePrivacy Directive 2002/58/EC (as amended), as transposed by the EU Member State of the user's residence; the GDPR, where the cookie processes Personal Data; the revFADP, where the cookie processes Personal Data of users in Switzerland; and equivalent national laws where applicable.
Except for Strictly Necessary Cookies (see §3.1), ORamaVR places cookies on your device only after you have given specific, informed, and unambiguous consent through the cookie consent banner presented at first visit and re-presented as required.
Consent is collected through an active opt-in (for example, by clicking “Accept” or by selecting categories in the preferences panel). Continued use of the Website does not constitute consent, and consent is not inferred from inactivity, scrolling, or pre-ticked boxes. This consent model is consistent with the requirements of Article 5(3) of the ePrivacy Directive as interpreted by the Court of Justice of the European Union in Planet49 (Case C-673/17) and the EDPB Guidelines 05/2020 on consent under the GDPR.
You may withdraw consent at any time by re-opening the cookie preferences centre at oramavr.com/legal/cookie-preferences (or via the persistent “Cookie Preferences” link in the Website footer). Withdrawal of consent takes effect immediately and does not affect the lawfulness of prior cookie processing.
| Cookie category | Lawful basis |
|---|---|
| Strictly Necessary | Legitimate interests (Art. 6(1)(f)) — operating and securing the Website; performance of a contract (Art. 6(1)(b)) where the cookie supports an authenticated session. No consent required. |
| Functionality / Preferences | Consent (Art. 6(1)(a)). |
| Performance / Analytics | Consent (Art. 6(1)(a)). |
| Targeting / Advertising | Not used by ORamaVR. See §3.4. |
This Section sets out the categories of cookies in use on the ORamaVR Website and Org-Admin Portal as at the Effective Date.
These cookies are essential for the Website and the Org-Admin Portal to function. They support core navigation, secure authentication, session persistence, load balancing, and consent recording. They do not require consent under Article 5(3) ePrivacy Directive because they are strictly necessary to provide a service explicitly requested by the user.
| Cookie name | Provider | Purpose | Duration | Party |
|---|---|---|---|---|
| CookieLawInfoConsent | CookieYes / GDPR Cookie Consent | Stores user's overall consent state across all categories | Session | 1st-party |
| viewed_cookie_policy | CookieYes / GDPR Cookie Consent | Indicates whether the user has acknowledged the cookie banner | 1 year | 1st-party |
| cookielawinfo-checkbox-necessary | CookieYes / GDPR Cookie Consent | Records user consent for the necessary cookie category | 1 year | 1st-party |
| cookielawinfo-checkbox-functional | CookieYes / GDPR Cookie Consent | Records user consent for the functional cookie category | 1 year | 1st-party |
| cookielawinfo-checkbox-analytics | CookieYes / GDPR Cookie Consent | Records user consent for the analytics cookie category | 1 year | 1st-party |
| cookielawinfo-checkbox-performance | CookieYes / GDPR Cookie Consent | Records user consent for the performance cookie category | 1 year | 1st-party |
| cookielawinfo-checkbox-advertisement | CookieYes / GDPR Cookie Consent | Records user consent for the advertising cookie category (no advertising cookies are set) | 1 year | 1st-party |
These cookies allow the Website to remember choices you have made and to provide enhanced features.
| Cookie name | Provider | Purpose | Duration | Party |
|---|---|---|---|---|
| __Secure-ROLLOUT_TOKEN | YouTube / Google LLC | Manages YouTube player feature rollout and playback session (set only when a page with an embedded YouTube video loads) | ~6 months | 3rd-party |
These cookies collect aggregated, mostly de-identified information about how visitors use the Website (pages visited, time on page, navigation paths, errors encountered). We use this information to understand and improve the Services.
Analytics providers: (1) Google LLC (Google Analytics 4) on oramavr.com — Property G-8G65EPRCR9; (2) HubSpot, Inc. on oramavr.com for CRM-integrated visitor tracking and form attribution. The ORamaVR Org-Admin Portal has no analytics provider deployed.
| Cookie name | Provider | Purpose | Duration | Party |
|---|---|---|---|---|
| _ga | Google LLC (Google Analytics 4) | Distinguishes unique users by assigning a randomly generated client ID | 2 years | 3rd-party |
| _ga_8G65EPRCR9 | Google LLC (Google Analytics 4) | Persists session state for the GA4 property G-8G65EPRCR9 | 2 years | 3rd-party |
| __hstc | HubSpot, Inc. | Tracks visitors for HubSpot analytics and form submissions (visitor identity, sessions, campaign source) | ~6 months | 3rd-party |
| hubspotutk | HubSpot, Inc. | Identifies unique visitors and links form submissions to the same contact record | ~6 months | 3rd-party |
ORamaVR does not use cookies for targeted advertising, behavioural advertising, advertising-network identifiers, ad-retargeting, ad-attribution, or sale of cookie-derived data to third parties for advertising purposes. The category is listed here for transparency to make the absence explicit. This position is consistent with Privacy Policy §3.6.
The VTC Platform consists of (a) web interfaces (the Org-Admin Portal and the customer portal) and (b) the in-headset XR runtime. The web interfaces use cookies in accordance with this Cookie Policy. The in-headset XR runtime does not use cookies. It uses local application storage, session tokens, and device-bound identifiers governed by the Privacy Policy and Exhibit C.
Where a third-party cookie processes Personal Data and that processing involves a transfer of Personal Data outside the EEA or Switzerland, the transfer is subject to the safeguards described in Privacy Policy §5.2, which include the 2021 EU Standard Contractual Clauses, Module Two (and, where applicable, the Swiss FDPIC supplemental clauses). The current third-party providers are also reflected at the Sub-processor List URL (oramavr.com/legal/sub-processors) where applicable.
6.1 Cookie preferences centre. You may set, review, or change your cookie preferences at any time through the cookie preferences centre at oramavr.com/legal/cookie-preferences (or via the persistent “Cookie Preferences” link in the Website footer). Changes take effect immediately.
6.2 Browser controls. Most browsers allow you to view, manage, and delete cookies stored on your device. If you set your browser to reject all cookies, parts of the Website and Services may not function correctly.
6.3 Effect of refusing non-essential cookies. If you refuse non-essential cookies, you can continue to use the Website and the Org-Admin Portal. Strictly Necessary cookies remain active in all cases.
6.4 Do Not Track and Global Privacy Control. ORamaVR honours the Global Privacy Control (GPC) signal; receipt of a GPC signal is treated as a withdrawal of consent for non-essential cookies for the relevant browsing session. ORamaVR does not currently honour the Do Not Track (DNT) signal as a stand-alone consent withdrawal mechanism, as DNT is no longer maintained as a standard.
In respect of Personal Data processed through cookies, you have the rights set out in Privacy Policy §8, including the rights of access, rectification, erasure, restriction, objection, data portability, withdrawal of consent, and the right to lodge a complaint with a supervisory authority (including the Swiss FDPIC). To exercise any right, contact the Data Protection Officer at dpo@oramavr.com.
ORamaVR may update this Cookie Policy from time to time. Where a change is material (addition of a new cookie category, a new third-party provider, or a new cross-border transfer mechanism), we will notify users by re-presenting the cookie consent banner and, where appropriate, by giving at least thirty (30) days' notice through the Website.
You may also lodge a complaint with the Swiss FDPIC at edoeb.admin.ch, or with the data protection supervisory authority of your country of habitual residence.
ORamaVR SA · CHE-478.871.980 · c/o FONGIT, Plan-les-Ouates, Geneva, Switzerland
ORM-COK-001 · Version 1.0 · oramavr.com/legal/cookie-policy