SOLGREEN — Cookie Policy

Plain English: We use the smallest set of cookies that lets the site work. No advertising trackers, no analytics that follows you across the internet, no session-replay tools recording your clicks. The full list is in Section 3.

Last updated: 2026-05-07 Effective date: 2026-05-07

1. What Are Cookies?

Plain English: Cookies are tiny text files a website stores in your browser. They help the site remember things between page loads.

Cookies are small text files that websites place on your device when you visit. They allow the website to recognize your device and to remember information about your visit. Similar technologies — localStorage, sessionStorage, web beacons, pixels, and fingerprinting — perform comparable functions and are covered by this Policy.

This Policy supplements the Privacy Policy and should be read together with it.

2. Our Approach

Plain English: First-party only. No advertising. No cross-site tracking. No third-party analytics calling home.

• First-party only: All cookies on solgreen.ee are set by SOLGREEN on the solgreen.ee domain.
• No advertising: We do not run advertising on the Site, do not embed Meta Pixel / Google Ads / LinkedIn Insight, and do not build advertising audiences from your visit.
• No cross-site tracking: We do not embed third-party analytics scripts that profile you across sites (no Google Analytics, no Mixpanel, no Amplitude).
• No session replay: We do not record your screen or click stream.
• Granular consent: Where any cookie requires consent under ePrivacy Article 5(3), we obtain it before setting that cookie. Reject is as easy as Accept.
• Honest disclosure: This Policy lists every cookie we set and is reviewed on every site change.

3. Cookies We Set

Plain English: We currently set only the minimum cookies required to operate the Site. The list below is the full inventory.

No analytics, no marketing, no advertising cookies are set. If we ever introduce one, we will update this Policy and re-prompt for consent before any such cookie is set.

4. Categories Explained

Plain English: Cookies are grouped so you can accept or reject in batches instead of one-at-a-time.

4.1 Strictly Necessary

Essential for the Site to function (recording your consent, preventing CSRF). Not subject to consent under ePrivacy Article 5(3).

4.2 Preferences

Remember choices that change how the Site looks (theme). Not strictly necessary but minimally invasive. Set only when you make the relevant interaction.

4.3 Analytics

Not used. If we add a privacy-preserving analytics provider later, we will list it here and obtain consent before setting any cookie.

4.4 Marketing / Advertising

Not used. Will not be used. If this changes, this Policy will be updated and re-consent will be obtained.

5. Your Choices

Plain English: Three ways to manage cookies.

5.1 Cookie Preference Center

A persistent Cookie preferences / Küpsiste eelistused link in the Site footer re-opens our consent UI at any time. You can:

• Accept all categories
• Reject all non-necessary categories
• Toggle individual categories

Your choice is recorded in sg_consent. Clearing that cookie re-prompts on next visit.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before withdrawal.

5.2 Browser Settings

Block or delete cookies via your browser:

• Chrome
• Firefox
• Safari (macOS)
• Safari (iOS)
• Edge

Browser private / incognito modes also limit cookies to the session.

5.3 Global Privacy Control (GPC)

If your browser sends a Global Privacy Control signal, we treat it as:

• Withdrawal of consent for any non-essential cookie category we have or may add
• An opt-out of any "sale" or "sharing" of Personal Information for cross-context behavioral advertising under CCPA/CPRA (currently a no-op since we do not sell or share)

GPC is honored automatically — no further action required.

5.4 Do Not Track (DNT)

DNT is not standardized and not honored uniformly. We honor GPC instead.

6. Cookies and Vendors We Do NOT Use

Plain English: For transparency, here's a non-exhaustive list of common trackers we explicitly do not embed.

7. Engagement-Specific Cookies (Client Deliverables)

Plain English: When we build a website or product for a client, that product may use cookies set by the client (not us). Those are governed by the client's own privacy notice, not this one.

Where SOLGREEN builds and operates a website or product on behalf of a client, the cookies set by that product are governed by the client's privacy and cookie notices, not by this Policy. For products SOLGREEN operates as a processor for the client, see the DPA.

8. Cookie Inventory Maintenance

Plain English: Cookie disclosures rot. Ours is reviewed quarterly and on every site change.

• Cookie inventory reviewed quarterly by the engineering team
• Pre-merge check on PRs that add scripts or third-party embeds
• Live audit (browser DevTools) at least quarterly to confirm no unintended cookies
• This Policy is updated within 30 days of any material change to the cookie inventory

9. Children

Plain English: We don't direct the Site at children and we don't knowingly set cookies for users under 13 (or the local consent age).

The Site is not directed at children. We do not knowingly set cookies for users under 13 (the Estonian consent age) or 16 (where the local member-state age applies). If you believe we have inadvertently done so, contact privacy@solgreen.ee.

10. Changes to This Policy

Plain English: Material changes get 30 days' heads-up before they take effect.

For material changes (new cookie category, change of analytics provider, etc.) we will provide at least thirty (30) days' notice via a prominent banner on the Site and update the "Last updated" date at the top. Non-material changes (typos, clarifications) take effect on posting.

11. Contact

• Privacy / cookies: privacy@solgreen.ee
• Postal: SOLGREEN OÜ, Tartu mnt 67/1-13b, 10115 Tallinn, Estonia
• Estonian supervisory authority: Andmekaitse Inspektsioon (AKI)