Cookie Policy

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TULPAR OÜ — Cookie Policy

· @Hasan AÇIKSARI

1. Introduction

1.1. This Cookie Policy explains how TULPAR OÜ, registry code 14927152, Estonia ("TULPAR", "we", "us"), uses cookies and similar technologies on https://tulparsoft.com and its subdomains, including the client portal (together, the "Website").

1.2. This Policy should be read together with our Privacy Policy, which describes how we process personal data, and applies to all visitors of the Website.

1.3. By setting your preferences in the cookie consent banner shown on your first visit, you choose which non-essential cookies we may use. You can change or withdraw your consent at any time as described in Section 6.

2. What Are Cookies

2.1. Cookies are small text files placed on your device (computer, tablet, phone) when you visit a website. They allow the website to recognize your device and remember information about your visit, such as your login session, language, or preferences.

2.2. We also use similar technologies — such as local storage, session storage, and pixels — which serve comparable purposes. In this Policy, "cookies" refers to all such technologies.

2.3. Cookies may be session cookies (deleted when you close your browser) or persistent cookies (stored for a defined period), and first-party cookies (set by us) or third-party cookies (set by other providers whose services we use).

3.1. We use cookies in accordance with the Estonian Electronic Communications Act (elektroonilise side seadus), implementing Directive 2002/58/EC (ePrivacy Directive), and — where cookies involve the processing of personal data — Regulation (EU) 2016/679 (GDPR).

3.2. Strictly necessary cookies are used without consent, as they are essential for providing the service you request (e.g., keeping you logged in to the client portal, security, load balancing).

3.3. All other cookies (preferences, statistics, marketing) are used only with your prior consent, given through the cookie consent banner. Consent is voluntary, and refusing non-essential cookies does not prevent you from using the Website.

3.4. Your consent choices are recorded and stored so that we can demonstrate compliance. You may withdraw consent at any time with effect for the future (Section 6).

4. Cookies We Use

The table below lists the cookies currently used on the Website. [Verify this table against the cookies actually set by the Website and the client portal before publishing.]

Cookie

Provider

Purpose

Duration

Category

session / auth cookie [●]

TULPAR (first-party)

Keeps you signed in to the client portal

Session

Strictly necessary

CSRF token [●]

TULPAR (first-party)

Security — prevents cross-site request forgery

Session

Strictly necessary

cookie_consent [●]

TULPAR (first-party)

Stores your cookie preferences

12 months

Strictly necessary

language / currency [●]

TULPAR (first-party)

Remembers interface language and currency

12 months

Preferences

__cf_bm / cf_clearance [●]

Cloudflare

Bot protection and security

30 minutes

Strictly necessary

_ga, ga* [●]

Google Analytics

Statistics — how visitors use the Website

up to 24 months

Statistics

Cookies in the "Strictly necessary" category are always active; all others load only after your consent.

5. Third-Party Cookies

5.1. Some cookies are set by third-party providers whose services are integrated into the Website (e.g., security/CDN providers, analytics, payment providers during checkout). These providers may process your data under their own privacy policies:

5.2. Where a third-party provider processes personal data outside the EU/EEA, transfers take place in accordance with Chapter V GDPR (adequacy decisions or standard contractual clauses).

5.3. We do not control third-party cookies; please review the respective providers' policies for details.

6.1. You can change or withdraw your cookie consent at any time via the "Cookie settings" link in the Website footer, which reopens the consent banner.

6.2. You can also control or delete cookies through your browser settings — block all cookies, delete existing ones, or receive a warning before a cookie is stored. Instructions: Chrome · Firefox · Safari · Edge

6.3. Blocking strictly necessary cookies may prevent parts of the Website — in particular the client portal — from functioning properly.

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

7. Changes and Contact

7.1. We may update this Cookie Policy from time to time, for example when we add or remove cookies or when the law changes. The current version, with its effective date, is always available on the Website; material changes will be highlighted via the consent banner.

7.2. Questions about this Policy or about how we process your personal data: TULPAR OÜ, registry code 14927152, Estonia · e-mail: [email protected].

7.3. You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or your local supervisory authority.

Version 1.2 — effective as of 01.09.2026.


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