1. WHAT ARE COOKIES?
Cookies are small text files that are placed on your device (computer, smartphone, or tablet) when you visit a website. Cookies help websites remember information about your visit, such as your preferences, login status, or items in a shopping cart.
Types of Cookies by Purpose:
- Essential Cookies: Necessary for the website to function properly
- Performance Cookies: Collect information about how visitors use the website
- Functionality Cookies: Remember your preferences and choices
- Targeting/Marketing Cookies: Track your online activity for advertising purposes
Types of Cookies by Duration:
- Session Cookies: Temporary cookies that expire when you close your browser
- Persistent Cookies: Remain on your device for a set period or until you delete them
Types of Cookies by Origin:
- First-Party Cookies: Set by the website you’re visiting (Paragon)
- Third-Party Cookies: Set by external services (e.g., Google Analytics)
2. COOKIES WE USE
Paragon uses the following categories of cookies on the Website:
- Targeting/Advertising Cookies: We do not use cookies for targeted advertising or retargeting
- Social Media Cookies: We do not embed social media tracking pixels or cookies
- Cross-Site Tracking: We do not track your activities across other websites
3. COOKIE CONSENT MECHANISM
3.1 Cookie Notice Plugin
We use the “Cookie Notice & Compliance for GDPR / CCPA” plugin created by hu-manity.co to manage cookie consent on our Website.
3.2 How the Cookie Banner Works
When you first visit our Website, you will see a cookie consent banner that:
- Clearly identifies which categories of cookies are used
- Distinguishes between essential and optional cookies
- Provides a brief description of each cookie category
- Allows you to accept all cookies, reject optional cookies, or customize your preferences
- Links to this detailed Cookie Policy
- Does NOT use pre-ticked boxes (you must actively consent)
3.3 Consent Requirements
Optional Cookies (Analytics): Only deployed AFTER you provide explicit consent through the cookie banner
3.4 Your Consent Choices
You have the following options:
- Accept All: Consent to all cookies (essential and optional)
- Reject Optional: Only essential cookies will be used
- Cookie Settings: Customize which optional cookie categories you consent to
4. HOW TO MANAGE COOKIES
4.1 Through Our Cookie Banner
You can manage your cookie preferences at any time by:
- Clicking the “Cookie Settings” link in the website footer
- Changing your consent preferences in the banner
- Saving your updated preferences
4.2 Through Your Browser Settings
All modern browsers allow you to control cookies through browser settings. You can:
- Block all cookies
- Block third-party cookies only
- Delete cookies after each browsing session
- Receive notifications before cookies are placed
Browser-Specific Instructions:
- Google Chrome: Settings → Privacy and security → Cookies and other site data
- Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
- Safari: Preferences → Privacy → Manage Website Data
- Microsoft Edge: Settings → Cookies and site permissions → Manage and delete cookies
- Opera: Settings → Privacy & Security → Cookies
For detailed instructions, visit your browser’s help section or:
4.3 Google Analytics Opt-Out
You can specifically opt out of Google Analytics tracking by:
- Rejecting analytics cookies through our cookie banner
- Installing the Google Analytics Opt-out Browser Add-on
4.4 Do Not Track (DNT) Signals
Some browsers support “Do Not Track” (DNT) signals. Currently, there is no universal standard for how websites should respond to DNT signals. We honor cookie preferences set through our cookie banner, which provides granular control over tracking.
5. OTHER TRACKING TECHNOLOGIES
5.1 Web Beacons / Pixels
We may use web beacons (also called “pixels” or “clear GIFs”) in conjunction with cookies. These are tiny graphics with unique identifiers that track user interactions. We currently use pixels for:
- Google Analytics page tracking
- Email newsletter open tracking (Mailchimp)
5.2 Local Storage
Our Website may use browser local storage (HTML5) to store non-sensitive data such as:
- Chatbot conversation state (temporary)
- User interface preferences
Local storage data is stored locally on your device and is not automatically transmitted to our servers.
5.3 Session Storage
Session storage is used to temporarily store data during your browsing session and is automatically deleted when you close your browser.
6. INTERNATIONAL DATA TRANSFERS
Cookies and USA Data Transfers
When you consent to Google Analytics cookies, data collected through these cookies is transferred to and processed by Google in the United States. This transfer is subject to:
- Standard Contractual Clauses (SCCs) between Paragon and Google
- Supplementary safeguards including encryption and data minimization
- Google’s Data Processing Agreement ensuring GDPR compliance
For more information about international data transfers, see our Privacy Policy, Section 5.2.
7. RETENTION OF COOKIE DATA
| Cookie Type | Retention Period | Deletion |
|---|---|---|
| Session Cookies | Until browser is closed | Automatic deletion |
| Essential Persistent Cookies | Up to 1 year | Automatic expiration or manual deletion |
| Google Analytics Cookies | Up to 2 years | Automatic expiration or manual deletion |
| Cookie Consent Record | 1 year | Automatic expiration or manual deletion |
8. YOUR GDPR RIGHTS REGARDING COOKIES
Under the GDPR, you have the following rights regarding data collected through cookies:
8.1 Right to Withdraw Consent
You can withdraw your consent to optional cookies at any time by:
- Clicking “Cookie Settings” in the website footer and changing your preferences
- Deleting cookies through your browser settings
- Contacting us at info@paragonagency.com
Note: Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
8.2 Right of Access
You have the right to request information about:
- What cookies are stored on your device
- What data has been collected through cookies
- How cookie data has been processed
8.3 Right to Erasure
You can request deletion of data collected through cookies by:
- Clearing cookies through your browser
- Contacting us to delete server-side analytics data
8.4 Right to Object
You have the right to object to cookie-based processing by:
- Rejecting optional cookies through our banner
- Blocking cookies in your browser settings
8.5 Right to Lodge a Complaint
If you believe our cookie practices violate GDPR, you may lodge a complaint with:
Address: Väike-Ameerika 19, 10130 Tallinn, Estonia
Email: info@aki.ee
Phone: +372 605 6000
Website: https://www.aki.ee/en
9. COOKIES AND CHILDREN
Our Website is not directed to children under the age of 16. We do not knowingly collect data from children through cookies or any other means. If you believe a child has provided cookie data, please contact us immediately at info@paragonagency.com.
10. THIRD-PARTY COOKIES
10.1 Google Analytics
Google Analytics is our primary third-party cookie provider. Google may use cookie data for:
- Providing analytics services to us
- Improving Google’s own services
- Contextualizing and personalizing ads in Google’s advertising network (if you haven’t opted out)
Google’s Use of Data: For information about how Google uses data collected through cookies, see:
10.2 Mailchimp
If you subscribe to our newsletter, Mailchimp may place cookies when you open emails or click links. These cookies are subject to Mailchimp’s privacy policy:
10.3 No Other Third-Party Cookies
We do NOT use cookies from:
- Social media platforms (Facebook, Twitter, LinkedIn tracking pixels)
- Advertising networks (beyond Google Analytics)
- Data brokers or marketing aggregators
- Cross-site tracking services
11. SECURITY OF COOKIE DATA
We implement appropriate security measures to protect data collected through cookies:
- Encryption: All cookie data transmitted between your browser and our servers is encrypted using TLS 1.3
- Secure Flag: Essential cookies use the “Secure” flag to ensure transmission only over HTTPS
- HttpOnly Flag: Session cookies use the “HttpOnly” flag to prevent JavaScript access and XSS attacks
- SameSite Attribute: Cookies use SameSite attributes to prevent cross-site request forgery (CSRF)
- Access Controls: Server-side cookie data is protected by role-based access controls
12. COOKIE POLICY UPDATES
We may update this Cookie Policy from time to time to reflect:
- Changes in cookie usage or tracking technologies
- Changes in legal or regulatory requirements
- New features or services requiring cookies
- Feedback from users or data protection authorities
Notification of Changes
When we make material changes to this Cookie Policy, we will:
- Update the “Last Updated” date at the top of this policy
- Display a notice in the cookie banner
- Request renewed consent for any new cookie categories (if required)
- Notify newsletter subscribers via email (for significant changes)
We encourage you to review this Cookie Policy periodically.
13. LEGAL BASIS FOR COOKIES
| Cookie Category | Legal Basis | GDPR Article |
|---|---|---|
| Strictly Necessary / Essential | Legitimate Interest / Contract Performance | Article 6(1)(b) and (f) |
| Performance / Analytics | Consent | Article 6(1)(a) |
| Functionality | Consent | Article 6(1)(a) |
| Targeting / Marketing | Not Used | N/A |
14. EPRIVACY DIRECTIVE COMPLIANCE
In addition to GDPR compliance, our cookie practices comply with the ePrivacy Directive (Directive 2002/58/EC as amended by Directive 2009/136/EC), which specifically governs cookies and electronic communications in the EU.
Key ePrivacy Requirements We Follow:
- Prior Consent: We obtain consent BEFORE deploying non-essential cookies
- Clear Information: We provide clear, comprehensive information about cookies
- Easy Withdrawal: Users can easily withdraw consent at any time
- Essential Cookie Exception: We only deploy essential cookies without consent
15. FREQUENTLY ASKED QUESTIONS (FAQ)
Q: Can I use the Website without accepting cookies?
A: Yes, you can use most of the Website with only essential cookies. However, some features (like the Chatbot) require essential session cookies to function. You can reject all optional (analytics) cookies and still access most content.
Q: How long do you keep my cookie consent preferences?
A: Your consent preferences are stored for 1 year. After this period, you will be asked to provide consent again when you visit the Website.
Q: Can I change my cookie preferences after I’ve accepted them?
A: Yes, you can change your preferences at any time by clicking “Cookie Settings” in the website footer.
Q: Do you use cookies for advertising?
A: No, we do not use cookies for targeted advertising, retargeting, or ad personalization. We only use Google Analytics for website performance monitoring.
Q: Are cookies the same as malware or viruses?
A: No, cookies are simple text files and cannot execute code, install software, or harm your device. They are a standard web technology used for website functionality and analytics.
Q: What happens if I delete all cookies?
A: If you delete cookies:
- You will need to provide cookie consent again
- Your Chatbot conversation state may be lost
- You may need to log in again (if applicable)
- Your preferences may be reset
Q: Do you share cookie data with third parties?
A: Cookie data is only shared with service providers who help us operate the Website (Google Analytics). We do not sell or share cookie data with advertisers or data brokers.
Q: How do I know which cookies are on my device right now?
A: You can view cookies in your browser settings:
- Chrome: Settings → Privacy and security → Cookies → See all site data and permissions
- Firefox: Settings → Privacy & Security → Cookies and Site Data → Manage Data
- Safari: Preferences → Privacy → Manage Website Data
16. CONTACT INFORMATION
If you have questions about this Cookie Policy or our cookie practices, please contact us:
Registration Number: 16800099
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145, Estonia
Email: info@paragonagency.com
Website: www.paragonagency.com
For Cookie-Specific Inquiries:
Email Subject: “Cookie Policy Inquiry”
Data Protection Authority:
Address: Väike-Ameerika 19, 10130 Tallinn, Estonia
Email: info@aki.ee
Phone: +372 605 6000
Website: https://www.aki.ee/en
17. COOKIE SUMMARY TABLE
| Cookie | Category | Purpose | Duration | Consent Required |
|---|---|---|---|---|
| PHPSESSID | Essential | Session management | Session | No |
| wordpress_* | Essential | Authentication | Session/14 days | No |
| wp-settings-* | Essential | User preferences | 1 year | No |
| cookie_notice_accepted | Essential | Cookie consent record | 1 year | No |
| _ga | Analytics | User identification | 2 years | Yes |
| _ga_* | Analytics | Session persistence (GA4) | 2 years | Yes |
| _gid | Analytics | User identification (24h) | 24 hours | Yes |
| _gat | Analytics | Request rate throttling | 1 minute | Yes |
- We use essential cookies for website functionality (no consent required)
- We use Google Analytics cookies ONLY with your consent
- We do NOT use advertising or social media tracking cookies
- You can manage cookies through our banner or browser settings
- Cookie data transferred to USA is protected by Standard Contractual Clauses
- You can withdraw consent at any time
Version 1.0 (October 7, 2025): Initial GDPR-compliant Cookie Policy
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