Terms & Conditions

1. CORPORATE INFORMATION AND WEBSITE OWNER

1.1 Company Details

The Latin American Digital Transformation Center (CLTD) and this website, located at solomonbrokerage.com (hereinafter, the “Website”), is owned and operated by Solomon Brokerage OÜ (hereinafter, “SOLOMON,” “we,” “us,” or “our”), a company incorporated and registered under the laws of Estonia.

• Legal Name: Solomon Brokerage OÜ.
• Company Registration No.: 16253938
• Legal Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.
• Principal Place of Business: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.
• Email: info@solomonbrokerage.com.
• Website: https://solomonbrokerage.com.
• Telephone: +372 5332 9390

1.2 Regulatory Authority

SOLOMON BROKERAGE OÜ is a limited liability company  established and operating in Tallinn, Estonia, under the regulatory framework of the Estonian federal law. The company complies with the following regulatory authorities and legal frameworks:

1.2.1 Primary Regulatory Bodies

1. Estonian Business Register (Centre of Registers and Information Systems – Registrite ja Infosüsteemide Keskus) – National Authority

• Issues, renews, and maintains the company’s business registration and identification number
• Approves business activities and trade name registration
• Monitors ongoing compliance with business registration requirements

2. Estonian Tax and Customs Board (EMTA) – National Authority

• Oversees corporate income tax registration and compliance
• Manages VAT registration (mandatory based on €40,000 annual turnover threshold)
• Enforces tax reporting requirements under the Estonian Tax Act and VAT Act

3. Ministry of Economic Affairs and Communications & Consumer Protection and Technical Regulatory Authority – National Authority

• Sets standards for consumer protection and fair business practices
• Oversees compliance with consumer protection laws
• Regulates commercial transactions and contractual obligations

1.2.2 Data Protection and Privacy Compliance

The company complies with the General Data Protection Regulation (GDPR) (Regulation EU 2016/679) as implemented in Estonia through the Personal Data Protection Act, which governs:

• Collection, processing, and storage of personal data
• Consent requirements for data processing
• Data security and breach notification obligations
• Rights of data subjects including access, correction, and deletion

1.2.3 Applicable Legal Framework

All services, contracts, and operations are governed by:

• Estonian Commercial Code
• Law of Obligations Act
• General Part of the Civil Code provisions applicable to business transactions
• Consumer Protection Act provisions applicable to consulting services
• Value Added Tax (VAT) Act (standard rate 24%)

1.2.5 Regulatory Compliance and Oversight

The company maintains:

• Active business registration with the Estonian Business Register
• Proper financial records and accounting systems compliant with Estonian accounting standards
• Regular compliance reviews with applicable regulatory requirements
• Professional liability insurance where required

Non-compliance with these regulations may result in penalties, license suspension, or legal action by the respective authorities.

2. ACCEPTANCE OF TERMS AND CONDITIONS

2.1 Binding Agreement

By accessing, browsing, or using this Website in any manner—including but not limited to viewing pages, downloading content, submitting forms, requesting quotes, or engaging with any services—you (“User,” “you,” or “your”) acknowledge that you have:

• Read and understood these Terms and Conditions in their entirety.
• Read and understood our Privacy Policy (available at https://solomonbrokerage.com/privacy).
• Read and understood our Cookies Policy (available at https://solomonbrokerage.com/privacycookies).
• Agreed to be legally bound by all provisions contained herein.

2.2 Refusal of Terms

If you do not agree with any part of these Terms and Conditions, the Privacy Policy, or the Cookies Policy, you must immediately cease all use of the Website. Continued use of the Website following any non-agreement constitutes acceptance of these terms.

2.3 Age and Capacity

By using this Website, you represent and warrant that you are:

• At least 18 years of age or the age of majority in your jurisdiction.
• Legally capable of entering into binding contracts.
• Acting on your own behalf or with proper authorization to act on behalf of an organization.

2.4 Modifications to Terms

SOLOMON reserves the right to modify, amend, or update these Terms and Conditions at any time. Material changes will be posted on this page with an updated “Last Updated” date. For significant changes affecting your rights or obligations, SOLOMON will provide thirty (30) calendar days’ prior written notice via email to the address you have provided or by prominent notice on the Website.

Your continued use of the Website following the publication of revised Terms and Conditions constitutes your acceptance of such revisions. If you do not accept revised terms, you must immediately discontinue use of the Website.

3. DESCRIPTION OF SERVICES

3.1 Service Overview

SOLOMON is a specialized wholesale trading, technology transfer and business consultancy firm providing comprehensive services to organizations globally. The company offers expert guidance across the following core service areas:

3.1.1 Business Consulting & Strategic Advisory Services

SOLOMON delivers comprehensive business advisory services, including:

• Management Consulting: Organizational structure optimization, management system design, and leadership advisory to support operational efficiency and strategic growth.
• Business Process Improvement: Process mapping, workflow optimization, and operational efficiency assessments to reduce costs and improve service delivery.
• Strategic Planning & Development: Market analysis, competitive positioning, growth strategy formulation, and long-term business planning aligned with client objectives.
• Organizational Restructuring: Advisory on organizational design, roles and responsibilities clarification, and structural optimization to enhance performance.
• Business Performance Analysis: Key performance indicator (KPI) development, operational metrics assessment, and performance improvement roadmaps.

Regulatory Alignment: All advisory services comply with Estonia’s Civil Code  and corporate governance best practices recognized in Estonia and the broader European Union (EU) market.

3.1.2 Information Technology Consultancy

SOLOMON provides full-spectrum IT advisory services including:

• Technology Strategy & Digital Transformation: IT roadmap development, digital transformation planning, and technology adoption strategy aligned with business objectives.
• Systems Consulting & Architecture: Enterprise systems analysis, cloud migration planning, legacy system modernization, and IT infrastructure design recommendations
• IT Infrastructure Planning: Network design, cybersecurity framework assessment, and IT infrastructure recommendations for organizational resilience.
• Digital Solutions Advisory: Guidance on enterprise software selection, implementation planning, and digital tool optimization.
• Remote Delivery Model: All IT consultancy services can be delivered remotely without geographic limitations, utilizing secure communication and digital collaboration tools compliant with Estonian data protection standards.

Regulatory Compliance: Services comply with Ministry of Economic Affairs and Communications & Consumer Protection and Technical Regulatory Authority, and the General Data Protection Regulation (GDPR) (Regulation EU 2016/679) as implemented in Estonia through the Personal Data Protection Act, in relation to  cybersecurity best practices, and electronic transactions regulations.

3.1.3 Business & Startup Support Services

SOLOMON supports emerging businesses and startups through:

• Startup Advisory & Business Planning: Comprehensive business plan development, market entry strategy, and operational roadmap creation for new ventures.
• Operational Excellence Guidance: Startup infrastructure, operational process design, compliance framework establishment, and scalability planning.
• Market Positioning & Growth Strategy: Competitive analysis, market opportunity assessment, and growth acceleration planning leveraging partner expertise.
• Procurement & Vendor Management Advisory: Guidance on vendor selection, procurement strategy, and supply chain setup for emerging operations.

Partnerships & Support: Services leverage the combined expertise of SOLOMON’s founding partners in operations, procurement, and strategic development to accelerate business maturity and market positioning.

3.1.4 Procurement & Supply Chain Advisory

SOLOMON provides specialized guidance in procurement strategy and supply chain management including:

• Procurement Strategy Development: Vendor evaluation frameworks, procurement process design, and cost optimization strategies.
• Supply Chain Optimization: Supply chain mapping, bottleneck identification, logistics efficiency improvements, and supplier relationship optimization.
• Vendor Management & Selection: Vendor qualification criteria development, contract negotiation guidance, and supplier performance management.
• Sustainability & Compliance in Procurement: Guidance on ethical sourcing, compliance with EStonia and the EU procurement regulations, and sustainable vendor selection
• Risk Management in Supply Chain: Supply chain risk assessment, contingency planning, and resilience strategy development.

Regulatory Framework: All procurement advisory aligns with Estonian business law, ethical procurement practices, and international supply chain standards.

3.2 Service Nature and Scope

Services offered by SOLOMON are consulting, advisory, technology transfer, wholesale trading, and commercial brokerage services. The company provides:

• Professional Assessment & Analysis: Technical assessments, business process analysis, market studies, and feasibility recommendations based on current market conditions and regulatory environments.
• Strategic Guidance & Planning: Strategic recommendations, operational roadmaps, and implementation frameworks to support client decision-making.
• Expert Advisory & Facilitation: Subject matter expertise, regulatory compliance guidance, and facilitation of client strategic initiatives.
• Interim Support & Advisory: Time-bound consulting engagements delivering targeted expertise for specific business challenges or opportunities.

Important Notice on Service Limitations:

SOLOMON does not provide direct implementation, execution, construction, installation, or operational management services unless explicitly contracted in a separate statement of work. Services are limited to advisory, assessment, planning, and strategic guidance. Client organizations remain responsible for:

• Final decision-making and business strategy implementation.
• Execution of recommended solutions and operational changes.
• Procurement and vendor management (except where specifically contracted).
• Regulatory approvals and licensing procedures.
• All financial, legal, and compliance obligations.

3.3 Service Delivery and Timeline

• Engagement Duration: Consulting engagements may be structured as short-term advisory assignments, project-based consulting, or ongoing advisory relationships, as mutually agreed.
• Deliverables: Deliverables are defined in individual statements of work and may include reports, recommendations, frameworks, roadmaps, presentations, and strategic documentation.
• Accessibility & Availability: Services are subject to the availability of qualified personnel, resources, and market conditions. SOLOMON operates from Tallinn with the ability to serve clients throughout Estonia, the EU, and beyond through in-person meetings and remote delivery.
• Professional Standards: All services are delivered in accordance with international consulting standards and best practices recognized in the Estonian and the EU business environment.

3.4 Service Limitations and Disclaimers

• SOLOMON does not provide direct construction, installation, or project implementation services unless explicitly contracted.
• SOLOMON does not guarantee the approval of any project by Mexico, Latin America, Middle East countries, or international regulatory authorities.
• SOLOMON does not guarantee the availability or terms of financing through any third party.
• Services are subject to the availability of qualified personnel and market conditions.

SOLOMON explicitly disclaims responsibility for:

3.4.1 Implementation and Execution

• SOLOMON does not execute, implement, or directly manage recommended solutions unless explicitly contracted for project management services.
• Client organizations are responsible for all implementation decisions, execution timelines, and operational deployment.
• Recommendations are advisory in nature; actual outcomes depend on client execution quality and market conditions.

3.4.2 Regulatory Approvals and Licensing

• SOLOMON does not guarantee approval of client initiatives by any regulatory authority, including Estonia, the EU, Mexico’s, the UAE’s or Saudi Arabia’s authorities, or any other government agency.
• Regulatory approval processes depend on client submissions, regulatory body discretion, and evolving regulatory requirements.
• SOLOMON provides guidance on regulatory compliance requirements at the time of service delivery; regulatory requirements may change subsequently.

3.4.3 Financing and Third-Party Arrangements

• SOLOMON does not guarantee access to, availability of, or terms of financing from any third-party financial institution, development bank, or investor.
• Financing success depends on financial institutions’ independent assessment, market conditions, and client creditworthiness.
• Where SOLOMON facilitates introductions or financing partnerships, such arrangements are subject to third-party approval and terms.

3.4.4 Market Conditions and External Factors

• Services are provided based on market information, regulatory environments, and conditions existing at the time of service delivery.
• Market conditions, regulatory environments, and economic factors may change, affecting the validity of recommendations.
• SOLOMON does not guarantee continued accuracy of assessments if significant market or regulatory changes occur after service completion.

3.4.5 Client Implementation Success

• Successful outcomes depend on client organizational commitment, quality of implementation, market conditions, and factors outside SOLOMON ’s control.
• SOLOMON provides expert guidance and recommendations but does not control client execution or operational outcomes.

3.4.6 Personnel and Resource Availability

• Services are contingent on the availability of qualified consulting personnel and resources.
• In the event of resource constraints, SOLOMON may recommend engagement delays or alternative engagement structures.

3.5 Service Engagement Process

3.5.1 Initial Consultation

Client organizations may request an initial consultation to discuss business challenges, objectives, and potential engagement scope.

3.5.2 Statement of Work

Formal consulting engagements require a mutually agreed Statement of Work defining:

• Scope of work and specific deliverables.
• Engagement timeline and milestones.
• Fees and payment terms.
• Deliverable specifications and acceptance criteria.
• Confidentiality and data protection requirements.

3.5.3 Engagement Conduct

• Consulting engagements are conducted with professional diligence in accordance with international consulting standards.
• Client organizations shall provide reasonable access to information, personnel, and systems necessary for service delivery.
• Both parties shall maintain confidentiality of sensitive business information shared during the engagement.

3.5.4 Termination and Disengagement

Consulting engagements may be terminated by either party per the terms specified in the Statement of Work or these Terms and Conditions, with notice as defined in the engagement agreement.

3.6 Regulatory Compliance Framework

SOLOMON ’s consulting services comply with:

• Law of Obligations Act (Kohustuste Seadus): Ensures fair, transparent, and ethical service delivery to all clients, including consumer protection standards and requirements for traders providing consulting services.
• Consumer Protection Act (Tarbijakaitse Seadus): Ensures fair, transparent service delivery.
• General Data Protection Regulation (GDPR) (Regulation EU 2016/679) and Personal Data Protection Act (Isikuandmete Kaitse Seadus): Protects client and third-party personal data processed during consulting engagements, with data subject rights including access, correction, and deletion.
• Professional Standards: International best practices including:
  • International Standards on Auditing (ISA)
  • International Code of Ethics for Professional Accountants
  • International Standards on Quality Management (ISQM)
  • Association of Estonian Accountants (ERK) Quality Standards for professional service delivery
  • Estonian Accounting Act standards and regulations for transparent financial record-keeping and professional conduct

4. INTELLECTUAL PROPERTY RIGHTS

4.1 SOLOMON’s Intellectual Property

All original content published on the Website, including but not limited to text, graphics, logos, photographs, project portfolios, technical brochures, software code, databases, research reports, and multimedia content (collectively, “Content”), is the exclusive property of SOLOMON or is licensed to SOLOMON by its partners, and is protected by:

• Estonia’s and the European Union’s copyright law.
• International copyright treaties (Berne Convention, TRIPS Agreement).
• Patent laws of Estonia, the EU, and applicable jurisdictions.
• Trademark and design registration laws.

4.2 User Restrictions

Except as expressly permitted herein, users are strictly prohibited from:

• Reproducing, copying, or downloading any Content without prior written consent.
• Distributing, transmitting, or displaying Content to third parties.
• Modifying, adapting, translating, or creating derivative works from Content.
• Using Content for any commercial, competitive, or unauthorized purpose.
• Removing, obscuring, or altering any copyright notices, trademarks, or proprietary markings.
• Reverse-engineering, decompiling, or attempting to derive source code from any software provided.
• Using Content in any manner that violates these Terms and Conditions.

4.3 Limited License

SOLOMON grants users a non-exclusive, non-transferable, revocable license to view and download Content solely for:

• Personal, non-commercial use.
• Internal business evaluation (if you are a prospective client).
• Academic or research purposes with proper attribution to SOLOMON .

This license terminates immediately upon violation of these Terms and Conditions or upon termination of your use of the Website.

4.4 Third-Party and Partner Content

Certain Content on the Website may originate from or reference SOLOMON ’s strategic partners, including but not limited to:

• The Solomon Brokerage Firm.
• QBRI.Digital.
• Quantum Brain Research Institute.
• Latin American Digital Transformation Center (CLTD).
• Euro Trade Summit.

4.4.1 Partner Content Rights

SOLOMON warrants that it possesses the right to publish and display partner-provided content, including technical specifications, project descriptions, case studies, and branding materials. Users acknowledge that some content may be protected by the intellectual property rights of SOLOMON’s partners.

4.4.2 Third-Party Imagery

Content on the Website may include photographs and descriptions of projects. SOLOMON either:

• Owns or has licensed the right to use such imagery, OR
• Uses such imagery under fair use or public domain provisions.

Users may not reproduce, distribute, or repurpose such imagery without express written consent from SOLOMON.

4.5 Trademark Rights

The SOLOMON name, logo, and any other SOLOMON trademarks, service marks, or trade dress are the exclusive property of SOLOMON and may not be used without prior written authorization.

4.6 User-Generated Content

If users submit content to SOLOMON (including inquiries, feedback, testimonials, or suggestions), users grant SOLOMON a non-exclusive, royalty-free, perpetual license to use, reproduce, modify, and publicly display such content for business purposes, including marketing, without additional compensation or attribution.

5. STRATEGIC ALLIANCES AND THIRD-PARTY LINKS

5.1 Partner Network

SOLOMON operates through a global network of strategic partners to enhance service delivery, enable technology transfer, and facilitate specialized advisory and financing solutions. Key partners include:

5.2 Third-Party Services and Limitations

SOLOMON partners with the organizations listed in Section 5.1 to provide supplementary expertise, technology transfer, and service delivery capabilities. The following terms govern these partner relationships:

5.2.1 Partner Independence

Strategic partners are independent third parties and are not employees, agents, or representatives of SOLOMON. Each partner operates under its own terms, conditions, and regulatory framework. SOLOMON does not control partner operations, business practices, or service delivery standards except as expressly defined in mutual partnership agreements.

5.2.2 Partner Service Limitations

SOLOMON does not guarantee:

• The continued availability or engagement of any strategic partner.
• Specific service levels, timelines, or outcomes from partner organizations.
• Partner compliance with any particular regulatory framework outside their own jurisdiction.
• Partner financial stability, creditworthiness, or continued operations.
• Partner service quality, professional standards, or performance metrics.

5.2.3 Client Responsibility and Due Diligence

Client organizations engaging with SOLOMON partners do so at their own risk and discretion. SOLOMON recommends that clients conduct independent due diligence on any partner organization, including verification of credentials, regulatory status, financial stability, and service capabilities. SOLOMON ’s recommendation or introduction of a partner does not constitute an endorsement of the partner’s reliability or qualifications.

5.2.4 Regulatory Compliance of Partners

While SOLOMON ensures its own compliance with Estonian regulations, individual partners operate under the regulatory frameworks of their respective jurisdictions (United States, Latin America, Middle East, or Europe). Clients shall be responsible for ensuring that any engagement with a partner complies with applicable laws in the client’s jurisdiction and the partner’s jurisdiction.

5.2.5 Data Protection and Information Sharing with Partners

SOLOMON may share client information with strategic partners as necessary to deliver consulting services. By engaging SOLOMON services, clients consent to reasonable information sharing with qualified partners on a need-to-know basis. Such sharing shall comply with:

• General Data Protection Regulation (GDPR) (Regulation EU 2016/679) requirements where applicable (for European partners).
• Personal Data Protection Act (Isikuandmete Kaitse Seadus).
• Applicable data protection laws in partner jurisdictions.
• Confidentiality obligations defined in SOLOMON ’s engagement agreement.

SOLOMON shall ensure that all partners execute appropriate data protection agreements, confidentiality obligations, and comply with information security standards before sharing sensitive client data.

5.2.6 Limitation of Liability for Partner Services

SOLOMON ’s liability for partner service delivery is limited as follows:

• SOLOMON is responsible for vetting and selecting qualified partners in good faith.
• SOLOMON is not liable for partner misconduct, negligence, breach of contract, or failure to deliver services unless such failure results directly from SOLOMON ’s gross negligence in partner selection.
• Disputes arising from partner service delivery shall be resolved between the client and the partner organization, not with SOLOMON .
• SOLOMON ’s liability cap (as defined in Section 9 of these Terms) does not extend to partner service failures unless SOLOMON is directly responsible for the partner’s performance.

5.2.7 Partner Service Engagement

If a client chooses to engage directly with a SOLOMON partner:

• The client agrees to contract directly with the partner under the partner’s own terms and conditions
• SOLOMON is not responsible for negotiations, service delivery, or disputes between the client and the partner
• SOLOMON may facilitate introductions but assumes no responsibility for the partner’s performance
• All partner engagements are conducted at the client’s sole risk and discretion

5.2.8 No Exclusivity

SOLOMON ’s partnerships are non-exclusive. SOLOMON may work with competing organizations and may recommend alternative providers when appropriate to serve client needs. Clients should not assume exclusive partnership arrangements unless expressly agreed in writing.

5.2 Partner Content and Endorsement Disclaimer

SOLOMON provides information regarding its partners to facilitate knowledge transfer and infrastructure development. SOLOMON does not represent that:

• Partner services are guaranteed to be available, of high quality, or legally compliant in all jurisdictions.
• Partners are licensed, certified, or authorized to operate in all markets.
• Partners will perform services as described or promised.
• SOLOMON endorses or guarantees the financial stability, legal compliance, or ethical conduct of any partner.

Users engaging with partner services do so at their own risk and assume all liability for due diligence regarding partner qualifications and performance.

5.3 External Links

The Website may contain hyperlinks to third-party websites, digital platforms, and resources operated by partners or unaffiliated third parties, including:

• Partner websites and digital storefronts.
• CLTD News and publications.
• Euro Trade Summit platforms.
• Government regulatory databases.
• Industry publications and resources.

5.4 Third-Party Website Disclaimer

SOLOMON is not responsible for the content, accuracy, completeness, legality, privacy practices, security measures, or operational status of any third-party website. The inclusion of links does not constitute endorsement, affiliation, or approval of the linked website or its operators.

Users accessing third-party websites do so at their own risk and are subject to the terms and conditions and privacy policies of such websites. SOLOMON strongly recommends that users review the terms, privacy policies, and security practices of any third-party website before providing personal or financial information.

5.5 Data Sharing with Partners

SOLOMON may share limited user information (name, email, contact preferences) with strategic partners solely to:

• Facilitate requested consulting services.
• Provide relevant industry updates and newsletters.
• Connect users with appropriate financing or technology partners.

Users will be notified of data sharing via our Privacy Policy. Users may opt out of partner communications at any time by selecting “unsubscribe” in any communication or contacting SOLOMON directly.

6. USER CONDUCT AND OBLIGATIONS

6.1 Lawful Use

Users agree to use the Website solely for lawful purposes in compliance with all applicable laws and regulations of:

• Estonia.
• The user’s country or jurisdiction of residence.
• International laws governing e-commerce, data protection, and intellectual property.

6.2 Prohibited Conduct

Users are strictly prohibited from:

6.2.1 Illegal Activities

• Using the Website to facilitate illegal activities, fraud, or deception.
• Violating applicable securities, export control, sanctions, or anti-corruption laws.
• Money laundering or financing of illegal activities
• Trafficking in contraband, controlled substances, or illegal goods.

6.2.2 Interference and Security

• Attempting to gain unauthorized access to any part of the Website, server, or database.
• Disrupting, overloading, or “flooding” the Website with requests (Denial of Service attacks).
• Installing malware, viruses, worms, or other malicious code.
• Attempting to reverse-engineer, decompile, or discover source code.
• Exploiting security vulnerabilities or reporting them to third parties without SOLOMON’s notification.

6.2.3 Spam and Unsolicited Communications

• Sending unsolicited commercial communications, advertisements, or promotional materials.
• Harvesting, scraping, or automatically collecting email addresses or user data.
• Engaging in “phishing” or social engineering to deceive users or SOLOMON staff.
• Posting repeated messages (flooding).

6.2.4 Misrepresentation

• Falsifying identity, company affiliation, or credentials when requesting quotes or engaging with SOLOMON.
• Impersonating SOLOMON staff or partners.
• Misrepresenting your authority to enter into contracts on behalf of an organization.
• Providing false, incomplete, or misleading contact information.

6.2.5 Defamation and Abuse

• Publishing defamatory, libelous, slanderous, or false statements about SOLOMON, its partners, or staff.
• Harassing, threatening, or abusing SOLOMON staff or other users.
• Publishing hate speech, discriminatory content, or content that incites violence.

6.3 Monitoring and Enforcement

SOLOMON reserves the right to:

• Monitor user activity for compliance with these Terms and Conditions.
• Investigate suspected violations.
• Restrict or terminate access to the Website for violations.
• Preserve and disclose user information to law enforcement when legally required.

Users waive any expectation of privacy regarding Website activity monitoring.

6.4 User Liability

Users assume full liability for any violations of these Terms and Conditions and agree to indemnify and hold harmless SOLOMON, its officers, employees, and agents from any claims, damages, losses, or expenses (including legal fees) arising from:

• User violation of these Terms and Conditions.
• User’s use of the Website.
• User-provided content or information.
• User’s infringement of third-party intellectual property rights.

7. PRIVACY AND DATA PROTECTION

7.1 Privacy Policy Integration

SOLOMON is committed to protecting user privacy in compliance with:

• Estonia’s data protection principles.
• The General Data Protection Regulation (GDPR) for users in the European Union.
• The Lei Geral de Proteção de Dados Pessoais (LGPD) for users in Brazil.
• The California Consumer Privacy Act (CCPA) for users in California, USA.
• General international data protection best practices in Mexico, Latin America, and the Middle East.

A complete Privacy Policy is available at https://solomonbrokerage.com/privacy and is incorporated by reference into these Terms and Conditions.

7.2 Data Collection

SOLOMON collects personal data from users through:

7.2.1 Contact Forms

• Name, Email Address, Phone Number.
• Company/Organization Name (if applicable).
• Service Inquiry Details and Project Description.
• Preferred Method of Contact.

7.2.2 Email Communications

• Government-issued identification for KYC compliance.
• Email address, subject matter, and content of inquiries.
• Engagement with newsletter subscriptions.
• Opt-out preferences.

7.2.3 Website Analytics

• IP address (anonymized).
• Browser type and version.
• Operating system.
• Pages visited and time spent.
• Referral source.
• Device information (with user consent via cookies).

7.2.4 Cookies and Tracking Technologies

• Session cookies (essential for Website functionality).
• Analytical cookies (Google Analytics, with user consent).
• Marketing cookies (third-party advertising platforms, with explicit user consent).

See Section 9 for complete Cookies Policy details.

7.3 Use of Personal Data

SOLOMON uses personal data solely for the following purposes:

7.4 GDPR Compliance (European Union Users)

For users located in the European Union, SOLOMON complies with the General Data Protection Regulation (GDPR) and provides the following rights:

7.4.1 User Rights Under GDPR

• Right of Access: You may request a copy of personal data SOLOMON holds about you.
• Right to Correction: You may request correction of inaccurate or incomplete data.
• Right to Erasure (“Right to Be Forgotten”): You may request deletion of your personal data, subject to legal retention requirements.
• Right to Data Portability: You may request your data in a structured, machine-readable format.
• Right to Restrict Processing: You may restrict SOLOMON’s use of your data pending resolution of disputes.
• Right to Object: You may object to marketing or profiling activities.
• Right to Withdraw Consent: You may withdraw consent for data processing at any time.
• Rights Related to Automated Decision-Making: You may object to decisions based solely on automated processing.

7.4.2 Exercising GDPR Rights

To exercise any of the above rights, submit a written request to:

• Email: info@solomonbrokerage.com.
• Physical Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.
• Subject Line: “GDPR Data Request”.

SOLOMON will respond within ten (10) business days for standard requests, and thirty (30) calendar days (or forty-five (45) days for complex requests, with notice of extension).

7.4.3 Data Processing Agreement

For users or organizations in the EU engaging SOLOMON for consulting services, SOLOMON offers a Data Processing Agreement (DPA) compliant with GDPR Article 28. Organizations may request a DPA by contacting info@solomonbrokerage.com.

7.4.4 International Data Transfers

SOLOMON may transfer personal data from the EU to countries in Mexico, Latin America, and the Middle East for processing. Such transfers are made under appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) as approved by the European Commission.
• Binding Corporate Rules (if applicable).
• Your explicit informed consent.

7.5 LGPD Compliance (Brazil Users)

For users located in Brazil, SOLOMON complies with the Lei Geral de Proteção de Dados Pessoais (LGPD) and recognizes users’ rights to:

• Access personal data held by SOLOMON.
• Request correction of inaccurate data.
• Request deletion of data (subject to legal obligations).
• Obtain information about data processing and third-party sharing.
• Opt out of certain processing activities.

Requests should be submitted to info@solomonbrokerage.com with the subject line “LGPD Data Request.”

7.6 CCPA Compliance (California Users)

For users located in California, USA, SOLOMON recognizes your rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to Know: Request information about categories and specific pieces of personal information collected.
• Right to Delete: Request deletion of personal information (subject to exceptions).
• Right to Opt-Out: Opt out of “sales” or “sharing” of personal information (SOLOMON does not sell personal data but may share with marketing partners).
• Right to Correct: Request correction of inaccurate information.
• Right to Limit Use and Disclosure: Limit use of sensitive personal information.

Requests should be submitted via email to info@solomonbrokerage.com.

7.7 Data Security

SOLOMON implements industry-standard security measures to protect personal data, including:

• Secure Socket Layer (SSL) encryption for data transmission.
• Password-protected access controls
• Regular security audits and vulnerability assessments.
• Restricted employee access to personal data (need-to-know basis).
• Data breach response and notification procedures.

However, no security measure is 100% secure. SOLOMON cannot guarantee absolute protection against unauthorized access, hacking, or data loss. Users assume risk for information transmitted over the internet.

7.8 Data Breach Notification

In the event of a data breach affecting personal data security, SOLOMON will:

• Notify affected users without undue delay and no later than 30 days from discovery.
• Provide details of the breach, affected data categories, and recommended protective actions.
• Report the breach to relevant regulatory authorities (EU, Mexico, Latin America, or Middle East countries’ supervisory authorities) where legally required.
• Cooperate with law enforcement investigations.

7.9 Third-Party Processors and Sub-Processors

7.10 Data Retention Schedule

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Cookies Policy

A complete Cookies Policy is available at solomonbrokerage.com/cookies and is incorporated by reference into these Terms and Conditions.

8.2 Types of Cookies Used

8.2.1 Essential Cookies

• Session ID cookies: Enable basic Website functionality (login, form submission).
• Security cookies: Prevent fraud and protect against attacks.
• Load balancing cookies: Optimize Website performance.
• Duration: Session (deleted upon browser close) or until logout.

Essential cookies are necessary for Website operation and do not require user consent.

8.2.2 Analytical Cookies

• Google Analytics: Measures Website traffic, user behavior, page performance.
• Data Collected: Anonymized IP addresses, pages visited, time on page, referral source, device type.
• Duration: Up to 26 months.
• Purpose: Improve Website design and user experience.

Analytical cookies require explicit user consent via cookie banner before placement.

8.2.3 Marketing and Advertising Cookies

• Third-party advertisers: Facebook, Google Ads, LinkedIn (if implemented).
• Data Collected: User browsing habits, interests, engagement with ads.
• Duration: Variable (typically 6-24 months).
• Purpose: Deliver targeted advertising and measure ad effectiveness.

Marketing cookies require explicit user consent via cookie banner before placement.

8.2.4 Social Media Cookies

• Facebook Pixel, LinkedIn Insight Tag: Track user interactions and conversions.
• Duration: Variable by platform.
• Purpose: Social media advertising and analytics.

Social media cookies require explicit user consent before placement.

8.3 Cookie Consent Management

8.3.1 Consent Mechanism

Upon first visit to the Website, users will see a cookie banner offering three options:

• Accept All: Accept all cookies (essential, analytical, marketing).
• Reject Non-Essential: Accept only essential cookies.
• Customize: Select specific cookie categories.

8.3.2 Cookie Preferences

Users may manage cookie preferences at any time by:

• Clicking the “Cookie Settings” link in the Website footer.
• Clearing browser cookies and revisiting the site.
• Modifying browser privacy settings to block or restrict cookies.

8.3.3 Withdrawal of Consent

Users may withdraw consent for non-essential cookies at any time. Withdrawal will take effect prospectively; previously placed cookies remain until naturally expiration or browser deletion.

8.4 Third-Party Cookies

SOLOMON uses cookies placed by third-party vendors:

• Google Analytics: View Google’s privacy policy at policies.google.com/privacy.
• Other Vendors: Details available in the complete Cookies Policy at solomonbrokerageg.com/cookies.

Users may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

8.5 Do Not Track (DNT)

Some browsers include a “Do Not Track” feature. SOLOMON does not currently respond to DNT signals; however, users may disable cookies at the browser level or through our cookie settings.

9. LIMITATION OF LIABILITY AND DISCLAIMERS

9.1 “As Is” Disclaimer

The Website and all Content, services, and information provided are offered on an “AS IS” and “AS AVAILABLE” basis, without warranties of any kind, express or implied. SOLOMON makes no representations regarding:

• The accuracy, completeness, or timeliness of information.
• Technical data, project capacity metrics (MW, kW, gallons per day, tons per year), or performance estimates.
• The suitability of services for any particular purpose.
• The non-infringement of third-party intellectual property rights.
• Freedom from viruses, malware, or other harmful code.

9.2 Disclaiming Specific Warranties

SOLOMON expressly disclaims all warranties, including:

9.2.1 Implied Warranties

• Merchantability (fitness for sale or commercial purposes).
• Fitness for a particular purpose.
• Non-infringement of intellectual property rights.
• Title and quiet enjoyment.

9.2.2 Service Warranties

• SOLOMON does not guarantee that consulting services will result in project approval by regulatory authorities.
• SOLOMON does not guarantee that financing will be available or on favorable terms.
• SOLOMON does not guarantee that infrastructure projects will be executed, completed on time, or function as designed.
• SOLOMON does not guarantee that partners will perform services, maintain operations, or comply with laws.
• SOLOMON does not warrant that recommendations will achieve desired outcomes.

9.2.3 Website Warranties

• SOLOMON does not guarantee uninterrupted, error-free Website operation.
• SOLOMON does not warrant that the Website will be available 24/7 or free of maintenance downtime.
• SOLOMON does not warrant that Website security is impenetrable or that user data is risk-free from theft or loss.

9.3 Limitation of Liability

9.3.1 Cap on Liability

Except where prohibited by Estonian law, SOLOMON’s total cumulative liability to clients arising from:

• Use of the Website or digital platforms;
• Delivery of consulting services or information;
• Engagement with SOLOMON or its partners;
• Any other cause related to these Terms and Conditions;

shall be limited to the greater of:

• The fees actually paid by the client for services in the twelve (12) months preceding the claim;
• The cap is specified in the Statement of Work.

This liability cap applies to SOLOMON, its directors, employees, and agents.

9.3.2 Excluded Damages

In no event shall SOLOMON be liable for any of the following types of damages, even if SOLOMON has been advised of the possibility of such damages:

• Indirect Damages: Lost profits, lost revenue, lost business opportunity, lost data, lost market share, or diminished business value;
• Consequential Damages: Damages arising as a consequence of other damages or losses, including failure to achieve expected business results;
• Punitive or Exemplary Damages: Damages intended as punishment or deterrence;
• Special or Unusual Damages: Damages not typically foreseeable or within the reasonable contemplation of the parties at the time of engagement;
• Incidental Damages: Expenses incurred as a side effect of alleged failures (e.g., costs to hire replacement consultants, remediation costs, or third-party correction services);
• Reputational or Goodwill Damages: Damages to business reputation or goodwill;
• Regulatory Fines or Penalties: Government fines, penalties, or sanctions imposed on the client by regulatory authorities;
• Third-Party Claims: Claims, damages, or liabilities arising from third-party actions, including partner misconduct or failure.

9.3.3 Exceptions to Liability Caps

The liability limitations in Section 9.3 do not apply to:

• Gross negligence or willful misconduct by SOLOMON.
• Violation of intellectual property rights (piracy claims).
• Fraud or intentional misrepresentation.
• Breach of confidentiality obligations.
• Indemnification obligations under Section 6.4.
• Claims arising from data breaches caused by SOLOMON’s failure to implement reasonable security measures.
• Liability that cannot be limited under Estonian law or applicable international law.

Notwithstanding Section 9.3.1 and 9.3.2, the liability limitations do not apply to SOLOMON’s liability for:

• Death or Personal Injury: Liability for death or personal injury caused by SOLOMON’s negligence, which cannot be excluded under Estonian law;
• Gross Negligence or Willful Misconduct: Gross negligence, fraud, or intentional misrepresentation by SOLOMON, its directors, employees, or agents;
• Fraud or Intentional Misrepresentation: Fraudulent statements or intentional misrepresentation of facts, services, or capabilities;
• Breach of Confidentiality Obligations: Unauthorized disclosure of confidential client information in breach of Section 7 of these Terms or applicable confidentiality agreements;
• Data Protection Violations: Breaches of GDPR and Personal Data Protection Act (Isikuandmete Kaitse Seadus), including:
  • Unauthorized processing or disclosure of personal data
  • Failure to implement reasonable security measures resulting in personal data breach
  • Failure to notify clients of data breaches as required by law
  • Violation of data subject rights under PDPL
• Intellectual Property Infringement: Infringement of client intellectual property rights or violation of third-party intellectual property rights;
• Indemnification Obligations: Indemnification obligations under Section 6.4 of these Terms;
• Mandatory Consumer Protection: Liability that cannot be limited under Consumer Protection Act (Tarbijakaitse Seadus) or other mandatory provisions of Estonian law that expressly prohibit limitation of liability;
• Professional Negligence: Liability arising from SOLOMON’s breach of the professional standard of care expected of management consulting firms in Estonia, where such breach causes direct financial loss to the client exceeding the liability cap.

9.3.4 Liability for Partner Services

SOLOMON’s liability for services delivered by strategic partners is limited as follows:

• SOLOMON is liable only for negligence in selecting or vetting partners, not for partner performance or misconduct;
• SOLOMON’s liability cap for partner-related failures is 50% of the stated liability cap in Section 9.3.1;
• Clients have a direct claim against the partner organization for partner service failures, not against SOLOMON;
• SOLOMON is not liable for any consequential or indirect damages resulting from partner service delivery.

9.3.5 Aggregated Liability Cap

In no event shall SOLOMON’s total cumulative liability for all claims arising from all causes (including partner services, data breaches, and consulting service failures) exceed the liability cap specified in Section 9.3.1, except where prohibited by Estonian law.

9.3.6 Insurance and Risk Management

SOLOMON maintains professional liability insurance as required by Estonian law. Clients may pursue claims under such insurance as an alternative remedy. The existence of insurance does not increase SOLOMON’s liability cap beyond the amounts specified in these Terms.

9.4 Client Assumption of Risk

By engaging SOLOMON for consulting services, clients acknowledge and assume full responsibility and risk for:

9.4.1 Consulting Advice and Professional Judgment

• Reliance on consulting recommendations, advice, and professional recommendations provided by SOLOMON;
• Implementation decisions based on SOLOMON’s strategic guidance or assessments;
• Business, operational, or financial outcomes resulting from clients’ decisions to implement or act upon consulting recommendations;
• The appropriateness of recommendations for the client’s specific business context and risk profile.

9.4.2 Third-Party Services and Partners

• Engagement with SOLOMON’s strategic partners and third-party service providers;
• Partner performance, service quality, professionalism, and compliance with client expectations;
• Partner regulatory compliance and adherence to applicable laws in partner jurisdictions;
• Partner financial stability, creditworthiness, and continued operations;
• Disputes with partners, including contract performance, pricing, and service delivery.

9.4.3 Regulatory Approvals and Government Processes

• Regulatory approval outcomes for any client initiative or business plan;
• Decisions by government authorities or any other regulatory body;
• Changes to regulatory requirements after service delivery that affect the validity or applicability of recommendations;
• Clients’ responsibility to obtain final regulatory approvals and maintain ongoing compliance;
• Regulatory fines, penalties, or enforcement actions resulting from the client’s business operations.

9.4.4 Financing and Investment Decisions

• Financing availability, terms, and conditions from any financial institution, development bank, or investor;
• Investment decisions based on SOLOMON’s financial analysis or advisory services;
• Financial outcomes, returns on investment, or cost savings resulting from client implementation of recommendations;
• Market conditions, interest rates, currency fluctuations, and other economic factors affecting project financial viability.

9.4.5 Technical and Operational Outcomes

• Technical feasibility, performance, or specifications of recommended solutions or systems;
• Implementation timelines, project costs, or resource requirements beyond SOLOMON’s control;
• Operational outcomes, performance metrics, or efficiency gains resulting from organizational changes or system implementations;
• Vendor, supplier, or technology performance where recommendations relate to third-party products or services.

9.4.6 Information Security and Data Protection

• Cybersecurity risks related to client systems, networks, or digital infrastructure;
• Data transmission security over the Internet, including potential interception or unauthorized access;
• Clients’ own implementation of recommended security measures and IT controls;
• Clients’ compliance with General Data Protection Regulation (GDPR) (Regulation EU 2016/679) and Personal Data Protection Act (Isikuandmete Kaitse Seadus) for personal data processed by client systems;
• Third-party security breaches, hacking, or cyber attacks affecting client systems.

Note: Clients should refer to SOLOMON’s Privacy Policy (available at solomonbrokerage.com/privacy) and Cookies Policy (available at solomonbrokerge.com/cookies) for information on how SOLOMON protects client data during consulting engagements. SOLOMON remains responsible for compliance with the General Data Protection Regulation (GDPR) (Regulation EU 2016/679) and Personal Data Protection Act (Isikuandmete Kaitse Seadus) for personal data SOLOMON processes on behalf of clients.

9.4.7 Market Conditions and External Factors

• Market volatility, economic cycles, and business environment changes after service delivery;
• Competitive dynamics, industry disruption, or technological change affecting recommendation relevance;
• External factors beyond SOLOMON’s or the client’s control, including geopolitical events, natural disasters, pandemics, or regulatory changes.

9.4.8 No Guarantee of Specific Outcomes

Clients acknowledge that consulting services are advisory in nature and do not guarantee:

• Specific business outcomes, financial results, or performance metrics;
• Achievement of client strategic objectives or business goals;
• Resolution of specific business challenges or problems;
• Client satisfaction with recommendations or advisory guidance;
• Continued relevance or accuracy of assessments if market or regulatory conditions change materially after service completion.

9.5 Indemnification by Client

To the extent permitted by Estonian law, clients shall indemnify, defend, and hold harmless SOLOMON, its directors, employees, and agents from any third-party claims, damages, liabilities, costs, and expenses (including reasonable legal fees) arising from:

• Client misuse of consulting recommendations or services;
• Client violation of applicable law in implementing recommendations;
• Client breach of third-party intellectual property rights;
• Client disclosure of SOLOMON confidential information to unauthorized parties;
• Disputes between the client and SOLOMON’s partners or third-party service providers;
• Client data or systems breaches unrelated to SOLOMON’s actions.

This indemnification obligation does not apply where the third-party claim results from SOLOMON’s gross negligence, fraud, or willful misconduct.

10. WEBSITE AVAILABILITY AND SERVICE LEVEL

10.1 Website Uptime Commitment

SOLOMON commits to maintaining the Website with 99.0% uptime on a monthly basis, calculated as: (Total Minutes in Month – Downtime Minutes) / Total Minutes in Month × 100.

Scheduled maintenance windows (up to 2 hours per month) are excluded from downtime calculations and will be announced with 48 hours’ notice via email or Website notice.

10.2 Downtime Exceptions

SOLOMON is not responsible for downtime caused by:

• Internet service provider outages.
• Domain name server (DNS) failures.
• Distributed Denial of Service (DDoS) attacks or malicious hacking.
• Circumstances beyond SOLOMON’s reasonable control (acts of God, war, natural disasters).
• User equipment or browser failures.

10.3 Maintenance and Updates

SOLOMON reserves the right to:

• Perform maintenance on the Website (with advance notice when possible).
• Update or modify Website features, design, or functionality.
• Temporarily disable features for security purposes.
• Upgrade or replace hosting infrastructure.

SOLOMON will use commercially reasonable efforts to provide advance notice of planned downtime.

10.4 No Service Level Agreement (SLA) for Consulting Services

SOLOMON does not guarantee response times for consulting inquiries. Standard response time is 3-5 business days; however, response times may vary based on:

• Complexity of the inquiry.
• Availability of specialized personnel.
• Seasonal business volume.
• Competing client priorities.

Urgent inquiries may be directed to info@solomonbrokerage.com with “URGENT” in the subject line.

11. SERVICES, REFUNDS, AND CANCELLATIONS

11.1 Nature of Services Offered via Website

SOLOMON (“the Company”) primarily offers the following via the Website:

• Free information and resources: Technical articles, case studies, management guides, procurement insights, and sustainability resources (no refund applicable).
• Consulting inquiries and quotes: Users may request a quote for business consulting, IT advisory, procurement, or management consulting services.
• Newsletter subscriptions: Free industry updates and business insights (cancellable at any time).

11.2 Consulting Engagement Process

11.2.1 Quote Request

Users may submit a consulting inquiry via the Website contact form or email to info@solomonbrokerage.com. SOLOMON will provide an estimated quote within 5 business days based on:

• Scope of work and project complexity.
• Required expertise and personnel allocation.
• Industry sector (business advisory, IT, procurement, management).
• Data availability and project timeline.

11.2.2 Formal Proposal and Statement of Work (SOW)

Upon request, SOLOMON will issue a Formal Proposal or Statement of Work (SOW) specifying:

• Description of consulting services to be provided.
• Deliverables, milestones, and timeline.
• Fee structure and payment terms.
• Service level expectations and performance standards.
• Termination conditions and refund eligibility.
• Limitation of liability and service disclaimers.

All formal proposals and SOWs incorporate these Terms and Conditions and will specify any service-specific terms that may modify or supplement this agreement.

11.2.3 Acceptance and Engagement

Consulting engagement commences only upon:

• SOLOMON’s receipt of a signed proposal/SOW from the Client.
• SOLOMON’s receipt of any required advance payment or deposit as specified in the SOW.

No binding obligation exists until both parties have executed a formal agreement and SOLOMON has received the required advance payment.

11.3 Refund Policy for Consulting Services

11.3.1 General Refund Terms

SOLOMON consulting and advisory fees are non-refundable once work has commenced, except as specifically provided herein. Work is deemed to have commenced when SOLOMON has:

• Commenced research, analysis, data gathering, or strategic review on behalf of the Client.
• Engaged specialized personnel, consultants, or external resources for the project.
• Incurred project-specific expenses or costs (including vendor fees, third-party consultations, or licensing).
• Delivered preliminary findings, reports, recommendations, or deliverables.

Once any of the above has occurred, consulting fees are final and non-refundable.

11.3.2 Cancellation Before Work Commences

If the Client cancels a consulting engagement before SOLOMON has commenced any substantive work (typically within 3 business days of formal proposal acceptance), SOLOMON will refund:

• 100% of advance payments or deposits,
• Minus any documented costs SOLOMON has already incurred in direct preparation for the engagement (such as vendor deposits, reserved resource allocation, or specialized research resources).

The Client will be notified in writing of any deductible costs prior to refund processing.

11.3.3 Partial Completion or Service Deficiencies

If SOLOMON fails to deliver services as described in the SOW, or if services delivered are substantially defective or non-compliant with agreed standards, the Client may:

1. Request remediation or correction at no additional cost within 30 days of discovery of the deficiency.
2. If remediation is not feasible or timely, receive a pro-rata partial refund reflecting the percentage of services not satisfactorily delivered, to be calculated by mutual agreement or, if disputed, by independent expert determination.

Service quality disputes must be submitted in writing within 30 days of service delivery. After 30 days, all services are deemed accepted and no refunds will be considered. SOLOMON reserves the right to remedy any deficiency before any refund is issued.

11.3.4 Refunds for Free Services

No refund is available for:

• Free consultation calls or preliminary scoping discussions.
• Free downloadable resources, case studies, technical guides, or whitepapers.
• Free newsletter subscriptions or informational content.

11.4 Procurement and Supply Chain Advisory Arrangements

11.4.1 SOLOMON’s Role

For procurement and supply chain engagements, SOLOMON acts as a consultant and strategic advisor, not as a vendor, contractor, guarantor, or project executor. SOLOMON’s role includes:

• Assessing procurement strategies and supply chain efficiency.
• Providing vendor evaluation and management advisory services.
• Facilitating introductions to pre-qualified vendors and partners (for information purposes only).
• Recommending procurement processes and optimization strategies.

11.4.2 Third-Party Obligations and Limitations

SOLOMON is not responsible for and assumes no liability for:

• Vendor performance, quality, pricing, or delivery timelines.
• Supply chain disruptions, delays, or cost overruns.
• Vendor solvency, regulatory compliance, or business viability.
• Contract negotiations or disputes between the Client and any vendor or supplier.
• Quality or performance of goods or services supplied by third parties.

11.4.3 Procurement Advisory Refund Policy

Fees paid to SOLOMON for procurement and supply chain consulting are:

• Non-refundable once SOLOMON has commenced work as defined in Section 11.3.1.
• Fully refundable if the Client cancels before work commences, minus documented preparation costs.
• Pro-rata refundable if SOLOMON materially fails to deliver the consulting services specified in the SOW, or if the Client terminates due to SOLOMON’s material breach of contract.

Fees paid directly to vendors, suppliers, or third parties are not refundable by SOLOMON and remain the sole responsibility of the Client and the respective third party.

11.5 Newsletter Subscriptions

Users may subscribe to SOLOMON’s free email newsletter featuring industry insights, business updates, and service announcements.

11.5.1 Unsubscribe Process

Users may unsubscribe from the newsletter at any time by:

• Clicking the “Unsubscribe” link at the bottom of any newsletter email.
• Emailing info@solomonbrokerage.com with the subject line “Unsubscribe from Newsletter”.
• Contacting the Company at the Legal Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.

Unsubscribe requests will be processed within 5 business days.

11.5.2 Newsletter Frequency

SOLOMON will send newsletters no more than twice per month. Additional service announcements, project updates, or time-sensitive communications may be sent as needed, but will be clearly marked as promotional or informational content.

11.6 Payment Terms and Methods

11.6.1 Accepted Payment Methods

SOLOMON accepts payment via:

• Bank transfer / Wire transfer (EUR or USD to EUR-based bank account).
• Credit card (Visa, MasterCard, American Express) through secure payment gateway.
• Digital payment methods (PayPal, bank e-transfer, or other authorized digital processors).

11.6.2 Payment Terms for Consulting Services

Standard payment terms are:

• 50% advance payment (deposit) upon formal proposal/SOW acceptance (required before work commences).
• 50% upon delivery of final deliverables and completion of services.

Alternative payment schedules may be negotiated and documented in the formal SOW at SOLOMON’s discretion.

11.6.3 Currency and Exchange Rates

All invoices are issued in Euros (EUR) or United States Dollars (USD), as specified in the SOW. If the Client elects to pay in a different currency, the Client assumes all costs of currency conversion and foreign exchange fees. Exchange rate calculations will be performed at the current market rate on the date of payment.

11.6.4 Invoice and Payment Due Date

All invoices are due within 30 days of invoice issuance. Invoices must be paid in full before SOLOMON is obligated to deliver final deliverables or release work products.

11.6.5 Late Payment Terms

Payments not received by the due date are considered overdue. Late payments are subject to the following terms in compliance with Law of Obligations Act (Kohustuste Seadus):

• Service suspension: If payment is not received within 60 days of the due date, SOLOMON reserves the right to suspend all services and deliverable access.
• Service termination: If payment is not received within 90 days of the due date, SOLOMON may terminate the engagement, cease work, and pursue collections through legal channels.
• Collection costs: The Client shall reimburse SOLOMON for all reasonable costs incurred in collecting overdue amounts, including attorney fees, court costs, and collection agency fees.

11.7 Dispute Resolution

Any disputes arising out of or relating to these Terms and Conditions, service delivery, refunds, or payment terms shall be governed by and construed in accordance with the laws of the Estonia without regard to its conflict of laws principles. Both parties agree to submit disputes to:

• Initial resolution: Good faith negotiation and written correspondence.
• Mediation: If unresolved within 30 days, mediation through the Estonian Chamber of Commerce & Industry (Koda) or equivalent recognized body.
• Jurisdiction: If mediation fails, disputes shall be heard exclusively by the competent courts of Tallinn, Estonia, and both parties irrevocably submit to their jurisdiction.

11.8 Service Limitations and Disclaimers

SOLOMON is a management and business consultancy firm providing advisory services only. The following limitations apply:

• SOLOMON does not provide legal advice, tax advice, or financial investment advice. Clients should consult appropriate licensed professionals for such matters.
• SOLOMON ’s recommendations are based on information provided by the Client and market conditions at the time of engagement. SOLOMON does not guarantee specific business outcomes or results.
• SOLOMON ’s liability for any breach of contract or service failure is limited to 100% of fees paid for the specific engagement in which the breach or failure occurred.
• SOLOMON shall not be liable for any indirect, consequential, incidental, or punitive damages, loss of profit, or business interruption arising from the use or inability to use services.

12. COMPLIANCE WITH LOCAL REGULATIONS

12.1 Estonian Legal Framework

SOLOMON (“the Company”) operates in compliance with the legal and regulatory frameworks of the Estonia. The Company’s services—including business consulting, management advisory, IT consultancy, procurement advisory, and management consulting—are designed to comply with all applicable EStonian federal and local regulations.

12.1.1 Business Registration Compliance

SOLOMON maintains current and valid business rgistration as required by Estonian regulatory authorities:

• Business Registration: Issued by the Estonian Business Register (Centre of Registers and Information Systems – Registrite ja Infosüsteemide Keskus), authorizing the Company to conduct its services.
• Annual Tax Declaration Compliance: All tax declarations in accordance with Estonian Tax and Customs Board (EMTA) requirements.

12.1.2 Data Protection and Personal Data Processing

The Company is fully committed to compliance with the Estonia’s comprehensive data protection legislation:

A. Legal Framework

SOLOMON operates in accordance with:

• Estonian Commercial Code
• Law of Obligations Act
• General Part of the Civil Code provisions applicable to business transactions
• Consumer Protection Act provisions applicable to consulting services
• Value Added Tax (VAT) Act.

B. Data Protection Principles

SOLOMON adheres to the core data protection principles outlined in General Data Protection Regulation (GDPR) (Regulation EU 2016/679) as implemented in Estonia through the Personal Data Protection Act:

• Lawfulness, fairness, and transparency: Personal data is processed in a lawful, fair, and transparent manner.
• Purpose limitation: Personal data is collected only for specified, explicit, and legitimate purposes and shall not be further processed for incompatible purposes.
• Data minimization: Only the minimum amount of personal data necessary for the stated purpose is collected.
• Accuracy and integrity: Personal data is kept accurate and up-to-date; measures are in place to ensure correction or deletion of inaccurate data.
• Storage limitation: Personal data is retained only as long as necessary to fulfill the purpose of processing, unless longer retention is required by law.
• Security and confidentiality: Personal data is protected against unauthorized or unlawful processing through appropriate technical and organizational measures.
• Accountability: SOLOMON maintains documentation of data processing activities and demonstrates compliance with data protection obligations.

C. Data Subject Rights

SOLOMON recognizes and respects the following rights of individuals (data subjects) whose personal data is processed:

• Right to access: Data subjects may request access to their personal data held by PSOLOMON .
• Right to correction: Data subjects may request correction of inaccurate or incomplete personal data.
• Right to erasure (“right to be forgotten”): Data subjects may request deletion of personal data when no longer necessary for the purpose of processing, subject to applicable exceptions.
• Right to restrict processing: Data subjects may request limitation of processing in certain circumstances.
• Right to object: Data subjects may object to processing of their personal data for direct marketing, profiling, or automated decision-making.
• Right to data portability: Data subjects may request transfer of their personal data to another organization in a structured, commonly used format.

D. Consent Requirements for Sensitive Data and KYC Processing

For consulting engagements that require collection of sensitive personal data (such as identification documents, biometric data, or financial information for Know Your Customer—KYC—due diligence), SOLOMON obtains explicit informed consent from the Client or data subject:

(1) Categories of Sensitive Personal Data (if applicable)

OLOMON may collect “Sensitive Personal Data” as defined in the General Data Protection Regulation (GDPR) (Regulation EU 2016/679) as implemented in Estonia through the Personal Data Protection Act, which includes:

• Government identification data: National identification number, passport number, copies of official identity documents.
• Source of funds information: Beneficial ownership information, patrimonial declarations, or income verification (for financial due diligence).
• Residence verification: Proof of residence documents or address information.

(2) Legal Bases for Processing Sensitive Data

Collection and processing of sensitive personal data is authorized under the following legal bases in compliance with Personal Data Protection Act:

• EXPLICIT INFORMED CONSENT: The Client/data subject provides clear, affirmative, and specific consent for collection and processing of sensitive data. Such consent must be:
  • Informed (understanding what data is collected, why, and how it will be used),
  • Affirmative (expressed through written signature, electronic consent form, or documented acknowledgment—NOT passive silence), and
  • Freely given (without coercion or undue influence).
• LEGAL OBLIGATION: Processing is necessary to comply with Estonian laws and regulations, including:
  • Money Laundering and Terrorist Financing Prevention Act (RahaPTS) obligations,
  • Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements,
  • Regulatory obligations under Estonia’s AML/CFT framework,
  • Obligations mandated by the Personal Data Protection Act or other competent authorities,
  • Sanctions compliance (OFAC, UN, EU designations).
• LEGITIMATE INTEREST: Processing is necessary for:
  • Fraud prevention and detection of suspicious activity,
  • Compliance risk assessment and regulatory due diligence,
  • Protection of the integrity of financial systems and the Company’s business,
  • Contract performance and dispute resolution (identity verification).

(3) Data Retention Periods

Sensitive personal data is retained in accordance with the following periods:

• Active Client Relationship: Active Client Relationship: Duration of engagement plus any applicable regulatory hold periods (minimum 5 years for AML records per Estonia’s standards under the Money Laundering and Terrorist Financing Prevention Act).
• Terminated Relationship: 5 years following termination of the engagement (in compliance with recommendations of Estonia’s AML regulations).
• Rejected Application: 6 months following rejection (for legal defense if the rejection is challenged).
• Non-Processed Data: 30 days (unprocessed applications or data not used shall be deleted or securely destroyed).

(4) International Data Transfers

SOLOMON does not transfer personal data outside the Estonia without appropriate legal safeguards, including:

• Approval by the Estonian Data Protection Inspectorate (once countries are officially designated as providing adequate protection under GDPR adequacy decisions),
• A data processing agreement with the recipient organization,
• Explicit consent from the data subject, or
• An exception recognized under Estonian Commercial Code (such as necessity for contract performance).

E. Data Breach Notification

In the event of a breach or unauthorized access to personal data, SOLOMON shall:

• Notify the Estonian Data Protection Inspectorate within 72 hours of discovery (as specified in GDPR Article 33 and the Personal Data Protection Act).
• Inform affected data subjects of the breach and take corrective measures.
• Document the breach, its impact, and remedial actions taken.

12.1.3 Anti-Money Laundering (AML) Compliance

A. Legal Framework

SOLOMON is committed to preventing money laundering, terrorist financing, and sanctions evasion in accordance with:

• Money Laundering and Terrorist Financing Prevention Act (RahaPTS): Estonia’s primary AML/CFT legislation governing obliged entities and compliance requirements.
• International Sanctions Act: Implements EU and international sanctions regimes in Estonia.
• FATF 40 Recommendations: International standards for AML/CFT/CPF compliance.
• Financial Intelligence Unit (FIU) Guidelines: Supervisory standards and expectations for financial crime compliance, including guidelines on suspicious activity reporting and risk assessment.
• EU Directive (EU) 2015/849 (4th AMLD) and Directive (EU) 2018/843 (5th AMLD): Transposed into Estonian law for harmonized AML/CFT standards across the EU.

B. Customer Due Diligence (CDD) and Know Your Customer (KYC)

For consulting engagements where SOLOMON collects Client information, the Company conducts Customer Due Diligence appropriate to the risk profile:

• Verification of identity using government-issued identification or other acceptable means.
• Verification of business purpose and source of funds (where applicable to the engagement).
• Assessment of beneficial ownership for corporate clients to identify the individuals who ultimately own or control the entity.
• Ongoing monitoring of client relationships for suspicious activity or changes in circumstances.

C. Sanctions Compliance

SOLOMON does NOT provide services to any individual or entity that is:

• Listed on OFAC (U.S. Office of Foreign Assets Control) sanctions lists or subject to U.S. economic sanctions.
• Listed on UN Security Council sanctions designations or UN-sanctioned country lists.
• Designated as a terrorist organization or supporter of terrorism by the U.S. State Department, EU, or UN.
• Subject to international sanctions regimes under the Estonian International Sanctions Act.

Clients warrant and represent that they are not sanctioned persons and that their use of SOLOMON services does not violate applicable international sanctions laws.

D. Suspicious Activity Reporting (SAR)

SOLOMON is committed to reporting suspicious activity related to money laundering or terrorist financing to the Financial Intelligence Unit (Rahapesu Andmebüroo) of Estonia, consistent with the reporting requirements under the Money Laundering and Terrorist Financing Prevention Act and applicable EU regulations.

12.1.4 Anti-Corruption Compliance

SOLOMON operates in strict compliance with international anti-corruption standards:

• U.S. Foreign Corrupt Practices Act (FCPA): Prohibition against bribery of foreign officials.
• UK Bribery Act 2010: Comprehensive anti-bribery and corruption standards.
• UN Convention Against Corruption (UNCAC): International corruption prevention standards to which the Estonia is a signatory.
• Estonian Penal Code (Sections 288, 294, 296, 298, 300, 301): Articles addressing bribery, embezzlement, and unlawful enrichment.
• Estonian Anti-Corruption Act (Korruptsioonivastane seadus): Comprehensive legislation addressing corruption prevention among all officials and in the private sector.
• Estonian Anti-Corruption Action Plan 2021-2025: National policies and initiatives to promote transparency and integrity in business and government

SOLOMON will not participate in bribery, corruption, illicit inducements, or any unlawful conduct in relation to the performance of consulting services.

12.1.5 Tax Compliance

A. Value Added Tax (VAT)

SOLOMON maintains full compliance with Estonia’s Value Added Tax regulations:

• VAT Rate: 24% standard rate applied to consulting services and other taxable supplies, as mandated by the Estonian VAT Act (effective from 1 July 2025).
• VAT Registration: The Company is registered with the Estonian Tax and Customs Board (EMTA – Maksu- ja Tolliamet) for VAT purposes and issues VAT-compliant invoices to all clients in the EU.
• VAT Return Filing: The Company files periodic VAT returns with the EMTA as required (typically monthly, depending on classification).
• Record Retention: The Company maintains detailed records of all VAT-related transactions for a minimum of 7 years as required by Estonian law.
• Input Tax Recovery: The Company claims input VAT on eligible business expenses in accordance with VAT Act regulations and EMTA guidelines.

12.1.6 Economic Sanctions Compliance

SOLOMON does not provide services to:

• Individuals or entities on U.S. OFAC (Office of Foreign Assets Control) sanctions lists.
• UN-sanctioned countries or entities.
• Individuals or entities designated as terrorists or supporters of terrorism by the U.S., EU, or UN.

Users represent that they are not sanctioned persons and that use of SOLOMON services does not violate Estonian International Sanctions Act, OFAC sanctions laws, or other applicable international sanctions regimes.

13.3 Mediation

13.3.1 Mandatory Mediation

If good faith negotiation does not resolve the dispute within thirty (30) days, either party may initiate mediation before pursuing litigation or arbitration, in accordance with the Conciliation Act (Kokkuleppimise Seadus) and EU Directive 2008/52/EC on certain aspects of mediation in civil and commercial matters, as implemented in Estonian law (the “Estonian Mediation Framework”).

13.3.2 Mediation Process

Mediator Selection: The parties will jointly select a neutral mediator accredited in accordance with Estonian mediation practices and EU standards. Mediators may include any natural person agreed upon by the parties, attorneys-at-law, or notaries registered in Estonia. Should the parties fail to reach agreement on a selection, they shall request the appointment of a mediator by either:

• The Estonian Chamber of Commerce and Industry (Eesti Kaubandus-Tööstuskoda), or
• The Court of Arbitration of the Estonian Chamber of Commerce and Industry, or
• A registered conciliator listed with the Estonian Bar Association or Chamber of Notaries, or
• The International Chamber of Commerce (ICC).

Location: Mediation will be conducted in Tallinn, Estonia, or virtually by mutual agreement of the parties.

Language: Mediation will be conducted in English, as agreed by the parties. Any submissions or documents in a language other than Estonian or English shall be accompanied by certified translations in accordance with Estonian legal requirements.

Duration: Mediation will be completed within forty-five (45) days from the date of the initiating party’s request, or such extended period as mutually agreed by the parties in writing.

Costs: Mediation costs, including the mediator’s fees and administrative charges, will be shared equally between the parties unless the mediator recommends otherwise based on settlement proposals and the conduct of the parties.

13.3.3 Confidentiality of Mediation

All statements, admissions, offers, and proposals made during mediation are strictly confidential and may not be disclosed to any court, tribunal, or third party, nor may they be used as evidence in any subsequent litigation or arbitration, except as required by mandatory provisions of Estonian law or EU Directive 2008/52/EC or court order. Confidentiality is preserved in accordance with the Conciliation Act and applicable EU mediation standards, which protect the communications and work product of the mediation process unless all parties consent to disclosure or unless disclosure is necessary to implement or enforce a settlement agreement reached during mediation.

13.3.4 Non-Binding Nature of Mediation

Mediation is non-binding and advisory in nature. Either party may terminate mediation at any time by providing written notice to the other party and the mediator. Failure to reach a settlement through mediation does not prejudice either party’s legal rights and does not waive or diminish any party’s right to pursue arbitration or litigation.

13.4 Arbitration as Preferred Dispute Resolution

13.4.1 Agreement to Arbitrate

If disputes are not resolved through good faith negotiation or mediation as outlined in Section 13.3, both parties agree to refer the dispute to binding arbitration administered by the Estonian Chamber of Commerce and Industry (Eesti Kaubandus-Tööstuskoda) under the Court of Arbitration of the Estonian Chamber of Commerce and Industry Rules, or alternatively by mutual written agreement to the International Chamber of Commerce (ICC) under the ICC Rules of Arbitration. Arbitration shall be the exclusive remedy for all disputes arising from or relating to these Terms, the Website, or SOLOMON’s services.

13.4.2 Arbitration Seat and Seat Law

Seat of Arbitration: The seat (legal place) of arbitration shall be Tallinn, Estonia, unless the parties expressly agree in writing to a different seat.

Applicable Arbitration Law: Arbitration shall be governed by and conducted in accordance with:

• The Estonian Code of Civil Procedure (CCP), Sections 712–757 (Tsiviilkohtumenetluse Seadustik), which regulate arbitration proceedings and implement the 1985 UNCITRAL Model Law on International Commercial Arbitration, or
• The Rules of the Court of Arbitration of the Estonian Chamber of Commerce and Industry (ECCI Rules), where arbitration is seated at the Court of Arbitration of the Estonian Chamber of Commerce and Industry, or
• The 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention), which governs the recognition and enforcement of arbitral awards in Estonia and internationally.

13.4.3 Tribunal Composition and Appointment

Number of Arbitrators: The dispute shall be decided by a sole arbitrator unless the parties mutually agree otherwise, or unless the ECCI Rules or applicable law require otherwise. If the amount in dispute exceeds €500,000, a three-member arbitral tribunal may be appointed by agreement.

Arbitrator Qualifications: Any arbitrator appointed must be independent, impartial, and knowledgeable in commercial and business matters. Arbitrators shall be appointed in accordance with the ECCI Rules 2024 or other applicable arbitration rules mutually selected by the parties (including ICC Rules or UNCITRAL Rules), as administered by the Court of Arbitration of the Estonian Chamber of Commerce and Industry.

13.4.4 Arbitration Language and Conduct

Language of Arbitration: The language of the arbitration shall be English unless the parties agree otherwise in writing. All submissions, evidence, and the award shall be in the language chosen by the parties. If documents are submitted in Arabic, a certified English translation shall be provided.

Conduct of Proceedings: The language of the arbitration shall be English unless the parties agree otherwise in writing. All submissions, evidence, and the award shall be in the language chosen by the parties. If documents are submitted in Estonian, a certified English translation shall be provided. The ECCI Rules 2024 permit proceedings to be conducted in Estonian or English at the parties’ discretion.

13.4.5 Confidentiality of Arbitration

All arbitration proceedings, documents, submissions, testimony, and awards shall be confidential. Neither party shall disclose details of the arbitration to third parties except as required by law, for enforcement purposes, or with the written consent of the other party. This confidentiality provision survives the termination of the arbitration and is governed by the Conciliation Act (Kokkuleppimise Seadus) and ECCI Rules 2024.

13.4.6 Arbitration Costs and Allocation

Each party shall bear its own legal and professional costs. The fees of the arbitrator and administrative costs of the Court of Arbitration of the Estonian Chamber of Commerce and Industry shall be allocated by the tribunal in its award, which may order that all or part of such costs be borne by the unsuccessful party, in accordance with the ECCI Rules 2024 and general principles of fairness.

13.4.7 Enforcement of Arbitral Awards

Any arbitral award rendered shall be final and binding on both parties. The award shall be directly enforceable in Estonia without the need for separate court recognition proceedings. Awards rendered by the Court of Arbitration of the Estonian Chamber of Commerce and Industry are enforceable in any country that is a signatory to the 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (to which Estonia is a party with no reservations). Either party may seek recognition and enforcement of the award before the competent Estonian courts or, if applicable, before the courts in any other jurisdiction where assets of the other party may be located.

13.5 Litigation in Estonian Courts (If Arbitration Is Not Elected)

13.5.1 Exclusive Jurisdiction

Notwithstanding Section 13.4, if either party elects not to pursue arbitration, or if arbitration is found to be invalid or unenforceable, both parties irrevocably agree that any and all legal action or court proceeding shall be brought exclusively before the competent civil courts of Estonia, as determined by the Estonian Code of Civil Procedure and applicable Estonian law. The specific court of competent jurisdiction shall be determined in accordance with the procedural rules applicable in Estonia, with Tallinn District Court or Harju County Court as the court of first instance and Tallinn Circuit Court as the appellate court.

13.5.2 No Other Jurisdiction

By using the Website or engaging SOLOMON’s services, users:

• Irrevocably consent to the exclusive jurisdiction of Estonian courts;
• Waive any right to sue in any other court, forum, jurisdiction, or venue;
• Waive any objection to venue in Estonian courts on grounds of inconvenience or otherwise;
• Waive any claim that Estonian courts are not a convenient forum for the resolution of disputes.

13.5.3 Applicable Procedural Law

All civil litigation proceedings shall be conducted in accordance with:

• The Estonian Code of Civil Procedure (Tsiviilkohtumenetluse Seadustik);
• The Law of Obligations Act (Kohustuste Seadus) and other applicable Estonian laws; or
• The rules of evidence, procedure, and substantive law applicable in Estonian courts.

Both parties submit to the jurisdiction and procedural rules of Estonian courts and acknowledge that such courts may make procedural orders as deemed necessary.

13.5.4 Language of Legal Proceedings

Court proceedings in Estonia shall be conducted in Estonian, the official language of the Republic of Estonia. Upon request, and at the cost of the requesting party, the courts may permit proceedings to be conducted in English with appropriate translation services. All documents must be translated into Estonian by a certified court translator or registered translation service before submission to the court, in accordance with Estonian court requirements and the Code of Civil Procedure.

13.6 Class Action Waiver and Individual Dispute Resolution

13.6.1 No Class Actions or Class Arbitration

Users and SOLOMON mutually waive any right to participate in or bring any class action, class arbitration, representative action, or consolidated action against SOLOMON or any of its officers, directors, employees, agents, or representatives. All disputes, whether resolved through mediation, arbitration, or litigation, must be brought and resolved on an individual basis, and any award or judgment shall apply only to the individual bringing the claim.

13.6.2 Enforceability

The class action waiver set forth in Section 13.6.1 shall be enforceable to the maximum extent permitted under Estonian law, EU law (including the General Data Protection Regulation), and all applicable laws, regulations, and international instruments to which Estonia is a party, including but not limited to the Estonian Code of Civil Procedure, the Law of Obligations Act, and the Commercial Code (Äriseadustik).

13.6.3 Severability

If any court or arbitral tribunal finds the class action waiver to be unenforceable in whole or in part, the unenforceable provision shall be severed from this agreement, and the remaining provisions shall continue in full force and effect. The parties’ intention to resolve disputes on an individual basis shall be preserved to the maximum extent possible under applicable law.

13.7 Governing Law

These Terms and Conditions, and all disputes arising from or relating to the Website or SOLOMON’s services, shall be governed by and construed in accordance with the laws of the Republic of Estonia, without regard to its conflict of law principles. The applicable Estonian laws include the Commercial Code (Äriseadustik), the Law of Obligations Act (Kohustuste Seadus), the Consumer Protection Act (Tarbijakaitse Seadus), the General Data Protection Regulation (GDPR), and the Personal Data Protection Act (Isikuandmete Kaitse Seadus). The parties expressly exclude the application of the United Nations Convention on Contracts for the International Sale of Goods (CISG) and any other international conventions or protocols that might otherwise apply, except where mandatory under Estonian law or EU law.

13.8 Notices of Dispute

Any party intending to initiate mediation, arbitration, or litigation must first provide the other party with written notice of the dispute, containing a detailed description of the claim, the relief sought, and the proposed resolution method. Such notice shall be sent to the address specified in Section 2 of the Privacy Policy and must be received within ninety (90) days of the event giving rise to the dispute, unless the law requires a longer or shorter period.

13.9 Right to Judicial Review

Notwithstanding the mandatory arbitration and mediation provisions above, nothing in these Terms shall prevent either party from seeking urgent interim relief, provisional measures, or precautionary orders from the competent Estonian courts or other courts of competent jurisdiction to prevent irreparable harm, preserve assets, or enforce intellectual property rights, pending the outcome of mediation or arbitration.

13.10 Attorneys’ Fees

In the event of litigation or mediation, the prevailing party (as determined by the court or mediator) may recover reasonable attorneys’ fees and court costs from the non-prevailing party.

13.11 Injunctive Relief

Notwithstanding the dispute resolution procedures above, SOLOMON may seek immediate injunctive relief (court order to cease harmful conduct) in the Estonian courts or any competent jurisdiction if:

• A user violates SOLOMON’s intellectual property rights.
• A user threatens irreparable harm to SOLOMON’s business.
• An emergency exists requiring immediate action.

This does not waive SOLOMON’s right to pursue full litigation or damages.

14. FORCE MAJEURE

14.1 Definition

“Force Majeure” means circumstances beyond the reasonable control of SOLOMON that prevent or delay the performance of obligations, including:

• Natural Disasters: Earthquakes, floods, hurricanes, tsunamis, tornados, severe weather.
• Pandemic or Epidemic: COVID-19, disease outbreaks affecting personnel or operations.
• War and Civil Unrest: War, armed conflict, terrorism, civil riots, civil war, insurrection, embargo.
• Government Action: Governmental prohibitions, sanctions, embargoes, nationalization, expropriation, unexpected regulatory changes.
• Infrastructure Failure: Widespread power outages, telecommunications failure, transportation disruption.
• Third-Party Actions: Strikes by non-SOLOMON employees (affecting partner services), supplier failures, logistics disruptions.

Force Majeure does NOT include:

• Economic hardship, recession, or market downturn.
• Increased costs or inflation.
• Staffing shortages (unless caused by pandemic).
• Cyberattacks (unless of exceptional scale and sophistication).
• Minor operational delays.

14.2 Force Majeure Relief

Upon occurrence of a Force Majeure event:

14.2.1 Notice Requirement

SOLOMON will notify affected users of the Force Majeure event without undue delay by:

• Email notification.
• Website banner or homepage notice.
• Phone call (for critical projects).

The notice will include:

• Description of the event.
• Expected duration or impact assessment.
• Alternative arrangements or postponement timeline.
• Contact information for updates.

14.2.2 Suspension of Obligations

SOLOMON’s obligations to perform consulting services, maintain Website availability, and meet project timelines are suspended during the Force Majeure event. This includes:

• Tolling (pausing) project timelines and deadlines.
• Suspending service level commitments (Website uptime guarantees).
• Deferring consulting deliverables until conditions normalize.

14.2.3 Resumption of Services

SOLOMON will resume full service performance as soon as reasonably practicable after the Force Majeure event ends. SOLOMON is not liable for delays caused by Force Majeure.

14.2.4 Termination Right

If a Force Majeure event prevents SOLOMON from performing consulting services for more than 90 consecutive days, the client may:

• Terminate the engagement by written notice.
• Receive a pro-rata refund of fees paid for services not delivered.
• Retain all preliminary reports and deliverables provided to date.

15. TERMINATION AND ACCOUNT SUSPENSION

15.1 Termination by User

15.1.1 Termination of Website Access

Users may discontinue use of the Website at any time by:

• Ceasing to access or use the Website.
• Deleting cookies and browser history (optional).
• Unsubscribing from newsletters (see Section 11.5).

No formal notice is required to stop using a free Website.

15.1.2 Termination of Consulting Engagement

For active consulting engagements under a signed SOW:

• User may terminate by providing written notice to info@solomonbrokerage.com with subject “Termination of Engagement”.
• Termination is effective 5 business days after SOLOMON receives notice.
• User remains liable for fees incurred up to the termination date.
• User retains all deliverables provided to date.

Refund policies for early termination are specified in Section 11.

15.2 Termination by SOLOMON

15.2.1 Termination for User Violation

SOLOMON may immediately terminate Website access if a user:

• Violates these Terms and Conditions (See Section 6.2).
• Engages in illegal activity.
• Harasses or threatens SOLOMON staff.
• Attempts to breach Website security.
• Misuses the Website for spam, phishing, or other harmful conduct.

Upon termination, SOLOMON will:

• Disable user account access (if applicable).
• Preserve user data per retention schedules (Section 7.10).
• Provide written explanation of termination (within 10 days if requested).

15.2.2 Termination for Non-Payment

SOLOMON may terminate active consulting engagements if:

• Client payment is 60 days overdue, with written notice of intent to terminate.
• Client fails to pay within 30 days of the termination notice.
• Upon termination, SOLOMON will suspend all services and may pursue debt collection.

Client remains liable for all fees incurred to the termination date plus late payment interest (Section 11.6.4).

15.2.3 Termination for Convenience

SOLOMON may terminate a consulting engagement for convenience by providing 14 days’ written notice to the client. Upon such termination:

• SOLOMON will refund 50% of advance fees not yet earned.
• SOLOMON will deliver all work-in-progress reports and preliminary findings.
• Client may not claim damages from convenience termination.

15.3 Account Suspension

15.3.1 Suspension Without Termination

SOLOMON may suspend (but not permanently terminate) a user’s Website access if:

• Payment is overdue by 30+ days.
• User’s conduct violates these Terms (pending investigation).
• Website maintenance or security measures require temporary shutdown.
• Legal process (court order, law enforcement) requires suspension.

Suspension is temporary and may be lifted upon cure of violation or payment.

15.3.2 Notice of Suspension

SOLOMON will provide written notice of suspension via email, specifying:

• Reason for suspension.
• Duration (if known).
• Required cure actions.
• Appeal process.

15.3.3 Data Preservation During Suspension

All user data is preserved during suspension. Upon reinstatement, users retain access to previous interactions and information.

15.4 Effect of Termination

Upon termination or account suspension:

• All rights to use the Website immediately cease.
• User must comply with SOLOMON ’s intellectual property restrictions (Section 4).
• User remains liable for all fees incurred before termination.
• Limitation of liability provisions (Section 9) survive termination.
• Privacy and data protection obligations survive termination (Section 7).

16. SEVERABILITY

16.1 Severable Provisions

If any provision of these Terms and Conditions is found to be invalid, illegal, or unenforceable by an Estonian court or competent jurisdiction, such provision shall be:

• Severed (removed) from these Terms and Conditions.
• Reformed to the minimum extent necessary to make it enforceable, or
• Replaced with a valid provision reflecting the original intent.

16.2 Remaining Terms Enforceable

The invalidity or unenforceability of any provision does not affect the validity or enforceability of other provisions. These Terms and Conditions shall continue in full force and effect, with the invalid provision reformed or removed.

16.3 Estonia Law Supremacy

If a provision conflicts with mandatory requirements of Estonian laws or applicable international laws (GDPR, LGPD, CCPA), such provision is void to the extent of the conflict, and Estonia or international law shall control.

17. ENTIRE AGREEMENT

17.1 Complete Understanding

These Terms and Conditions, together with the Privacy Policy and Cookies Policy, constitute the entire agreement between SOLOMON and users regarding:

• Use of the Website.
• Provision of services.
• User rights and obligations.
• Limitation of liability.

17.2 Integration Clause

These Terms and Conditions supersede and replace all prior agreements, understandings, negotiations, and discussions between SOLOMON and users, whether written or oral, relating to the Website or services.

17.3 Incorporated Documents

The following documents are incorporated into these Terms and Conditions by reference and are binding on users:

• Privacy Policy at solomonbrokerage.com/privacy.
• Cookies Policy at solomonbrokerage.com/cookies.
• Statement of Work (SOW) or Formal Proposal for active consulting engagements (specific SOW terms may modify general T&C).

In case of conflict between the SOW and these T&C, the SOW controls for that specific engagement.

17.4 No Other Agreements

No website user, customer service representative, or partner is authorized to make oral agreements that modify these Terms and Conditions. Modifications must be in writing and signed by an authorized representative of SOLOMON (typically the President or Legal Officer).

18. WAIVER

18.1 No Waiver by Silence

SOLOMON’s failure to enforce any provision of these Terms and Conditions does not constitute a waiver of that provision. SOLOMON retains the right to enforce all provisions at any time.

18.2 Specific Waivers

No waiver of any provision is effective unless in writing and signed by an authorized representative of SOLOMON. Oral waivers are void and unenforceable.

18.3 Waiver Does Not Excuse Future Performance

If SOLOMON waives enforcement of a provision in one instance, such waiver does not excuse non-compliance in future instances. Each instance is separate and independent.

18.4 Waiver of Rights

Users waive the following rights by accepting these Terms and Conditions:

• Right to jury trial (if applicable).
• Right to participate in class action litigation.
• Right to sue in a non-EU jurisdiction.
• Right to demand oral hearing in mediation or arbitration (if mediation/arbitration is elected).

19. CONSTRUCTION AND INTERPRETATION

19.1 Headings

Section headings (e.g., “Intellectual Property Rights,” “Privacy and Data Protection”) are for convenience only and do not define or limit the scope of those sections.

19.2 No Strict Construction

These Terms and Conditions shall not be construed strictly for or against either party based on who drafted the document. Both parties had the opportunity to review and negotiate these terms.

19.3 Definitions

• “Website” means solomonbrokerage.com and all subdomains, content, and services accessible through it.
• “SOLOMON,” “we,” “us” means Solomon Brokerage OÜ and its officers, employees, and authorized agents.
• “User,” “you,” “your” means any person or entity accessing the Website.
• “Services” means consulting, advisory, information, and other services provided by SOLOMON.
• “Personal Data” means any information relating to an identified or identifiable individual.
• “Force Majeure” has the meaning specified in Section 14.1.
• “Effective Date” means December 17, 2024, the date these Terms and Conditions become effective.

19.4 Plural and Singular

The plural form of any term includes the singular, and the singular includes the plural, as context requires.

19.5 Business Days

“Business Days” means Monday through Friday, excluding Estonian public holidays and SOLOMON office closures. Notices sent on non-business days are deemed received on the next business day.

20. CONTACT AND NOTICES

20.1 Notice Requirements

Any notice, demand, or communication required or permitted under these Terms and Conditions must be:

• In writing (email, letter, or certified mail).
• Delivered to the addresses specified below.
• Delivered in Spanish or English.

20.2 SOLOMON’s Contact Information

All notices to SOLOMON must be sent to:

For General Inquiries:

• Email: info@solomonbrokerage.com.

For Legal Notices:

• Email: info@solomonbrokerage.com.
• Physical Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.
• Subject Line: “LEGAL NOTICE”.

For Data Protection Requests (GDPR, LGPD, CCPA):

• Email: info@solomonbrokerage.com.
• Subject Line: “GDPR Data Request,” “LGPD Data Request,” or “CCPA Data Request” (as applicable).

20.3 User’s Contact Information

Users are responsible for maintaining current contact information. Users may update contact information by:

• Contacting info@solomonbrokerage.com.
• Updating account settings on the Website (if applicable).

Notices sent to the user’s last known email address are deemed received.

20.4 Timing of Receipt

Notices are deemed received:

• Via Email: Within 24 hours of sending (unless email is undeliverable).
• Via Certified Mail: Upon signature or after 5 business days if unclaimed.
• Via Courier (FedEx, DHL): Upon delivery confirmation.
• Via Hand Delivery: Upon personal receipt.

20.5 Effective Date of Notices

Notices become effective on the date of receipt, except that termination notices become effective on the date specified in the notice (or 5 business days if no date is specified).

21. MISCELLANEOUS PROVISIONS

21.1 Assignment and Delegation

21.1.1 SOLOMON’s Right to Assign

SOLOMON may assign these Terms and Conditions to any successor company, acquirer, or affiliate without user consent. Such assignment is effective upon written notice to users.

21.1.2 User’s Restriction

Users may not assign these Terms and Conditions or any rights hereunder without SOLOMON ’s prior written consent. Any unauthorized assignment is void.

21.2 Relationship of Parties

Nothing in these Terms and Conditions creates:

• A partnership, joint venture, or agency relationship.
• An employment relationship.
• A confidential relationship (except as explicitly stated regarding data protection).
• An exclusive dealing arrangement.

21.3 Third-Party Beneficiaries

These Terms and Conditions are for the exclusive benefit of SOLOMON and users. No third party (including strategic partners, investors, or creditors) has any right to enforce these terms.

21.4 No Obligation to Monitor

SOLOMON has no obligation to:

• Monitor user content or activity (except for security and compliance purposes).
• Police violations of these Terms and Conditions.
• Remove user-submitted content or communications.

However, SOLOMON reserves the right to do any of the above at its discretion.

21.5 Survival of Terms

The following provisions survive termination or expiration of these Terms and Conditions:

• Intellectual Property Rights (Section 4).
• Limitation of Liability (Section 9).
• Privacy and Data Protection (Section 7).
• Governing Law (Section 13).
• Dispute Resolution (Section 13).
• Severability (Section 16).
• Entire Agreement (Section 17).
• Indemnification (Section 6.4).

All other provisions terminate upon termination of these Terms and Conditions.

22. EFFECTIVE DATE AND ACCEPTANCE

22.1 Effective Date

These Terms and Conditions are effective as of December 17, 2024 and apply to all users accessing the Website on or after this date.

22.2 Acceptance by Use

By accessing the Website, submitting a contact form, requesting a quote, or engaging with SOLOMON services, users acknowledge that they:

• Have read these Terms and Conditions in their entirety.
• Understand and accept all provisions.
• Agree to be legally bound by these terms.

22.3 Acknowledgment

Users may print or download these Terms and Conditions by selecting “Print” or “Save As PDF” in their browser.

22.4 Questions

If users have questions about these Terms and Conditions, they should contact:

• Email: info@solomonbrokerage.com.
• Physical Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia.

ACKNOWLEDGEMENT

By accessing and using the Website or engaging SOLOMON’s services, you acknowledge:

• You have read these Terms and Conditions in full.
• You understand and accept all provisions.
• You are legally bound by these terms.
• You waive any claim that you did not have adequate notice of these terms.
• You consent to electronic delivery of notices and disclosures.
• You represent that you have the authority to enter into this agreement.

SOLOMON BROKERAGE OÜ

• Address: Tornimäe 5, Harju County, 10145 Tallinn, Estonia
• Email: info@solomonbrokerage.com
• Effective: December 17, 2024

END OF TERMS AND CONDITIONS

Document Version: 1.2
Last Updated: August 18, 2026
Status: APPROVED FOR USE