Cookie Policy

Last updated: January 29, 2026

1. What are cookies?

Cookies are small text files that are stored on your device (computer, tablet, or mobile) when you visit a website. These cookies allow the website to remember your actions and preferences over a period of time, so you don't have to reconfigure them every time you return to the site or navigate from one page to another.

Cookies are a tool used by web servers to store and retrieve information about visitors or users, and to improve the browsing experience.

2. Types of cookies

2.1. By purpose

• Technical cookies: These allow the user to navigate through a website and use the different options or services available. They are necessary for the site to function.
• Analytics cookies: These allow tracking and analysis of user behavior on websites. The information collected is used to measure website activity and create user navigation profiles.
• Personalization cookies: These allow the website to remember information so the user can access the service with certain characteristics that may differentiate their experience from other users.
• Marketing/advertising cookies: These store information about user behavior obtained through continuous observation of their browsing habits, which allows developing a specific profile to display advertising based on it.

2.2. By duration

• Session cookies: These are temporary and are deleted when the user closes the browser.
• Persistent cookies: These remain on the device for a certain period or until the user manually deletes them.

2.3. By origin

• First-party cookies: These are sent to the user's terminal equipment from a computer or domain managed by the publisher and from which the service requested by the user is provided.
• Third-party cookies: These are sent to the user's terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that processes data obtained through cookies.

3. Cookies used on this website

Note: This table may be updated periodically. Analytics and marketing cookies are only activated with your explicit consent.

4. Legal basis and applicable regulations

The use of cookies on this website is governed by the following European Union and Estonian regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016(General Data Protection Regulation - GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
• Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002(ePrivacy Directive) concerning the processing of personal data and the protection of privacy in the electronic communications sector, as implemented in Estonian law.
• Personal Data Protection Act of Estonia (Isikuandmete kaitse seadus), RT I, 15.03.2019, 39, which implements the GDPR in Estonia and establishes specific provisions for data protection in Estonia.
• Electronic Communications Act of Estonia (Elektroonilise side seadus), RT I 2004, 87, 593, which implements the ePrivacy Directive and regulates the use of cookies and similar technologies.

As a company operating in Estonia and serving users in the European Union, we are committed to full compliance with all applicable data protection and privacy regulations. Our cookie practices are designed to respect your privacy rights and provide you with full control over your personal data.

5. Consent and cookie management

In accordance with the GDPR and Estonian data protection legislation, we process cookies based on the following legal bases:

• Technical cookies: These are necessary for the website to function and are processed based on our legitimate interest (Article 6(1)(f) GDPR) in providing a functional website. These cookies do not require your consent under the ePrivacy Directive as they are strictly necessary for the service you have requested.
• Analytics, personalization, and marketing cookies: These require your explicit, informed, and freely given consent (Article 6(1)(a) GDPR and Article 5(3) ePrivacy Directive). We will only use these cookies if you have given your consent, which you can withdraw at any time.

Your consent must be:

• Freely given - you have a genuine choice
• Specific - you can consent to different categories separately
• Informed - you understand what you are consenting to
• Unambiguous - clear affirmative action is required
• Withdrawable - you can withdraw consent at any time

You can manage your cookie preferences at any time in the following ways:

• Through the cookie banner that appears on your first visit or when you clear your cookies.
• Through the "Configure Cookies" button available in the footer of all pages, which opens a preferences panel where you can enable or disable each category of cookies.
• Through your web browser settings (see the following section).

Your consent preferences are stored locally on your device and will be remembered for up to 12 months, after which we will ask for your consent again. You can change your preferences at any time, and your new preferences will take effect immediately.

6. How to disable or delete cookies

You can configure your browser to reject cookies or alert you when a website attempts to place a cookie on your device. Below, we provide links to instructions for the main browsers:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

Important: Please note that if you disable cookies, some website functionalities may not be available or work correctly.

7. Withdraw or modify consent

Under Article 7(3) of the GDPR, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. To withdraw or modify your consent:

1. Click on the "Configure Cookies" button in the footer of any page.
2. Modify your preferences in the panel that opens - you can disable any category of cookies (except technical cookies which are necessary for the website to function).
3. Click "Save preferences" to apply the changes immediately.

When you withdraw consent:

• We will immediately stop processing your personal data for the withdrawn categories
• Existing cookies from those categories will be disabled (though they may remain in your browser until you delete them)
• No new cookies from the withdrawn categories will be set
• Your withdrawal will be recorded and stored for our compliance records

You can also delete cookies stored in your browser by following the instructions provided in the previous section. Please note that if you delete all cookies, you will need to reconfigure your preferences, and we will ask for your consent again on your next visit.

8. Third-party cookies and data processors

This website may use third-party services that, in turn, use cookies. These third parties act as data processors on our behalf in accordance with Article 28 of the GDPR. We have entered into data processing agreements with these providers to ensure they comply with GDPR requirements. These services include:

• Vercel Analytics: Web analytics service that helps us understand how visitors interact with our website. Vercel processes data on our behalf and is GDPR compliant. Data is processed in the European Union. For more information, see Vercel's Privacy Policy.
• Google Analytics: Web analytics service provided by Google LLC. Google may process data in the United States under the EU-US Data Privacy Framework. We use Google Analytics only with your explicit consent. You can opt-out at any time through our cookie preferences. For more information, see Google's Privacy Policy and Google Analytics Opt-out.

Data transfers: Some third-party services may transfer data outside the European Economic Area (EEA). When such transfers occur, we ensure they are based on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or the EU-US Data Privacy Framework, in accordance with Chapter V of the GDPR.

9. Your rights under GDPR and Estonian law

As a data subject, you have the following rights regarding your personal data processed through cookies:

• Right of access (Article 15 GDPR): You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and access to that personal data.
• Right to rectification (Article 16 GDPR): You have the right to have inaccurate personal data corrected.
• Right to erasure (Article 17 GDPR): You have the right to request deletion of your personal data in certain circumstances.
• Right to restriction of processing (Article 18 GDPR): You have the right to restrict the processing of your personal data in certain circumstances.
• Right to data portability (Article 20 GDPR): You have the right to receive your personal data in a structured, commonly used format.
• Right to object (Article 21 GDPR): You have the right to object to processing of your personal data based on legitimate interests.
• Right to withdraw consent (Article 7(3) GDPR): You have the right to withdraw your consent at any time where processing is based on consent.
• Right to lodge a complaint (Article 77 GDPR): You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) if you believe your rights have been violated.

To exercise any of these rights, please contact us using the information provided in the Contact section below.

18. Contact Information

If you have any questions about these Terms of Service, please contact us:

• Company Name: ICI Mager
• Legal Entity Name: ICI Mager Consultant OÜ
• VAT Number: EE102732810
• Registered Address: Harju maakond, Tallinn, Kesklinna linnaosa, Pirita tee 26f-11, 12011