Privacy Policy

Last updated: January 29, 2026

At ICI Mager ("we," "our," or "us"), we are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us.

1. Information We Collect

1.1. Information You Provide

We collect information that you voluntarily provide to us when you:

• Register for our services or request a consultation
• Fill out contact forms or subscribe to our newsletter
• Communicate with us via email, phone, or other channels
• Participate in surveys, webinars, or other events
• Provide property and revenue data for our consulting services

This information may include: name, email address, phone number, company name, property portfolio details, revenue data, business information, and any other information you choose to provide.

1.2. Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and browsing behavior, including:

• IP address and location data
• Browser type and version
• Device information
• Pages visited and time spent on pages
• Referring website addresses
• Cookies and similar tracking technologies (see our Cookie Policy)

1.3. Information from Third Parties

We may receive information about you from third-party services, such as Property Management Systems (PMS), Channel Managers, and analytics providers, when you authorize us to access these services for our consulting and revenue management services.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To provide, operate, and maintain our Revenue Management and consulting services, including dynamic pricing, analytics, and reporting.
• Communication: To respond to your inquiries, send service-related communications, and provide customer support.
• Business Operations: To analyze property performance, generate revenue reports, create profitability dashboards, and optimize pricing strategies.
• Marketing: To send you promotional materials, newsletters, and information about our services (with your consent where required).
• Legal Compliance: To comply with legal obligations, enforce our terms of service, and protect our rights and interests.
• Improvement: To improve our website, services, and user experience through analytics and feedback.

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

• Contract Performance: To fulfill our contractual obligations when you engage our services.
• Legitimate Interests: To operate our business, improve our services, and communicate with clients (where our interests do not override your rights).
• Consent: When you have given explicit consent for specific processing activities, such as marketing communications.
• Legal Obligation: To comply with applicable laws and regulations.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information only in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our business (e.g., cloud hosting, analytics, payment processing), subject to strict confidentiality obligations.
• Business Partners: With Property Management Systems, Channel Managers, and other platforms you authorize us to integrate with for service delivery.
• Legal Requirements: When required by law, court order, or government regulation, or to protect our rights and safety.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, where your data may be transferred to the acquiring entity.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and updates
• Employee training on data protection
• Limited access to personal data on a need-to-know basis

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your data, we will securely delete or anonymize it. For active clients, we retain data for the duration of our service relationship and for a reasonable period thereafter for legal and business purposes.

7. Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data under certain circumstances.
• Right to Restrict Processing: Request limitation of how we process your data.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for marketing purposes.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.

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

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. We ensure that appropriate safeguards are in place to protect your data, including standard contractual clauses and adequacy decisions under GDPR.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will take steps to delete such information.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, 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

You also have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns adequately.