Privacy Policy
Last updated: April 2026
1. Data Controller
ICMD ("we," "us," or "our") is the data controller responsible for your personal data collected through icmd.app. If you have any questions about how we process your data, contact us at privacy@icmd.app.
2. Information We Collect
2.1 Information You Provide Voluntarily
- Newsletter subscription: When you subscribe to our newsletter, you provide your email address. We collect this only with your explicit consent.
- Contact inquiries: If you contact us via email, we collect the information you provide in your message.
2.2 Information Collected Automatically
- Server logs: Our web server may collect standard log data including your IP address, browser type and version, operating system, referring page, pages visited, and timestamps. This data is collected based on our legitimate interest in maintaining website security and performance.
- Cookies: We use minimal, strictly necessary cookies. See our Cookie Policy for full details.
2.3 Information We Do Not Collect
We do not collect special categories of personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data). We do not use third-party advertising trackers or behavioral profiling.
3. Legal Basis for Processing (GDPR Article 6)
We process your personal data only when we have a valid legal basis to do so:
| Processing Activity | Legal Basis | GDPR Article |
|---|---|---|
| Newsletter delivery | Consent — you actively opt in | Art. 6(1)(a) |
| Server log collection | Legitimate interest — security & performance | Art. 6(1)(f) |
| Cookie consent storage | Legitimate interest — functional necessity | Art. 6(1)(f) |
| Responding to your inquiries | Legitimate interest — communication | Art. 6(1)(f) |
4. How We Use Your Information
We use the information we collect to:
- Deliver our newsletter to consenting subscribers
- Ensure the technical functionality and security of our website
- Analyze aggregated, anonymized traffic patterns to improve content
- Respond to your inquiries and requests
- Comply with legal obligations
We do not sell, rent, or share your personal data with third parties for marketing purposes. We do not engage in automated decision-making or profiling that produces legal effects concerning you.
5. Data Sharing and Recipients
We may share your data with the following categories of recipients, strictly as needed:
- Hosting providers: To serve our website infrastructure
- Email service providers: To deliver newsletter emails (only for subscribers)
All service providers are contractually bound to process data only on our instructions and in compliance with GDPR (Article 28 — Data Processing Agreements).
6. International Data Transfers
Your data may be processed in countries outside the European Economic Area (EEA). When this occurs, we ensure appropriate safeguards are in place, including:
- EU Commission adequacy decisions (GDPR Article 45)
- Standard Contractual Clauses (GDPR Article 46(2)(c))
You may request a copy of the safeguards in place by contacting us at privacy@icmd.app.
7. Data Retention
| Data Type | Retention Period |
|---|---|
| Newsletter subscriber email | Until you unsubscribe, then deleted within 30 days |
| Server logs (IP, browser, pages) | 90 days |
| Cookie consent preference | 365 days (stored locally in your browser) |
| Contact inquiry data | Until resolved, then 12 months |
After the retention period expires, data is securely deleted or anonymized.
8. Your Rights Under GDPR
Under the General Data Protection Regulation, you have the following rights regarding your personal data:
- Right of access (Article 15): Request a copy of all personal data we hold about you.
- Right to rectification (Article 16): Request correction of inaccurate or incomplete data.
- Right to erasure (Article 17): Request deletion of your personal data ("right to be forgotten").
- Right to restriction (Article 18): Request that we limit how we process your data.
- Right to data portability (Article 20): Receive your data in a structured, commonly used, machine-readable format.
- Right to object (Article 21): Object to processing based on legitimate interest.
- Right to withdraw consent (Article 7(3)): Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at privacy@icmd.app. We will respond within 30 days as required by GDPR Article 12(3). If we need additional time (up to 60 more days for complex requests), we will inform you within the initial 30-day period.
9. Right to Lodge a Complaint
If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement (GDPR Article 77). We encourage you to contact us first so we can address your concern directly.
10. Cookies
ICMD uses minimal cookies necessary for website functionality. We do not use advertising cookies or third-party tracking cookies. For complete details, please see our Cookie Policy.
11. Children's Privacy
ICMD does not knowingly collect personal information from children under 16 years of age. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information promptly (GDPR Article 8).
12. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction (GDPR Article 32). These measures include:
- HTTPS encryption for all connections (TLS)
- Security headers (X-Content-Type-Options, X-Frame-Options, Referrer-Policy)
- Regular review of data processing practices
- Access controls limiting who can access personal data
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes that affect how we process your data, we will provide prominent notice on our website. We encourage you to review this page periodically.
14. Contact
For any questions about this Privacy Policy or to exercise your data protection rights:
- Email: privacy@icmd.app
- Subject line: "Data Protection Request" for GDPR-related inquiries