Privacy Policy

Privacy Policy

Effective Date: Last Updated:

This Privacy Policy describes how Rafael Tats LLC, doing business as ICM Tracker ("ICM Tracker," "we," "us," or "our"), collects, uses, shares, and protects your information when you visit, register, or otherwise interact with the ICM Tracker website, funnel, forms, SMS/text messaging programs, and related services (collectively, the "Services").

By using the Services, you acknowledge that you have read, understood, and agree to this Privacy Policy.


1. Information We Collect

We collect the following categories of information:

Information You Provide Directly:

  • Identity & contact information: name, email address, phone number, mailing address

  • Account information: username, password, profile details

  • Communication content: messages, form submissions, support inquiries

  • Payment information (when applicable): processed through PCI-compliant third-party processors; we do not store full card numbers

  • Information you submit when opting in to SMS/text messaging

Information Collected Automatically:

  • Device and browser information (IP address, browser type, operating system, device identifiers)

  • Usage data (pages viewed, time on site, referring URLs, click activity)

  • Cookies, pixels, and similar tracking technologies

Information from Third Parties:

  • Social media platforms when you log in via social authentication

  • Marketing partners and analytics providers

  • Publicly available sources


2. How We Use Your Information

We use the information we collect to:

  • Provide, operate, and maintain the Services

  • Process transactions and deliver requested products or services

  • Communicate with you regarding your account, inquiries, appointments, and customer support

  • Send you marketing, promotional, and informational communications (where permitted)

  • Send transactional and marketing SMS messages to numbers that have opted in

  • Personalize your experience and improve the Services

  • Detect, prevent, and address fraud, security issues, and abuse

  • Comply with legal obligations and enforce our agreements


3. SMS / Text Messaging Program Disclosure

This section governs our SMS messaging program and complies with the Telephone Consumer Protection Act (TCPA) and CTIA / A2P 10DLC carrier guidelines.

Opt-In: By providing your mobile phone number through any of our forms, opt-in checkboxes, keyword responses, or by initiating a text conversation with us, you expressly consent to receive recurring autodialed text messages from ICM Tracker at the number provided. Consent is not a condition of any purchase.

Types of Messages You May Receive:

  • Appointment reminders, scheduling confirmations, and transactional notifications

  • Lead follow-up and response communications

  • Marketing and promotional offers

  • Account, service, and customer-care messages

Message Frequency: Message frequency varies based on your interaction with us.

Message & Data Rates: Message and data rates may apply. Check with your wireless carrier for details.

Opt-Out: You may opt out at any time by replying STOP to any message you receive from us. After replying STOP, you will receive a single confirmation message and will not receive any further marketing or promotional texts. You may continue to receive transactional or service-related messages required to fulfill an existing transaction.

Help: For help, reply HELP to any message or contact us at [email protected].

Supported Carriers: Available on most major U.S. carriers, including AT&T, T-Mobile, Verizon Wireless, Sprint, Boost, U.S. Cellular, MetroPCS, and others. Carriers are not liable for delayed or undelivered messages.

No Mobile Information Sharing — Required A2P 10DLC Disclosure:

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All categories of information described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or affiliates. Information sharing strictly limited to subcontractors that directly support the Services (such as SMS delivery providers, e.g., Twilio) is permitted solely to the extent necessary to deliver the messages you have opted in to receive.


4. Cookies and Tracking Technologies

We use cookies, pixels, web beacons, and similar technologies to operate the Services, remember your preferences, analyze traffic, and deliver relevant content. Categories include:

  • Strictly necessary cookies (required for site functionality)

  • Performance and analytics cookies (e.g., Google Analytics)

  • Advertising and retargeting cookies (e.g., Meta Pixel)

  • Functional cookies (preferences and personalization)

You can control cookies through your browser settings or our cookie banner where available. Disabling cookies may limit certain features.


5. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information, including encryption in transit (TLS/SSL), access controls, and routine security review. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security of your data.


6. How We Share Your Information

We do not sell your personal information. We may share information only as follows:

  • Service providers / subcontractors that support the Services (e.g., hosting, payment processing, analytics, SMS delivery via Twilio, CRM via GoHighLevel) — under written agreements limiting use to the services they provide to us

  • Legal compliance — when required by law, subpoena, court order, or to protect rights, safety, or property

  • Business transfers — in connection with a merger, acquisition, financing, or sale of assets (you will be notified of any change in ownership)

  • With your consent — when you direct us to share information

As stated in Section 3, mobile opt-in data and SMS consent information are never shared with third parties or affiliates for marketing or promotional purposes.


7. Third-Party Links and Social Logins

The Services may contain links to third-party websites or allow you to register or log in via third-party social media accounts. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their policies before providing any information.


8. Your Rights and Choices

You have the following rights regarding your personal information:

  • Access — request a copy of the personal information we hold about you

  • Correction / Update — request that we correct inaccurate or incomplete information

  • Deletion — request that we delete your personal information, subject to legal retention requirements

  • Unsubscribe (Email) — click the "unsubscribe" link in any marketing email

  • Unsubscribe (SMS) — reply STOP to any text message

  • Opt out of cookies — adjust your browser or cookie banner settings

  • Withdraw consent — withdraw any consent you previously provided, where applicable

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before fulfilling certain requests.

California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to delete it, the right to correct inaccurate information, and the right to opt out of the "sale" or "sharing" of personal information. We do not sell or share personal information as those terms are defined under the CCPA. To submit a verifiable consumer request, email [email protected]. You may also designate an authorized agent to make a request on your behalf.


9. Children's Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from anyone under 13. If you believe a child has provided us with personal information, please contact us at [email protected] and we will promptly delete it.


10. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we securely delete or anonymize it.


11. Changes to This Privacy Policy

ICM Tracker reserves the right to update this Privacy Policy at any time. When we do, we will revise the "Last Updated" date above and post the revised policy on this page. Material changes will be communicated through the Services or by email where appropriate. Your continued use of the Services after changes take effect constitutes acceptance of the revised policy.


12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, contact us at:

Rafael Tats LLC d/b/a ICM Tracker Email: [email protected] Website: ICM Tracker


By using the ICM Tracker Services, you acknowledge that you have read, understood, and agree to this Privacy Policy and the related Terms and Conditions.