IceBrkn Privacy Policy

IceBrkn Holdings, Inc. ("IceBrkn," "we," "us") operates the IceBrkn web and mobile applications and related services (the "Services") — a relationship-intelligence network that helps you understand and connect with people in your network. This Policy explains what personal information we collect, how we use and share it (including how AI is used), and your rights.

Purpose & intended use. IceBrkn is designed to help users understand and strengthen existing professional and personal relationships — not to facilitate surveillance, background investigations, or the collection of information for employment screening, credit, housing, insurance, or other regulated decision-making. (This aligns with the FCRA limits in our Terms of Service.) We are committed to providing meaningful transparency about what information we collect, how it is used, who it is shared with, and the choices available to you.

Your Choices. You control the information you provide, the Connected Services you authorize, your profile visibility, your AI provider (where applicable), and many privacy settings within the Services. Additional rights and choices are described in Section 9.

1. Information We Collect

You provide:

• Account & profile: name, email, phone, password, photo, headline, role, company, industry, location, and the profile details you add across your business, professional, personal, and lifestyle information.
• Authentication providers: where supported, sign-in identifiers from an identity provider you choose (such as Sign in with Apple or Google Sign-In).
• Contacts you import: when you connect an account or upload contacts, the contact details you choose to share (names, emails, phones, companies, notes). You represent you have the right to share them — see the Terms. We do not automatically message the contacts you import.
• Content: messages, connection requests, private notes you record about people, events you create/attend, and search prompts.
• Your AI credentials (BYOK): if you connect your own AI provider key (such as Anthropic, OpenAI, Google, or xAI), we store it encrypted at rest and use it only to perform the AI tasks you request. We do not use it for anything else.
• Payment information: processed by third-party payment providers, such as Stripe or the Apple App Store, as applicable. IceBrkn does not store your full payment card information.

Collected automatically: device and identifier data (IP, device type, OS, app/browser), usage data (screens, actions, timestamps), AI usage and consumption data (which AI features you use and the volume and processing cost of that usage, which we use to operate the Services and to calculate your credit usage — see the Terms), approximate/precise location (e.g., for event check-in and "current location," where you permit it), QR-scan events, and cookies/SDK identifiers.

Our use of cookies and similar technologies is described in our Cookie Policy. IceBrkn does not use cookies to build advertising profiles or sell advertising based on your browsing behavior.

We generate or infer:

• Briefs and inferences: AI-synthesized summaries of a person, "why-match" reasoning, suggested approaches, match scores, and network insights. These are automated inferences and may be inaccurate (see the Terms).
• Trust tiers and relationship signals: computed from your connections, interactions, co-attendance, and reputation (see §4, Relationship Intelligence).

From third-party sources (enrichment): to build and complete profiles, we draw on (a) information already within IceBrkn, (b) publicly available information (e.g., public web and social profiles), and (c) data connectors you authorize (for example, a business-data or meeting-intelligence provider you connect). This may include information about people who are not IceBrkn users (see §11).

2. How AI Is Used (important)

IceBrkn uses AI to generate Briefs, dossiers, match suggestions, assistant replies, drafts, and insights. AI runs in one of two modes: managed AI (the AI we run for you) or Bring-Your-Own-Key (BYOK) (AI you run on your own provider key).

• Managed AI (AI we run for you). On the free tier and on paid tiers, IceBrkn runs AI on your behalf using third-party AI providers under IceBrkn's own provider accounts. We currently use Anthropic, OpenAI, and Google as managed AI providers. To generate an output, we send the provider only the data needed for that request (for example, the visibility-permitted facts about a subject and your request or notes). For reliability, a request may be routed to an alternate provider if one is unavailable, and for certain relationship synthesis we may send the request to more than one provider and combine the results to cross-check them. We surface which provider and model were used.
• Our commitments for managed AI. We engage these providers under terms intended to (a) use your data only to perform your request, (b) not train the providers' models on your data, and (c) limit how long they retain it. Some AI also grounds on public information. To prepare a dossier or enrich a profile, managed AI may search publicly available sources (for example, public web pages) about the person you are preparing to meet, extract relevant information, retain only what is necessary to provide the Services, and discard temporary retrieval results where appropriate (see §§10–11 on non-users and enrichment).
• Bring-Your-Own-Key (BYOK): AI synthesis runs through the AI provider you configure, using your API key. When you request a Brief, we send that provider only the visibility-permitted facts about the subject plus your private notes.
• We do not sell your data — or your prompts or personal information — to AI providers, and we do not use your content to train our own models.
• Provider control (important): your chosen AI provider processes the request under its own terms and policies. We cannot control how your selected AI provider processes, retains, or uses information under its own policies, and different providers have different retention practices. We surface which provider/model was used.
• Automated processing / profiling: Briefs, match scoring, trust tiers, and your personal agents are automated. Where required (e.g., GDPR Art. 22, CCPA), you may request human review or object — see §9.
• Actions on your behalf are gated. Where Noa can act for you (for example, drafting an outreach message, or booking or sending on a connected account), it prepares the action and you approve it before it happens — nothing is sent or scheduled without your specific approval.
• Changes to managed AI. Managed AI, and the providers we use, are described above. If we materially change which providers we use, or how managed AI processes your data, we will update this Policy and the in-product disclosures.

3. Relationship Intelligence

Relationship intelligence is core to how IceBrkn works, so we describe it plainly. To help you understand and strengthen your relationships and to recommend introductions and opportunities, we analyze information such as:

• your connections and connection pathways / warm paths (routes to reach someone through people you both know);
• mutual contacts and mutual introductions;
• shared experiences, shared organizations, and event / conference overlap;
• interaction history and communication activity you authorize; and
• information you provide (notes, goals, and preferences).

From these, we generate estimates — connection strength, relationship scores, warm-path recommendations, and the reasoning that may be used to prioritize introductions and opportunities. These are estimates, not verified facts or endorsements, and should be independently verified before you act on them (see the Terms). Where helpful, IceBrkn may provide a limited "why this recommendation" explanation based on available information.

4. Visibility & Your Control of Your Profile

IceBrkn uses a tiered visibility model: you control which profile fields are visible to whom based on your relationship tier with the viewer (e.g., public → connected → inner circle). Briefs only ever include facts a given viewer is permitted to see. Your private notes are never visible to anyone else — they are for you alone. You can edit visibility, block users, and manage your profile in Settings.

5. How We Use Information

To provide and personalize the Services; generate Briefs/insights and relationship intelligence; surface your Daily Brief and notifications; run the personal agents you enable; operate trust and visibility; process payments and meter AI usage and calculate credit consumption; secure the Services and prevent abuse; comply with law; and communicate with you.

6. How We Share Information

• Other users, per your visibility settings.
• Service providers / processors acting on our behalf, described by category with representative examples (a current list is available at Connected Services ):
• Payment providers (e.g., Stripe, Apple App Store)
• Identity providers (e.g., Sign in with Apple, Google)
• Messaging / SMS (e.g., Twilio)
• Push notifications (e.g., Google Firebase Cloud Messaging)
• Email & auth (e.g., Google, Microsoft) Embeddings / search, analytics, and hosting/infrastructure providers
• AI providers, on the managed and BYOK bases described in §2 — We use one or more AI providers, as described on our Connected Services page.
• Legal / safety: to comply with law, enforce terms, or protect rights/safety (see §14).
• Corporate transactions: in a merger, acquisition, financing, or sale.
• We do not sell personal information.

Each of these providers processes personal information only on our behalf and under our documented instructions — as a "processor" or "sub-processor" under the GDPR/UK GDPR and as a "service provider" under the CCPA/CPRA — solely to perform services for us. We enter into data processing agreements with them that require confidentiality, appropriate security safeguards, and (for EEA/UK data) Standard Contractual Clauses or another lawful transfer mechanism. We do not authorize them to use your information for their own purposes, and we do not "sell" or "share" (as those terms are defined under California law) personal information to them. A current list of these providers is available on our Connected Services page.

7. Messaging & SMS

If you send a connection request or message that results in an SMS, you direct us to send it on your behalf to a person you are connecting with. Recipients can opt out (reply STOP). We use a messaging provider (e.g., Twilio) for delivery. You direct us to send these messages when you initiate an action (such as a connection request or a verification), each message identifies IceBrkn and includes opt-out instructions, and we honor a STOP reply by suppressing further messages to that number (reply HELP for information). Message and data rates may apply. Opting out of SMS does not affect email or in-app notifications. This aligns with the SMS terms in our Terms of Service and our TCPA/A2P compliance posture.

8. Retention

We keep personal information as long as needed to provide the Services, meet legal obligations, resolve disputes, and enforce agreements; retention varies by data type and your settings. We delete or de-identify when no longer needed.

9. Your Rights & Choices

• Access, correct, delete, export your information: privacy@icebrkn.com.
• What deleting your account removes. When you delete your account, we will delete or de-identify your profile, messages, private notes, imported contacts, dossiers, stored BYOK key, subject to limited exceptions required by law or for security/fraud, and to backups that expire on a rolling schedule.
• Data portability. Where supported, you may export your information in a machine-readable format (e.g. CSV).
• BYOK key: view (masked), revoke, or delete your stored AI key anytime in Settings.
• Profile visibility, blocking, notification preferences: in-app.
• GDPR/UK (EEA users): access, rectification, erasure, portability, restriction, objection (incl. to profiling), withdraw consent, and complain to a supervisory authority. Legal bases: performance of a contract, our legitimate interests, and, where applicable, your consent, depending on the processing.
• California (CCPA/CPRA): know, delete, correct, opt-out of sale/share, limit sensitive-data use, non-discrimination; authorized agents.
• Automated decisions: request human review/objection where applicable (§2).

10. People Who Are Not IceBrkn Users

IceBrkn may hold information about non-users (e.g., a user's imported contact, or enrichment from publicly available or authorized sources) to provide the Services, including relationship intelligence, to our users. We use non-user information only to provide the Services to our users; we do not use it to create public-facing profiles of non-users, and we do not sell it. If you are not a user and want to access or delete information about you, contact privacy@icebrkn.com ; we will honor applicable rights and provide a mechanism to opt out / be removed.

11. Enterprise & Company Workspaces

If you use IceBrkn through a company, team, or organization ("Workspace"): the organization (through its administrators) controls the Workspace and the data submitted to it, and that data is treated as owned and controlled by the organization. Administrators may provision and remove employee accounts, configure settings, and export or delete Workspace data, and may access content associated with the Workspace consistent with the organization's policies and applicable law. If you use IceBrkn as part of an organization, this Policy applies together with the organization's own policies and any enterprise agreement.

12. Security

We use technical and organizational safeguards designed to protect personal information, including encryption in transit and at rest (for sensitive items such as BYOK keys), role-based access controls, least-privilege access, and audit logging, among other measures. No method of storage or transmission is perfectly secure.

13. Law Enforcement & Legal Requests

We may access, preserve, and disclose information in response to lawful legal requests (such as subpoenas, court orders, or other valid legal process), to comply with applicable law, or to protect the rights, property, or safety of IceBrkn, our users, or the public. Where appropriate and permitted, we review requests for validity and scope.

14. International Transfers

We may process information in the United States and other countries. For EEA/UK transfers we rely on Standard Contractual Clauses or other appropriate safeguards.

15. Children

The Services are not directed to children under 18 years of age; we do not knowingly collect their data.

16. Additional Permissions & Connected Services

Depending on the features you choose to use, IceBrkn may request permission to connect to third-party services or device capabilities. These connections are always optional, and you can disconnect them at any time through your account settings or the applicable third-party service. Examples include:

• Contacts — to import and organize your professional network.
• Calendar (a calendar provider such as Google Workspace, Microsoft 365, or Apple/iCloud, where supported) — to prepare meeting Briefs and event-related insights.
• Email (an email provider such as Google Workspace or Microsoft 365) — to generate meeting preparation and power user-authorized relationship intelligence.
• Meeting Notes & Notetakers (a meeting-intelligence provider) — to analyze user-authorized meeting transcripts and generate follow-ups and relationship insights.
• CRM systems — to enrich relationship data and provide business intelligence.
• Messaging platforms — to support user-authorized communication workflows.
• AI providers (BYOK) — to generate AI-powered Briefs and insights using your selected provider.
• Camera & QR code access — for profile photos, event check-in, and exchanging contact information.
• Location — for nearby events, check-in, and location-enabled features, when enabled.
• Microphone & voice — for voice interactions with Noa and voice-powered features.
• Connected wearables or smart glasses (future) — only with additional disclosures and consent where required (see below).

Two principles govern this section: 1. IceBrkn only accesses information that you explicitly authorize, and only for the functionality you choose to enable. 2. Disconnecting a Connected Service stops future synchronization from that service but does not automatically remove information previously imported into IceBrkn unless you delete it or request deletion, as described in this Policy.

We describe connected services by category here; a separate Connected Services page lists the current integrations and any service-specific disclosures, so this Policy stays stable as integrations are added or changed.

Biometrics (camera / glasses). If we launch capture via connected eyewear (e.g., a smart-glasses integration) or any feature that processes faces or other biometric identifiers, we will provide a separate, explicit consent flow and disclosure before enabling it, consistent with biometric-privacy laws (e.g., Illinois BIPA).

17. Changes & Contact

We will post changes here and update the Effective Date; material changes will be notified as required by law. Contact: privacy@icebrkn.com IceBrkn Holdings, Inc., 5600 W. Lovers Lane #116-214, Dallas, TX 75209.

Connected Services

Last Updated: August 11, 2026

IceBrkn connects to third-party services that you choose to authorize in order to provide Relationship Intelligence, AI-powered features, meeting preparation, introductions, and other functionality.

Connections are always optional. You control which services you connect, the permissions you grant, and you may disconnect them at any time.

Our Principles

IceBrkn follows four core principles when working with Connected Services.

User Authorization

IceBrkn only accesses third-party services that you explicitly choose to connect.

Purpose Limitation

Information from Connected Services is used only to provide the features you enable.

Transparency

We identify the categories of Connected Services we support and describe how they are used.

User Control

You may disconnect Connected Services or revoke permissions at any time through IceBrkn or the applicable third-party provider.

Connected Service Categories

Identity Providers

Examples include:

• Sign in with Apple
• Google Sign-In
• Microsoft Purpose
• Authentication
• Secure account access
• Account recovery Email Providers Examples include:
• Gmail
• Google Workspace
• Microsoft Outlook
• Microsoft 365
• Apple Mail (where supported) Purpose
• Meeting preparation
• Relationship activity
• User-authorized relationship intelligence
• Communication workflows IceBrkn only accesses information necessary for the features you enable.

Calendar Providers

Examples include:

• Google Calendar
• Microsoft Outlook Calendar
• Apple Calendar (where supported) Purpose
• Meeting Briefs
• Relationship preparation
• Event intelligence
• Scheduling assistance Contacts Examples include:
• Google Contacts
• Apple Contacts
• Microsoft Contacts Purpose
• Import your network
• Relationship management
• Introduction pathways
• Duplicate detection IceBrkn does not automatically message imported contacts.

CRM Platforms

Examples may include:

• Salesforce
• HubSpot
• Affinity
• Wealthbox
• Redtail Purpose
• Relationship intelligence
• Customer insights
• Team collaboration
• Meeting preparation Meeting Intelligence Examples may include:
• Fireflies.ai
• Otter.ai
• Fathom
• Zoom AI Companion Purpose
• Analyze meeting transcripts
• Generate follow-up actions
• Capture relationship context
• Improve meeting preparation AI Providers Managed AI currently uses providers such as:
• Anthropic
• OpenAI
• Google Bring Your Own Key (BYOK) also supports providers such as:
• Anthropic
• OpenAI
• Google
• xAI Purpose
• Generate Briefs
• Relationship Intelligence
• Meeting preparation
• Writing assistance
• Voice interactions When using BYOK, requests are processed under your selected provider's terms and privacy policies.

Voice Providers

Examples may include:

• ElevenLabs Purpose
• Voice conversations with Noa
• Voice output
• Audio playback Messaging Providers Examples include:
• Twilio Purpose
• SMS delivery
• Verification codes
• User-authorized communication Recipients may opt out of SMS communications at any time.

Cloud Infrastructure

IceBrkn uses AWS infrastructure providers for hosting, storage, networking, and security.

Purpose

• Operate the Services
• Store authorized information
• Secure the platform
• Maintain availability Push Notification Providers
• Examples include:
  • Google Firebase Cloud Messaging (FCM)
  • Apple Push Notification service (APNs)
• Purpose
  • Deliver in-app and push notifications
  • Alert you to connection requests, Briefs, and account activity
  Permissions Each Connected Service requests only the permissions necessary for the functionality you choose to enable.

Depending on the service, permissions may include:

• Read contacts
• Read calendar events
• Read email metadata
• Read meeting transcripts
• Access CRM records
• Authenticate your account
• Generate AI requests
• Send user-authorized messages You can review or revoke permissions through the applicable provider at any time.

Disconnecting a Connected Service

Disconnecting a Connected Service:

• Stops future synchronization.
• Prevents IceBrkn from accessing new information from that service.
• Does not automatically remove information previously imported into your IceBrkn account.

Previously imported information continues to be governed by the Privacy Policy unless you delete it or request its deletion where applicable.

Provider Changes

IceBrkn may add, remove, or replace Connected Services over time.

This page reflects the current categories and representative providers supported by the Services.

Learn More

For additional information, please see:

• Terms of Service