Privacy Policy

Last updated: July 15th, 2024

Your privacy is important to us. This Privacy Policy explains our collection, use and disclosure of personal information that is collected or processed by IceBrkn Holdings, Inc. (“IceBrkn,” “we,” “us” or “our”) in connection with your access to and use of our website, register for events or webinars, your application for employment, or otherwise interact with us outside of our products and services (individually or collectively, our website and other interactions are referred to herein as the “Website”).  

Please take a moment to read this Privacy Policy to learn about our personal information collection, use, and disclosure practices that may affect you (“User,” “you” or “your”) when you access or use our Website. This Privacy Policy applies to our Website that displays or references this Privacy Policy, but it does not apply to our products and services governed under any separate agreements or where the data collection references a different privacy policy or notice.‍

IceBrkn products and services are intended for and provided to businesses and other organizations, and individual consumers or end-users. We process personal information relating to consumers or end-users at the direction of said individuals or our business customers, as applicable. In any case, and in all instances we process such information as a service provider or a “data processor” to those organizations, but we do not control and are not responsible for the privacy practices of those organizations. If you are a consumer end-user of an employer who instructs us to process your information, you should read that organization’s privacy statement and direct any privacy inquiries to that organization.‍

Your use of the Website and any information you provide through the Website remains subject to the terms of this Privacy Policy as well as our Terms of Use.

Personal Information We Collect

The personal information we collect depends on how you interact with us and the choices you make.‍

We collect information about you from different sources and in various ways when you use our Website, including information you provide directly, information collected automatically, information from third-party data sources, and information we infer or generate from other information.‍

Information you provide directly. We collect personal information you provide to us. For example:

• Name and contact information. We collect name, username or alias, and contact details such as email address, company name, postal address, and phone number. 
• Demographic information. We may collect job title or role, industry, or other demographic or firmographic information.  
• Content and files. If you send us email messages or other communications, we collect and retain those communications.  ‍
• Professional and employment information. We may collect information necessary to consider you for employment, such as your shift preferences, dependent information, government identifiers, date of birth, civil status, gender, and emergency contact information.  

Information we may collect automatically. When you use our Website, we collect some information automatically. For example:

• Identifiers and device information. When you visit our Website, our web servers may automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our Website stores and retrieves cookie identifiers, mobile IDs, and other data.
• Geolocation data. Depending on your device and settings, we collect geolocation data when you use our Website and during the onboarding process through integration with Google API. Users also have the option to manually add the location information of their contacts.  
• Usage data. We automatically log or record and analyze your activity on our Website, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our Website.
• Data Collection on IB Users. Contacts Information: We solely collect users’ contact information with the explicit consent of the users. We also may create profiles for users who are not currently using the IceBrkn platform, based on the information collected from the users’ social accounts or other public sources. We also collect information through integrations with third parties to enhance user experience and provide necessary services.
• Cookies Usage. We use cookies to enhance the user experience on our website and app.
• Google Analytics. We utilize Google Analytics to understand how our users use the website. You can read more about how Google uses personal information here: Google Privacy Policy. Users can also opt-out of Google Analytics using this link: https://tools.google.com/dlpage/gaoptout.

Information we create or generate. We may infer new information from other information we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.‍

Third-Party Tools and AI Models: Icebrkn does not share any user data with third-party tools, including AI models. We are committed to maintaining user privacy and ensuring that user data is not transferred or used by any third-party services that we do not control.

Information we obtain from third-party sources. We also obtain the categories of information described above from third parties. These third-party sources include, for example:

• Third party partners. Third-party applications and services, including any you choose to connect with or interact with through our Website.  When you voluntarily elect to link IceBrkn Service(s) with Third Party Services via OAuth or similar technologies, such as API Keys, IceBrkn does not collect your username or password to link such Third Party Services to  IceBrkn Service(s).
  IceBrkn’s use and transfer to any other app of information received from Google Accounts will adhere to the Google API Services User Data Policy, including the Limited Use requirements. For more information, please review the Google API Services User Data Policy. 

We use Stripe for payment processing. You can review their privacy policy here: Stripe Privacy Policy. Twilio is used to send out SMS. Their privacy policy can be found here: Twilio Privacy Policy.  Firebase is configured to send out emails for OTP verification. For more details, please refer to Firebase Privacy Policy.

• Co-Branding/Joint Partners. Partners with which we offer co-branded features or engage in joint marketing activities.
• Service providers. Third parties that may collect or provide data in connection with work they may do on our behalf, for example companies that determine your device’s location based on its IP address.
• Publicly available sources. Public sources of information such as open government databases.

When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or function correctly. ‍

Cookies, Mobile IDs and Similar Technologies

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our Website and to help collect data, including usage data, identifiers, and device information.‍

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.‍

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our Website (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.‍

How do we and our providers use cookies and similar technologies?

We, and our analytics and advertising providers, may use these technologies in our Website to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our Website, including personal information about your online activities over time and across different websites or online services. This information would be used to store your preferences and settings, enable you to sign-in, analyze how our Website performs, track your interaction with the Website, develop inferences, combat fraud, and fulfill other legitimate purposes. We and/or our providers also may share the information we collect or infer with third parties for these purposes.‍ For more information about the analytics and advertising providers that collect personal information on our Website, please see the “Our Disclosure of Personal Information ” section of this Privacy Policy.‍

What controls are available?

There are a range of cookie and related controls available through browsers, mobile operating systems, and elsewhere. See the “Choice and Control of Personal Information” section below for details.

Our Use of Personal Information. We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you. For example, we use personal information for the following purposes: 

We combine data we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience.

Our Sharing of Personal Data

We combine data we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience.

Our Disclosure of Personal Information

We disclose personal information as necessary to complete or fulfill the transactions you have requested or authorized or with your consent. For example, we disclose usage data and inferences with our advertising providers for analytics purposes. In addition, we disclose each of the categories of personal information described in this Privacy Policy, to the categories of recipients described below, for the following business purposes:  

• Vendors and Service Providers: We disclose personal information with vendors or agents working on our behalf for the purposes described in this Privacy Policy. For example, service providers who facilitate user account authentication or assist us in analyzing how our Website is being used. 
• Corporate Transactions: We may also disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

‍We will also access, transfer, disclose, and preserve personal information when we believe that doing so is necessary to:

• comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
• protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of our Website, including to prevent or stop an attack on our computer systems or networks; or
• protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

‍

Analytics and advertising companies may also collect personal information through our Website including identifiers and device information (such as cookie IDs, device IDs, and IP address), marketing and communications data, content and files, geolocation data, usage data, and inferences based on and associated with that data, as described in the Cookies section of this Privacy Policy. These providers may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our Website to help us understand how users interact with our Website; you can learn how Google collects and uses information at http://www.google.com/policies/privacy/partners.  ‍

Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states.  Please see the “Choice and Control” and “California Privacy Rights” sections below for more details.‍

Please note that some of the features on our Website may include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to disclose personal information with them, that information is governed by their privacy policies.‍

Finally, we may disclose de-identified information in accordance with applicable law. ‍

Choice and Control of Personal Information

We provide a variety of ways for you to control the personal information we process about you, including choices about how we use that information. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.‍

Access, correction, and deletion. If you wish to access, correct, or delete personal information about you that we hold about you, please email us at legal@icebrkn.com. 

Communications preferences. You can choose whether to receive promotional communications from us by email. If you receive a promotional email from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the “Contact Us” section below. These choices do not apply to certain informational communications including surveys and mandatory service communications. ‍

Targeted Advertising controls. To opt-out from or otherwise control targeted advertising, you have several options:  

• Modify the settings in your account; or 
• You can use the browser or platform controls described below.

These choices are specific to the browser you are using. If you access our Website from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.

Browser or platform controls.

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our Website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.  
• Do Not Track. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. There is not a common understanding of how to interpret the DNT signal; therefore, our Website does not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.  

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law.

European Data Protection Rights

If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that data: 

• You can request access to, and rectification or erasure of, personal information; 
• If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
• If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing; 
• You can to object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
• For residents of France, you can send us specific instructions regarding the use of your information after your death.

To make such requests, please email us at legal@icebrkn.com. When we are processing data on behalf of a business customer that is the “data controller,” you should direct your request to that business. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.‍

We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary for the functionality and maintenance of our Website, operate our business, meet our contractual and legal obligations, protect the security of our systems and our users, or fulfill other legitimate interests.

Our Data Processing Agreement: Data Processing Agreement‍

If you have questions or concerns about this Privacy Policy, you can reach our Data Protection Officer using the following information:

Email:  legal@icebrkn.com

Address: 5600 W Lovers Lane, Suite 116-214 Dallas, TX 75209‍

‍California Privacy Rights

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.  ‍

Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy by clicking on the above links.  ‍

Right to Know.  You have a right to request that we disclose to you the personal information we have collected about you.  You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information.  Note that we have provided much of this information in this Privacy Policy. To make such a “request to know” please email us at legal@icebrkn.com.‍

Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, please email us at legal@icebrkn.com.‍

Right to Opt-Out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.  ‍

Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by using the controls described in the “Choice and Control” section of this Privacy Policy. If you opt-out using these choices, we will not share or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA.  However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.  ‍

We do not knowingly sell or share the personal information of minors under 16 years of age.‍

Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use and disclosure of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law.  ‍

Note that we do not use or disclose sensitive personal information for any such additional purposes. ‍

Right to Non-Discrimination. You have a right to not be discriminated against for exercising these rights set out in the CCPA.‍

Exercising Your Rights. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.  ‍

‍Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law.‍‍

We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.  ‍

Retention of Personal Information 

We retain personal information for as long as necessary for operation of our Website and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data categories in the context of different transactions, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Location of Personal Information

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the information we collect under this Privacy Policy is processed and protected according to the provisions of this Privacy Policy and applicable law wherever the data is located.‍

Location of Processing European Personal Information. If we transfer personal information from the European Economic Area (EEA), UK, and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal information protection, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Our Policy Toward Children

IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE WEBSITE AT ANY TIME OR IN ANY MANNER.  

How We Protect Your Personal Information

We take reasonable steps to safeguard your information from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect personal information, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Changes to this Privacy Policy

We will update this Privacy Policy when necessary to reflect changes in our Website, how we use personal information, or the applicable law. When we post changes to the Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

Contacting UsIf you have any questions about our Privacy Policy or information practices, please contact us at legal@icebrkn.com. our address is  5600 W Lovers Lane, Suite 116-214, Dallas, TX 75209.