Last updated 1/22/24 

Introduction 

At Icebreaker, we take protecting your privacy very seriously. This Privacy Policy explains how we use personal information we collect about you when you use this website, our mobile apps, communications services, and other products and services (collectively, “our products”). This Privacy Policy applies to personal information we collect: 

• On the website and any of our mobile apps.

• In email, text, and other electronic messages between you and Icebreaker.

• Information provided to us through software applications we host or operate. 

• Through your social media platforms connected to your Icebreaker account.

As used below, “our products” refers to all of the above. By using any of our products, you agree to this Privacy Policy. This Privacy Policy may change from time to time, with dates posted upon each revision. By continuing to use our products, you agree to those changes.  

‍Children Under the Age of 18 

Icebreaker is not intended for use by anyone under eighteen (18) years of age. If you are under eighteen, please do not use our products. Icebreaker does not knowingly collect personal data from individuals under the age of 18. If you believe we might have any information from or about a child under eighteen (18), please contact us at privacy@icebreaker.xyz so we can delete that information. 

The Kinds of Personal Information We Collect 

‍Information You Provide to Us: This may include: 

• Information that you provide by filling in forms in our products, including credit card information, digital wallet information, or any other applicable payment information;

• Information that you provide directly or by adding or linking external accounts. This may include name, email address, postal address, telephone number, social media handle and content you publish on this social media handle or any other identifiers through which you may be contacted online or offline (collectively, “personal information”);

• Details of transactions you carry out through our products and of the fulfillment of your orders, as you may be required to provide financial information before placing an order;

• Information about blockchain transactions, including but not limited to your public key address or other public identifier related to your blockchain account and information about how you are using the Company’s blockchain infrastructure;

• Records and copies of your correspondence, including email addresses, if you contact us;

• Transcripts of your interaction with our site’s live chat; or

• Details regarding how you found our products and how you intend to use them, if applicable.You also may provide information to be published or transmitted to other users of our products, or third parties (collectively, “Your Contributions”). Your Contributions are provided at your own risk. Additionally, while we will take every measure to ensure Your Contributions are displayed only to authorized users, we cannot control the actions of other users of our products with whom you may choose to share Your Contributions. Therefore, we do not guarantee that Your Contributions will not be viewed by unauthorized persons.

• If you submit information to us that we believe places your privacy or security at risk, we may immediately delete that information. 

‍Information Collected Automatically: As you navigate through and interact with our products, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: 

• Your IP address

• Usage details, including the total time you spend on our website, the time you spend on each page, the order in which those pages were visited and the internal links clicked, the general geographic location from which you access our products, which browser and operating system you are using to visit our products, and the referring website;

• Performance details, including monitor page load times, CPU/memory usage, browser crashes and React component rendering; or

• Information about your computer and internet connection, including your IP address, operating system, and browser type. 

The technologies we use for this automatic data collection may include: 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.  

Social Media Sharing

Icebreaker products include social media features, such as the ability for a user to link their Twitter account. If you consent to link your Twitter account, we may share Tweets you have published with other authorized users of Icebreaker products. 

‍How We Use Your Information & Why We Collect It

‍We use information that we collect about you or that you provide to us, including any personal information:

• To present our products, and their contents to you;

• To manage our relationship with you;

• To communicate with you on how to use our products;

• To market our services and features;

• To fulfill any other purpose for which you provide it (including to interact with our affiliates or subsidiaries, or third parties that we contract with to provide our products on a white label basis);

• To carry out our obligations and enforce our rights under our Terms of Use, including restricting access to our products from specific Prohibited Jurisdictions (as defined in our Terms of Use);

• To allow you and other Icebreaker users to participate in interactive features on our products;

• To help facilitate the ongoing development of our products;

• In any other way we may describe when you provide the information; or

• For any other purpose with your consent. 

‍Disclosure of Your Information

‍We may disclose aggregated information, and information that does not directly identify any individual about our users without restriction. We may disclose personal information that you provide to us as described in this Privacy Policy: 

• To our subsidiaries and affiliates;

• To contractors, service providers, and other third parties we use to support our products;

• To provide you with information, products, or services that you request from us;

• To fulfill any other purpose for which you provide it;

• To provide you with notices about your account, including expiration and renewal notices;

• To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Icebreaker’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding;

• For any other purpose disclosed by us when you provide the information; or

• With your consent. 

We may also disclose your personal information: 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Icebreaker, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, or identifying malicious actors using our products, or Icebreaker’s affiliates or subsidiaries. We do not sell your personal information to third parties for monetary compensation. 

  
  

‍Privacy & The Blockchain

‍A key feature of many blockchain technologies, including any blockchain on which the Company’s services rely, is the transparency and public accessibility of on-chain transactions. As such, any information stored on-chain may be public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your account with the Company may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our services. 

‍Data Security

‍We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or our software applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our products. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our products. 

Special Disclosures related to the General Data Protection Act (GDPR)

Icebreaker is intended for and made available to U.S.-based individuals over 18. Notwithstanding, we are providing notice, that under the European General Data Protection Act, every user is entitled to the following:

• ‍Under the European General Data Protection Act, every user is entitled to the following: 

• The right to access – You have the right to request for copies of your personal data from us. We may charge you a small fee for this service.

• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

• The right to data portability – You have the right to request we transfer the data that we have collected to another organization, or directly to you, under certain conditions. 

If you make a request, we aim to respond to you within one month. If you would like to exercise any of these rights, please contact us at privacy@icebreaker.xyz. 

‍Data Protection Rights Under the California Consumer Privacy Act (CCPA) 

‍Icebreaker does not currently meet the threshold requirements for being in-scope for CCPA. Notwithstanding, if you are a California resident, you are entitled to learn what data we collect about you, ask us to delete your data, and not to share it. To exercise your data protection rights, you can ask us: 

• What personal information we have about you. If you make this request, we will return to you the categories of personal information we have collected about you.

  • The categories of sources from which we collect your personal information.

  • The business or commercial purpose for collecting your personal information.

  • The categories of third parties with whom we share your personal information.

  • The specific pieces of personal information we have collected about you.

  • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your information, we will inform you of that fact.

  • A list of categories of personal information that we have disclosed for business purposes, along with the category of any other company we shared it with. 

Please note, you are entitled to ask us to provide this information twice at any point in a rolling twelve (12) month period. When you make this request, the information we provide will be limited to the previous twelve (12) months. 

• To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate. 

• Icebreaker does not sell personal information without user consent, which may be obtained directly from Icebreaker or a third party used to access the Icebreaker products/services. Questions? Email privacy@icebreaker.xyz. Please note, if you ask us to delete your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. In no circumstances we will discriminate against you for exercising your rights. To exercise a deletion request, please send your request to privacy@icebreaker.xyz.

‍Changes to Our Privacy Policy

‍It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the website or app home page, or other digital communication channel. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. If you do not agree with this Privacy Policy, please refrain from using our website and platforms. Continued use of our products after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. 

‍What If I Have Questions About this Privacy Policy? 

If you have any questions about this Privacy Policy, please send a detailed message to privacy@icebreaker.xyz and we will try to resolve your concerns and provide further information.