Privacy Policy

1. Introduction

Welcome to Icebreaker. This Privacy Policy explains how Icebreaker Connect, Inc. ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our networking platform and related services (the "Service"). By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Information You Provide to Us

Account Information: When you create an account, we collect information such as:

• Name and contact information (email address)
• Professional information (job title, company, work experience)
• Profile information (bio, skills, interests, profile photo)
• Location information (city, state, country)

Communications: We collect information you provide when you:

• Send messages to other users
• Contact our customer support
• Participate in surveys or provide feedback
• Post content on the platform

Payment Information: If you purchase premium features, we collect billing information such as your name, billing address, and payment method details (processed securely through third-party payment processors).

2.2 Information We Collect Automatically

Usage Information: We automatically collect information about how you use our Service, including:

• Pages you visit and features you use
• Time spent on different sections
• Search queries and results
• Connections and interactions with other users

Device Information: We collect information about the device you use to access our Service:

• Device type, operating system, and browser type
• IP address and general location information
• Device identifiers if you opt into push notifications

Log Information: Our servers automatically record information when you use our Service:

• Access times and dates
• Referring websites
• Error logs and crash reports

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision

• Create and maintain your account
• Facilitate networking connections and communications
• Provide personalized content and recommendations
• Process payments for premium features

3.2 Service Improvement

• Analyze usage patterns to improve our platform
• Develop new features and functionality
• Conduct research and analytics
• Test and optimize user experience

3.3 Communication

• Send you service-related notifications
• Respond to your inquiries and support requests
• Provide updates about our Service

3.4 Safety and Security

• Protect against fraud, spam, and abuse
• Enforce our Terms of Service
• Comply with legal obligations
• Protect the rights and safety of users

3.5 AI-Powered Features

We use artificial intelligence and machine-learning systems, including third-party large language model and embedding APIs, to provide certain Service features. These features include:

• Spark, our AI networking assistant, which you can chat with to find relevant people, understand why someone may be a good connection, and draft outreach.
• Generating suggested messages and conversation starters that you may choose to use when communicating with other users.
• Generating a hypothetical preview of how a conversation with another member might go ("Imagine the Conversation").
• Producing short descriptive summaries of profile content (such as descriptions of projects you have shared) used in discovery features.
• Generating numerical representations ("embeddings") of profile content that allow us to surface relevant matches through semantic search.
• Ranking, filtering, and recommending profiles to help you find relevant people to connect with.

Information processed by AI features.To provide these features, we process information such as your profile, the networking goals you set, the assistant's saved context (or "memory") of your prior interactions with it, your chat history with Spark, the recent messages in a conversation for which you request a suggested reply, and the profiles of other members that are surfaced to you (for example, when Spark explains why someone may be a relevant connection).

When we use AI features:

• The profile and member information we send to AI providers is limited to what is needed to produce the feature. Before profile text is sent, we use automated measures designed to remove contact and identifying details such as email addresses, phone numbers, and links or URLs (including LinkedIn and other social profiles), and we limit any location information to a general area. These measures are automated and may not remove every instance, so you should avoid putting sensitive information you do not want processed into free-text profile fields.
• To suggest replies within an ongoing conversation, we send recent messages from that conversation to our AI providers. If you would prefer that we not use your conversations for these features, you can opt out by emailing privacy@joinicebreaker.com.
• We use OpenAI and Anthropic as our third-party AI providers (subprocessors). We send them only the information needed to produce the feature. Under their published API terms, these providers represent that they do not use data submitted through their APIs to train their models, and we rely on those representations.
• Embeddings derived from your profile are stored on our infrastructure and used internally for matching and discovery. They are not shared with other users.
• We keep our own records of AI feature usage (such as the request type, token counts, and cost) to monitor quality, manage costs, and detect abuse. See §7 for how long these are retained.

4. How We Share Your Information

4.1 With Other Users

• Profile information you choose to make public
• Messages and content you share through the platform

4.2 With Service Providers

We may share information with trusted third-party service providers who help us operate our Service:

• Cloud hosting and data storage providers
• Payment processors
• Email and communication service providers
• Analytics and marketing tools
• Customer support platforms
• Artificial intelligence and machine-learning service providers, currently OpenAI and Anthropic (used to generate suggested conversation prompts, profile summaries, embeddings used for semantic search, and similar AI-derived features described in §3.5). Under their published API terms, these providers represent that they do not use data submitted through their APIs to train their models, and we rely on those representations.

4.3 For Legal Reasons

We may disclose your information if required by law or in good faith belief that such disclosure is necessary to:

• Comply with legal obligations or court orders
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing
• Protect the safety of users or the public

4.4 Business Transfers

If Icebreaker Connect, Inc. is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

4.5 With Your Consent

We may share your information with third parties when we have your explicit consent to do so.

5. Your Privacy Rights and Choices

5.1 Account Settings

You can access, update, and modify your account information and privacy settings through your account settings in the app.

5.2 Communication Preferences

You can control the types of communications you receive from us by updating your notification settings or unsubscribing from marketing emails.

5.3 Data Access and Portability

You have the right to:

• Access the personal information we have about you
• Request a copy of your data in a portable format
• Correct inaccurate or incomplete information

5.4 Data Deletion

You can request deletion of your account and associated data, subject to certain limitations for legal compliance and legitimate business purposes.

5.5 Cookies and Tracking

You can control cookies through your browser settings, though this may affect the functionality of our Service.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy. Specific retention periods depend on the type of information and how it's used:

• Account information: Retained while your account is active and for a reasonable period after account deletion
• Communications: Retained according to our data retention policies
• Usage data: Typically retained for analytical purposes for a limited time
• AI provider logs: When we use AI features (see §3.5), our third-party AI providers may retain request logs for a short period (typically up to 30 days) for abuse prevention and operational integrity. Under their published terms, these providers state that they delete these logs after their retention window and do not use API data to train their models.
• AI interaction logs: We retain our own records of AI feature usage (such as request type, token counts, and cost), used for quality and cost monitoring and abuse detection, for a limited period consistent with our operational and security needs.

8. International Data Transfers

Our Service is operated from the United States. If you are located outside the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Service, you consent to the transfer of your information to the United States.

9. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

10. Third-Party Links and Services

Our Service may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.

11. State-Specific Privacy Rights

11.1 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act, including:

• Right to know what personal information is collected and how it's used
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising privacy rights

11.2 Other State Laws

Residents of other states may have additional privacy rights under applicable state laws. Please contact us to learn more about your specific rights.

12. European Economic Area (EEA) and UK Residents

If you are located in the EEA or UK, you have additional rights under the General Data Protection Regulation (GDPR), including:

• Right of access, rectification, and erasure
• Right to restrict or object to processing
• Right to data portability
• Right to withdraw consent
• Right to lodge a complaint with supervisory authorities

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our website
• Sending you an email notification
• Providing notice through our Service

Your continued use of our Service after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

14. Contact Us

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