Privacy Policy

IB-DOC-002
Icebreaker Privacy Policy
Document ID: IB-DOC-002
Version: 1.0
Effective Date: July 14, 2026

Icebreaker Data LLC (“Icebreaker,” “we,” “our,” or “us”) respects the privacy of our customers and is committed to protecting the information entrusted to us.

This Privacy Policy explains how Icebreaker collects, uses, maintains, and protects information obtained through the Icebreaker Platform, our website, and related evaluation services.

This Privacy Policy applies to customers evaluating the Icebreaker Platform under the Icebreaker Evaluation License Agreement (IB-DOC-001).

By accessing or using the Platform, you acknowledge that you have read and understand this Privacy Policy.

This Privacy Policy applies to information collected through:

• The Icebreaker website
• The Icebreaker Platform
• Evaluation environments
• Customer support interactions
• Product demonstrations
• Documentation portals
• Technical support requests

This Privacy Policy does not apply to third-party services that customers may choose to integrate with the Platform. Those services remain subject to their own privacy policies and terms.

Icebreaker collects only the information reasonably necessary to provide and support the evaluation of the Platform.

The information we collect generally falls into four categories.

When customers request an evaluation or create an account, we may collect:

• Name
• Business email address
• Company name
• Job title
• Telephone number
• Business address
• Communication preferences

This information allows us to administer the evaluation and communicate with Customer.

The Platform may use trusted third-party identity providers to authenticate users.

Depending on the authentication method selected, Icebreaker may receive:

• User name
• Business email address
• Organization
• Unique identity provider identifier

Icebreaker does not receive or store Customer passwords managed by those identity providers.

To operate and improve the Platform, Icebreaker may collect operational information such as:

• Browser type
• Operating system
• Device information
• IP address
• Session identifiers
• Login timestamps
• Platform version
• Diagnostic information
• Error reports

This information is used solely to operate, secure, troubleshoot, and improve the Platform.

When customers contact Icebreaker for assistance, we may retain:

• Email correspondence
• Meeting notes
• Support tickets
• Diagnostic information voluntarily provided by Customer
• Product feedback

This information is used only to support Customer’s evaluation and improve the Platform.

Customer Data remains the property of Customer at all times.

Icebreaker does not acquire ownership of Customer Data through Customer’s use of the Platform.

For purposes of this Privacy Policy, Customer Data includes:

• Structured data
• Metadata
• Queries
• Prompts
• Configuration information
• Reports
• Dashboards
• Analytics
• Files
• Documents
• Other business information processed through the Platform

Icebreaker processes Customer Data only as necessary to:

• Provide the evaluation environment
• Execute Customer requests
• Troubleshoot issues
• Improve platform reliability
• Maintain security

Customer remains responsible for ensuring that it has the necessary rights and permissions to process Customer Data using the Platform.

Icebreaker uses collected information to:

• Provide Platform access
• Authenticate users
• Respond to support requests
• Improve Platform reliability
• Diagnose technical issues
• Monitor Platform performance
• Communicate product updates
• Schedule evaluation meetings
• Maintain Platform security
• Comply with legal obligations

Icebreaker does not use collected information for unrelated marketing purposes without Customer’s consent.

Icebreaker is designed to support customer-selected artificial intelligence services.

Customer determines which AI providers, if any, are connected to its evaluation environment.

Unless expressly agreed otherwise in writing:

• Icebreaker does not use Customer Data to train foundation models.
• Icebreaker does not use Customer Data to train generative AI systems.
• Icebreaker does not sell Customer Data.
• Icebreaker does not license Customer Data to third parties.

Where AI integrations are used, Icebreaker is designed to minimize unnecessary transmission of Customer information and to limit data shared with external AI services to the extent practical.

Icebreaker encourages customers to evaluate any third-party AI provider independently before using it with Customer Data.

Icebreaker does not sell Customer Data or personal information.

Icebreaker may share limited information only under the following circumstances:

Icebreaker may engage trusted third-party service providers to assist in operating the Platform, including providers of cloud infrastructure, authentication, communications, and technical support.

These providers are permitted to process information only as necessary to perform services on Icebreaker’s behalf and are contractually obligated to protect such information.

The Platform may integrate with third-party services selected by Customer, including artificial intelligence platforms, cloud services, databases, analytics tools, or identity providers.

Any information shared with those services is governed by Customer’s configuration choices and the privacy practices of the applicable third party.

Icebreaker may disclose information when required to do so by applicable law, regulation, court order, or other lawful governmental request.

Where permitted, Icebreaker will make reasonable efforts to notify Customer before disclosing Customer information.

If Icebreaker is involved in a merger, acquisition, financing, reorganization, or sale of substantially all of its assets, Customer information may be transferred as part of that transaction, subject to applicable confidentiality obligations.

The Icebreaker website may use cookies and similar technologies to improve the user experience.

These technologies may be used to:

• Maintain user sessions.
• Remember preferences.
• Authenticate users.
• Measure website performance.
• Improve website functionality.

Customers may configure their web browsers to reject cookies; however, doing so may affect the functionality of portions of the website or Platform.

Icebreaker may also use aggregated website analytics to understand general usage trends. These analytics are intended to improve the website and do not involve the sale of personal information.

Protecting Customer information is a core principle of the Icebreaker Platform.

Icebreaker maintains commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction.

Depending on the deployment architecture, these safeguards may include:

• Encryption in transit using industry-standard protocols.
• Authentication through trusted identity providers.
• Role-based access controls.
• Operational logging and monitoring.
• Secure software development practices.
• Controlled administrative access.
• Infrastructure monitoring.

Additional information regarding Icebreaker’s operational security practices is available in the Icebreaker Security, Privacy & AI Principles (IB-DOC-003).

While Icebreaker strives to protect Customer information, no system can guarantee absolute security. Customers remain responsible for maintaining appropriate security controls within their own environments.

Icebreaker retains information only for as long as reasonably necessary to:

• Provide the evaluation.
• Support Customer.
• Maintain Platform security.
• Resolve technical issues.
• Meet legal obligations.
• Preserve appropriate business records.

Upon completion or termination of an evaluation, Icebreaker may disable access to the Platform and delete or return Customer information as appropriate, subject to applicable legal, contractual, or operational requirements.

Customers may request deletion of certain evaluation-related information by contacting Icebreaker.

Depending upon applicable law and Customer’s jurisdiction, individuals may have rights regarding personal information, including the right to:

• Request access to personal information.
• Request correction of inaccurate information.
• Request deletion of personal information.
• Object to certain processing activities.
• Request information regarding how personal information is processed.

Icebreaker will respond to applicable requests within a commercially reasonable timeframe and in accordance with applicable law.

Requests may be submitted using the contact information provided at the end of this Privacy Policy.

Customer information may be processed in jurisdictions where Icebreaker or its service providers operate.

Where applicable, Icebreaker will implement commercially reasonable safeguards intended to protect personal information during such transfers and to comply with applicable privacy laws.

Customers are responsible for determining whether their own regulatory obligations impose additional requirements regarding international transfers of Customer Data.

The Icebreaker Platform is intended solely for business and professional use.

It is not directed toward individuals under the age of eighteen (18), and Icebreaker does not knowingly collect personal information from children.

If Icebreaker becomes aware that it has unintentionally collected personal information from a child, it will take reasonable steps to delete such information.

Icebreaker may update this Privacy Policy from time to time to reflect changes in the Platform, applicable law, operational practices, or business requirements.

The most current version will be made available through the Icebreaker website.

Material changes will become effective upon publication unless otherwise stated.

Continued use of the Platform following publication of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy.

Questions regarding this Privacy Policy or Icebreaker’s privacy practices may be directed to:

Icebreaker Data LLC
Privacy Inquiries privacy@icebreakerdata.com

Version History
Version 1.0
Effective Date: July 14, 2026
Initial publication.