Last Updated July 13, 2020
Information We Collect and Use:
When we refer to “Personal Data,” we mean any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier.
We, directly and through third-parties, collect information that you provide to us, from your use of the Services, and from other sources. The information that we collect and how we process it depends on how you use and access the Services and we combine all of the information we have about you so that we can analyze it and provide better Services to you. We collect information, including Personal Data, as follows:
Your Submissions to Us. Personal Data will be collected when you sign up for an online newsletter or contact us with a question or request. For example, if you submit a request to advertise with us, you may provide us with your name, email address, telephone number, address, and company. We use this information as necessary to respond to your request or inquiry and to provide and improve the Services and our products and services. We process this Personal Data as long as we have a legitimate interest or based on your consent.
Your Content Submissions. You may be able to submit content, such as videos, photographs and comments, which we may post on the Services with your consent. When you do so, we may request your name, email address, information about the content you are submitting, social media page links, and a link to your content. We receive any Personal Data in the videos, photographs or comments you submit to us. We process this Personal Data as long as we have a legitimate interest, based on your consent, and necessity for the performance of a contract with you. If, in addition to you, other persons are identifiable in the content, you are obliged to obtain consent from these persons to the publication of the content.
Your Location. “Location Data” is collected with your consent or inferred as you use the Services. Such information will include the location of the mobile device or computer used to access the Services derived from GPS or WiFi use, calculated based on your device’s IP Address, or the geographic information you provide to us (e.g., your city). We use this information to analyze the use of the Services, customize and improve the content for you on the Services, send you location-specific content, and show you events or businesses near you. We use and retain the Personal Data for as long as necessary and useful to provide personalized and improved services to you or until you withdraw consent.
Your Social Media Interactions. We receive Personal Data about you when you interact with us using the social media aspects to our Services (such as comment plug-ins), on our social media pages and channels, or on other channels and content. The Personal Data includes profile name, profile identifier, and the content of your submissions. We use this information to communicate with you and for internal analysis of visitors and content. We use and retain your Personal Data for these purposes until you withdraw consent or we do not use the social media pages anymore. Please review the privacy policies and settings of any websites, mobile applications, or social networks should you have any questions about their privacy practices.
Please bear in mind that any content (e.g., comments, photographs, videos, information and other materials) that you post directly on our Services, including our social media pages, is public and can be read, collected or used by others. Please be cautious when disclosing any Personal Data through public activities or submissions.
You may opt out from receiving marketing-related communications by either clicking on the unsubscribe link at the bottom of marketing-related emails we send you or by contacting us at email@example.com. We will process opt-out requests without unreasonable delay.
We use and retain your Personal Data until you withdraw your consent or request that we delete your contact information.
Events, Contests and Sweepstakes. We request Personal Data, such as your name, email address, and date of birth when you choose to participate in an event, contest, or sweepstakes. We use this information to determine eligibility, process your registration or entry, enforce the terms of the event, contest, or sweepstakes, and contact you about the event, contests, and sweepstakes you are participating in. We may also disclose the Personal Data to third-parties or the public in connection with the event, contest, or sweepstakes, such as for winner selection and announcements and prize fulfillment, as stated in the official rules, and as otherwise required by law. We will retain your Personal Data for as long as this is necessary to conduct the contest, i.e., until all prizes have ultimately been distributed and possible accordant time limits for legal actions have lapsed.
Your Employment Applications. You may submit Personal Data to us through electronic mail or our career pages when you express interest in or apply for employment or the provision of contract-related services. You may submit your name, email address, telephone number, resume, and cover letter to us. You may also submit Personal Data to us using your social media account, such as LinkedIn. When you do this, we receive the Personal Data you permit LinkedIn to share with us based on your LinkedIn settings, such as your email address and telephone number. We also receive you work experience, education, skills, and recommendation information. We use such information as a necessity to respond to your inquiry and contact you about employment and thus in preparation for the performance of a contract with you. If your application is successful, we retain the Personal Data for the duration of your employment with us, and beyond based on statutory retention periods. If we do not employ you, we will delete your Personal Data when accordant time limits for legal actions have lapsed.
Pseudonymization and Anonymization. In some circumstances we pseudonymize and/or anonymize your Personal Data for business purposes including to improve our products and services, in which case we use such information without further notice to you. The processing of your Personal Data for this purpose is based on our legitimate interests to provide better products and services. We retain the Personal Data for as long as they are necessary and useful to improve our products and services.
Legal and Other Similar Uses. We process information, including your Personal Data, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; enforce our Terms and Conditions; or protect your, our, or others’ rights, property, or safety. This processing is based on our legitimate interests in legal protection of our and others’ rights. We retain the Personal Data for as long as allowed or required by statutory laws.
How We Share Information:
Enabling Services on the Site. We offer a variety of services and functions through the Services. Personal Data that is collected through the Services will be used and/or disclosed to third-parties in order to enable us to provide the Services. For example, the Services allow you to interface with third-party websites, content, advertising, and features. To facilitate that interaction, we use your Personal Data and/or disclose your Personal Data to the third-party operating the websites and features.
Legal and Similar Disclosures. We may access, preserve, and disclose your information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; enforce our Terms and Conditions; or protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
Public Information. Please note that any information you include in a message you post to any comment box, chat room, forum or other public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
We use industry standard website tracking and delivery technology to serve you relevant advertising on and off the Services. With your consent, our Services display advertisements to you via targeted advertising methods. This permits us to show you certain advertising about products and services tailored to your individual interests based on information we receive from visitors of the Services and by third-parties. You may also see certain ads though your use of the Services because we participate in advertising networks. Ad networks allow us to target our advertising to users through the use of click-stream, demographic, behavioral and contextual information. The use of third-party tracking technologies to collect this information is often subject to their own privacy policies.
Third-Party Content, Widgets, and Links to Third-Party Sites:
The Services may contain, or link to, content that is hosted and served by third-parties, which may include third-party widgets (such as those that allow you to share content with third-party web sites and online services), functionality, and content. Our Services may also contain links to other third-party web sites that we do not control. These third-parties may collect information about you through the use of their own cookies and web beacons, may independently collect data or solicit Personal Data, and may or may not have their own published privacy policies. We are not responsible for the privacy practices employed by any third-party.
Where Personal Data Is Used and Stored:
We operate the services in the State of New York in the United States of America. Therefore, if you provide us with Personal Data during your use of the Services, we collect, process, and store that information in the United States. We may also transfer that information to our affiliates and subsidiaries or to other third-parties, across borders to other countries or jurisdictions around the world. If you are visiting from the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that you may be transferring your Personal Data to the United States, which does not have the same data protection laws as the EU or other countries.
We maintain appropriate safeguards to properly protect Personal Data concerning you when it is transferred to the United States. These safeguards are set forth in internal policies that include EU-approved standard contractual clauses that include EU-equivalent Data Subject rights and remedies. For more information about our data transfer safeguards, please send a request to firstname.lastname@example.org
California Privacy Rights:
Accuracy of Personal Data and your Individual Rights:
While we take various steps to ensure the accuracy and completeness of your Personal Data, we rely upon you to provide accurate and complete Personal Data when interacting with us. You may also have the legal right, for example if you are using the Services from the EU, to request:
Also, where our processing of your Personal Data is based on your consent, you may withdraw consent at any time for the future. Please note that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal.
Any such requests should be submitted by email to email@example.com.
Please see for additional information: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
If you are using the Services from the EU, you also have the right to lodge a complaint with an EU supervisory authority if you do not think we are handling your Personal Data in compliance with applicable law. However, if you have a complaint regarding the processing of your Personal Data, we kindly request that you first contact us directly by sending us an email at firstname.lastname@example.org, and we will reply promptly.
How Long We Keep Your Personal Data:
We consider several factors to determine how long we keep Personal Data. We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Once we no longer have a need for your Personal Data, we will securely destroy it in accordance with our standards and applicable laws and regulations.
We will attempt to honor requests to delete your Personal Data, but please note that we may be required to keep such information for legal purposes and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
How We Protect Personal Data:
We maintain administrative, technical and physical safeguards designed to assist us in protecting the Personal Data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We also limit access to Personal Data about you to employees or service providers who we believe reasonably need to come into contact with that Personal Data to provide products or services to you or in order to do their jobs.
While we implement these and other security measures on our Services, please note that 100% security is not always possible. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective.
We especially care about the privacy of young children. Accordingly, we do not direct our websites to children under the age of eighteen or knowingly collect Personal Data from them. If we learn that a user is under eighteen years of age, we will promptly delete any Personal Data that the individual has provided to us.
Enforcement and More Information:
When Icebreaker receives formal written inquiries or complaints, Icebreaker will contact the individual regarding his/her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the handling of Personal Data that cannot be resolved between Icebreaker and an individual.
How to Contact Us:
Icebreaker Entertainment, LLCAttn: General Counsel201 E. 87th Street, Suite 3DNew York, NY 10128Tel: (212) 360-1706Email: email@example.com
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And of course, if your mobile device offers an uninstall process, you can always stop us from collecting information through the app by uninstalling the Snapchat app.
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