Privacy Policy

Our commitment to protecting your privacy and personal data

2025/11/04

Last updated: November 4, 2025

Introduction

This Privacy Policy explains how Ice Breaker Games ("we," "our," or "us") collects, uses, and protects your personal information when you use our ice breaker games and facilitation services. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other international privacy regulations.

By using our services, you agree to the collection and use of information in accordance with this policy.

Information We Collect

Personal Information You Provide

  • Communication Data: Messages you send to us through contact forms or support channels
  • Feedback Data: Your feedback, ratings, and suggestions about ice breaker games and features
  • Newsletter Signups: Email address if you subscribe to our newsletter (optional)
  • Contact Requests: Information provided when requesting support or information

Information We Collect Automatically

  • Usage Data: Pages visited, games selected, time spent on our service, and interaction patterns
  • Game Preferences: Which ice breaker categories and activities you engage with most
  • Device Information: IP address, browser type, operating system, device identifiers
  • Log Data: Server logs, error reports, and system activity
  • Analytics Data: Aggregated usage statistics and performance metrics

Information from Third Parties

  • Analytics Providers: Anonymized usage data for website performance and user experience improvement
  • Email Service Providers: Newsletter delivery and engagement metrics (for subscribers)

We process your personal data based on the following legal grounds:

Contract Performance:

  • Customer support and response to inquiries
  • Service delivery and website functionality
  • Security and fraud prevention

Legitimate Interests:

  • Service improvement and analytics
  • Security monitoring and threat detection
  • Marketing communications (with opt-out option)
  • Legal compliance and dispute resolution

Consent:

  • Optional analytics cookies
  • Marketing email subscriptions
  • Non-essential service features

Legal Obligation:

  • Tax and accounting records
  • Compliance with applicable laws
  • Response to legal requests

How We Use Your Information

Core Service Operations

  • Service Delivery: Providing ice breaker games, questions, and facilitation tools
  • Game Selection: Operating the spinning wheel and game recommendation features
  • Customer Support: Responding to inquiries and resolving issues
  • Security: Protecting against fraud, abuse, and unauthorized access
  • Newsletter Delivery: Sending subscribed newsletters and updates

Service Improvement

  • Analytics: Understanding which ice breaker games and features are most popular
  • Performance Monitoring: Ensuring game selection and website reliability
  • Feature Development: Developing new games and features based on user preferences
  • Quality Assurance: Testing and maintaining game content quality

Communications

  • Service Updates: Important notifications about your account or our services
  • Marketing: Promotional emails about new ice breaker games and features (with opt-out option)
  • Support: Responses to your inquiries and support requests

Third-Party Services

We work with trusted third-party service providers to deliver our services:

Email Services (Optional)

  • Provider: Resend
  • Data Shared: Email addresses and message content
  • Purpose: Transactional and marketing emails
  • Data Location: United States and other regions
  • Protection: Secure transmission and storage

Analytics and User Experience

We use multiple analytics services to understand and improve your experience:

Google Analytics

  • Data Shared: Anonymized usage statistics, page views, and user interactions
  • Purpose: Website performance analysis and user experience improvement
  • Data Location: Google's secure servers
  • Protection: Google's privacy and security standards

Microsoft Clarity

  • Data Shared: Anonymized user session recordings, heatmaps, and interaction patterns
  • Purpose: Understanding user behavior and improving website usability
  • Data Location: Microsoft's secure servers
  • Protection: No personal data collection, privacy-focused configuration

Self-hosted Plausible Analytics

  • Data Shared: Minimal, privacy-focused analytics data
  • Purpose: Website performance monitoring without intrusive tracking
  • Data Location: Our controlled infrastructure
  • Protection: No cookies, no personal data collection, GDPR compliant

Infrastructure

  • Cloud Providers: Cloudflare (CDN), AWS S3 (file storage), and database providers
  • Data Shared: All service data as necessary for operations
  • Purpose: Hosting, storage, CDN delivery, and service delivery
  • Protection: Enterprise-grade security and encryption

Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

  • Support Communications: 2 years after resolution
  • Newsletter Subscriptions: Until you unsubscribe
  • Contact Form Data: 1 year after submission
  • Analytics Data:
    • Google Analytics: 14 months (Google's standard retention)
    • Clarity: 30 days for session recordings, 90 days for aggregated data
    • Plausible: Indefinitely for aggregated, anonymized data
  • Log Files: 90 days for security and troubleshooting purposes
  • Marketing Data: Until you unsubscribe or withdraw consent

International Data Transfers

As a global service, we may transfer your personal data to countries outside your residence, including:

  • United States: For analytics services (Google Analytics, Clarity), email services (Resend), and infrastructure
  • European Union: For users in EU/EEA regions when possible
  • Global: Content delivery through Cloudflare's global network

We ensure appropriate safeguards for international transfers through:

  • Adequacy Decisions: Transfers to countries with adequate protection
  • Standard Contractual Clauses: EU-approved contract terms
  • Certification Programs: Providers with recognized privacy certifications
  • Binding Corporate Rules: For transfers within corporate groups

Your Rights and Choices

Data Subject Rights (GDPR/CCPA)

You have the following rights regarding your personal data:

Right to Access: Request a copy of the personal data we hold about you Right to Rectification: Request correction of inaccurate personal data Right to Erasure: Request deletion of your personal data Right to Restrict Processing: Request limitation of data processing Right to Data Portability: Request your data in a portable format Right to Object: Object to processing based on legitimate interests Right to Withdraw Consent: Withdraw consent for consent-based processing

How to Exercise Your Rights

  • Email: support@icebreakergame.net
  • Account Settings: Many preferences can be managed in your account
  • Support Portal: Submit requests through our support system
  • Response Time: We will respond within 30 days (GDPR) or 45 days (CCPA)

California Residents (CCPA)

California residents have additional rights:

  • Right to Know: Categories and specific pieces of personal information collected
  • Right to Delete: Request deletion of personal information
  • Right to Opt-Out: Opt-out of the sale of personal information
  • Right to Non-Discrimination: Equal service regardless of privacy choices

Note: We do not sell personal information to third parties.

Data Security

We implement comprehensive security measures to protect your personal data:

Technical Safeguards

  • Encryption: Data encrypted in transit (TLS 1.3) and at rest (AES-256)
  • Access Controls: Role-based access with multi-factor authentication
  • Network Security: Firewalls, intrusion detection, and monitoring
  • Regular Updates: Security patches and system updates
  • Secure Development: Security-focused coding practices and reviews

Organizational Safeguards

  • Staff Training: Regular privacy and security training for employees
  • Access Limitation: Strict need-to-know access policies
  • Incident Response: Procedures for handling security incidents
  • Vendor Management: Security requirements for third-party providers
  • Regular Audits: Internal and external security assessments

Data Breach Response

In the event of a data breach, we will:

  • Immediate Response: Contain and assess the breach within 24 hours
  • Authority Notification: Notify relevant authorities within 72 hours if required
  • User Notification: Inform affected users without undue delay
  • Remediation: Take steps to prevent future incidents

Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we discover that we have collected personal information from a child under 13, we will delete it immediately.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@icebreakergame.net.

Cookies and Tracking

We use cookies and similar technologies to enhance your experience. For detailed information about our cookie practices, please see our Cookie Policy.

Essential Cookies

  • Session management and authentication
  • Security and fraud prevention
  • Basic functionality and preferences
  • Analytics and performance monitoring
  • Feature enhancement and personalization
  • Marketing and advertising (if applicable)

You can manage cookie preferences through your browser settings or our cookie consent banner.

Marketing Communications

Email Marketing

  • Opt-In: We only send marketing emails with your explicit consent
  • Opt-Out: Unsubscribe links in all marketing emails
  • Frequency: Reasonable frequency with option to adjust preferences
  • Content: Relevant updates about our services and features

Communication Preferences

You can manage your communication preferences:

  • Account Settings: Update preferences in your user account
  • Unsubscribe Links: Use links in emails to opt-out
  • Contact Us: Email support@icebreakergame.net for assistance

Automated Decision Making

We may use automated systems for:

  • Fraud Detection: Automated analysis of payment and usage patterns
  • Game Recommendation: Algorithmic suggestions for ice breaker games based on user preferences
  • Service Optimization: Automated performance and reliability improvements

You have the right to:

  • Request Human Review: Ask for human intervention in automated decisions
  • Explanation: Understand the logic behind automated decisions
  • Challenge: Contest automated decisions that significantly affect you

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make changes:

  • Notification: We will notify you via email or prominent notice on our website
  • Effective Date: Changes take effect 30 days after notification
  • Continued Use: Your continued use constitutes acceptance of the updated policy
  • Version History: Previous versions available upon request

Contact Information

Data Protection Officer

For privacy-related inquiries, contact our Data Protection Officer:

General Privacy Inquiries

Regulatory Complaints

If you believe we have not addressed your privacy concerns adequately, you may file a complaint with:

  • EU/EEA: Your local data protection authority
  • UK: Information Commissioner's Office (ICO)
  • California: California Attorney General's Office
  • Other Regions: Relevant privacy regulatory authority

Definitions

Personal Data: Any information relating to an identified or identifiable natural person. Processing: Any operation performed on personal data, including collection, use, storage, and deletion. Data Controller: The entity that determines the purposes and means of processing personal data. Data Processor: The entity that processes personal data on behalf of the data controller. Consent: Freely given, specific, informed, and unambiguous indication of agreement to data processing.

Contact Us

If you have any questions about this Privacy Policy, please contact us.