PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) describes the types of information that COOKIE CRUMBLE LABS PRIVATE LIMITED (“Company”), as the Platform's operator and as the Platform's owner, may collect from a user (“You”, “Your”, or “User”) on or through Our mobile application (“ice”) or website (https://myice.link) (collectively “Platform”), either directly (the Platform's owner and operator are collectively referred to as “We”/ “Us”/ “Our”) or in connection with other services rendered by Us, (each a “Service”, and collectively the “Services”), and how We use, process, disclose and try to protect such information. You acknowledge and agree that the Company is responsible for the Platform's operation and maintenance, and that any information collected and processed on the Platform is gathered and used only for the purposes of Our business.

By accessing or using Our Platform or Services, You acknowledge that You have read, comprehended, and agreed to the privacy policies contained in this Privacy Policy (and to the collection, storage, and processing of Your information in accordance with them).

This Privacy Policy is in compliance with the following Laws and Regulations:

- Digital Data Protection Act, 2023 (“DPDP Act”)

- Regulation 3(1) of the Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediaries Guidelines”);

- Section 43A and Section 72A of the Information Technology Act, 2000 (“IT Act”); and

- Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”).

Capitalised terms not defined here, including the terms Personal Data, shall have the meaning stated in the Digital Data Protection Act, 2023.

In compliance with section 5 of the DPDP Act, this policy acts as a notice on collection of your Personal Data and the purpose of its collection (clause 1 below); the manner in which rights under section 6(4) & 13 may be exercised (clause 6 below); and, the manner in which you may make a complaint to the Board. As soon as practicable, and by means that we deem appropriate, we may inform you of the same from time to time.

1. GENERAL TERMS

By using this Platform or Service or providing Us with Your information in any other way, You confirm that You have the legal capacity to enter into a legally binding contract under Indian law, specifically the Indian Contract Act, 1872 as set out in our Terms of Use, and that You have read, understood, and agreed to the practices and policies outlined in this Privacy Policy and agree to abide by them.

If You access or use Services on the Platform from an overseas location, You (or Your Guardian, as the case may be) are entirely responsible for compliance with any local laws.

You consent to the collection, use, sharing, and disclosure of Your information in accordance with this Privacy Policy. We retain the right, in Our sole discretion, to alter, modify, add, or delete elements of this Privacy Policy at any time, and your continuing use of the App, Services, or Platform after any such amendments will be regarded as an implicit acceptance of the Privacy Policy in its revised form. You should review the Privacy Policy on a regular basis to ensure that you are informed of any modifications or updates to the policy's terms. We may also send you notifications of any significant changes to our Privacy Policy or on how we collect and handle private information.

If you do not agree to any of the terms and conditions included in this Privacy Policy, please do not use this Platform, or any Services. This Privacy Policy is subject to change without notice at any time. Please check this policy on this Platform on a frequent basis to ensure that You are aware of any changes.

2. YOUR CONSENT

By accessing our Platform and filling out our onboarding forms or clicking on any notification or other messages or by supplying your information by yourself, you agree to the collection, use, storage, disclosure, and other processing of your Personal Information on the Platform in accordance with the terms of this Privacy Policy. We may reject any submission made by you at any time without assigning any reason.

You consent to us contacting you through notification, email, and/or other methods for the reasons indicated in this Privacy Policy by giving your Personal Information on the Platform.

3. INFORMATION HANDLING

Due to the nature of our Services, please be aware that You may give or We may collect information that can specifically identify You or any other individual when you browse the Platform or use the Service(s).

We collect the following information:

1. Age: We collect your age to verify that you are eligible to use our app. The minimum age required to join ice is 13 years old. If you are under 18 years old, you need the consent of your parents or legal guardian to use our app.

2. Gender: We collect your gender as it is required for app functionality.

3. Instagram Username: We collect your Instagram username as it is required for app functionality.

4. School or College name: We collect your school or college name as it is required for app functionality.

5. Chat messages: Message content is processed to provide the service.

6. Notification preferences: We collect your notification preferences to customize your experience.

The information we collect is stored in your mobile device (local data storage) and on Google Firebase (third-party service).

We also collect information while you use the Platform and which are required for providing You Services on the Platform including but not limited to the Platform and features you use, and what actions you take in them. You can choose not to provide certain information, but You may not have access to the full extent of the features available on our Platform.

4. DISCLOSURE OF INFORMATION

We may release account and other personal information when We believe in good faith that such release is appropriate to comply with applicable law including to:

- Comply with legal standards or legal process;

- To prevent a crime or to protect national security;

- Protect rights, property, or related businesses; and

- Ensure the personal safety of Our Users and the general public.

We may also share Your personal information in order to enforce or apply Our Terms and other agreements, or to defend Our rights, property, or safety, as well as the safety of Our Users or others. This involves exchanging information with other businesses, organizations, governments, or regulatory agencies in order to combat fraud and reduce credit risk.

If we (or our affiliates) are involved in a merger, acquisition, or sale of all or substantially all of its assets or equity, your information may be transferred as part of that transaction. Such information shall be disaggregated to the extent possible and shall be subject to execution of appropriate non-disclosure agreements and binding privacy undertakings.

Subject to applicable legislation, We may transmit personal information to any other body corporate (as defined in the Information Technology Act, 2000) based in India or any other country that provides at least the same level of data protection as We provide under the provisions of this Agreement.

5. THIRD PARTY SERVICES

We use the following third-party services:

- Google Firebase: Used for storing user data and app functionality.

- PostHog: Used for analytics purposes.

These third-party services may collect information sent by your device as part of their functionality. We ensure that these third parties handle your data in compliance with this Privacy Policy and applicable data protection laws.

6. USER RIGHTS

We want to ensure that you are fully empowered on our platform and are completely aware of the rights that you are entitled to in the course of using our platform. In accordance with sections 11, 12, 13 & 14 of the DPDP Act, You have a number of rights in relation to the information we hold about you and We are fully committed to provide you the best and reasonably practicable means of exercising these rights:

Access: The right to access the information we hold about you, and to obtain details of the processing. You also have the right to access a list of all the third parties that have your Personal Information through us.

Correction: The right to seek, correct, update and modify the information available with us, to ensure accuracy.

Erasure: The right to seek to cancel or erase, free of charge, your personal data when it is inadequate, excessive, or unnecessary. This shall be subject to lawful processing measures and any legal prescriptions.

Objection: The right to withdraw your consent to our continued processing of the information, at any point of time, subject only to any legitimate reason for continued processing in certain circumstances.

Nomination: The right to nominate an individual who shall in the event of Your death or incapacity exercise Your rights in accordance with the provisions of the DPDP Act.

Grievance Redressal: You may report any act or omission in exercise of your rights by writing to us at team@myice.link or by such means as may be prescribed by law.

You may exercise any of these rights by contacting us at team@myice.link. This shall be subject to the legal requirements, and our internal procedure.

7. DATA SECURITY PRACTICES

We implement appropriate technical and organizational security measures to ensure that your personal data is protected to a level commensurate with the risk, taking into account state-of-the-art technologies, implementation costs, the nature, scope, context, and purposes of processing, as well as the likelihood and degree of risk. Personal data is generally transferred encrypted between your end device and us. Third-party access cannot be ruled out if you connect with us through internet service providers or broadband connections. All Personal Information is encrypted in motion and in storage.

8. IF YOU ARE A MINOR

The Platform is accessible to those who are 13 years of age or older. If you are under 18 years old, you need the consent of your parents or legal guardian to use our app. We implement security measures by processing Personal Information provided by you, to verify your age. We will restrict Your access to the Platform if you are under 13 years old or if you are between 13 and 18 years old and have not provided consent from your lawful guardian under section 9 of the DPDP Act.

If You are a parent or guardian and discover that Your child under the age of 18 has created an account on the Service without your permission, You may contact Us at team@myice.link and request that We delete that minor's Personal Information from Our systems.

9. INTERNATIONAL TRANSFER OF DATA

As we use Firebase services provided by Google, Personal information about You may be transmitted to and stored in data centers outside of India for processing, storage and other purposes outlined in this Privacy Policy. You understand and accept that these countries may have different (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds, and that such information may become subject to such countries' laws and disclosure requirements.

If we transfer your personal data to third parties for the purposes stated in this Privacy Policy, we will use our best efforts to put appropriate controls and safeguards in place to ensure that your personal data is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a fair, transparent, and lawful manner, and is stored for no longer than is absolutely necessary.

10. INFORMATION RETENTION AND PURGE

We store your Personal Information for certain predetermined periods based on:

- Statutory and legal requirements;

- Industry guidelines;

- De-identified or pseudonymized data sets to be used in an aggregated format for analytical purposes.

We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes. Any other information which is processed by us for analytical purposes will only be processed in an aggregated or non-identifiable basis.

Additionally, We have safeguards in place to ensure that Your Personal Information is deleted and/or anonymized as soon as it is reasonable to anticipate that:

i. The reasons for collecting Your Personal Information have been met; and
ii. Retention is no longer required by law or for any other reason.

If You wish to revoke Your consent to the processing of Your personal information, cancel Your account, or request that We stop using Your personal information to deliver Our services, please contact Us at team@myice.link. Please keep in mind, however, that withdrawing permission or cancelling your account may result in Our inability to provide services to You, or in the termination of any existing relationship We may have with You.

11. NOTICES

If You have any concerns or complaints regarding the Platform, please contact Us with a detailed explanation and We will attempt to address the matter for You. If You have any concerns or questions in relation to this Privacy Policy, You may address them to Our grievance officer at:

Name: Shreyan Budhouliya
Email: shreyan@myice.link
Address: 54, Front Side Basement, National Park, Lajpat Nagar IV, New Delhi - 110024
Company Details: COOKIE CRUMBLE LABS PRIVATE LIMITED, CIN - U74909DL2025PTC444330

We shall endeavor to resolve Your grievances within 1 (one) month from the date of receipt of such grievances.

12. MISCELLANEOUS

You agree and undertake to compensate Us in the event of any third-party claim or dispute arising out of Your disclosure of information to third parties, whether via Our Platform or elsewhere. We disclaim any duty for third-party activities involving Your personal information that You may have supplied to such third parties.

Unless otherwise specifically stated or implied by the context of this Privacy Policy, each clause of this Privacy Policy will be and remain distinct from, independent of, and severable from, all other provisions hereof.

We cannot guarantee that Your personal information will never be disclosed in methods not explicitly stated in this Privacy Policy. As a result, although We are dedicated to safeguarding Your privacy, We cannot guarantee that Your information or private conversations will always stay private, and You should not anticipate that they will. As a User of the Platform, You acknowledge and accept that You are solely responsible and liable for Your use of the Platform, the internet in general, and the information You post or access, as well as for Your behavior on and off the Platform.

This privacy policy was last updated on March 20, 2025.