Privacy Policy
Version dated 20 June 2025 – supersedes all previous versions

This Privacy Policy (“Policy”) describes how personally identifiable information (“Personal Information”) that you may provide on the website www.iceopro.com (“Website” or “Service”) and any of its related products and services (collectively, the “Services”) is collected, protected, and used, in accordance with the General Data Protection Regulation (GDPR).

It also explains the choices available to you regarding our use of your Personal Information and how you can access and update such information.
This Policy constitutes a legal agreement between you (“User”, “you” or “your”) and the operator of the Iceopro.com website (“Operator”, “we”, “us”, or “our”).

This Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage.

Automatic collection of information
When you access the Website, our servers automatically record information that your browser sends. This data may include information such as your device’s IP address, browser type and version, operating system type and version, language preferences, the webpage you were visiting before accessing the Website and the Services, the pages of the Website and Services that you visit, the time spent on those pages, the information you search for on the Website, access times and dates, and other statistics.

The automatically collected information is used solely to identify potential cases of abuse and to establish statistical information regarding the usage and traffic of the Website and Services.

This statistical information is not otherwise aggregated in a way that would identify any particular User of the system.

Collection of personal information
You may access and use the Website and the Services without telling us who you are or revealing any information by which you could be identified as a specific, identifiable individual.
However, if you wish to use certain features of the Website, you may be required to provide certain Personal Information (for example, your name and email address).
We receive and store any information you knowingly provide to us when you create an account, post content, or complete online forms on the Website.

Where required, this information may include the following :
- Personal data such as name, country of residence, etc.
- Contact details such as email address, postal address, etc.
- Account details such as username, unique user ID, password, etc.

Some of the information we collect is obtained directly from you through the Website and the Services.
However, we may also collect Personal Information about you from other sources, such as publicly available databases and our joint marketing partners.
You may choose not to provide your Personal Information to us, but you may not be able to use certain features of the Website as a result.

Users who are unsure about which information is mandatory are invited to contact us at the following address : contact-rgpd@iceopro.com.

Use and processing of collected information
In order to make the Website and the Services available to you, or to comply with a legal obligation, we must collect and use certain Personal Information.
If you do not provide the information we request, we may be unable to provide you with the products or services you have requested.

Any of the information we collect from you may be used for the following purposes :
- Creating and managing user accounts
- Sending administrative information
- Requesting user feedback
- Improving the user experience
- Enforcing terms and conditions and policies
- Operating and managing the Website and the Services

The processing of your Personal Information depends on how you interact with the Website and the Services, where in the world you are located, and whether one of the following conditions applies :
(i) you have given your consent for one or more specific purposes; however, this does not apply whenever the processing of Personal Information is subject to European data protection law;
(ii) the provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
(iii) the processing is necessary for compliance with a legal obligation to which you are subject;
(iv) the processing is related to a task carried out in the public interest or in the exercise of official authority vested in us;
(v) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Please note that, under certain legislation, we may be permitted to process information until you object to such processing (by opting out), without having to rely on consent or any of the legal bases listed above.

Summary Table of Data Processing Activities

Management of information
You may delete certain Personal Information that we hold about you.
The Personal Information you are able to delete may change as the Website and the Services evolve.
However, when you delete Personal Information, we may retain an unaltered copy of such Personal Information in our records for as long as necessary to comply with our obligations to our affiliates and partners, and for the purposes described below.
If you wish to delete your Personal Information or permanently delete your account, you may do so by contacting us at : contact-rgpd@iceopro.com.

Disclosure of personal data to third parties
Depending on the Services requested, or where necessary to process any transaction or provide any Service you have requested, we may share your information—with your consent—with our trusted third parties who work with us, as well as with any other affiliated or subsidiary companies on which we rely to support the operation of the Website and the Services made available to you.
We do not share Personal Information with unaffiliated third parties.
These service providers are not permitted to use or disclose your information except as necessary to perform services on our behalf or to comply with legal requirements.
We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to adhere to our Personal Information handling policies.
These third parties receive only the Personal Information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing purposes or for any other purpose.
We will disclose any Personal Information we collect, use, or receive if required or permitted by law, for example to comply with a subpoena or a similar legal process, and when we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

You may consult the Standard Contractual Clauses (SCCs) adopted by the European Commission governing data transfers to our service providers established outside the European Union at the following link : https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32021D0914

Processors
OVH : The website www.iceopro.com is hosted by OVH – 2 rue Kellermann, 59100 Roubaix, France.
OVH’s Privacy Policy is available at the following link: https://www.ovhcloud.com/fr/personal-data-protection/

Stripe : Sensitive data entered during a payment (in the pop-up window used to fill in payment card information) does not pass through our servers and is therefore not subject to any processing or storage by us.
This information is transmitted directly to our service provider, Stripe, which then confirms the validation of the transaction.
Stripe is a US company with its registered office at the following address:
Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA 94107, United States of America.
Stripe’s Privacy Policy is available at the following link : https://stripe.com/fr/privacy

Others
Google: If you choose to enable analytical and advertising cookies (SEO and SEA), the data collected will be used by Google.
Google is a US company with its registered office at the following address: Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America.
Google’s Privacy Policy, which covers data collected through Google Analytics and Google Ads, is available at the following link : https://support.google.com/analytics/answer/6004245?hl=fr
A dedicated page addressing personal data issues relating to Google Analytics can be accessed here :
https://support.google.com/analytics/answer/12017362?hl=fr
The legal framework under which Google carries out data transfers can be consulted at the following link : https://policies.google.com/privacy/frameworks?hl=fr

Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you have updated or deleted it, but not in a manner that would personally identify you.
Once the retention period has expired, Personal Information will be deleted.
Accordingly, the rights of access, erasure, rectification, and data portability cannot be exercised after the retention period has expired.

Retention period
In accordance with European Union regulations and national legislation, we retain Personal Data based on the following data categories :
- sessionStorage data : duration of the session
- localStorage data: 13 months
- Accounts and customer data : 3 years after the end of the commercial relationship in the operational database / 10 years in a “definitive archive” to comply with statutory accounting data retention requirements
- Connection logs : 1 year
- Data archives (backups) : 3 years (“intermediate archives”) / 10 years (“definitive archives”)
- Essential technical cookies : 180 days

Our processor Stripe places the following cookies or similar technologies :
m : This cookie is used to track a user’s first visit.
Retention period: 10 years.
stripe_mid : This data stored in localStorage is used to process credit card payments.
It enables Stripe to remember who you are and allows the website to process payments without storing credit card information on its own servers.
Retention period : 1 year.
stripe_sid : This data stored in localStorage is also used to process credit card payments.
It enables Stripe to remember who you are and allows the website to process payments without storing credit card information on its own servers.
Retention period: 1 day.
A complete list of cookies used by Stripe is available at the following link : https://stripe.com/cookies-policy/legal

If you choose to enable analytical and advertising cookies (SEO and SEA), Google will place the following cookies in your browser:
_ga : This cookie is used to store and count page views.
Retention period: 13 months.
ga[id] : This cookie is also used to store and count page views.
Retention period: 13 months.
_gcl_au : This cookie is used to store and track conversions.
Retention period: 90 days.
AEC : This cookie is used to detect spam, fraud, and abuse to ensure that advertisers are not wrongly charged.
Retention period: 180 days.
NID : This cookie is used to enable ad delivery or retargeting, and to record user preferences.
Retention period: 3 months.
SOCS : This cookie is used to store your cookie preferences.
Retention period: 13 months.
Secure-ENID : This cookie is used for analytics purposes on Google Search.
Retention period: 13 months.

User rights
In accordance with Articles 15 to 22 of the GDPR, you have the following rights: access, rectification, erasure, restriction, objection, and data portability.
You may exercise these rights by contacting us at : contact-rgpd@iceopro.com.
We will respond within 30 days.

More specifically, you have the right to do the following :
(i) You have the right to withdraw your consent where you have previously given consent to the processing of your information;
(ii) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent;
(iii) You have the right to know whether we are processing information, to obtain disclosure regarding certain aspects of the processing, and to obtain a copy of the information undergoing processing;
(iv) You have the right to verify the accuracy of your information and request that it be updated or corrected;
(v) You have the right, in certain circumstances, to restrict the processing of your information, in which case we will not process your information for any purpose other than storing it;
(vi) You have the right, in certain circumstances, to obtain the erasure of your Personal Information from us;
(vii) You have the right to request the retrieval of your professional data in a structured, commonly used, and machine-readable format, in accordance with the European Data Act.

Lodging a complaint with a supervisory authority
If you believe that your rights have not been respected or that your data is being processed in violation of the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with a supervisory authority.

In particular, you may contact :
- The CNIL (Commission Nationale de l’Informatique et des Libertés), the competent authority in France :
3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07
Website : www.cnil.fr
Complaint form : https://www.cnil.fr/fr/plaintes

- or any other supervisory authority of the European Union competent for your habitual residence, place of work, or the location where the alleged violation occurred.

Children’s privacy
We do not knowingly collect any Personal Information from children under the age of 18. If you are under 18, please do not submit any Personal Information through the Website and the Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and the Services without their permission.
If you have reason to believe that a child under the age of 18 has provided us with Personal Information through the Website and the Services, please contact us.
You must also be old enough to consent to the processing of your Personal Information in your country (in some countries, we may allow your parent or guardian to consent on your behalf).

Cookies and Trackers
When you browse www.iceopro.com, cookies may be placed on your device in order to :
- ensure the proper functioning of the website (technical cookies),
- secure forms through Google reCAPTCHA,
- generate anonymous audience statistics (analytics cookies).

Non-essential cookies (e.g., reCAPTCHA, analytics) are only placed after you have given your consent.
You may accept or refuse all or part of the cookies through the CookieBot banner displayed upon your arrival on the website.
You may consult CookieBot’s Privacy Policy at the following link : https://www.cookiebot.com/fr/privacy-policy/

Do Not Track Signals
Some browsers include a “Do Not Track” feature that signals to websites you visit that you do not wish to have your online activities tracked.
Tracking is not the same as the use or collection of information in connection with a website.
For these purposes, “tracking” refers to the collection of personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
The way browsers communicate the Do Not Track signal is not yet uniform.
Therefore, the Website and the Services are not currently configured to interpret or respond to Do Not Track signals sent by your browser.
Nonetheless, as described in greater detail throughout this Policy, we limit our use and collection of your Personal Information.

Email Marketing
We offer newsletters that you may voluntarily subscribe to at any time.
We are committed to keeping your email address confidential and will not disclose your email address to third parties, except as permitted in the section on the use and processing of information or for the purpose of using a third-party provider to send such emails.
We will retain information sent by email in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all emails we send will clearly indicate who the email is from and will provide clear information on how to contact the sender.
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in those emails or by contacting us.
However, you will continue to receive essential transactional emails.

Links to other resources
The Website and the Services contain links to other resources that are not owned or controlled by us.
Please be aware that we are not responsible for the privacy practices of such other resources or third parties.
We encourage you to be aware when you leave the Website and the Services and to read the privacy statements of any resource that may collect Personal Information.

Artificial Intelligence (AI) tools
Iceopro does not use any AI system classified as “high-risk” under the AI Act, and no automated decision-making is currently used to restrict or filter access to the Services.

Reporting and DSA (Digital Services Act)
In accordance with the Digital Services Act (DSA), you may report any illegal content through the contact form.
Each report is reviewed within a reasonable timeframe, a response is provided, and an internal appeal process is available.

Information security
We secure the information you provide on computer servers in a controlled and secure environment, protected against unauthorized access, use, or disclosure.
We maintain reasonable administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of the Personal Information under our control and custody.
Security measures implemented include : TLS encryption, regular backups, restricted access, and multi-factor authentication (MFA) for administrator areas.
However, no data transmission over the Internet or any wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that :
(i) there are inherent security and privacy limitations of the Internet which are beyond our control;
(ii) the security, integrity, and confidentiality of all information and data exchanged between you and the Website and the Services cannot be guaranteed;
(iii) such information and data may be accessed or altered in transit by a third party, despite all efforts.

We do not sell, rent, or otherwise disclose Personal Information collected through our Website to third parties in the ordinary course of business.

Data Breach
If we become aware that the security of the Website and the Services has been compromised, or that Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity — including, but not limited to, security attacks or fraud — we reserve the right to take reasonably appropriate measures. These measures may include, without limitation, investigations and reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, Iceopro undertakes to notify the CNIL within 72 hours and to inform the affected individuals as soon as possible when required.

Changes and Amendments
We reserve the right to modify this Policy or its terms relating to the Website and the Services from time to time at our discretion, and we will inform you of any material changes in the way we process Personal Information.
When we do so, we will post a notice on the main page of the Website. We may also notify you in other ways at our discretion, such as through the contact details you have provided.
Any updated version of this Policy will take effect immediately upon the posting of the revised Policy, unless otherwise specified.
Your continued use of the Website and the Services after the effective date of the revised Policy (or any other act specified at that time) will constitute your acceptance of such changes.
However, we will not use your Personal Information, without your consent, in any manner that is materially different from what was stated at the time your Personal Information was collected.

Acceptance of this Policy
You acknowledge that you have read this Policy and agree to all its terms and conditions.
By accessing and using the Iceopro.com Website and the Services, you agree to be bound by this Policy.
If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and the Services.

Last updated : 20 June 2025
Version history available upon request.

Data Controller and Contact Information

Data Controller : Iceopro – RCS Lyon 508 181 252 00026
Address : 37 rue Saint Maurice, 69008 Lyon, France
Contact : contact-rgpd@iceopro.com

In accordance with Article 37 of the GDPR, Iceopro has not appointed a Data Protection Officer (DPO).

Competent supervisory authority in France :
CNIL (Commission Nationale de l’Informatique et des Libertés)
Website: www.cnil.fr