Ghost Ice LLC

Effective Date: March 12, 2021

Last Updated: June 11, 2026

 

IMPORTANT NOTICE: This Privacy Policy describes how Ghost Ice LLC ("we," "us," or "our") collects, uses, shares, and protects your personal information. Please read this policy carefully before using our services. By accessing or using our website and services, you acknowledge that you have read and understood this Privacy Policy.

1. About This Policy

This Privacy Policy applies to Ghost Ice LLC (“Company,” “we,” “us,” or “our”), a S Corporation incorporated in Los Angeles, CA, with its principal place of business at 3312 1/2 Isabel Dr. Los Angeles, CA 90065. This policy governs all personal information collected through:

• Our website(s) at www.ghosticesystem.com and all related subdomains

• Our mobile applications and desktop software 

• Our APIs and developer tools

• Customer support communications

• Marketing and advertising activities

• Third-party integrations and partner platforms

 

This policy is designed to comply with all applicable privacy laws as of 2026, including but not limited to: the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA); the General Data Protection Regulation (GDPR) and UK GDPR; the Colorado Privacy Act (CPA); the Virginia Consumer Data Protection Act (VCDPA); the Connecticut Data Privacy Act (CTDPA); the Texas Data Privacy and Security Act (TDPSA); the Oregon Consumer Privacy Act (OCPA); the Montana Consumer Data Privacy Act (MCDPA); the Delaware Personal Data Privacy Act (DPDPA); Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial equivalents; and other applicable state, federal, and international privacy regulations.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• Create an account: name, email address, username, password (hashed), profile photo, and date of birth

• Make a purchase: billing name, billing address, payment card details (tokenized via third-party processor — we do not store full card numbers), and transaction history

• Contact us: name, email, phone number, and the content of your message

• Complete surveys or participate in promotions: responses, contact details, and demographic information you choose to share

• Submit user-generated content: posts, comments, reviews, and any attached media

2.2 Information Collected Automatically

When you visit our website or use our services, we and our technology partners automatically collect:

• Device Information: IP address, device type, operating system, browser type and version, device identifiers (IDFA/GAID), screen resolution, and language preferences

• Usage Data: pages and features visited, time and date of access, time spent on each page, links clicked, referring URLs, search queries, and navigation paths

• Performance Data: page load times, JavaScript errors, crash reports, and API response times

• Location Data: general geographic location derived from IP address; precise location only if you explicitly grant permission via your device settings

• Communications Metadata: email open rates, click-through rates, and push notification engagement

2.3 Tracking Technologies

We use the following tracking technologies, each governed by our Cookie Policy (see Section 7):

• Cookies: small text files stored on your device that help us remember your preferences and session state

• Pixel Tags / Web Beacons: invisible 1x1 images embedded in emails and web pages that confirm delivery and engagement

• Local Storage & Session Storage: browser-based storage used for user interface preferences and temporary session data

• Software Development Kits (SDKs): code embedded in our mobile apps for analytics and crash reporting

• Fingerprinting: we do NOT use device fingerprinting for cross-context behavioral advertising

2.4 Google Analytics and Third-Party Analytics

We use Google Analytics 4 (GA4) and may use other analytics platforms including: Ecwid, Six, Twipla Session Recordings, Kliken, and others to understand how users interact with our services. These tools may collect:

• Session duration, bounce rate, and user flow data

• Demographic and interest data (if enabled in your Google account and consented to)

• E-commerce data including product views, cart additions, and purchase completions

• Custom events we configure to track specific feature usage

 

Google Analytics uses cookies and similar technologies. Google’s use of this data is governed by Google’s Privacy Policy (https://policies.google.com/privacy). You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) or by adjusting your consent preferences in our Cookie Preference Center.

We have enabled IP anonymization in Google Analytics and have signed a Google Analytics Data Processing Addendum. We do not send Personally Identifiable Information (PII) to Google Analytics.

2.5 Advertising and Retargeting Technologies

With your consent where required by law, we use advertising technologies from partners that may include:

• Google Ads / Google Tag Manager

• Meta Pixel (Facebook/Instagram)

• Tik Tok Ads

 

These technologies allow us and our partners to show you relevant advertising on third-party websites and apps based on your interactions with our services. Each partner’s data practices are governed by their own privacy policies.

2.6 Information from Third Parties

We may receive information about you from third-party sources, including:

• Social login providers (Google, Apple, Facebook, etc) when you choose to connect your account

• Data enrichment vendors who help us maintain accurate business contact information

• Advertising partners who share aggregate audience segments

• Payment processors who confirm transaction status

• Identity verification providers for age verification or fraud prevention

3. How We Use Your Information

We process your personal information only where we have a lawful basis to do so. The following table outlines our primary processing purposes and the legal basis under GDPR and equivalent frameworks:

• Service Delivery — Legal Basis: Contract Performance. We use your information to create and manage your account, process transactions, provide customer support, and deliver features you’ve requested.

• Service Improvement — Legal Basis: Legitimate Interests. We analyze usage patterns, conduct A/B testing, and review crash reports to improve the performance, quality, and security of our services.

• Personalization — Legal Basis: Consent / Legitimate Interests. We customize your experience based on your usage history, preferences, and inferred interests.

• Marketing Communications — Legal Basis: Consent / Legitimate Interests. We send promotional emails, product updates, and special offers. You may opt out at any time.

• Safety and Fraud Prevention — Legal Basis: Legitimate Interests / Legal Obligation. We monitor for and investigate fraudulent activity, abuse, and security vulnerabilities.

• Legal Compliance — Legal Basis: Legal Obligation. We process data as required to comply with applicable laws, regulations, court orders, and government demands.

• Analytics and Research — Legal Basis: Consent / Legitimate Interests. We use analytics data to understand aggregate usage trends, conduct market research, and develop new features.

• Advertising — Legal Basis: Consent (where required). We and our advertising partners use data to show relevant ads, measure campaign performance, and build lookalike audiences.

4. How We Share Your Information

We do not sell your personal information for monetary compensation. We may share your information with:

4.1 Service Providers (Data Processors)

We engage vendors who process data on our behalf under binding contractual data processing agreements, including:

• Cloud infrastructure providers (e.g., [AWS / GCP / Azure])

• Payment processors (e.g., [Stripe / lightspeed])

• Customer relationship management (CRM) platforms

• Email delivery services

• Analytics platforms (Google Analytics and others)

• Customer support software

• Security and fraud detection services

4.2 Business Partners

We may share limited information with integration partners and marketplace co-sellers to fulfill services you’ve requested. These partners are contractually prohibited from using your data for their own independent marketing.

4.3 Advertising Partners

With your consent where required, we share hashed identifiers and behavioral data with advertising partners to deliver targeted advertising and measure campaign performance. California and other state residents may opt out of this “sharing” (which may constitute a “sale” under certain state laws) via our Cookie Preference Center or by submitting a request as described in Section 8.

4.4 Legal and Safety Disclosures

We may disclose your information to government authorities, regulators, or law enforcement:

• To comply with a valid legal obligation, court order, or subpoena

• To protect the rights, property, or safety of Ghost Ice LLC, our users, or the public

• To investigate or prevent fraud, abuse, or illegal activity

4.5 Business Transfers

In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to a successor entity. We will notify you via email and/or prominent notice on our website if a transfer occurs and your rights would materially change.

4.6 Aggregated or De-Identified Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, or other business purposes.

5. International Data Transfers

Ghost Ice LLC is based in Los Angeles, CA, USA. If you access our services from outside the United States, your information may be transferred to, stored, and processed in countries that may have different data protection standards than your own jurisdiction.

For transfers of personal data from the European Economic Area (EEA), United Kingdom (UK), or Switzerland to countries without an adequacy decision, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• The EU-U.S. Data Privacy Framework (DPF) and/or UK Extension where applicable

• Binding Corporate Rules (BCRs) where applicable

 

By using our services, you consent to your information being processed in the countries where we and our service providers operate.

6. Data Retention

We retain personal information only as long as necessary for the purposes for which it was collected, or as required by applicable law. Our general retention periods are:

• Account Data: retained for the duration of your account plus at least 7 years after closure to fulfill legal obligations and resolve disputes

• Transaction Records: at least 7 years for financial and tax compliance

• Usage and Analytics Data: at least 26 months (aligned with Google Analytics retention defaults) or shorter if technically feasible

• Marketing Data: until you opt out, plus a reasonable suppression period

• Support Communications: at least 7 years from resolution

• Legal Hold Data: indefinitely while subject to legal proceedings

 

When data is no longer required, we can securely delete or anonymize it in accordance with industry-standard data destruction practices.

7. Cookies and Tracking

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential to operate our website (authentication tokens, session cookies, CSRF protection). These cannot be disabled.

• Functional Cookies: Remember your preferences (language, region, UI layout). Disabling these may affect functionality.

• Analytics Cookies: Collect aggregate statistics about website usage via Google Analytics, and similar tools. May be disabled via our cookie banner on the website

• Advertising / Targeting Cookies: Used to deliver personalized ads and measure ad effectiveness. Require your consent in jurisdictions where required by law.

7.2 Managing Your Cookie Preferences

You can manage your cookie preferences at any time via:

• Our Cookie Preference Center: our cookie banner on the website

• Your browser settings: most browsers allow you to block or delete cookies

• Industry opt-out tools: the Digital Advertising Alliance (optout.aboutads.info), the Network Advertising Initiative (optout.networkadvertising.org), or Your Online Choices (youronlinechoices.eu)

• The Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

 

Please note that disabling certain cookies may impair the functionality of our services.

7.3 Do Not Track

Our website currently does not respond to browser-level "Do Not Track" (DNT) signals. However, we honor Global Privacy Control (GPC) signals as an opt-out of sale/sharing of personal data where required by law (e.g., California).

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information. We honor all legally required requests without discrimination.

8.1 Rights Available to All Users

• Right to Know / Access: Request a copy of the personal information we hold about you

• Right to Correction / Rectification: Request correction of inaccurate or incomplete data

• Right to Deletion / Erasure: Request deletion of your personal information, subject to legal retention obligations

• Right to Portability: Receive your data in a machine-readable format

• Right to Opt Out of Marketing: Unsubscribe from marketing emails at any time via the unsubscribe link or by contacting us

8.2 California Residents (CCPA/CPRA)

California residents have the following additional rights under the CCPA as amended by the CPRA:

• Right to Know the categories of personal information collected, the purposes of collection, and the categories of third parties with whom we share information

• Right to Opt Out of Sale or Sharing of personal information for cross-context behavioral advertising. To exercise this right, email us at: info@ghosticesystem.com

• Right to Limit Use of Sensitive Personal Information to uses reasonably necessary to provide requested services

• Right to Non-Discrimination: we will not deny you services or charge you different prices for exercising your privacy rights

• Right to Correct inaccurate personal information we hold about you

 

We do not knowingly sell or share the personal information of minors under the age of 16 without affirmative authorization.

8.3 EEA, UK, and Swiss Residents (GDPR / UK GDPR)

In addition to the rights listed in 8.1, residents of the EEA, UK, and Switzerland have:

• Right to Restrict Processing: request that we limit how we use your data in certain circumstances

• Right to Object: object to processing based on legitimate interests or for direct marketing purposes

• Right to Withdraw Consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing

• Right to Lodge a Complaint with a Supervisory Authority: you have the right to file a complaint with your local data protection authority (e.g., the ICO in the UK, or the relevant EEA supervisory authority)

 

8.4 How to Submit a Privacy Request

To exercise any of the rights above, you may:

 

• Email us at: info@ghosticesystem.com

• Write to us at: 3312 1/2 Isabel Dr, Los Angeles, CA 90065, Attn:  Ghost Ice LLC Privacy Team

 

We will verify your identity before processing your request. We will respond within the timeframes required by applicable law (typically 30-45 days, with extensions where permitted). Authorized agents may submit requests on your behalf with appropriate documentation.

9. Children’s Privacy

Our services are not directed to children under the age of 18. We do not knowingly collect personal information from children without verifiable parental consent. If we learn that we have inadvertently collected personal information from a child, we will delete it promptly.

If you believe we have collected information from a child in error, please contact us immediately at: info@ghosticesystem.com

10. Security

We implement commercially reasonable technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Access controls and multi-factor authentication for systems storing personal data

• Regular vulnerability assessments and penetration testing

• Incident response plans and breach notification procedures

• Employee training on data handling and security practices

 

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach affecting your rights and freedoms, we will notify you and applicable regulators as required by law.

11. Third-Party Links and Services

Our website and services may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through links on our platform. We are not responsible for the privacy practices or content of third-party sites.

12. Sensitive Personal Information

To the extent we collect or process any of the following categories of sensitive personal information, we do so only with your explicit consent or as otherwise permitted by law:

• Government-issued identification numbers

• Financial account credentials

• Health or medical data

• Biometric data used for identification purposes

• Racial or ethnic origin

• Sexual orientation or gender identity

• Contents of private communications

 

You have the right to limit our use of sensitive personal information to uses strictly necessary to provide the service you requested.

13. Automated Decision-Making and Profiling

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on individuals.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of material changes by one of the ways below:

• Posting the updated policy on our website with a new "Last Updated" date

• Sending an email to the address associated with your account (for material changes)

• Displaying an in-app or in-service notice

 

Your continued use of our services after the effective date of the updated policy constitutes your acknowledgment of the changes. For material changes requiring fresh consent, we will obtain it before processing your data under the new terms.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

 

Ghost Ice Llc

Attn: Privacy Team / Data Protection Officer

3312 1/2 Isabel Dr    

Los Angeles, CA 90065

Email: info@ghosticesystem.com

Phone: 213-222-8070

 

We aim to respond to all privacy inquiries within 30 days. For requests related to your legal rights, we will respond within the timeframe required by applicable law.