Privacy Policy

Last Updated: March 6, 2026

Mini App Labs, LLC ("Ice Breaker," "we," or "us")

Overview

Ice Breaker is an AI-powered jobs and recruiting platform that helps job seekers and employers connect more effectively. This Privacy Policy explains how we collect, store, use, disclose, and process personal information when you use our services, visit our website, or interact with us.

This Policy covers:

By using Ice Breaker, you acknowledge the collection, use, and handling of your information as described here.

California Residents: You have the right to know, delete, correct, and opt out of the sale or sharing of personal information under the CCPA.

1. Information You Provide to Us

Account Information

When you create an account or use Ice Breaker, you may provide:

Payment Information

If you purchase a subscription or paid feature, you may provide payment or credit card information. This data is used solely to process your purchase.

Communications

When you contact us for support, submit feedback, or respond to surveys, we collect the content of those communications.

All information in this Section 1 is referred to as "Account Information."

2. Information We Collect Automatically

We and our service providers use automated means to collect information when you visit our website or use Ice Breaker, including:

Cookies

Files stored on your device that identify your browser or store settings. You can control cookie preferences in your browser, though disabling cookies may limit certain features.

Web Server Logs

Our servers record:

Web Beacons and Pixels

Small tags that link pages to servers and cookies. These may be included in emails we send you.

Mobile Data

If you use Ice Breaker on a mobile device, we may collect:

Inferred Information

We may use data like your IP address or device identifiers to infer additional information about you, such as your location or industry, for analytics and service improvement.

All information in this Section 2 is referred to as "Usage Information."

3. Information from Marketing and Sales Activities

You may voluntarily provide information through:

Website Forms

Events

If you attend an in-person or virtual event or agree to a recorded meeting, we may record some or all of that session for business and marketing purposes.

All information in this Section 3 is referred to as "Marketing Information."

4. How We Use Your Information

4a. Account Information

We use Account Information to:

Artificial Intelligence and Machine Learning:

Ice Breaker uses AI and machine learning to power core features including job matching, resume analysis, candidate recommendations, interview preparation, and personalized career insights. To provide these features, we may process your Account Information using internally developed models and third-party AI providers. You have the right to object to or opt out of AI-based profiling by contacting us.

4b. Usage Information

We use Usage Information to:

4c. Marketing Information

We use Marketing Information to:

4d. Safety and Compliance

We may use any of the above information to:

5. How We Share Your Information

5a. Service Providers

We share information with service providers who help us operate Ice Breaker, including:

5b. Employers and Job Seekers

When you apply for a job through Ice Breaker, your profile and application materials are shared with the relevant employer. Employers' job listings are displayed to job seekers based on matching criteria.

You control what information is visible on your profile and what gets shared with employers.

5c. Other Sharing

We may share information:

6. Analytics, Advertising, and Do-Not-Track

Advertising

We and our advertising partners may collect data about your activity on Ice Breaker and other sites to deliver targeted ads. This includes the use of cookies, pixels, and similar technologies.

We may retarget you with ads for Ice Breaker when you visit other websites.

Opt-Out Options

You can opt out of interest-based advertising through:

These opt-outs apply per browser and must be repeated across browsers. Opting out does not block all cookies or prevent all data collection. You will still see ads, but they may be less relevant.

7. Your Choices

Account Settings

You can update your profile, preferences, and notification settings through your Ice Breaker account at any time.

Data Deletion

You can request deletion of your account and personal data by contacting us at lucas.h@kresus.com. We will process your request in accordance with applicable law.

Data Access

You can request a report of the personal information we hold about you by contacting lucas.h@kresus.com.

Marketing Opt-Out

You can unsubscribe from marketing emails using the link in any marketing email we send, or by contacting us directly.

8. Security

We take information security seriously and implement appropriate technical and organizational measures to protect your data. That said, no system is perfectly secure. When you provide information to us, you do so at your own risk.

To help protect your account:

9. Third-Party Links and Services

Ice Breaker may contain links to third-party websites, applications, or services. We may also integrate third-party content or features. Your interaction with these third parties is governed by their own privacy policies. We are not responsible for their practices.

10. Children

Ice Breaker is not intended for use by anyone under the age of 16. We do not knowingly collect personal information from individuals under 16. If you believe a minor has provided us with personal information, contact us at lucas.h@kresus.com and we will delete it.

11. Information for European Territory Residents

This section applies to residents of the European Economic Area, Switzerland, or the United Kingdom (the "European Territories").

Legal Basis for Processing

We process your personal data based on:

Where we rely on legitimate interest, we conduct a balancing test to ensure your rights are not overridden. You may object to this processing at any time by contacting lucas.h@kresus.com.

Your Rights

As a European Territory resident, you have the right to:

  1. Access, correct, update, or delete your personal data
  2. Object to or restrict our processing of your personal data
  3. Withdraw consent at any time (this does not affect the lawfulness of processing before withdrawal)
  4. Data portability: receive your personal data in a structured, machine-readable format
  5. File a complaint with your local data protection authority

To exercise any of these rights, contact us at lucas.h@kresus.com.

If you are uncertain whether we process your data as a controller or processor in a specific context, contact us for clarification.

Data Retention

We retain your personal data for as long as your account is active or as needed to provide our services. We also retain data as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

When data is no longer needed, we delete or anonymize it. If you request deletion, we may retain limited information in a suppression file to ensure we don't re-collect your data in the future.

12. International Transfers

Ice Breaker is hosted in the United States. If you access Ice Breaker from outside the United States, your personal information may be transferred to and processed in the United States. By using Ice Breaker, you consent to this transfer.

Laws regarding personal data processing in the United States may differ from those in your country. Do not provide information to us unless you have the proper consents required in your jurisdiction.

13. Data Privacy Framework Compliance

Mini App Labs, LLC complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce.

We have certified that we adhere to the DPF Principles for personal information received from the EU, UK, Gibraltar, and Switzerland. If there is any conflict between this Privacy Policy and the DPF Principles, the Principles govern.

To view our certification, visit dataprivacyframework.gov.

Complaints

If you have a complaint about how we handle your personal data under the DPF, contact us first at lucas.h@kresus.com. If we cannot resolve your complaint, we commit to cooperating with the panel established by the EU data protection authorities, the UK Information Commissioner's Office, the Gibraltar Regulatory Authority, and the Swiss Federal Data Protection and Information Commissioner.

You may, under certain conditions, invoke binding arbitration for complaints not resolved through other mechanisms. See dataprivacyframework.gov for details.

The Federal Trade Commission has jurisdiction over our compliance with the DPF.

Onward Transfers

We are liable for the processing of personal information we receive under the DPF and subsequently transfer to third parties acting on our behalf. We remain liable if a third party processes that information in a manner inconsistent with the DPF Principles, unless we prove we are not responsible for the event causing the damage.

Disclosures to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for national security or law enforcement purposes.

14. Changes to This Policy

We may update this Privacy Policy as our practices and legal requirements evolve. When we do, we will post the updated policy on our website with a new "Last Updated" date.

If you disagree with any changes, you should stop using Ice Breaker and delete your account.

15. Contact Us

Questions, requests, or concerns about this Privacy Policy? Reach out:

Email: lucas.h@kresus.com

Mail:
Mini App Labs, LLC
120 Corte Madera Rd
Corte Madera, CA 94925