Privacy Policy

Last Updated: March 26, 2024
This Privacy Policy describes the privacy practices of Santa’s AI Lab Inc. (“Santa AI”, “we”, “us”, or “our”) and how we handle personal information that we collect through our mobile application Iceberg Messenger, our website located at https://www.iceberg.chat/ (the “Site”) and through any other applications, websites or services that we own or control and that link to this Privacy Policy (collectively, the “Service”). The Service is designed to be an AI-powered chat platform to enhance how you communicate with friends through recommendations, goal settings and other personalized features.We care about the protection and confidentiality of your personal information and have developed this Privacy Policy to describe the information we collect through the Service and to explain how it is used and to whom it may be disclosed. It also explains how you can contact us if you have any questions or concerns.Personal Information We CollectInformation you provide to us:Contact and account information, such as your first and last name, email address, date of birth, phone number and password. If you create an account or log into the Service using third-party services, such as Google, we will receive personal information about you (such as your name, email address and/or phone number) as permitted by your profile settings on the third-party service in order to authenticate you. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with our Service.Biographical information. We may ask you to provide us with some additional personal information about you that will be visible in our Service, such as a profile picture, and information you may choose to provide in your profile to tell others more about you, such as gender, age, school or job.  
Interests and preferences. In creating your account, you will have the option to share information about your preferences so that we may offer you a more customized experienced. We also learn about your interests and your preferences over time through your use of the Service to personalize the features of the Service.Contact information of your friends. We may, with your permission, access your mobile contact list including saved phone numbers, names and profile photo, to help you connect with people you know on the Service.Content and metadata of any messages, including chats, that you send using the Service or to us directly. When you choose to send messages and reactions to friends on the Service, you provide us with the message or reaction sent. We may review the contents of these messages if a user reports, or we otherwise detect, a potential trust and safety violation or potentially illegal or illicit activity or violations of our Terms and Conditions, as permitted by applicable laws.Communications that we exchange with you, including when you respond to our surveys or contact us with questions, feedback or otherwise.Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.Where you provide us with the personal information of third parties, such as people in your mobile contact list, it is your responsibility to inform them about the processing of their personal information in accordance with this Policy, and to confirm that they have given their permission.Automatic data collection. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Service, online resources, and our communications, such as:Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings and general location information such as city, state, or geographic area.Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications.We use the following tools for automatic data collection:Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.Information we receive from third parties.We maintain pages on social media platforms (which may include Facebook, TikTok and Instagram) that collect and process your personal information in accordance with their own privacy policies. You or the platform providers may provide us with information through the social media platform, and we will treat such information in accordance with this Policy.If you are a mobile contact of a user and that user has given Santa AI permission to access their mobile contact list, Santa AI may collect and process your phone number from that list.How We Use Personal InformationWe use personal information for the following purposes or as otherwise described at the time of collection:Provide our Service. We use personal information to operate, maintain, and provide you with our Service, including to allow you to set up and manage chats and to enable you to sync your mobile contact list to find and connect with people you may know on the Service and to invite new people to join the Service more easily.Communicate with you about our Service. We use personal information to respond to your requests, provide user support, communicate with you about our Service, including by sending announcements, surveys, reminders, updates, security alerts, and support and administrative messages.Improve, monitor, personalize, and protect our Service. We use your personal information to improve and keep our Service safe for our users, which includes: Understanding your needs and interests, and personalizing your experience with the Service and our communications.Improving and adding features to our services.
Troubleshooting, testing and research, and keeping the Service secure.
Research and development. We may use personal information for research and development purposes, including to analyze trends, usage, activities and statistics, and to improve the Service and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect and use the resulting information for statistical analysis regarding the use of the Service, such as to better understand our user base, or for other purposes. Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).Audit our internal processes for compliance with legal and contractual requirements and internal policies.Enforce the terms and conditions that govern the Service.Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.How We Disclose Personal InformationWe may disclose your personal information to third parties as described below:Service providers. We may rely on third-party service providers in furtherance of the purposes described above. In these cases, personal information may be accessed by these third parties and processed or stored on our behalf. These service providers can include hosting services, cloud computing and storage services, maintenance services, security services, and user support services. To enable us to provide you with relevant responses, we will also disclose some of your information to AI technology providers that power our Service. For example, we will disclose conversations and chat history to AI technology providers to generate intelligent and personalized responses and recommendations in conversations with users. We require our AI service providers to use your information only for the purpose of generating responses to your chats, and we do not allow those providers to train their AI models using your data.Professional advisors. We may disclose personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, our company (including, in connection with a bankruptcy or similar proceedings).How You Disclose Personal Information:Other users. When you establish an account on our Service, you disclose certain of your information provided on the Service to the Iceberg Messenger community. This information may include your profile information, interests and other information or content you may elect to share in accordance with the privacy settings you establish on the Service.Privacy ChoicesDelete your account. You can delete your account in our account settings.Personal information requests. Where applicable, you may request the following in relation to personal information:Information about how we have collected and used personal information. We have made this information available to you by including it in this Privacy Policy.Access to a copy of the personal information that we have collected about you.Correction of personal information that is inaccurate or out of date.Deletion of personal information that we no longer need to provide the Service or for other lawful purposes.To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions in the emails you receive from us. You may also opt out of receiving marketing communications from us by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Service-related and other non-marketing communications.Third-party opt-out. There are a number of ways to limit online tracking, which we have summarized below. Please note that these opt-out tools are not associated with Santa AI and we cannot guarantee that these tools work as their providers advertise them:Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/. Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.  Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.SecuritySecurity plays a crucial role in the effectiveness of conversational AI: it is essential for individuals to have confidence in the responsible and secure management of their data to truly reap the benefits of our Services. We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. Other Sites and ServicesOur Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.Use of the Service by MinorsOur Service is not intended for individuals under the age of 13. If you have reason to believe that a minor under the age of 13 has provided personal information to us through the Service, please contact us, and we will endeavor to delete that information from our databases.Changes to This Privacy PolicyWe reserve the right to modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service, or as otherwise required by law. How to Contact UsIf you have any questions about this Policy or our privacy practices, or to submit a personal information request, please contact us by email at hi@santasailab.com.