Privacy Policy

How we handle your information and privacy

Your privacy is very important to us. Please read below to see how International Cycling Executives (ICE) handles information in connection with ICE’s websites and the related mobile applications and services (collectively, the “Services”). Before we get to the details, here are a few of our fundamental privacy principles:

  • ICE is a social platform and information you upload or post to ICE may be publicly viewable and searchable by ICE members and non-members.
  • We aggregate certain information about our members’ use of the Services for business purposes and we sometimes publish that information or share it with others.
  • We give you several ways to control what information is shared with others and the public and are continuously working to enhance privacy options available to you.

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with the Services. Please also read our Terms of Service which sets out the terms governing the Services.

ICE is headquartered in Sydney Australia and our Services are provided to you by International Cycling Executives Pty Ltd (ICE), or one of our local trading entities in various countries. If you are a resident of the European Union (“EU”), ICE is the controller of your personal data for the purposes of EU data protection law.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail to the address below.
International Cycling Executives Pty Ltd (ICE).
app@internationalcylingexecutives.com

We Collect, Use, Share and Otherwise Process Information

ICE relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we may not be able to provide the Services unless we collect and use your location information;
  • where you have consented to the processing;
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • to protect your vital interests, or those of others, such as in the case of emergencies;
  • where you have made the information public; and
  • where necessary for the purposes of ICE’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.

Information ICE Collects

ICE collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with ICE. We receive information in a few different ways, including when you track, complete or upload activities using the Services. ICE also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with ICE. For example:

  • We collect basic account information such as your name, email address, date of birth, gender, username and password that helps secure and provide you with access to our Services.
  • Profile, activity and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information as well as your speed and pace) or post, join an activity, view others’ activities, or otherwise use the Services.
  • ICE may collect or infer health information. Certain health information may be inferred from sources such as activity duration or other information about your perceived exertion. Before you can upload health information to ICE, you must give your explicit consent to the processing of that health information by ICE. You can withdraw your consent to ICE processing your health information at any time.
  • We gather information from the photos, posts, comments, kudos and other content you share on the Services, including when you participate in partner events or create activities.
  • When you make a payment on ICE, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information.
  • We collect and process location information when you sign up for and use the Services such as connecting to Starva. For example, to record your activity and to provide you with your training statistics and inclusion in the Service’s features (for example, the leader board for a route), it is necessary to collect and record the physical location of your device including, data such as speed and direction. Processing of your location data is essential to the Services which we provide and a necessary part of our performance of the agreement we have with you.
  • ICE allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Linked, Instagram, Strava and Twitter (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences with the applicable Third-Party Account. This information is collected by the Third-Party Account provider and is provided to ICE under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.
  • To help us to provide you with the best possible service, you can choose to provide us with your contact information so we can better respond to your support requests and comments.
  • We also obtain additional third party information about our members from marketers, partners, researchers, and others. We may combine information that we collect from you with information obtained from other members, third parties and information derived from any other subscription, product, or service we provide. We may also collect information about you from other members such as when they give you kudos or comment on your activities.
  • We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.
  • The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, may be linked to session IDs, athlete IDs and device identifiers.

How ICE Uses Information

ICE uses the information we collect and receive to administer and operate the Services and to customize them for you. For example, we use your Strava information to provide you with interesting and useful performance analysis. Subject to your privacy controls, your information, including your profile, username, photos, members you follow and who follow you, clubs you belong to, your activities, the devices you use, and kudos and comments you give and receive will be shared on ICE so that you may be able to participate in the Services, for example to show your place on a leaderboard. Certain information (e.g., your name and some profile information) may also be available to non-members on the web. Your precise location information, such as a route or segment, may also be shared on ICE or to non-members, in accordance with your privacy controls.

We use the information we collect about you, your followers, and your activities to customize your experience. We also use the information we collect to process payments, provide support related to the Services, protect members and enforce our Terms of Service, promote safety, and to communicate with you (including to send marketing communications) where you have agreed to receive such messages and notifications.

We also use the information we collect to analyse, develop and improve the Services. To do this, ICE may use third party analytics providers to gain insights into how our Services are used and to help us improve the Services.

We may also use the information we collect to market and promote the Services, activities on ICE, and other commercial products or services. This includes customizing your ICE experience.

ICE may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. To do this, we remove certain account information, such as your name, and combine the resulting information with similar information from other ICE members. Examples of the type of information we may aggregate in this way include information about equipment, usage, demographics, routes and performance.

How Information is Shared

In addition to sharing aggregated data about our members as described above, we also share information that identifies you in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.

Service Providers

We may share your information with third parties who provide services to ICE such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote ICE or display information that may be relevant to your interests on the Services or other websites or services.

Sharing Information and Activities

As a social network, we share your information with other ICE members and the public in accordance with your privacy controls. For example, all or a portion of your name and other profile information is viewable by other ICE members and the public and, subject to your privacy controls, additional information you provide may also be viewable. If you link your ICE account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.

Publicly Available Information

Your information and content may be publicly accessible to and searchable by other ICE members and non-members. We provide a variety of tools to control the sharing of your information.

Third Party Business via API or Other Integrations

When you choose to use third party apps, plugins, or websites that integrate with the Services, or when you use ICE features that are offered in conjunction with third parties such, they may receive your information and content, including your photos and your activity data (including private activities). Information collected by these third parties is subject to their terms and policies. ICE is not responsible for the terms or policies of third parties.

Affiliates and Acquirers of our Business or Assets

We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If ICE becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.

Legal Requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of ICE or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

DMCA Notices

We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.

How We Protect Information

We take several measures to safeguard the collection, transmission and storage of the data we collect. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. ICE engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm ICE’s identity before any personal information is sent. In addition, ICE’s secure servers protect this information using advanced firewall technology.

To help ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You should use a security-enabled browser to submit your credit card information and other personal information at the Services. Please note that if you do not use a SSL-capable browser, you are at risk for having data intercepted.

Most browsers have the ability to notify you if you change between secure and insecure communications, receive invalid services identification information for the Services you are communicating with, or send information over an unsecured connection. ICE recommends that you enable these browser functions to help ensure that your communications are secure. You can also monitor the URL of the services you are visiting (secure URLs begin with https:// rather than http://), along with the security symbol of your browser to help identify when you are communicating with a secure server. You can also view the details of the security certificate of the services to which you are connected. Please check the validity of any Services you connect to using secure communications.

Disclaimer

While ICE continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and ICE cannot ensure or warrant the security of any information you transmit to ICE. Transmitting personal information is done at your own risk.

Managing Your Settings

Privacy Controls

ICE offers several features and settings to help you manage your privacy and how you share your activities. Most privacy controls are located in your setting page, please refer to the menu in the app to manage your privacy controls.

Adjust Notification and Email Preferences

ICE offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preference by contacting us. You may also unsubscribe by following the instructions contained at the bottom of each email. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or our Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.

Updating Account Information

You may correct, amend or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact ICE. ICE will generally respond to your request within 10-14 business days.

Deleting Information and Accounts

To request that your account is deleted, please contact us. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated.

Note that content you have shared with others, such as photos, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

ICE also provides you the option to remove individual activities you have posted from view on the Services without deleting your account. The activities will typically remain on ICE’s systems. Please contact ICE at if you would like to restore the visibility of an individual activity.

EU Members’ Rights

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Access and Porting

You can access much of your information by logging into your account. If you require additional access or if you are not a ICE member, contact us at to download a copy of your data.

Rectify, Restrict, Limit, Delete

You can also rectify, restrict, limit or delete much of your information by logging into your account, such as to edit your profile, delete photos you have posted, remove individual activities from view, or delete your account. If you are unable to do this, please contact us. ICE will generally respond to your request within 10-14 business days.

Object

Where we process your information based on our legitimate interests explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke consent

Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

Complain

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Transfers

The Services are operated from Australia. If you are located outside of Australia and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in Australia, as it is necessary to provide the Services and perform the Terms of Service. Australian privacy laws may not be as protective as those in your jurisdiction.

Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, where you withdraw your consent to ICE processing your health-related information, ICE will delete all health-related information you uploaded. Following your deletion of your account, it may take up to 30 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to ICE, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services and we use aggregated information. This information will be de-associated with your name and other identifiers.

Other ICE Sites

ICE maintains certain websites that can be accessed outside of https://internationalCyclingexecutives.com, such as https://cyclingexecs.com (the “Other Sites”). The Other Sites maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Site. Please be aware that any personal information you submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. ICE is not responsible for the personal information you choose to submit via the Other Sites.

Privacy Policy Information

ICE reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If ICE makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services please contact us to delete your account.

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