Privacy notice
Version 2026-10-31 · pre-launch pilot
Who is responsible
IcePlans is operated by FUNARO LTDA, a company registered in Brazil, business registration (CNPJ) 64.534.917/0001-59 (“we”). Contact: Contact address will be published before launch.
Which rules apply
As a Brazilian company we process personal data under Brazil’s General Data Protection Law (LGPD, Law no. 13.709/2018). Greenland has its own data-protection rules, and the EU General Data Protection Regulation (GDPR) can apply in some situations — for example when a service is offered to people in the EU. It does not apply automatically because of Greenland’s relationship with Denmark, and a Brazilian company is not automatically exempt either. We follow the LGPD and, where they apply to you, Greenland’s rules and the GDPR. If you have a question about your rights, contact us.
1. When you request pilot access
What we store: the e-mail address and company name you type (the only required fields) and, if you fill them in, the number of activities, your answer about the price, website, role, how you heard about us and the optional survey answer. We also store the date, the offer and policy versions shown, the page language and a reference number. If you allowed analytics, the campaign source of your visit (from a fixed list) is added; otherwise it is recorded as “not-consented”.
Why: to reply to your request about the pilot and to understand whether the offer is useful. Legal basis under the LGPD: steps prior to a contract, at your request (art. 7, V).
Product updates are a separate purpose: only if you tick the optional, unticked box. We record the exact text version and the date of that choice. No product updates are being sent during this pre-launch phase; before any sending starts there will be an unsubscribe link in every message. You can withdraw at any time by writing to us.
How long: there is no automatic deletion yet. Our proposal is to delete requests that do not lead to a pilot 90 days after our last reply; this is an operational proposal, not a legal deadline, and it will be stated here once it is in place. Until then, we delete on request.
2. Optional analytics
Analytics is off unless you choose “Allow analytics”. Before that choice nothing is sent to our measurement endpoint, no analytics identifier is created and no campaign is stored. Choosing “Necessary only” keeps it off.
If you allow it, your browser sends us events such as page viewed, pricing seen, demo started/step/completed, video played, form started and request sent. Each event contains: the event name, the page path (without query string), the offer version, the page language, the campaign source from a fixed list, a random session identifier and a random page-view identifier. It never contains your name, e-mail, company, free text, full URL or IP address. The session identifier is kept in your browser’s session storage and is replaced after 30 minutes of inactivity; the page-view identifier exists only in memory. These identifiers are pseudonymous, not anonymous: they do not identify you or your company, but they link the events of one visit. We do not build a profile and there is no advertising use.
Your choice is stored in your browser (local storage “tb_privacy”: version, choice, time). We ask again after 12 months or when this text changes — an operational choice, not a legal deadline. You can change it any time with Privacy settings in the footer; withdrawing stops sending events and deletes the identifiers in your browser. Events already received are kept with their pseudonymous identifiers. There is no automatic deletion of events yet.
3. Necessary technical processing
The site runs on Cloudflare (hosting, Workers and the D1 database). To deliver and protect the site, Cloudflare processes your IP address and request data; our rate limiting uses the IP address only in memory as a counter key — it is not written to our database. Cloudflare keeps its own service logs under its policies. Our application logs record the event type, the price answer and a test flag, never your e-mail. These security and operational logs are separate from optional analytics.
In your browser: the theme (light/dark) is stored only if you switch it; a service worker keeps a copy of static files (styles, fonts, images, scripts and an offline notice) to load faster — never form data or answers from our server. Fonts are served from this site. There are no third-party analytics, advertising pixels, heatmaps, session recording, captcha or embedded third-party video.
4. Providers and international transfer
Cloudflare, Inc. (United States) and its global network process data on our behalf. A regional preference for the database does not by itself guarantee where data is processed or which jurisdiction applies, and it does not cover logs, backups or support. We therefore do not promise storage exclusively in the EU or in any single country. Cloudflare processes this data under its standard data processing terms.
Request notifications: when you send a request, a short notice with your company name, e-mail address, your optional answers about activities and price and the reference number is sent through Telegram (Telegram Messenger Inc.) to the account of the person who replies to you, so that new requests are seen quickly. Telegram processes this notice under its own terms. Your request itself is stored in our database first; the notice is only a copy of these fields.
5. Sharing
We do not sell personal data. The providers above process it on our behalf. We may disclose data where the law requires it.
6. Documents
During this pre-launch phase no real safety-plan documents are uploaded. The demo uses fictitious data only. How documents would be processed in a pilot will be described in the written pilot terms before anything is uploaded.
7. Your rights
You can ask for access, correction, deletion, information about sharing and withdrawal of consent by writing to the contact above. Deletion removes your data from our active database; copies in provider logs or backups may remain for a limited time under those providers’ policies, and some data may have to be kept where the law requires it.
Pending before launch
- Contact address.
- Automated retention for requests and events.