Privacy Policy

Last Updated: January 30, 2026

1. INTRODUCTION

Icy Studios LLC ("Company," "we," "us," or "our") operates the Noobo mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you of any changes by updating the "Last Updated" date and, for material changes, through in-app notifications or email. Your continued use of the App after changes are posted constitutes acceptance of the revised Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

We may collect personal information that you voluntarily provide when you:

• Create an Account: Email address, username, password, date of birth

• Make Purchases: Payment information is processed by Apple App Store or Google Play Store; we do not store your payment card details

• Contact Support: Name, email address, and any information you provide in communications

• Use AI Features: Build images or descriptions you submit for AI Build Roast analysis

• Interact with Content: Favorites, saved builds, viewing history, search queries

2.2 Information Automatically Collected

When you use the App, we automatically collect certain information, including:

Device Information:

• Device type, model, and operating system

• Unique device identifiers (IDFA for iOS, Advertising ID for Android)

• Mobile network information

• Device settings and preferences

Usage Information:

• Features accessed and time spent in the App

• Content viewed, searches performed, and interactions with builds

• Subscription status and purchase history

• App performance data, crashes, and error logs

• Session duration and frequency of use

Location Information:

• General location data derived from IP address (country/region level)

• We do NOT collect precise GPS location data

2.3 Information from Third Parties

We may receive information from:

• App Stores: Apple App Store and Google Play Store provide purchase and subscription information

• Analytics Providers: Aggregated usage statistics and performance data

• Social Media: If you choose to connect social media accounts (profile information you permit us to access)

2.4 Cookies and Tracking Technologies

We use cookies, beacons, tags, and similar tracking technologies to track activity and hold certain information:

• Analytics Cookies: To understand how users interact with the App

• Preference Cookies: To remember your settings and preferences

• Advertising Cookies: To deliver relevant advertisements (if applicable)

You can instruct your device to refuse cookies or alert you when cookies are being sent. However, some portions of the App may not function properly without cookies.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 Providing and Maintaining the Service

• Create and manage your account

• Process transactions and subscriptions

• Deliver content, features, and functionality

• Provide customer support and respond to inquiries

• Send transactional emails (purchase confirmations, password resets)

3.2 Improving and Personalizing the Service

• Analyze usage patterns and trends

• Personalize content recommendations

• Develop new features and improve existing ones

• Conduct research and analytics

• Test new features and functionality

3.3 AI Build Roast Feature

• Process images and descriptions you submit

• Generate AI-powered feedback and analysis

• Improve AI model accuracy and performance

• Note: AI-generated content is created in real-time and may be stored temporarily for service improvement

3.4 Communication

• Send you updates about the App

• Notify you of changes to our services

• Provide promotional communications (with your consent where required)

• Respond to your comments and questions

3.5 Legal and Security

• Comply with legal obligations

• Protect against fraud and abuse

• Enforce our Terms of Service

• Protect our rights and property

• Resolve disputes

3.6 Marketing

• Send promotional materials about features, offers, and events (you can opt-out)

• Measure effectiveness of marketing campaigns

• Serve targeted advertisements (where permitted)

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We may share information with third-party vendors who perform services on our behalf:

• Cloud Hosting: Amazon Web Services, Google Cloud Platform, or similar

• Analytics: Google Analytics, Firebase Analytics, or similar

• Payment Processing: Apple App Store, Google Play Store

• Customer Support: Email service providers, help desk software

• AI Services: Third-party AI/ML services for AI Build Roast functionality

• Crash Reporting: Tools to identify and fix technical issues

These service providers have access to your information only to perform specific tasks and are obligated to protect your information.

4.2 Business Transfers

If we are involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal processes (subpoena, court order)

• Government or regulatory requests

• Protection of our rights, property, or safety

• Investigation of potential violations

• Prevention of fraud or security issues

4.4 With Your Consent

We may share information for any other purpose with your consent or at your direction.

4.5 Aggregated or De-identified Information

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

5. THIRD-PARTY SERVICES

5.1 App Store Platforms

Your use of the App involves Apple App Store or Google Play Store, which have their own privacy policies:

• Apple Privacy Policy: https://www.apple.com/legal/privacy/

• Google Privacy Policy: https://policies.google.com/privacy

5.2 Third-Party Links

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

5.3 Social Media

If you connect social media accounts, those platforms may collect information about your use of the App according to their own privacy policies.

6. DATA RETENTION

We retain your personal information for as long as necessary to:

• Provide the Service and maintain your account

• Comply with legal obligations

• Resolve disputes and enforce agreements

• Achieve the purposes outlined in this Privacy Policy

Specific Retention Periods:

• Account Information: Retained while your account is active and for a reasonable period thereafter

• Transaction Records: Retained for tax and accounting purposes (typically 7 years)

• Usage Data: Typically retained for 24-36 months for analytics purposes

• Support Communications: Retained for 3 years or as needed for legal purposes

• AI Submissions: Temporarily stored for processing, then deleted unless needed for model improvement

When information is no longer needed, we will securely delete or anonymize it.

7. DATA SECURITY

We implement appropriate technical and organizational measures to protect your information:

• Encryption in transit (TLS/SSL)

• Encryption at rest for sensitive data

• Access controls and authentication

• Regular security assessments

• Employee training on data protection

• Secure data centers and cloud infrastructure

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

8. CHILDREN'S PRIVACY

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

Age Verification: Users must confirm they are at least 13 years old to create an account.

Parental Consent: Users between 13 and 18 must have parental consent to use the App.

If we learn we have collected information from a child under 13 without parental consent, we will delete that information promptly. If you believe a child under 13 has provided us with personal information, please contact us at admin@icystudios.net.

8.1 COPPA Compliance

We comply with the Children's Online Privacy Protection Act (COPPA). We do not:

• Knowingly collect personal information from children under 13

• Allow children under 13 to create accounts

• Serve targeted advertising to children under 13

9. YOUR PRIVACY RIGHTS

Depending on your location, you may have certain rights regarding your personal information:

9.1 General Rights

• Access: Request a copy of the personal information we hold about you

• Correction: Request correction of inaccurate or incomplete information

• Deletion: Request deletion of your personal information (subject to legal obligations)

• Portability: Request a copy of your information in a portable format

• Objection: Object to certain processing of your information

• Restriction: Request restriction of processing in certain circumstances

• Withdraw Consent: Withdraw consent where we rely on consent as the legal basis

9.2 How to Exercise Your Rights

To exercise these rights, contact us at admin@icystudios.net. We will respond within the timeframe required by applicable law (typically 30 days).

Identity Verification: We may need to verify your identity before fulfilling requests.

Account Deletion: You can delete your account in the App settings or by contacting us.

9.3 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights:

Right to Know: Request information about personal information collected, used, disclosed, or sold in the past 12 months.

Right to Delete: Request deletion of personal information, subject to certain exceptions.

Right to Opt-Out: We do not sell personal information, but if we did, you could opt-out.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Shine the Light: California residents can request information about sharing of personal information with third parties for their marketing purposes (we do not share for this purpose).

California Minors: Users under 18 can request removal of publicly posted content.

To exercise California privacy rights, email admin@icystudios.net with "California Privacy Rights" in the subject line.

9.4 European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing:

• Contract Performance: Processing necessary to provide the Service

• Legitimate Interests: Improving the Service, security, and fraud prevention

• Consent: Marketing communications and optional features

• Legal Obligations: Compliance with laws

Your Rights:

• Access, correction, deletion, portability (as described above)

• Object to processing based on legitimate interests

• Lodge a complaint with your local data protection authority

Data Transfers: If we transfer data outside the EEA, we ensure appropriate safeguards (Standard Contractual Clauses, adequacy decisions).

Data Protection Officer: For GDPR inquiries, contact admin@icystudios.net.

9.5 Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate. If you have questions about your privacy rights, contact us at admin@icystudios.net.

10. MARKETING COMMUNICATIONS

10.1 Opting Out

You can opt out of promotional emails by:

• Clicking the "unsubscribe" link in emails

• Adjusting notification settings in the App

• Contacting us at admin@icystudios.net

Note: You cannot opt out of transactional emails (e.g., purchase confirmations, account notifications).

10.2 Push Notifications

You can disable push notifications through your device settings.

11. DO NOT TRACK SIGNALS

Some browsers have "Do Not Track" (DNT) features. Currently, there is no industry standard for DNT, and we do not respond to DNT signals. If a standard is established, we will update this policy accordingly.

12. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer information internationally, we implement appropriate safeguards:

• Standard Contractual Clauses approved by the European Commission

• Adequacy decisions recognizing equivalent data protection

• Other legally approved transfer mechanisms

By using the App, you consent to the transfer of your information to the United States and other countries where we operate.

13. DATA BREACH NOTIFICATION

In the event of a data breach that affects your personal information, we will:

• Notify you within the timeframe required by applicable law

• Provide information about the breach and steps to protect yourself

• Report the breach to relevant authorities as required

• Take immediate steps to secure systems and prevent further breaches

14. YOUR RESPONSIBILITIES

You are responsible for:

• Providing accurate information

• Maintaining the security of your account credentials

• Notifying us of unauthorized access

• Reviewing and understanding this Privacy Policy

• Using the App in compliance with our Terms of Service

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect:

• Changes in our practices

• New legal requirements

• New features or services

• User feedback

Material Changes: We will notify you of material changes via:

• In-app notifications

• Email to your registered address

• Prominent notice in the App

Non-Material Changes: Updated "Last Updated" date reflects minor changes.

Your continued use after changes are posted constitutes acceptance. If you do not agree with changes, please stop using the App.

16. CONTACT US

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

Icy Studios LLC
Email: admin@icystudios.net
Subject Line: Privacy Inquiry

Response Time: We will respond to privacy inquiries within 30 days (or as required by applicable law).

Data Protection Inquiries: For GDPR, CCPA, or other privacy law inquiries, please specify the applicable law in your email subject line.

17. SPECIFIC FEATURES AND DATA USE

17.1 AI Build Roast

When you use the AI Build Roast feature:

• We collect images/descriptions you submit

• Information is processed by AI systems (may include third-party AI services)

• AI-generated feedback is provided in real-time

• Submissions may be temporarily stored to improve AI accuracy

• We do not share your individual submissions with other users

• We may use aggregated, anonymized data to improve the feature

17.2 3D Guides

When you view 3D guides:

• We track which guides you view for analytics and recommendations

• Viewing history helps personalize your experience

• Usage data helps us create better content

17.3 Build Library

When you browse the build library:

• We track searches and views to improve content

• Your favorites and saved builds are stored in your account

• We may recommend content based on your interests

17.4 Subscription Management

For subscription features:

• Subscription status is managed through App Store platforms

• We receive confirmation of active subscriptions

• Payment information is processed by Apple/Google, not stored by us

• Subscription history is retained for accounting purposes

18. ANALYTICS AND ADVERTISING

18.1 Analytics Services

We use third-party analytics services to understand App usage:

• Google Analytics: Usage patterns, demographics, interests

• Firebase Analytics: App performance, user engagement, crashes

• These services may use cookies and similar technologies

You can opt out of analytics:

• Google Analytics: https://tools.google.com/dlpage/gaoptout

• Device Settings: Limit ad tracking in iOS/Android settings

18.2 Advertising

If we serve advertisements:

• We may use your information for targeted advertising

• We may work with advertising partners who use cookies and identifiers

• You can limit ad tracking through device settings

• You can opt out of interest-based advertising through industry opt-out tools

Advertising Partners: We may work with partners like Google AdMob, Meta Audience Network, or similar services, each with their own privacy policies.

19. AUTOMATED DECISION-MAKING

We may use automated decision-making for:

• Content recommendations based on your interests

• AI-generated feedback on builds

• Personalized feature suggestions

You have the right to object to automated decisions that significantly affect you. Contact us at admin@icystudios.net if you have concerns.

20. SENSITIVE INFORMATION

We do not intentionally collect sensitive personal information such as:

• Social Security numbers

• Financial account information (handled by payment processors)

• Health information

• Biometric data

• Information about race, religion, political beliefs, or sexual orientation

If you voluntarily provide such information in support communications or AI submissions, please be aware it will be processed according to this Privacy Policy.

ACKNOWLEDGMENT

By using the Noobo App, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

This Privacy Policy was last updated on January 30, 2026. Please review this page periodically for updates.

Contact for Privacy Questions: admin@icystudios.net
Contact for General Support: admin@icystudios.net
Contact for Legal Inquiries: admin@icystudios.net