ICE LOCK Privacy Policy

Effective Date: January 8, 2026

ICE LOCK is a data protection solution developed and provided by Flothers. Flothers is committed to protecting the privacy and security of personal and organizational data. This Privacy Policy explains how information is collected, used, stored, and protected when organizations and users use the ICE LOCK platform, including its data classification, encryption, access control, and secure file-sharing capabilities.

By using the ICE LOCK platform, you agree to the terms of this Privacy Policy.

Ownership

ICE LOCK is owned and operated by Flothers, the entity responsible for managing user data and ensuring compliance with applicable data protection regulations.

1. Information We Collect

ICE LOCK collects only the information necessary to deliver and operate its security services.

1.1 User Information

• User names, email addresses, and organizational identifiers
• Authentication and authorization details
• User roles, permissions, and access rights

1.2 File and Metadata Information

• File metadata such as file name, size, type, and classification labels
• Access and activity logs (e.g., file access, sharing, revocation)
• Policy enforcement and audit events

1.3 Device and Usage Information

• Device type, operating system, and application version
• IP addresses, timestamps, and security-related telemetry for auditing and threat detection

2. How We Use Information

Flothers uses collected information solely to:

• Classify and label data according to defined security policies
• Encrypt files and enforce persistent access control
• Enable secure internal and external file sharing
• Authenticate users and devices
• Monitor security events and prevent unauthorized access
• Provide auditing, reporting, and compliance support
• Maintain, operate, and improve the ICE LOCK platform

3. Data Protection and Security

ICE LOCK applies industry-standard security measures, including:

• Strong encryption for data at rest, in transit, and in use
• Persistent file-level access control and digital rights enforcement
• Centralized policy management and administration
• Secure authentication and authorization mechanisms
• Continuous monitoring, logging, and auditing

Security policies remain enforced even when files are shared externally or accessed from computers or mobile devices.

4. Data Sharing and Disclosure

Flothers does not sell, rent, or trade personal or organizational data.

Information may be disclosed only:

• To authorized users as defined by the organization's access control policies
• To external users explicitly invited through secure sharing mechanisms
• When required by applicable laws, regulations, or legal processes
• To trusted service providers strictly for operating and supporting ICE LOCK, under confidentiality and data protection obligations

5. External File Sharing

When organizations use ICE LOCK to share files externally:

• Access is protected using email verification, passwords, and defined permissions
• Files remain encrypted and governed by ICE LOCK policies
• Access rights can be revoked or modified at any time by authorized administrators

6. Data Retention

Flothers retains data only for as long as necessary to:

• Provide and operate the ICE LOCK service
• Meet legal, regulatory, and contractual requirements
• Support audit, compliance, and security investigations

Organizations control retention and access policies through the centralized ICE LOCK management portal.

7. User and Organization Rights

Subject to applicable data protection laws, users and organizations may have the right to:

• Access and review their personal or organizational information
• Correct or update user information
• Request deletion of user-related data
• Control access, sharing, and revocation of protected files

Such requests are typically managed by the organization's designated ICE LOCK administrator.

8. International Data Transfers

ICE LOCK may process data in different geographic regions depending on deployment and customer configuration. Flothers ensures that all data transfers are protected using appropriate technical and organizational safeguards in accordance with applicable data protection laws.

9. Changes to This Privacy Policy

Flothers may update this Privacy Policy from time to time. Any material changes will be communicated through ICE LOCK or official Flothers communication channels. Continued use of the platform after changes constitutes your acceptance of the updated policy.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your data, please contact us:

• Company: Flothers
• Email: support@flothers.com