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Privacy policy

Effective date: 2026-09-14

1. Introduction

Welcome to Ice Open Network.

Ice Open Network (“us”, “we”, or “our”) operates the ice.io website, the ION network and the ION products: ION VPN, ION Mail, ION Browser, ION Vault, ION Proxies and ION Agents (together, the “Service”).

This Privacy Policy explains what information we collect when you visit ice.io or use any part of the Service, how we use and protect it, and when we share it. Several of our products are built so that we never receive certain data in readable form; section 5 explains what that means for each product.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used here have the same meanings as in our Terms of Service (“Terms”), which together with this Privacy Policy constitute your agreement with us (“agreement”).

2. Definitions

SERVICE means the ice.io website, the ION apps, the ION network and its gateways, and the products ION VPN, ION Mail, ION Browser, ION Vault, ION Proxies and ION Agents, operated by Ice Open Network.

NODE OPERATOR means a person who installs ION node software on an internet connection they control and chooses to relay traffic for the ION network in return for payment.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of the Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide information that can be used to contact or identify you (“Personal Data”). Depending on the products you use, this may include:

  • your email address, including the address you give when you join the waitlist;
  • your name, if you choose to provide it;
  • your ION Mail address, for example a handle on @ice.io or @online.io;
  • billing details, such as your plan, invoices and payment status;
  • the public wallet address you pay from, or receive node operator payouts to;
  • the messages you send to our support team.

We do not require identity verification to use the Service, except where the law requires it for a particular payment or payout.

We may use your email address to send you service messages and, where you have agreed or the law allows it, news and offers. You may opt out of receiving marketing messages at any time by following the unsubscribe link.

Payment Data

Card and other conventional payments are processed by our payment providers. We receive confirmation of the payment and limited details, such as the card type and its last four digits, but never the full card number.

Payments made in digital assets, including x402 payments made by ION Agents and node operator payouts, are recorded on a public blockchain. Anyone can see these transactions and the wallet addresses involved, and neither we nor anyone else can delete them.

Usage Data

We may also collect information that your browser sends whenever you visit our website, or that our apps send when you use them (“Usage Data”).

This Usage Data may include information such as your Internet Protocol address (IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, the type of device you use, its operating system, unique device identifiers and other diagnostic data.

Usage Data about our website and apps is separate from the traffic you send through ION VPN, ION Proxies or ION Agents, which is covered in section 5.

Tracking Cookies Data

We use cookies and similar tracking technologies to track activity on our website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts, to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.
  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies: We use Security Cookies for security purposes.
  • Analytics Cookies: We use Analytics Cookies to understand how visitors use our website (see section 15).
  • Advertising Cookies: Where we advertise, our advertising partners may use cookies to measure and personalise ads (see section 16).

5. How Each Product Handles Your Data

The commitments below describe how each product is built, and they form part of this Privacy Policy.

ION VPN

Your traffic is encrypted on your device with a key that never reaches our servers, before it leaves the device. It is relayed through a node operator’s connection, and neither the node operator nor we can read it. We do not keep logs of the websites you visit or of the content of your traffic, exits rotate every session, and your billing identity is never attached to the route your traffic takes. We keep only the minimum technical data needed to run the network, such as aggregate bandwidth counts.

ION Mail

Messages between ION addresses are end-to-end encrypted, with keys generated on your device. Mail that arrives from outside the ION network is encrypted to your key as it arrives, before it is written to disk. Search runs against an encrypted index on your device, so we never receive your search queries. Tracking pixels and link trackers are removed from incoming mail.

To deliver mail, our servers necessarily process routing information, such as sender and recipient addresses, message size and delivery times. You can export your mail at any time.

ION Browser

ION Browser blocks trackers by default and changes its browser fingerprint every session, so websites cannot use your fingerprint to recognise you across sessions. We do not collect your browsing history. If you import saved logins when you first launch the browser, they are moved into ION Vault and encrypted on your device.

ION Vault

Your vault is encrypted on your device with a key derived from your master password. We never receive your master password or that key, so we cannot read the contents of your vault, and we cannot recover them if you lose your master password. We store only your encrypted vault and the technical data needed to keep it in sync across your devices.

ION Proxies

We bill on byte counters, not on request records. The URLs you fetch and the content of your requests are not stored. We keep your account details, usage totals and billing records.

ION Agents

ION Agents requires no account and no API key. Each request is paid for with an x402 payment from the agent’s wallet. We process the payment details needed to accept the request, and those payments are recorded on a public blockchain as described in section 4. As with ION Proxies, we do not store the URLs your agents fetch.

Node Operators

If you run an ION node, we process the wallet address you receive payouts to, the bandwidth cap you set, the amount of traffic your node relays and the payouts it earns, the node’s IP address and approximate location, and the basic device information needed to route traffic safely. ION VPN traffic relayed through your node is encrypted, and you cannot read its contents.

6. Use of Data

Ice Open Network uses the collected data for various purposes:

  • to provide, maintain and secure our Service;
  • to process payments, subscriptions, refunds and node operator payouts;
  • to apply founding pricing for people who joined the waitlist;
  • to notify you about changes to our Service;
  • to provide customer support;
  • to gather analysis or valuable information so that we can improve our Service;
  • to monitor the usage of our website and apps;
  • to detect, prevent and address technical issues, fraud and abuse of the ION network;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  • to provide you with news, special offers and general information about our products, unless you have opted not to receive such information;
  • to measure and personalise advertising, with your consent where the law requires it;
  • for any other purpose with your consent.

7. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when it is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain it for longer. Data that section 5 says we do not store is not retained for any period.

8. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Ice Open Network will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

9. Disclosure of Data

Ice Open Network does not sell your personal information. We disclose it only in the circumstances below.

9.1. Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities. We can only disclose what we hold. Because of how the Service is built, we do not hold the contents of your ION VPN traffic, your ION Mail messages or your ION Vault, or the URLs fetched through ION Proxies and ION Agents, so we cannot provide them.

9.2. Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

9.3. Other cases. We may disclose your information also:

  • to our subsidiaries and affiliates;
  • to Service Providers acting on our behalf (see section 14);
  • to fulfil the purpose for which you provide it;
  • with your consent in any other cases.

10. Security of Data

We use encryption and access controls to protect your data, and several of our products are designed so that we never hold it in readable form. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR.

We process your Personal Data to perform our contract with you, to meet our legal obligations, for our legitimate interests in running and securing the Service, and, where required, with your consent, for example for analytics and advertising cookies.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at hi@ice.io.

In certain circumstances, you have the following data protection rights:

11.1. the right to access, update or to delete the information we have on you;

11.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

11.3. the right to object. You have the right to object to our processing of your Personal Data;

11.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;

11.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

11.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide the Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

12. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA requires commercial websites and online services that collect personally identifiable information from California consumers to post a conspicuous privacy policy stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

12.1. users can visit our site anonymously;

12.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the home page of our website;

12.3. users will be notified of any privacy policy changes on our Privacy Policy Page;

12.4. users are able to change their personal information by emailing us at hi@ice.io.

Our Policy on “Do Not Track” Signals:

There is no common industry standard for responding to Do Not Track signals, and we do not currently change how our website collects data when it receives one. You can refuse or delete cookies in your browser settings at any time, and you can opt out of analytics as described in section 15.

13. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

13.1. What personal information we have about you. If you make this request, we will return to you:

13.1.1. The categories of personal information we have collected about you.

13.1.2. The categories of sources from which we collect your personal information.

13.1.3. The business or commercial purpose for collecting or selling your personal information.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

13.2. To delete your personal information. You can ask us to delete your personal information by emailing hi@ice.io. Once your account is deleted, you will no longer be able to use the products tied to it. Transactions recorded on a public blockchain cannot be deleted.

13.3. Stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” or “sharing” under California law, including some forms of advertising described in section 16. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling or sharing your personal information, we will stop making such transfers.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances will we discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email: hi@ice.io.

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

14. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), for example for hosting, payment processing, email delivery, analytics and customer support, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

15. Analytics

We use Google Analytics 4, a service provided by Google, to understand how visitors use our website. Google Analytics uses cookies and collects information such as the pages you visit, how long you stay, your approximate location and details about your device and browser. It runs on our website only: it is not used to monitor the traffic you send through ION VPN, ION Proxies or ION Agents, or the contents of ION Mail or ION Vault.

You can learn how Google uses this data at policies.google.com, and you can opt out with the Google Analytics opt-out browser add-on.

16. Advertising

We may use advertising services, such as Google Ads, Meta and X, to show you ads for ION on other websites and apps after you visit our website, and to measure how well those ads work. These partners may use cookies and similar technologies based on your visits to our website. Where the law requires your consent for this, we will ask for it before these technologies are used.

Advertising is never based on the contents of your ION VPN traffic, ION Mail messages, ION Vault or the requests you send through ION Proxies and ION Agents. You can opt out of personalised advertising in the settings of each advertising partner and through your browser’s cookie settings.

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

18. Children’s Privacy

Our Services are not intended for use by children under the age of 16 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 16. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

20. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: hi@ice.io.

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