Icetrak Limited’s Privacy Notice


1          Definitions


We use the following definitions in this notice:

2          Responsibilities


Icetrak Limited is responsible for processing your personal data.

The Controller is Icetrak Ltd,  2 Nimrod House, Malvern, Worcestershire with a Company Registration Number of 04415020

If you have any questions regarding this Privacy Notice or our privacy practices, you may contact our Privacy team and Data Protection Officer via the email address


3          About icetrak Services


Icetrak is a Communications Platform-as-a-Service (CPaaS) provider. While providing Services to our customers, we act either as the controller or the processor, depending on the situation.

When we act as a processor

Our customers are mainly companies that integrate our Services into their business operations through their own software. By using our Services, our customers are able to send or exchange communications with their end-users using different communication channels (SMS, fax etc.). We do not have a direct relationship with our customers’ end-users.  Therefore we simply distribute our Customers communications requests through telecom operators and other communications providers. When we do this, we act as the processor on behalf of our customers, and process the relevant data for the sole purpose of providing our Services to them. We do that within limits and according to customers’ instructions and in line with our Terms of Services.

In this scenario i.e. when you as an end-user of a communication from one of our customers it means that the customer is the controller, and Icetrak is the processor. Any request we may receive from customers’ communication recipients regarding their rights related to our activities taken on behalf of our customers will be forwarded to customers, or the end-user will be asked to contact them directly.

When we act as a controller

This Privacy Notice describes the activities which Icetrak undertakes as a controller. Icetrak is a controller when we process personal data for our own purposes and do not act on behalf of someone else.


4          How we obtain personal data


The personal data we process is mostly provided to us directly by you when you register to use and subsequently send communication requests to end-users via our Services

We also collect data when you visit our website, or otherwise communicate with us.

We can also receive personal information from other sources, such as in the following situations:


5          What Personal data do we collect, why do we collect it and how do we use it.

We typically collect and use personal data for 2 different reasons.

5.1      To provide communication services to our customers


We collect personal data to provide communication services for our customers.

In this instance we are acting as a Data Controller.

5.1.1  Why

Icetrak collects customer data in order to maintain a business relationship with that customer, create a customer account so the customer can use our Services and bill the customer accordingly.  Collecting this data is in our legitimate interest in the sense of providing our Services to your organisation.

In order to create an account for a customer and provide services to our customers Icetrak will collect the following data directly from the customer typically during the customer registration process.


5.1.2  Retention

The customer account data will be kept for 7 years after the account is closed.


5.2      To allow customer to communicate and send messages to their end users and produce billing data.


We collect personal data to allow our customers to send messages to their end users and produce billing reports for those transactions.

In this instance we are acting as a Data Processor only.

5.2.1  What we collect


Icetrak collects communications data sent directly to us by the customer that includes:

We also collect “usage data”, which is information created during your use of our Services. This includes information communicated by the customers application to Icetrak (e.g. IP addresses, information on your usage, routing information), as well as logs of your activities.

5.2.2  How we collect it

5.2.3  Why we collect it

Communications content is collected and processed solely on behalf of a given customer. We act as a processor and in line with the customer’s instructions.

Traffic data is generally kept in the form of communication detail records, and we collect it and use it to:

The carrying out of these activities is in our legitimate interest in the sense of handling payments and resolving financial disputes.

Please note that in order to comply with our legal obligations, we may be obliged to share communications related data upon government request.

5.2.4  Retention

6          How do we share personal data

We may engage suppliers (also known as vendors or service providers) to help us in the processing of your personal data for the activities that we conduct as a controller and that we describe in this Privacy Notice.

For example we use a 3rd party accounts system to manage our accounts and invoices.  Details of this can be found at

We do not share personal data with third parties except when strictly necessary and on a need-to-know basis, such as with:

8          Data Security

For Accounting and Invoicing purposes Icetrak uses a 3rd party product  We upload customers billing contact details and Invoice details to this platform.

Other than our Invoicing system all personal data where we act as a controller is stored on our secure servers in the UK.

Only Icetrak staff have any access to these servers.

9          Your Data Protection Rights


Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at if you wish to make a request.

10       Personal Data Retention Periods

Retention periods are listed under the activities in section 5 of this Privacy Notice. The retention periods listed are the standard default periods. In some cases, exceptions apply due to local laws related to law enforcement, tax, or other purposes. Additionally, if legal matters such as litigation, law enforcement requests, or government investigations require us to preserve records, including those containing personal information, for longer periods than listed in section 5, then we will delete the records in question when we are no longer legally obligated to retain them.