ColdSnap Privacy Policy (this “Privacy Policy”)

Last Updated: January 20, 2026

This Privacy Policy describes how ColdSnap, Corp. (“ColdSnap,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards your data (“Data”):

·      via the online store and website located at: https//coldsnap.com/ including all related information, content, features, tools, products and services, in order to provide you, the customer, with a curated shopping experience and information about our products and services (the "Site");

·      through ColdSnap equipment you purchase that includes software and connectivity features (“ColdSnap Devices”); and

·      that you may provide to us when you meet us in person such as at business conferences, when you are involved in our networking activities, or in an online event hosted by us such as a webinar (collectively, “Networking Activities”).

As used herein: (a) the Site, ColdSnap Devices, and Networking Activities shall collectively be referred to as the “Services”; (b) “you” and “your” mean a user of or someone who engages with the Services; and (c) the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within ColdSnap or among our affiliates within the United States or internationally.

ColdSnap respects your privacy and is committed to taking steps designed to protect your personal information.

Please read this Privacy Policy carefully. By using, accessing, or engaging in any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your Data as described herein. You consent to the practices described in this Privacy Policy and the Terms of Use, available at https://coldsnapb2b.myshopify.com/policies/terms-of-service. If there is a conflict between the Terms of Use and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your Data.

1.     Data We Collect

We collect various types of Data in connection with the Services to operate effectively and provide you with the best possible experience, including:

·      Data You Provide: This includes your name, email address, phone number, addresses, company name (if applicable), information necessary to process refunds, demographic information that may be optionally shared through surveys (such as age, gender, etc.), and any other details you provide through forms such as our contact or newsletter sign-up forms. You may also provide login credentials, e.g., username, password, security questions, preferences and settings, when registering an account.

·      Data Automatically Collected: Our systems may collect your IP address, device type, operating system, device ID, statistics associated with the interaction between device or browser and the Site, browser type and browser version, referring URL, and other unique identifiers as well as user interactions with the Services such as page visits and time spent on pages.

·      Payment Data: Our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly.

·      Machine Data: Certain ColdSnap Devices such as ColdSnap equipment that includes software and connectivity features may collect machine functionality, operational, performance, software or firmware status, error codes, and usage information such as the number, type (SKU), and timing of pods processed (“Machine Data”), as further described in ColdSnap’s Equipment Terms and Conditions of Sale available at https://coldsnapb2b.myshopify.com/pages/terms-and-conditions-of-purchase. Machine Data is collected for purposes including customer support, diagnostics, maintenance, product improvement, analytics, enforcing contractual rights (including suspension or remote deactivation for nonpayment where applicable), and legal or regulatory compliance.

2.     Data Sources

We may collect Data from the following sources:

·      Directly from you including when you create an account, visit or use the Services, communicate with us, or otherwise provide us with Data.

·      Automatically through the Services including from your device when you use the Services, and through the use of cookies and similar technologies. Please see Section 5 below for more details regarding our use of cookies.

·      From our service providers including when we engage them to enable certain technology and when they collect or process your Data on our behalf, such as from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Services.

·      From our commercial partners or other similar third parties, including to create or augment user profiles.

3.     How We Use Your Data

ColdSnap uses Data and Machine Data to operate and improve its business, including for the following purposes:

·      To provide the Services to you.

·      Processing transactions and delivering products you purchase using the Services.

·      Responding to customer service inquiries, product questions, and support requests.

·      For marketing and promotional purposes, such as to send or show you marketing and promotional communications, and/or personalizing content and tailoring marketing communications. Unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may send you electronic newsletters, contact you about the Services, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email using the contact details set out below.

·      Analyzing traffic and user behavior to improve the Services, including to perform statistical analysis of user behavior.

·      Monitoring, supporting, and improving ColdSnap equipment and services.

·      Security and fraud prevention, for instance to authenticate your account; to provide a secure payment and shopping experience; detect, investigate or take action regarding possible fraudulent, illegal, unsafe, or malicious activity; protect public safety; and to secure our Services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you use a secure password and do not share your username, password or other access details with anyone else.

·      Enforcing contractual rights (including suspension or deactivation of equipment for nonpayment, where applicable).

·      When we believe it is necessary or appropriate to comply with applicable laws, regulations, and legal obligations (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities.

·      In addition, we may also anonymize your Data (so that it can no longer be associated with you), in which case we may use and/or disclose such anonymous information for our lawful business purposes. We use reasonable safeguards designed to minimize the risks associated with the process of anonymizing your Data.

·      We may use your Data to send announcements and updates regarding the Services or, if applicable, about your billing account status. You will not be able to unsubscribe from these Services announcements and updates as they contain important information relevant to your use of the Services and are necessary for the performance of our contract with you.

4.     How We Disclose Your Data

We generally disclose Data we gather in connection with our provision of the Services to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you:

·      We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Services, such as hosting and maintaining the Services, providing credit card processing and fraud screening, including the Payment Services Provider, and developing applications for the Services. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information. As examples, these Outside Contractors also include trusted service providers, such as Shopify, fulfillment partners, IT management, and cloud hosting platforms, who support our operations.

·      We may provide Data to third parties, including where such information is combined with similar information of other users of the Services. For example, we might inform third parties regarding the number of unique users who use the Services, the demographic breakdown of our users of the Services, or the products and/or services purchased using the Services and the vendors of such products and services. In addition to the above, when users use our Services, third parties (including without limitation third-party analytics service providers and commercial partners) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect Data may include vendors, analytics services providers, and website tracking services, affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Services use Google Analytics, including its data reporting features. Data collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

·      We may disclose your Data if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Services or the general public.

·      We reserve the right to transfer Data to a third party in connection with a sale, merger, general corporate reorganization, or other transfer of all or substantially all of the assets of ColdSnap or any of its Corporate Affiliates (as defined below), or that portion of ColdSnap or any of its Corporate Affiliates to which the Services relates, or in connection with a strategic investment by a third party in ColdSnap, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

·      We may provide your information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

·      We may disclose Data about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with ColdSnap, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

 

5.     Cookies and Tracking Technologies

We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Services and other websites. Cookies can be used to personalize your experience on the Services (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Services (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Services to help us improve our offerings, and to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services. In the course of providing such analytics services, such third-party analytics service providers could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Services. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Services may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Services may use third-party service platforms (including to help analyze how users use the Services). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here are links to the main third-party platform we use:

·         https://www.google.com/policies/privacy/

·         https://www.shopify.com/legal/cookies

·         https://woocommerce.com/document/woocommerce-cookies/

·         https://legal.hubspot.com/cookie-policy

·         https://www.avalara.com/us/en/legal/cookie-policy.html

In particular, we would like you to be aware that, when you make a payment through the Services and interact with our Payment Services Provider, the Payment Services Provider may place cookies on your computer or mobile device in connection with the provision of its services, including for fraud prevention purposes. Please see https://stripe.com/cookie-settings for more information.

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Services, including e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Services and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete. Note that information collected from cookies and other similar technologies (which may include device identifiers) may be used to send you online advertising for the Service. In particular, information collected from cookies (including cookies placed by third-party vendors, such as Google and its partners) and other similar technologies (which may include device identifiers) may be used to deliver advertisements to users of our Services when such users are using other websites, including Facebook, LinkedIn, and YouTube. These third-party vendors may use cookies and/or device identifiers to serve ads based on your past usage to our Service. You may opt out of a third-party vendor’s use of cookies and/or device identifiers for personalized advertising by visiting https://thenai.org/how-to-opt-out/.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Services. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.

We also collect information through our Internet log files, which record Data such as user IP addresses, browser types, domain names, and other anonymous statistical information involving the use of the Services. This information may be used to analyze trends, to administer the Services, to monitor the use of the Services, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Services and evaluating the Services in general.

6.     Do Not Track (DNT) Signals

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

7.     Data Security and Retention of Data

We take steps designed to implement commercially reasonable administrative, technical, and physical safeguards to protect your Data. Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." In addition, any Data you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. How long we retain your Data depends on different factors, such as whether we need the information to maintain your account, to provide you with Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies. In general, Data is retained only as long as necessary to fulfill the purposes described herein, unless otherwise required by law. To determine the appropriate retention period for Data, we consider the amount, nature, and sensitivity of that Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8.     Children’s Privacy

We are committed to protecting the privacy of children. The Services are not designed for or directed to children under the age of 13. We do not collect Data from any person we actually know is under the age of 13.

9.     Your Rights and Choices

Depending on your jurisdiction and the laws to which we are subject, you may have certain rights, including the right to access, correct, delete, or receive a copy of your Data. To submit a request to exercise any of your rights, or to unsubscribe from marketing communications, contact info@coldsnap.com. Please include the subject “Privacy” in your email.

In the event you submit a request, to protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the Data you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your Data may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your Data stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

10. Third-Party Links

The Services may include links to third-party websites. These sites have their own privacy policies, and ColdSnap does not guarantee and is not responsible for their content or privacy practices. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us or on our behalf in connection with the Services.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will not make changes that result in significant additional uses or disclosures of your Data without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your Data, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Services.

12. Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or your Data, please contact us at:

ColdSnap, Corp.
Attn: Privacy Compliance
6 Enterprise Road
Billerica, MA 01821
Email: info@coldsnap.com. Please include the subject “Privacy” in your email.