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Privacy Policy

Last updated: 14 March 2026


Data controller: Black Bear Studio — blackbear.so Product: Glacier — getglacier.ai Privacy contact: hello@getglacier.ai


1. Data we collect

Account data

When you sign up or sign in, Clerk (our authentication provider) collects and stores your email address, name, and OAuth profile information (e.g. from Google). We receive a user ID and basic profile from Clerk to associate your account with your workspace.

Workspace content

Any data you create in Glacier — cards, columns, documents, comments, labels, and project settings — is stored in our database and associated with your workspace.

Usage analytics

We use Vercel Web Analytics (privacy-preserving, no cookies, no cross-site tracking) to measure aggregate page views and performance metrics. No individual-level tracking data is stored.

Technical data

Standard server logs including IP addresses, timestamps, and request metadata. Retained for up to 30 days for security and debugging purposes.


2. How we use your data

We use your data exclusively to:

  • Provide and operate the Glacier service
  • Authenticate you and manage your workspace
  • Send transactional emails (invitations, notifications) via Postmark
  • Monitor service health and debug issues
  • Comply with legal obligations

We do not use your workspace content for AI model training. We do not sell your data to third parties.


3. Legal basis (GDPR)

For users in the European Economic Area (EEA), we process your data under the following legal bases:

Data typeLegal basis
Account dataPerformance of a contract (Article 6(1)(b))
Workspace contentPerformance of a contract (Article 6(1)(b))
AnalyticsLegitimate interest — service improvement (Article 6(1)(f))
Security logsLegitimate interest — fraud prevention (Article 6(1)(f))
Marketing emailsConsent (Article 6(1)(a)) — only if you opt in

4. Data storage and hosting

ComponentProviderLocation
ApplicationVercelEdge / US
DatabaseNeon (Postgres)AWS us-east-1
File storageCloudflare R2Global edge
AuthenticationClerkUS / EU
EmailPostmarkUS

We use standard contractual clauses (SCCs) for international transfers where required under GDPR.


5. Third-party processors

We work with the following sub-processors:

ProcessorPurposePrivacy policy
ClerkAuthentication and user managementclerk.com/privacy
VercelApplication hosting and analyticsvercel.com/legal/privacy-policy
NeonPostgres database hostingneon.tech/privacy
PostmarkTransactional email deliverypostmarkapp.com/privacy-policy
CloudflareFile storage (R2)cloudflare.com/privacypolicy

All processors are bound by data processing agreements and are GDPR-compliant.


6. MCP server data handling

Glacier exposes an MCP (Model Context Protocol) server that allows AI agents (such as Claude) to read and write your workspace content.

  • API key auth: When you use an API key to connect an MCP client, that key grants access scoped to your workspace only. Your data is never accessible to other users via MCP.
  • OAuth auth: OAuth tokens are scoped to the workspace and projects you authorised at consent time.
  • What AI agents can access: Only the data you have permission to access in the Glacier web app. There is no elevated privilege via MCP.
  • We do not log or store MCP request content beyond standard server access logs (retained 30 days).

7. Data retention

Data typeRetention period
Account and workspace dataFor the lifetime of your account
Server logs30 days
Deleted workspace content30 days after deletion, then permanently removed
Closed accounts30 days after closure, then permanently removed

8. Your rights (GDPR)

If you are in the EEA, you have the following rights:

  • Access — request a copy of your personal data
  • Rectification — correct inaccurate data
  • Erasure — request deletion of your data ("right to be forgotten")
  • Portability — receive your data in a machine-readable format
  • Restriction — ask us to limit processing of your data
  • Objection — object to processing based on legitimate interest

To exercise any of these rights, contact us at hello@getglacier.ai. We will respond within 30 days.

You also have the right to lodge a complaint with your national data protection authority. In Italy, this is the Garante per la protezione dei dati personali.


9. Cookies and analytics

Glacier uses:

  • Session cookies set by Clerk for authentication (strictly necessary, no consent required)
  • Vercel Web Analytics — no cookies, no fingerprinting, privacy-preserving aggregate metrics only

We do not use advertising cookies, third-party tracking pixels, or behavioural analytics.


10. Children's privacy

The Service is not directed at children under 16. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, contact us at hello@getglacier.ai and we will delete it.


11. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top and notify you of material changes by email or via a notice in the Service.


12. Contact

For privacy questions, requests, or complaints:

Black Bear Studio hello@getglacier.ai blackbear.so