Privacy Policy

1. Who we are

Frostline is operated by BLACK FROST DISTILLING, LLC, a Minnesota limited liability company with its registered office at 201 1st Street North, New Ulm, Minnesota, United States ("Frostline", "we", "us"). You can reach us at support@debtidepot.com.

This Privacy Policy explains what personal information we collect when you visit debtidepot.com and use our brewing-recipe and brew-reel generation service (the "Service"), why we collect it, how we use it, who we share it with, and the rights you have under the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA").

By using Frostline you agree to the practices described here. If you do not agree, please do not use the Service.

2. What we collect

We collect personal information in the following categories.

2.1 Account information

When you create an account or sign in, we receive your email address, name (if you provide one), authentication identifier issued by our identity provider, and any profile fields you choose to fill in.

2.2 Brewing inputs

When you use the Service we receive the bean-bag photos you upload, the brew-method, equipment, flavor target, and any free-text prompts you submit. This is the data we need to generate your recipe and your reel.

2.3 Generated outputs

We store the recipes, recipe-card images, and brew-reel videos we generate for you so that you can return to them and download them.

2.4 Billing and transaction data

If you purchase a paid plan or a credit pack, our payment processor Stripe collects your payment-method details, billing name and address, and the country your card was issued in. We receive a record of the purchase, the plan or credits purchased, the amount, and a payment identifier; we do not see or store full card numbers.

2.5 Usage and device data

We log feature usage, request and response timestamps, credit consumption, plan status, IP address, user agent, browser language, device type and approximate location derived from IP. We use access logs to operate, secure and bill the Service.

2.6 Communications

When you write to support@debtidepot.com or open a support thread, we keep the messages you send and the replies we send you.

2.7 Cookies and similar technologies

We and our processors set cookies and use local storage as described in our Cookie Policy. The technologies we use are limited to what is necessary to operate the Service and to optional analytics that you can decline.

3. Why we use it

We use your personal information to:

• create and manage your account, deliver authentication and prevent abuse;
• accept your brewing input, run it through our AI providers, and return your recipe and reel;
• track credits, send invoices, process refunds and respond to disputes;
• provide customer support and security monitoring;
• comply with legal obligations including tax, anti-fraud, and content-safety reporting;
• improve the reliability of the Service through aggregated, de-identified analytics.

We do not use your brewing inputs to train any third-party foundation model. We do not sell your personal information.

4. Legal bases (GDPR / UK GDPR)

Where GDPR or UK GDPR applies, we process personal information on the following bases:

• Contract to provide the Service and bill you for it;
• Legitimate interests to secure the Service, prevent abuse, and improve reliability;
• Consent for optional analytics or marketing cookies, which you can withdraw at any time;
• Legal obligation to retain records required by tax, accounting and consumer-protection laws.

5. Who we share with — sub-processor list

Frostline relies on the following sub-processors to operate the Service. Each sub-processor is bound by a written data-processing agreement (DPA) that limits processing to the purpose of the Service and prohibits using your personal information for unrelated purposes. We will give thirty (30) days' prior notice on this page before adding or replacing a sub-processor in a way that materially affects your data.

For an up-to-date list of sub-sub-processors used by the AI gateway, write to support@debtidepot.com.

In addition to sub-processors above, we may also disclose personal information to:

• Professional advisors (lawyers, accountants, auditors) under confidentiality;
• Authorities when required by valid legal process or to protect rights and safety;
• a successor entity in the event of a merger, acquisition, financing or asset sale, subject to this Policy.

6. International transfers

Frostline is operated from the United States. If you are in the European Economic Area, the United Kingdom, or another jurisdiction with cross-border data-transfer rules, your personal information will be transferred to and processed in the United States and other countries where our processors operate. We rely on Standard Contractual Clauses, equivalent UK Addendum, and adequacy decisions where available.

7. Retention

We retain personal information for as long as your account is active. Bean-bag photos and prompts are retained for up to thirty (30) days for support and abuse review; you may request earlier deletion at any time. Generated outputs are retained while your account is active and for up to ninety (90) days after deletion. Billing records are retained for the period required by tax law (typically seven years).

8. Your rights

Depending on where you live, you have the following rights:

• access to the personal information we hold about you;
• correction of inaccurate or incomplete data;
• deletion of your account and personal information ("right to be forgotten");
• restriction or objection to certain processing;
• portability of your data in a machine-readable format;
• withdrawal of consent for optional analytics;
• the right to lodge a complaint with a supervisory authority;
• under CCPA/CPRA: the right to know, delete, correct, opt out of sale or sharing (we do not sell), and limit use of sensitive personal information; we honor Global Privacy Control signals as a valid opt-out.

To exercise any of these rights, write to support@debtidepot.com. We respond within thirty (30) days.

9. Minors

Frostline is not intended for users under thirteen (13). Users between thirteen and seventeen need verifiable parental or guardian consent. We do not knowingly collect personal information from a child under thirteen. If you believe we have, write to support@debtidepot.com and we will delete it.

10. Security

We use TLS in transit, encrypted storage at rest, role-based access controls, audit logs, and annual security reviews. No system is perfectly secure; if we discover a breach affecting your personal information we will notify you and the relevant authority within seventy-two (72) hours where required.

11. Changes

We will post material changes to this Policy at debtidepot.com/privacy-policy and notify you by email if you have an active account. The "Effective" date above marks the most recent version.

12. Contact

Questions, complaints, and rights requests: support@debtidepot.com — BLACK FROST DISTILLING, LLC, 201 1st Street North, New Ulm, Minnesota, United States.