IMPORTANT PRIVACY INFORMATION



In order to use the service, we will ask you to enter your name and email. We will also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service and to measure ads.

For improving the service and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Amplitude, Appsflyer, Google, Firebase, Twitter, TikTok, Pinterest, Snapchat. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions (how often users make purchases); (2) serve and measure ads (and show them only to a particular group of users, for example, only to those, who have made a purchase).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). f any questions remain unanswered, please contact us at support@bsnj.co.

PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use Breeze: Mental Health mobile application (the “App”), the website located at: https://breeze-wellbeing.com/ (the “Website”), the services and products provided through them (together with the App and Website, the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) delete the App from your device or leave the Website and not access or use it; and (c) cancel any active subscriptions or trials.

Any translation from English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy available at [LINK], and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

1. PERSONAL DATA CONTROLLER

2. CATEGORIES OF PERSONAL DATA WE COLLECT

3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

7. AGE LIMITATION

8. INTERNATIONAL DATA TRANSFERS

9. CHANGES TO THIS PRIVACY POLICY

10. CALIFORNIA PRIVACY NOTICE

11. VIRGINIA PRIVACY NOTICE

12. DATA RETENTION

13. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

14. CONTACT US

1. PERSONAL DATA CONTROLLER

Basenji Apps Limited, a legal entity incorporated under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Facebook). We also collect data automatically (for example, your IP address).

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3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

  1. 3.1 To provide our Service

    This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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  2. 3.2 To customize your experience

    We process your personal data to adjust the content of the Service and provide content tailored to your personal preferences. For example, we will use the information provided by you during the quiz on to make the most suitable offer to you.

    3.3 To provide you with customer support

    We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

    Our support team is using Freshdesk, a service that makes it possible to speed up customer support, automate some time-consuming tasks, and, thus, resolve your issues faster. Privacy Policy.

  3. 3.4 To communicate with you regarding your use of our Service

    We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Service. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Service. To opt out of receiving push notifications, you need to change the settings on your device. To opt-out of receiving emails, you should click unsubscribe link in the footer of email.

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  4. 3.5 To research and analyze your use of the Service

    This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

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  5. 3.6 To send you marketing communications

    We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Service. We may show you advertisements on our Service, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

  6. 3.7 To personalize our ads

    We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website or installed the App, you might see ads of our products in your Facebook’s feed.

    How to opt out or influence personalized advertising

    iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.

    Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.

    macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.

    Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.

    To learn even more about how to affect advertising choices on various devices, please look at the information available here.

    In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

    Browsers:

    It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

    Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

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  7. 3.8 To process your payments

    We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.

    To enable the purchase and to process your payments we use PayPal, Solid and Stripe, payment processing providers.

  8. 3.9 To enforce our Terms and Conditions of Use and to prevent and combat fraud

    We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

  9. 3.10 To comply with legal obligations

    We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3 . This section applies only to EEA-based users.

We process your personal data under the following legal bases:

  1. 4.1 to perform our contract with you;

    Under this legal basis we:

    • Provide our Service (in accordance with our Terms and Conditions of Use)
    • Customize your experience
    • Provide you with customer support
    • Communicate with you regarding your use of our Service
    • Process your payments
  2. 4.2 for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

    We rely on legitimate interests:

    • to communicate with you regarding your use of our Service

      This includes, for example, sending you email or push notification to notify you that we have released a new product or reminding to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.

    • to research and analyze your use of the Service

      Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Service easier and more enjoyable, or to introduce and test new features).

    • to send you marketing communications

      The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.

    • to personalize our ads

      The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

    • to enforce our Terms and Conditions of Use and to prevent and combat fraud

      Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.

  3. 4.4 to comply with legal obligations.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

  1. 5.1 Service providers

    We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

    • cloud storage providers (Amazon, Digital Ocean)
    • data analytics providers (Facebook, Firebase, Appsflyer, Amplitude, BigQuery)
    • measurement partners
    • communication service providers (Apple)
    • marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, Twitter)
    • payment service providers (Stripe, PayPal, Solid)
  2. 5.2 Law enforcement agencies and other public authorities

    We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

  3. 5.3 Third parties as part of a merger or acquisition

    As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Service.

Deleting your personal data. You can request erasure of your personal data as permitted by law.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.

7. AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), (ii) the European Commission adequacy decisions about certain countries (details available here), or (iii) the EU-U.S. Data Privacy Framework, which facilitates the secure and compliant transfer of personal data between the EU and the U.S. (details available here).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires us to disclose what personal information we have collected, used, and shared over the last 12 months.

Section 2 describes the personal information we have collected about you, including the categories of sources of that information. We collect this information for the purposes described in Section 3. Section 5 enumerates the categories of third parties to whom personal information was disclosed.

The categories of personal data we have collected and shared in the past 12 months are:

Under CCPA you as a California resident have the following rights:

Right to Know. You have the right to request that we disclose to you the personal information we collect, use, or disclose.

Right to Delete. You have the right to request that we delete your personal information that we have collected from you.

Right to Opt-Out. CCPA requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information.

Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights. We will not deny you our services, charge you different prices, or provide you a lower quality of services if you exercise your rights under the CCPA.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

To exercise any of your privacy rights, please send a request to support@bsnj.co.

11. VIRGINIA PRIVACY NOTICE

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).

12. DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences.

We currently do not support “Do Not Track” requests because no DNT standard has been adopted.

Our third-party services may collect information about you and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services honor the “Do Not Track” requests, please read their privacy policies.

14. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@bsnj.co

Effective as of: 21.10.2024