Breathonix Pte Ltd. (collectively with its affiliates and subsidiaries shall be referred to as “Breathonix”, “ we”, “us”, or “our”) is committed to your right to privacy. Protecting our users’ privacy is a core value of Breathonix, and we take precautions to ensure the protection of our users’ personal data as well as to comply with applicable privacy and data protection legislation. 

This privacy policy (“Privacy Policy” or “ Policy”) which is incorporated by reference in our  Terms of Use (“Terms”), governs the processing and transfer of data collected in connection with our website, available at https://www.breathonix.com (“ Website“).

If you access our site as a visitor (“user(s)”) or if you are our business partners, investor and shareholder (shall be referred to herein as “Partners ” and collectively with our users as “you” or “your”) this Privacy Policy governs the processing of your personal data. 

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the Singapore Personal Data Protection Act ( PDPA) EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“ CCPA”).

Please note, that our website may contain links to other websites, products or services offered by third parties, which are not governed by this Policy. In the event you click on links to third-party landing pages, registration pages or websites, their privacy practices may differ from ours, and are not under our control or responsibility. We advise you to review the applicable privacy policy of these third parties. 

THE HIGHLIGHTS 

• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However some of the Company’s operations, may depend on providing us with certain Personal Data, as specified below.
• In general we use Personal Data (1) where we have a legitimate interest to do so (for example for website’s security purposes); (2) in order to perform a contract (for example, to provide you with the support you have requested or response to your inquiry); (3) where there is a legal obligation imposed on us or to protect our legal rights; and (4) otherwise with your consent to do so.
• Children under the age of 18 are not permitted to use the Website or provide us with any Personal Data. 
• You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data, all as detailed under this Policy. 
• We do not sell, trade, or rent users’ Personal Data to third parties. We only share Personal Data for limited circumstances as specified herein. 

If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Policy, please send us an email to  [email protected]

POLICY CHANGES AND UPDATES

We may update or revise this Policy from time to time. Modifications to this Policy will be posted on the website and shall be effective as of the date reflected under the “Recently Updated” header above. We encourage you to periodically review this Policy to stay informed about our practices related to the collection and processing of Personal Data.

In the event you access or interact with our website, we collect both Personal and Non-personal data, as follows:

“Personal Data”, means information which identifies or may with reasonable effort identify an individual, including online identifiers, as detailed below. 

“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated use of the website. This data is not used to identify individuals.

Non-Personal Data Processed by Us

We collect Non-Personal Data regarding use of the website and the operation of the Company, such as technical and aggregated data about you, such as: type of browsers; type of operation system; type of device; time and date you access the website; users’ navigation and actions in the website; language preference; country level location. Non-Personal Data is used mainly for click stream analysis in order to provide, maintain, develop and enhance our Website, including among others, in order to measure and understand the level of engagement with our Website, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Website, etc.

Personal Data Processed by Us

We collect the following Personal Data, and process it in accordance with the purposes and legal basis specified in the table below.

Type of Personal Data

‍If you voluntarily contact through any means of communication we make available (for example, through a “Contact Us” page in the website, by sending us an email, or any other request or notification) you may be required to provide us with certain information such as your name, organization name and email address.

Your contact details and contact history with us will be processed in order to provide you with the support you have requested or respond to your inquiry, as well as in the event we find it applicable (e.g., in the event of a future claim). Performance of a contract and the necessity of processing for the purposes of our legitimate interests.

1. Online Identifiers
‍We will collect your Internet Protocol (“IP”) addresses. This data might be collected by us or by our service providers or business partners. We use this data in order to maintain, protect and manage the website; improve our Website, as well as enhance your experience while you use our Website; for analytic and statistic purposes regarding traffic flow and users’ interaction with our website; in order to audit our affiliates, calculate payments and detect fraud, as well as to detect and resolve security or technical issues. The necessity of processing for the purposes of our legitimate interests, and your consent, where required under applicable law.

2. Newsletter

If you are our Partner or voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or rather or by contacting customer support at [email protected]. We will use your email address in order to send you information related to our Company and to keep you up to date regarding new information regarding the Company, as well as provide you with tips related to sales strategy.

3. Recruitment‍

If you are interested in working with us, you may voluntarily send us your CV through the applicable button located in the Website.

In the event, you send us your CV, note that your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

HOW PERSONAL DATA IS COLLECTED

Certain Personal Data is collected automatically by using cookies and other similar tracking technologies, while other Personal Data is provided by you voluntarily and actively, for example, when you contact us.

‍COOKIES & TRACKING TECHNOLOGIES

When you access or use the Website, we may use “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to as enhance your experience of the Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website or assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our Website quicker and easier, as well as to help customize your experience and for advertising purposes (including personalized advertising). You can find more information about cookies at  www.allaboutcookies.org.

DIRECT MARKETING

We may send our subscribers an email or other messages about us. We may also send our updates or newsletter to individuals who have registered to the newsletter or are engaged with the Company’s operations. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at  [email protected]

Please note that in the event you are our Customer, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions, without offering you the opportunity to opt-out of receiving them unless you terminate and delete your account. If you wish to delete your account, please contact us at  [email protected]

Note that even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need it for the purpose of managing our financials.

SHARING DATA WITH THIRD PARTIES

We will not share any Personal Data  collected from you with third parties or any of our partners except in the following events: 

1. Authorized Disclosures. We may disclose your Personal Data to third parties when you consent to a particular disclosure. Please note that once we share your information with a third party, that information becomes subject to the third party’s privacy practices. 
2. Compelled Disclosures. We will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights. 
3. Agents / Service Providers. We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf (among others, as detailed in the “ Cookies and other technologies” Section above). For example, we may share your email address with a third-party service provider in order to assist us with email marketing. These entities are prohibited from using your personal information for any purposes other than providing us with requested services. 
4. Business Transfers. We may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy. 
5. Online Identifiers. We may share Online Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Website, as well as to calculate payments and detect fraud, security or technical issues in connection with the operation of the Company.

Regarding Non-Personal Data, we may share or aggregate Non-Personal Data with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal Data and Personal Data on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Website as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

USER RIGHTS 

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information.

The right to access your Personal Data that we process;The right to ensure your Personal Data is accurate, complete and up to date;The right to have your Personal Data amended (by correcting, deleting or adding information);The right to object to the processing of your Personal Data, to the extent applicable;The right to send or “port” your Personal Data;The right to file a complaint with a supervisory authority in your jurisdiction; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination; andRights to submit a “Do not sell” request, where applicable. 

You may exercise any or all of your above rights in relation to your Personal Data contacting us at  [email protected]

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

In addition to your rights detailed above, you may opt-out of data collection and sharing process made through cookies. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored.

DATA RETENTION

We retain the information we collect solely for as long as required to fulfil the purposes for which it was collected.

In some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with using the event of any complaints, all, in compliance with applicable laws as well as our Partners’ data. 

SECURITY OF THE DATA

We make best efforts keep our website and the data we secure. We employ industry standard and implemented technical and administrative security measures to ensure the safety of our users’ Personal Data and prevent unauthorized access or use of such Data. In spite of all our efforts, it is not guaranteed that the protection is hermetic and that data transmission over the Internet or any wireless network is 100% secure and we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access.

If you feel that your privacy was treated, or if suffered from an individual attempt to abuse our website or acted in an inappropriate manner, please contact us directly at  [email protected]

‍CHILDREN PRIVACY AND DATA

The Website is not intended for individuals under the age of eighteen (18). Accordingly, we do not use the website to knowingly solicit data from or market to children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area ( “EEA”) individuals). We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us at  [email protected]

CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at  [email protected]

Breathonix Pte Ltd

Updated on Nov 2020