Breezy Privacy Notice – Customer

Last updated: 27th October 2022

Hello, welcome to the Breezy Privacy Notice. This is where we tell you how we process and protect your data and how we respect your privacy.

This notice applies to the following people: anyone who is a Breezy user, customer or subscriber, or just anyone who is visiting our website, breezy.io ("Website"). Please make sure you check this notice and if you don't agree with it, then (although we hate to turn you away) you shouldn't use our website or services we offer via our website ("Services"). This is because by accessing or browsing our website, or using any of the Services we provide, you confirm that you have read, understood and agreed to this.

Alternatively, feel free to email us at team@breezy.io if you have questions or concerns.

We may update our Privacy Notice from time to time. Any changes we make will be posted on this page and, where appropriate, we will send you an email to confirm the changes as well.

1. About Breezy

We are registered as a limited company in the UK as Partnered Limited and refer to ourselves in the first person ("we", "our", "us") throughout this notice. Our registration number is 11690208 and our registered office is 34B George Street, W1U 7DP.

2. The personal information we collect

Personal information is the term we use to describe information which we collect, and which can be used to personally identify someone. For example, a name, a personal address or even an IP address.

Here is a list of the types of personal data we collect:

Information you give to us (e.g. on contact forms, questionnaires or when registering or signing up)

• Contact details - such as your name, address, email, guest emails, phone number you give to us when registering your details, trialling our services, setting up a subscription, or signing up for marketing emails

• Responses to surveys or promotions you participate in - thank you for your participation in these.

• Any updates to the information you provide to us - and thanks for keeping us updated.

This is essential information for us to provide the best service we can to you. If you ask us to delete it, it's possible we may no longer be able to provide our services to you.

Information we collect automatically when you visit our Website

• Technical information - such as your IP addresses, domain names, the country you're visiting from, files requested, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

• Information on your visit - such as the full URL clickstream to, through and from our Website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We keep this information anonymous as much as possible to protect your privacy.

Information we receive from other sources.

• Advertising networks and information providers - we work closely with advertising networks, analytics and search information providers and we sometimes receive information about you from them.

• Information from other websites and services we operate and provide - where this happens, we will let you know about sharing the information internally or combining it with information from the Website.

3. How do we use it and why?

We only ever use your information in line with data protection laws - in particular, the EU General Data Protection Regulation, otherwise known as the GDPR. We will only use your personal data if we have a lawful basis to do so. Under the GDPR we'll never use your data without a specific purpose.

Here are the specific reasons we process your personal information and the legal basis for which we use your information:

4. Sharing your information

We may share your personal information with the following categories of third parties, including:

• our service providers and subcontractors, including but not limited to payment processors, suppliers of technical and support services and cloud service providers;

• companies that assist us in our marketing, advertising and promotional activities;

• analytics and search engine providers that assist us in the improvement and optimisation of our Website; and

• any third parties that you have agreed that we may share your personal information with for marketing purposes.

If we share your personal information to third parties, they will only legally be able to use it for the purpose of providing services to us. We make sure that third parties we share personal information with follow equivalent privacy and security procedures to our own to protect your information.

We may anonymise and aggregate your data to create health reports and statistics. This may be used for marketing or shared with third parties for purposes of academic research.

Finally, we may also disclose your personal information to third parties in certain exceptional circumstances as follows:

• if we sell or buy any business or assets, we may disclose your personal information to the seller or buyer of that business or those assets;

• if we or most of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

• if we are required by any applicable law or law enforcement organisation to do so;

• in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

• to protect our rights, property, or safety, our customers or other persons. This may include exchanging information with other organisations for the purposes of fraud protection and credit risk reduction.

Except for what is written in this notice, we will never share any of your personal information to any third party without notifying you and/or getting your consent. If you do consent and later change your mind, you can remove consent and therefore our permission to use this information. See below for your rights to withdraw consent.

5. How long we store your data for

We store personal information for as long as you use the Services we provide and until you either unsubscribe to the communications or opt out by contacting us at team@breezy.io.

6. Your choices and rights

Choices:

At any time:

You can choose not to provide us with personal data

If you choose to do this, you can continue to visit our website and browse its content, but we won't be able to provide you with services, even if you have already paid for them.

You can turn off cookies in your browser settings

If you turn off cookies, you can continue to visit our website and browse its content, but our online services might be less effective.

You can choose for us not to use your personal information for marketing

We will request your consent to do this, but you can choose to refuse your consent. If you have given your consent and want to retract it later, then you can either unsubscribe to the communications or opt out by contacting us at team@breezy.io.

Rights:

You can contact us by email at team@breezy.io at any time, to request that we:

• update any personal information which is out of date or incorrect;

• delete any personal information which we are holding about you;

• restrict the way that we process your personal information;

• provide your personal information to a third party provider of services; or

• provide you with a copy of any personal information which we hold about you on request to team@breezy.io (although we reserve the right to charge a reasonable fee for this if requests are excessive or repetitive);

• we do not undertake an automated decision making.

You have the right to withdraw your consent in relation to us processing your special categories of personal data (as mentioned above) at any time. You can do this by contacting us through online chat or via team@breezy.io.

If you withdraw your consent to us processing your personal data, especially the special categories above, this will mean that we are unable to provide our Services to you and may mean that we have to terminate any Subscription, close any Brand Account or remove access to certain or all Services in accordance with our Breezy Customer Terms of Service, that you can find here.

7. Transfers of information

The personal data we collect is processed at our offices in London and in any data processing facilities operated by the third parties. Technology businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We carefully vet any services we use to ensure they adhere to high standards of security and privacy.

When we do this, sometimes it is necessary for us to share your data with them in order to allow these services to work. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy notice.

Below is a list of the main third-party providers we use:

• Infrastructure: Amazon Web Services, CommonCrawl, Sentry, MOZ, Alexa, Ahrefs

• Analytics: Mixpanel, Segment, OneSignal, Google Analytics, Freshsales

• Communications: Mailchimp, Intercom, Reply.io, Octopus CRM, LinkedIn

• Payments: Chargebee

If we transfer or store your information outside of the EEA, then we will take steps to inform you of this by outlining it in our Privacy notice and taking all reasonable precautions to ensure privacy rights continue to be protected.

8. Security of your personal information

Our responsibility to you

At Breezy, we have physical, electronic and managerial procedures in place to protect and secure the information we collect. We are committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and we take all reasonable precautions to safeguard the confidentiality of personal information.

We make every effort to protect your personal information. However, there is always an inherent risk, beyond our control, in sending information over the internet. If we do ever encounter any online data breaches, we commit to taking prompt action to resolve the situation to protect your information.

We use Chargebee for payment transactions and so do not hold payment or payment card data.

Your responsibility to us

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

You may also be subject to our Breezy Customer Terms of Service found here.

9. Third party websites

Our Website may, from time to time, contain links to websites operated by third parties. This Privacy notice only applies to the personal information that we collect through this Website and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy notices, and you should read these carefully before you submit any personal information to these websites. We don't endorse or accept any responsibility for the content of those third party websites or third party terms and conditions or notices.

10. Cookies

Some pages on our Website use cookies, which are small text files placed on your device (such as your computer, tablet or mobile phone) when you visit our Website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

What are cookies?

• Some pages on our Website use cookies, which are small text files placed on your device (such as your computer, tablet or mobile phone) when you visit our Website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

• Cookies help us provide you with the best possible experience. When you re-visit our Website, cookies allow our Website to recognise you, remember your preferences and tailor your use of our Website. Information provided by cookies can help us to analyse your use of our Website and help us to provide you with a better user experience.

• Cookies are referred to as either \"session\" or \"persistent\" cookies, depending on how long they are used for:

  • Session cookies only last for the duration your online session and disappear from your device when you close your browser. Session cookies are not stored on the hard drive of your device.

  • Persistent cookies are stored on the hard drive of your device after the browser has been closed and last until you delete them or they reach their expiry date. Persistent cookies are activated each time you visit the site where the cookie was generated.

For more information, please see www.allaboutcookies.org.

What types of cookies do we use?

• The types of cookies that may be used on our Website fall into one of four categories as follows:

  • 'Strictly necessary' cookies. These cookies are essential for the operation of our Website and enable you to access certain features. Without these cookies, we would be unable to provide you with the online Services you request, for example, remembering your login subscription decisions and logging into your account. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

  • Functional cookies. Functional cookies are used to recognise you when you return to our Website. They also remember your preferences (such as your username, language and region) on our Website and enable us to personalise our content for you. The information collected by these cookies is usually anonymised, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising, but they do help with serving advertising.

  • Analytical cookies. Analytical cookies are used to monitor the performance of our Website. For example, they allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. The information provided by these cookies allows us to analyse patterns of user behaviour and we use that information to enhance user experience or identify areas of our Website which may require maintenance. All of the information collected by these cookies is anonymous and is only used for statistical purposes.

  • Targeting cookies. These cookies may be placed on your device by us or by trusted third parties. They remember that you have visited our Website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioural advertising (OBA) and involves the monitoring of interests based upon web browsing history. Your web browsing history can be used to infer things about you (for example, your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioural advertising cookies can track your activity around the internet they cannot identify you personally, even if you are signed in to our Website. Without these cookies, online advertisements you encounter will be less relevant to you and your interests.

• Our emails and Website pages may contain a web beacon to track whether you open an email and if you click on any of the links in the email or Website page. We may use this information to help us analyse the types of topics that you are interested in, for fraud detection and to let our advertisers know how many of our anonymised, aggregated users click on their advertisements. When you delete the email, the web beacon will be deleted.

• When you browse our Website some cookies may be set by third parties, over which we have no control. When you visit a page with embedded third party content, the service provider may set their own cookies on your device. You may also encounter third party cookies resulting from our use of third party services, which help us monitor traffic on our Website. We do not control the use of these cookies and you should refer to the relevant third party websites for more information.

How can I manage or disable cookies?

• There are a number of ways for you to manage cookies. Your browser settings should allow you to accept or reject cookies and you can set your browser to prompt you before accepting a cookie.

• You can delete any cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Most browsers will have a help feature or menu that will tell you how to delete or disable cookies. You can also delete similar data used by browser add-ons by changing the settings of your add-on or visiting the manufacturer's website.

• Please be aware that if you set your browser to disable cookies entirely it may affect the way our Website operates and you may not be able to use certain features of our Website or Services.

11. Contact us

Questions, comments and requests about this privacy notice or how we collect, use or store your personal information are welcomed and should be emailed to team@breezy.io.

If you believe we have breached your rights, you can make a complaint to the UK Information Commissioner's Office (https://ico.org.uk) or seek remedy through your local courts if you believe your rights have been breached.

This privacy notice was last updated on 27th October 2022, but we may update it at any time.