PRIVACY POLICY

Last Updated: 17 November 2025

This Privacy Policy describes how Breathless Pty Ltd (“Breathless”, “we”, “us”, “our”) collects, uses, and discloses your personal data when you use the Breathless Academy mobile application (“Breathless App” or “App”) and the choices you have regarding that data. By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined, terms have the same meaning as in our App Terms & Conditions.

1. ABOUT THIS POLICY

This Privacy Policy outlines our policies regarding the collection, use, disclosure, and protection of personal data when you use the Breathless App, and explains your rights regarding your data.

2. DEFINITIONS

Breathless App (or “App”): The Breathless Academy mobile application operated by Breathless. The App includes information, text, videos, audios, programs, training content, community interactions, links, images, and other materials provided by Breathless or third parties.

Personal Data: Data relating to an identifiable individual, directly or indirectly.

  • Usage Data: Data automatically collected through the App, such as session length, device type, feature use, crash logs, IP address, and diagnostics.

  • Cookies / App Tracking Technologies: Identifiers or storage mechanisms used for analytics, authentication, and personalisation.

  • Data Controller: Breathless Pty Ltd.

  • Data Processor / Service Provider: Third-party companies that process data on behalf of Breathless.

  • User / Data Subject: Any individual using the App whose data is collected.

3. INFORMATION COLLECTION AND USE

We collect data to operate, maintain, and improve the App.

(a) Personal Data

We may collect: name, email, phone, address, profile information, health info (with consent), payment data (via third-party processors), communications, and device identifiers. We may send updates, newsletters, or promotional messages. You may unsubscribe anytime.

(b) Usage Data

Collected automatically: device type, model, OS, IP, app version, session duration, screens viewed, crash logs, timestamps, and interactions.

(c) Location Data

With permission, the App may collect location data for personalisation, feature relevance, or security. You may disable location access in device settings.

(d) Tracking Technologies

The App may use SDK trackers, device IDs, analytics tags, local storage, and similar technologies for functionality, security, and analysis.

4. USE OF DATA

Breathless uses data to: operate the App; personalise your experience; communicate updates; provide support; monitor performance; detect issues; improve functionality; offer promotions (unless opted out); analyse behaviour.

5. LEGAL BASIS (GDPR – EEA USERS)

Breathless may process your data under: contract performance, consent, legitimate interests, legal obligations, payment processing, or vital interests.

6. RETENTION OF DATA

Breathless retains Personal Data only as long as required to provide services, comply with laws, resolve disputes, or enforce agreements. Usage Data may be retained longer for security or legal reasons.

7. TRANSFER OF DATA

Your data may be transferred to servers outside your jurisdiction. By using the App, you consent to this transfer. Breathless ensures reasonable safeguards for your data during all transfers.

8. DISCLOSURE OF DATA

(a) Law Enforcement

Breathless may disclose data when required by law or government requests.

(b) Legal Requirements

Breathless may disclose data to comply with legal obligations, protect our rights, prevent fraud, protect user safety, or defend against claims.

9. SECURITY OF DATA

We use commercially acceptable measures to protect your data. However, no electronic transmission or storage is 100% secure. You acknowledge inherent risks.

10. “DO NOT TRACK” (DNT) SIGNALS

Mobile apps do not support browser-based DNT. The Breathless App does not respond to DNT requests. Tracking preferences may be managed through device settings.

11. GDPR RIGHTS (EEA USERS)

You may request: access, correction, deletion, restriction, objection, data portability, or withdrawal of consent. You may also lodge a complaint with your local Data Protection Authority. We may require identification before responding.

12. SERVICE PROVIDERS

Third-party companies may process data to provide analytics, hosting, payments, communication tools, support, and App functionality. They may not use your data for any other purpose.

13. ANALYTICS

We may use mobile analytics services such as:

Google Analytics for Firebase / Firebase Analytics: collects device, usage, engagement, and crash data. Privacy info: https://policies.google.com/privacy

Other analytics SDKs may also be used to improve App performance and user experience.

14. PAYMENTS

In-App purchases may be processed via Apple, Google Play, Stripe, or similar providers. Breathless does not store full payment details. Payment processors comply with PCI-DSS security standards.

15. LINKS TO EXTERNAL CONTENT

The App may include links to external content. Breathless is not responsible for external sites or their privacy practices.

16. CHILDREN’S PRIVACY

The App is not intended for individuals under 18. We do not knowingly collect their data. If a minor’s data is identified, we will delete it upon request.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Policy periodically. Changes take effect once posted in the App. We may notify users through email or App notifications.

18. CONTACT US

For privacy-related questions, contact: [email protected]