Welcome, and thank you for your interest in BreathFinder Ltd (“We” or “BreathFinder” and also “Our” or “Us”) who is committed to protecting and respecting your privacy.

This Privacy Policy (the “Policy”) (together with our Terms of Use and any other documents referred to therein and all other communications with individuals though from oral means such as email or phone) constitutes a legal, binding agreement between you (“You”, “Your” or “User(s)”), a user of our website and BreathFinder Ltd.  This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, with whom it may be shared, and your choices about such uses and disclosures.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  You are considered to have accepted our privacy policy notice when you first use our site.  If you do not agree with and accept this policy notice, you must stop using our site immediately.

By visiting and using our website or submitting information to our website at BreathFinder.io (our “Site” or “Website” or “App”) or by purchasing or using our services, as a breath coach professional or practitioner listed in, or applying to be listed in, the BreathFinder Directory (the Directory), a visitor to our site or a contributor you are accepting and consenting to the practices described in this Policy.

When you trust us with your personal information, we take our responsibility to protect it very seriously. We respect your privacy and your rights to control your personal information. With that in mind, we want to be clear about the information we collect and why.  Where we have described any example scenarios in this notice, these are for guidance only. They are not actual and do not cover all scenarios. 

The main purpose of collecting your information is to provide you with the services offered on our website (our site), whether that’s using our site to find information, to contact a breath coach or practitioner, to advertise your business, or for some other reason. No matter how you use our site, we want to help you to use it as effortlessly as possible.

1.  Who we are:

We are BreathFinder Ltd and we have the following brand name: BreathFinder.io  We are committed to safeguarding the privacy of BreathFinder.io visitors and customers. For that reason, we fulfil all data protection requirements applied under new GDPR regulation (EU) 2016/679 about the processing of your personal data and the free circulation of this data.  We do not collect ‘sensitive data’ (that is data about such matters as your religious beliefs or political opinions).

We are the data controller, which means that we are responsible for how personal information is gathered, stored and used.  For the purpose of data privacy laws applicable to our site and broader offering, including, without limitation, the General Data Protection Regulations (“GDPR”) (EU) 2016/679, the data controller in regards to your personal data is BreathFinder Ltd, we are a brand name called BreathFinder.io 

We’re registered in Jersey, Channel Islands under company registration number 135013, and our registered office is Plat Douet Rd, St. Saviours, Jersey, JE2 7PN.  We are also registered with the Information Commissioner’s Office (ICO) under registration number 70198.  Our Data Protection Officer (DPO) is Sue Pallot. If you have any questions or concerns about your personal information, you can contact her Here.  If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

2.  Storing your Personal Data & Security:

BreathFinder Ltd places great importance on safeguarding the confidentiality of your personally identifiable information. To protect your information, we have put in place suitable physical measures, electronic and managerial administrative procedures to protect the misuse, loss, unauthorised access, modifications or disclosure of information collected through our site. Only those employees, agents, contractors and other third parties who need your information for business purposes will have access to it.  They will only process your personal information when we instruct them to, and they must keep the information confidential.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA“). It may also be processed by staff and/or third party suppliers engaged by BreathFinder Ltd who operate outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services such as email communications, and collecting and storing comments.

By submitting and providing your personal information, you agree to that information being transferred, stored and processed outside the EEA.  We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy notice.  We will have controls in place, such as agreements containing appropriate clauses, to make sure that your information is protected to the same standard as if it were in Jersey, Channel Islands.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee that hackers or unauthorised personnel will not gain access to your personal information despite our efforts. Ultimately, you are responsible for keeping your account information secure, you do so at your own risk (meaning that you are responsible for the consequences of doing so).  Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.

We have procedures in place to deal with any situation where we suspect that an unauthorised person has had access to your personal information or this privacy policy has been broken. We will tell you and any appropriate regulator about such a situation if we are required to do so by law.

3.  Uses made of Personal Information:

In general, we may collect and process information about you in the following ways:

3.1.  Information you give us:  

• We will use this information to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
• To provide you with information about other products and services we offer which are similar to those that you have already purchased or enquired about.
• To provide you, or permit selected third parties to provide you, with information about goods and services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) or by phone with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form).

• We will not sell your personal information to third parties.

• To notify you about changes to our service.
• To ensure that content from our site is presented in the most effective manner for you and your computer.

3.2.  Information you give us:

• You may give us information about you by completing registration forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, place a request for services, apply to supply the services, participate in reviews on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal identifiable descriptions and photographs to verify your identity.

3.3.  Information we collect about you.   

We will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our site to ensure that content is presented in the most effective manner for you and your computer.
• To allow you to participate in interactive features of our service, when you choose to do so.
• As part of our efforts to keep our site safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others and deliver relevant advertising to you.
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

 3.4.  Information we collect about you automatically:

With regard to each of your visits to our site we may automatically collect the following information:

• Technical information, for example, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the device you use to visit our site.
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products, services or pages you viewed or searched for; page response times, download errors, 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 and any phone number used to call our customer membership service number.

3.5.  Information we receive from other sources:

 We may receive information about you if you use any of the other websites we operate or the other services we provide.

• We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) and may receive information about you from them. 
• We may also receive information about you about content related to our directory that you have viewed. 
• If you’re a breath coach or practitioner applying to be listed in our directory, we may get information from, for example, the website of any professional body you are a member of. We would do this to help us approve your application more quickly.

• We may combine this data with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

3.6.  Special category data (sensitive information): 

 When you provide information through our site, you are in control of the type and amount of information you provide.

• You may choose to provide information that may be classed as ‘special category data’. For example, you may choose to give a breath coach or practitioner on our site information about your health to help them respond to your enquiry.
• Special category data includes information about your mental or physical health, your racial or ethnic background, your sex life or sexuality, your political opinions, trade-union memberships, or your religious or philosophical beliefs.
• By using the forms on our site to contact a breath coach or practitioner, share a personal experience, or send us any other information, you agree to us processing your information (including any special category data you have provided) as is necessary for the service you’ve requested (for example, emailing a copy of your enquiry to the breath coach or practitioner you have chosen, or publishing your story on our site).
• We will not be responsible for the type of information you voluntarily provide through our site. However, to make sure that we keep to the General Data Protection Regulation (EU) 2016/679 (GDPR), we will ask you to tick a box on the appropriate form to confirm that we have your permission to process this information. We will only process the information if you have ticked the relevant box.
• Please do not include sensitive information (such as details of your medical history) in any comment you post to our website.
• Please do not send us any information about criminal convictions, offences or similar measures (criminal offence data) using any of our online forms, or include this information in any comments you make on our website.

 3.7.  Analytics services: 

 Analytics services track and report on the use of our website, including who uses it. They give us insights into how our customers use our products, which helps us to improve the service we offer.

• We may get information from analytics services (for example, Google Analytics and Facebook Pixel) to evaluate your use of our site, produce reports on things such as pages visited, time spent on pages, and clicks on our Facebook posts or links, and collect and evaluate other information relating to our site and use of the internet.
• The information we collect is anonymous.
• The providers of these analytics services use cookies and other technologies to help them analyse and provide information to us. By visiting or using our site, you are agreeing to analytics services processing information about you for the purposes set out in this privacy policy notice.  We will make sure that all your personal information that we have is stored and used lawfully, in an open, honest and fair way, without removing or reducing your rights. We will only process your personal information if any of the following applies.

• You have given us permission to process your personal information for one or more specific purposes (for example, by signing up to receive our newsletter).
• We need to process the information to enter into a contract with you or meet our obligations under a contract we have with you.
• We need to process the information to meet a legal requirement.
• We need to process the information to protect the vital interests of you or another person.
• Processing the information is in our legitimate interests or those of a third party who provides a service to us (for example, a company that processes card payments we take), unless these interests are outweighed by your basic rights. It is in our legitimate interests to process your personal information so that we can give you relevant information when appropriate, so that we can look at ways of establishing and improving our relationship with you. Our legitimate interests include using your information to analyse and improve our services and the content on our websites and apps, send you information about our services, and tell you about similar products and services that you might be interested in.
• If, while visiting our site or using our services, you provide personal information about another person, you should make sure they know about this privacy policy notice and you have their permission to provide the information.
• It may sometimes be appropriate for us to combine your personal information with other information we have about you, such as combining your name with the history of your relationship with us or where you live, work or visit.

4.  If you fail to provide personal information:

If you do not provide the personal information we ask for, you can still visit most areas of our site, but you may not be able to choose certain options and services.  In some cases, we may need to collect some personal information by law or under a contract, and you will be limited in the services you can use if you don’t provide personal information. For example, if you do not provide your personal information you will not be able to be listed in our directory. We will let you know how this will affect you at the time.

5.  Cookies:

We use cookies to distinguish you from other people visiting or using of our site.  This helps us to improve and provide you with the best online experience when you browse our site (for example, allowing you to save content, or keep you logged in to your profile on our site).  For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

6.  What we use your personal information for:

We use your personal information to provide you with the products and services we offer. Below we have given some examples of how we may use your personal information. 

Example 1: if you use our site to contact a breath coach or practitioner

If you use our site to contact a breath coach or practitioner, we only use the personal information you provide in the online contact form to email the professional. In this case we will not store your personal information for any longer than we need it to complete this process. We will not use it for any other purpose. We will send you a single email acknowledgement to confirm that your email has been sent and giving you the option to subscribe to our newsletter, but this acknowledgement will not be stored on our systems.

The server of our site is secure and keeps on record the IP addresses of people who visit our web pages for a short time, so we can monitor the performance of our site, but we will remove and delete this information as soon as we no longer need it. We may also store information about you, such as your IP address or website activity, to record certain actions (for example, when you contact a breath coach professional listed on our site, we use Google Analytics and Facebook Pixel to record that you’ve successfully completed this action). We use this information to monitor and manage our site (such as evaluating how effective our advertising is).

 Example 2: if you apply to be listed in, or are listed in, our directory

If you:

• are applying to be listed in the directory;
• are already listed in the directory; or
• sign up to the directory for updates;

we will use your personal information to manage our service to you and to communicate with you (for example, telling you about your account, new services available, security and other types of updates). Also, if you contact us in any way, we may use your personal information to improve our service or to communicate with you.

 Example 3: if you sign up to receive our newsletter

If you sign up to receive our newsletter, we will use your details to communicate with you and to keep you informed about other news and services that may interest you. We won’t pass your details on to any third parties except where this is necessary.  We will give you the option to change your email preferences or to stop getting the newsletter.

Below is a summary of how we may use your personal information. Depending on the way you use our site, some of the following points may not apply.

• To display the content on our site in the most effective way for you and your device.
• To provide information, products and services that you ask for, or which we think you may be interested in.
• To meet our obligations under any contract we have with you.
• To allow you to use our interactive services.
• To allow you to sign up for our services or publications.
• To tell you about changes to our services.
• To tell you about other goods and services that might interest you.
• To manage our site and for internal purposes like troubleshooting, analysing data, testing systems, carrying out research, producing statistics and carrying out surveys.
• To help us keep our site safe and secure.
• To produce records, we must keep by law (for example, we have to produce accounting records and keep them for at least six years).
• To settle disputes.
• To respond to feedback and comments.

If you have used our services before, we will only email you about things similar to the service you previously used. If you are a new customer, we will only contact you if you agree to it. If you want to be contacted for marketing purposes, tick the relevant box that you will find on the screen when we collect your information.

We usually only need your permission to use your personal information if we are using it for marketing purposes. If you don’t want us to use your personal information for any particular purpose, let us know by emailing us. We will delete your information. However, this will limit our ability to provide the best possible service to you, and some parts of our service may not be available to you as a result.

As we have already explained clause 3, with your permission (or where we are allowed by law) we may use your personal information for marketing purposes. This may lead to us phoning or emailing you to give you information, news and offers on our services. We will not do anything not covered by this privacy policy notice, and we will not send you any spam emails. We will take all reasonable steps to make sure that we fully protect your rights and meet our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

7.  Disclosure of your information:

We may share your personal information to others and with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties (others) or information publicly available which includes:

• Our suppliers and subcontractors (i.e., processors) that have been engaged by BreathFinder Ltd such as processing card payments, email providers and technical support.
• Business partners, subject to your affirmative consent, who may wish to use your personal information for marketing purposes. You may unsubscribe at any time via the link provided in our email correspondence. Alternatively, you can deactivate your account via your dashboard on our Site.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• If we need to share your personal information we will take all reasonable steps to make sure it is handled safely and securely, and always in line with the GDPR and relevant laws.

• When you fill in an online form to contact a breath coaching professional listed in the directory, we need to give your personal information to the breath coach or practitioner you have chosen so they can provide the service you’ve asked for. We do not use your personal information for any other purpose, and we will always do our best to protect your information as set out in this privacy policy notice.

We may disclose your personal information to third parties for the following reasons:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.

• If BreathFinder Ltd or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements (including those entered into with our business partner whose brand is applied to the Site from which you accessed this Policy).

• To protect the rights, property, safety or rights of BreathFinder Ltd together with our customers, or others by law. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction or any legal proceedings.

• Our site may, from time to time, contain links to and from the website of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

8.  Social Media:

Our service includes social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing them.

9.  External Links:

Our website may contain links to and from external websites of our partner networks, advertisers and affiliates. Those external websites may collect personal information about you.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for the privacy practices of other businesses or the content of their website that are linked to our website.  Please check the other party’s privacy polices before you submit any personal information to make sure you understand how they collect and use your information on these websites as we have no control over how your personal information is collected, stored or used.  We also use service providers to gather and process comments received through our website. Under our contracts with those service providers, they must keep to data-protection regulations.  This privacy policy notice (and any documents referred to in it) does not apply to any contact between you and a breath coach or practitioner displayed on our site.  When you contact a life coach or NLP practitioner through our site, their privacy policy will apply to the personal information you give them. You can get specific details from them.

10.  KYC and other background searches:

We reserve the right to carry out Know Your Customer (KYC) and other background searches on both our users and breath coaching professionals alike who wish to utilize our site. All information we collect from such background searches will be kept completely confidential and will only be used by us to evaluate your application / registration to our site. Except for providing this background information to our vendors and/or legal authorities, no other parties will be given access to this information without your prior consent.

11.   Data Retention Period:

We only retain the personal information collected from a user for as long as the user’s account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it, or unless otherwise required by law. We will retain and use information as necessary to comply with our legal or statutory obligations (for example, accounting records), resolve disputes, and enforce our agreements as follows:

• the contents of closed accounts are deleted within 3 months of the date of closure;
• backups are kept for 3 months;
• billing information is retained for a period of 7 years as of their provision to BreathFinder Ltd in accordance with the Jersey accounting and taxation laws
• information on legal transactions between users, breath coaching professionals and BreathFinder Ltd is retained for a period of 10 years as of their provision to BreathFinder Ltd in accordance with the general limitation period set for civil claims.

We are committed to maintaining confidentiality when you contact a breath coach or practitioner for help. For this reason, when you contact a listed breath coach or practitioner using the email form linked from their profile, we will delete the information you typed into the form as soon as the form has been received by the breath coach or practitioner.

Upon your request to us, and after proper review, we may edit, deactivate and/or delete your personal data and other information from our active databases.  Please be advised that we may not be able to delete all of your personal information from some of our secure databases and, in such case, we will make the data permanently inaccessible to any third parties. You may also be able to edit the personal information we store about you, by going to your account settings in the site.

This privacy policy notice and our internal guidelines will apply to all the personal information we keep. We will also keep anonymous information for statistical and analytical purposes (for example, to understand how people use our site and services). 

12.  Your Data, Your Rights:

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third parties for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us via the following contact form at the end of the page.  If you are listed in our directory, you can also do this by sending us an email  

Under the GDPR, you have the right to control how your personal information is used and you can do the following.

• Ask us for a free copy of the personal information we hold about you.
• Ask us to correct any personal information that we hold about you or to make any changes to your personal information (for example, if your name or contact details have changed).
• Ask us to transfer your personal information to another person.
• Ask to be kept informed of what data processing is taking place.
• In certain situations, ask us to restrict how your information is processed, or object to your personal information being processed.
• certain situations, ask us to delete personal information we hold about you.

If you have given us permission to use your personal information, you can withdraw that permission at any time. If we process your personal information because it is in our legitimate interest or the public interest, you can object to this at any time.

You are responsible for making sure that your personal information is complete, accurate and up to date. If any of your personal information changes or is incorrect, tell us as soon as reasonably possible by sending us an email. We will correct the information as soon as possible, but certainly within 30 days.

13.  Access to information:

Applicable privacy regulations (e.g. GDPR) give you certain rights in regards to the personal information we collect about you. Those rights include the following:

• Right to be forgotten (delete your data)
• To request from us personal data portability (request your data)
• To request the rectification of personal data (rectify your data)
• To request from us right of access to personal data we may hold on you (request to see if data is being processed)
• To impose restrictions on, or otherwise object to, processing your Personal Data (objection to sharing data)

If you request that your personal data be deleted before a service transaction is complete, we may not be able to provide that service. In addition, we expressly reserve the right to delay or otherwise deny any such request that you submit to us if said request would result in a violation of applicable laws and regulations, or otherwise adversely affect any legitimate interest we seek to assert.

You may be required to put your request in writing for security reasons.  Any access request may be subject to a fee of £10 to meet our costs in searching for and providing you with details of the information we hold about you on a per request basis.

 14.  Changes to our privacy policy:

Please revisit this page periodically to stay aware of any changes to this policy, which we may update and amend from time to time without notice at our sole and final discretion.  This policy is incorporated by reference to our Terms of Use that applies to the services provided by BreathFinder Ltd.  Any changes will take effect when they are made or posted on our website.  Your simple access or use of our services after such amendments or changes become effective is your acknowledging and acceptance of the new policy.

15.  Complaints:

If you have a complaint about our privacy policy or believe that we have breached your privacy, please contact us via email, as we are committed to working with you to settle any complaint or concern you may have about your personal information. We will investigate your complaint and attempt to resolve any breach that may have occurred in accordance with Article 12(4) of the Data Protection (Jersey) law 2018 (the “DPJL”).  If you do not receive acknowledgement of your complaint or, if your complaint is not satisfactorily addressed by BreathFinder Ltd within 30 days from your submission of same, then please contact the Information Commissioner’s Office (ICO) by visiting the website.

 16.  How to Contact Us:

If you have any questions, concerns about this privacy policy, your personal information, our use and disclosure practices, or your consent choices, please contact us via email.  Our Data Protection Officer is in charge of answering questions about this privacy policy notice and dealing with your requests to exercise your rights who will work with our customer services team if needed.