Breakthru Privacy Policy

1. Scope of this Policy

2. Agreement to Terms

3. Information We Collect

4. Cookies

5. Our Use of Collected Information

6. Our Sharing of Information

7. Our Storage and Retention of Personal Information

8. Children’s Privacy

9. Third-Party Links

10. Your Privacy Choices

11. Additional Disclosures for United Kingdom (UK) and European Union (EU) Residents

12. Additional Disclosures for Canadian Residents

13. Changes to this Privacy Policy

14. Contact Information

1. Scope of this Policy

Breakthru Immersive, Inc. (referred to as “Breakthru,” “we,” “us,” “our”) provides immersive wellbeing experiences for the workday that are powered by spatial computing, artificial intelligence and body movements. Breakthru provides two-minute immersive microbreaks (“Breaks”) to remind users to harness small restorative movements each day to boost mood, productivity and wellbeing.  

Breakthru respects your privacy and values your trust. We are committed to ensuring that the personal information stored by our systems is suitably protected and used appropriately. The purpose of this Privacy Policy is to inform you of the treatment and handling of information that we may learn about you from using our application (the “App”), your visit to the Breakthru website at www.breakthru.me  (the “Site”), your engagement with our content, and/or by use of any of our services (collectively, the “Service”). If you have any questions regarding this information or our privacy practices, please see the section entitled Contact Information at the end of this Privacy Policy.

2. Agreement to Terms

If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Service without providing us any personally identifiable information.

3. Information We Collect

We collect different types of personal information from you depending on how you interact with us, for example, if you use of our App, visit our Site, or communicate directly by sending an email to support@breakthru.me or contacting us through the Site. The categories of information we may collect through these methods is described below.

Using Our App

Our App is available through Microsoft Teams. If you choose to download the App through Microsoft Teams, we collect the following information:

• Email address. This is the email address associated with your Microsoft Teams account.
• Microsoft Teams Tenant ID. This is a unique identifier that is assigned by Microsoft and associated with the company or educational organization through which you use Microsoft Teams.
• Microsoft Teams ID. Also referred to as the Microsoft Teams Group ID, this is a unique identifier assigned by Microsoft, which identifies your membership within a specific team in Microsoft Teams.
• Payment Information. We may collect payment details, such as your name and credit or debit card information. We use certain third parties to process payments on our behalf (e.g., Stripe, Microsoft) and your payment details will be collected and processed directly by these third-party payment processors.

We maintain a history of the Breaks you have selected and allow you to set reminders to participate in a Break.

In addition, Microsoft makes certain unidentified and/or aggregate information available to us when you use of the App. This information includes when users access the App, which Breaks they select, and the locations (limited to city, state, and country) of users who access the App. Users are not identified by name, email address, or other directly identifiable personal information and we never attempt to individually identify users through this information.

Visiting Our Site

If you visit our Site, we may collect information through cookies. The cookies on our Site collect information such as your computer or mobile device type, browser type, geolocation information (limited to city, state, and country), and information regarding your interaction with our Site (such as when you accessed the Site, which pages you visited, and how long you stayed on each page).

For more details regarding the types of cookies on our Site, please see the Cookie section below.

Contacting Us

If you contact us directly, such as by sending an email to support@breakthru.me, we may collect the content of any email or communication you send to us, including any personal information you choose to include in a message to us (e.g., your name, email address, and company name).

4. Cookies

As noted above, our Site uses cookies. A cookie is a small string of information that a website you visit or mobile device transfers to your computer or device for identification purposes. Cookies can be used to follow your activity on a website and across websites, and that information helps websites to understand your preferences and improve your website experience. Some cookies are necessary to operate a website, while others can be functional or analytical. Cookies on our Site are generally divided into the following categories:

• Strictly Necessary Cookies. These are cookies that are required for the operation of certain features of our Site. Because our Site uses Vimeo’s embedded video player, Vimeo sets cookies that are essential to the video player experience. You can read more about Vimeo’s cookie policy at https://vimeo.com/cookie_policy.
• Analytical/Performance Cookies. These allow us to recognize and count the number of users on the Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located). This helps improve how the Site works, for example, by ensuring that users can find what they are looking for easily.
  We use Google Analytics for part of this process. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics’ collection and use of data generated by your use of the Site by going to https://tools.google.com/dlpage/gaoptout.

You can prevent the use of certain cookies by modifying your Internet browser settings typically under the sections “Help” or “Internet Options.” If you disable or delete certain cookies in your Internet browser settings, you may still access our website and App, however, you might not be able to access or use important functions or features of our website or App.

Do-Not-Track Signals

At this time, Breakthru does not recognize automated browser signals regarding tracking mechanisms, which may include “do-not-track” instructions.

5. Our Use of Collected Information

We use personal information for the following purposes:

• To provide Breaks through our App;
• To provide users with a history of Breaks taken and to allow them to set reminders;
• If you contact us directly, to communicate with you, respond to your email, and to manage our relationship with you.

We use unidentified and/or aggregate information to:

• To analyze use of the App and Site, and to improve our Service;
• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible.

We may also use personal information to comply with and enforce legal and regulatory requirements, relevant industry standards, and our policies.

6. Our Sharing of Information

We do not sell personal information and personal information will not be shared with third parties for their marketing purposes. Breakthru only shares personal information where necessary for a business purpose (such as to provide or improve our Service) or as otherwise required by law.

The types of third parties with whom we share information depends on how you interact with us, as described below.

Using Our App

Because our App is integrated with Microsoft Teams and Microsoft provides certain analytics information concerning use of the App to us, information is shared between Microsoft and Breakthru. This information is shared to allow you to use the App (including the history and reminder functions) and to allow us to analyze use of the App, improve the App, and detect and protect against security and similar incidents.

We also use authorized third parties to process payments on our behalf (e.g., Stripe, Microsoft). If you enroll in a subscription to the App, you may be required to submit payment details directly to these authorized payment processors. These payment processors may be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such payment processors directly, for example, via their websites.

Visiting Our Site

If you visit our Site, we may share information with service providers, including video-hosting providers (e.g., Vimeo) and web analytics service providers (e.g., Google Analytics), through the use of cookies. For more information about cookies, see the Cookies section above.

In General

We may share information with advisers and financial institutions that provide legal advice, tax advice, business continuity support services, and/or risk, audit and compliance advice to us.

In addition, in the event of a corporate restructuring, sale, transfer or assignment of assets, merger, divestiture or other change to the company’s control or financial status, and where permitted by applicable laws, we may share information with the acquiring party and their advisers. In the event the acquiring party wishes to alter the use or sharing of personal information in a manner that is materially inconsistent with this policy, you will be provided notice of, and provided an opportunity to consent to, the new or changed practice.

We may also share information with government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with: (a) responding to a subpoena, search warrant or other lawful request for information we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

7. Our Storage and Retention of Personal Information

We retain information collected through the App for as long as you use the App. If you delete the App, we typically retain personal information for no longer than three months after the App is deleted. We may retain personal information for a longer period but only if it is needed for the purpose of addressing tax, corporate, compliance, employment, litigation, or other legal rights and obligations. In those cases, we will only retain your information for as long it is needed for those purposes.

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction.

Unfortunately, the transmission of information via the Internet is not always completely secure. Although we make reasonable efforts to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

8. Children’s Privacy

The Service is not intended for users under the age of 13. Breakthru does not knowingly collect personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Service without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.

9. Third-Party Links

For your convenience, we may link to third-party sites and services, or otherwise display third-party content through our Site. This includes:

• Links to Microsoft to allow users to download and access the App;
• Links to our profile on social media sites such as LinkedIn, Twitter, and Vimeo; and
• Videos embedded in our Site that are hosted by Vimeo.

We have no control over these linked sites, each of which has independent privacy and information collection practices. As such we have no responsibility or liability for and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to you, collect data, or solicit personal information. We encourage you to review their policies before engaging with these third-party sites.

10. Your Privacy Choices

You may view or modify scheduled Breaks by accessing your calendar through the App. You may also view your Break history by clicking on the history tab in the App. To request to access, modify, or delete your personal information, contact us at support@breakthru.me.

11. Additional Disclosures for United Kingdom (UK) and European Union (EU) Residents

Data Transfers

As a US company, most of our operations are conducted in the United States and in order to provide the Service, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, we implement the standard contractual clauses approved by the European Commission. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

Retention of Your Personal Information

As noted above, if you delete the App, we typically retain personal information for no longer than three months after the App is deleted. We may retain personal information for a longer period but only if it is needed for to address tax, corporate, compliance, employment, litigation, or other legal rights and obligations. In such cases, we only retain your information as long it is needed for those purposes.

Legal Basis for Processing Your Personal Information

We collect and process your personal information for the purposes set out in the Our Use of Collected Information section above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Service).

Automated Decision-Making

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

Your Rights

As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:

• Access. You have the right to request a copy of the personal information we process about you. We will provide a copy to you in electronic form.
• Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is changed.
• Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such data to comply with a legal obligation or to establish or defend a legal claim.
• Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data is inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
• Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
• Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise, or defend a legal claim.
• Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information based on your consent collection prior to withdrawal.

Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about our exercise the rights listed above, at any time, contact us at support@breakthru.me with the subject line “Privacy” so that we can get your email to the right team members. We will respond to your request consistent with applicable law.

If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.

12. Additional Disclosures for Canadian Residents

Please contact us at the information in the Contact Information section below:

• If you wish to access, update, and/or correct inaccuracies in your personal information or change your consent preferences (note: we may need to collect additional personal information for the purposes of verifying your identity before responding to your request); or
• If you have questions or complaints about the way we treat your personal information.

13. Changes to This Privacy Policy

This Privacy Policy is effective as of the date listed at the end of this Policy. Breakthru may update this Privacy Policy at any time. When we do, we will revise the last updated date below. We encourage users to frequently check this page for changes and to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically.

In the event of a material change to this Privacy Policy, we will provide a message through our Site informing you of the change.

14. Contact Information

If you have any questions about this Privacy Policy or our Service, please contact us at support@breakthru.me.

This policy was las updated March 14, 2022.