Guided Breathing cares about the privacy and personal data of its users.
INFORMATION PURSUANT TO ART. 13 OF THE EU REGULATION N. 679/2016 (“GDPR”)
This Policy explains which of your personal data are collected by Guided Breathing (hereinafter “we” or “Guided Breathing”), for which purposes and how they are processed. You can also find below the necessary information to enforce your rights provided for by GDPR.
Generally, we collect your personal data if you create an account, when you use our services and products, when you email or call us or send us a message, when you use our websites, apps and social media. We inform you that the personal data collected during such processes will be used in order to reply to your queries, to allow you to use the services and products provided by Guided Breathing, to carry out marketing activities, to provide customer support and to carry out analyses in order to ensure you have a customized user experience on the website and the app, as specified below.
1. Data Controller
Guided Breathing BV with registered office in Amsterdam, Danzigerkade 5, 1013AP, is the Data Controller of the processing of your personal data, necessary to provide you with the services and products of Guided Breathing and, upon your consent, for marketing purposes, consistently with the purposes and modalities indicated below.
2. Data collection methods
Directly from you. For example, if you download the app, if you create an account, send us content or if you send us a query via email or through other communication means. If you do not communicate your data we may not activate your account or we may provide you with a very limited service.
From third parties. Your activities on our websites and apps may be posted on the social media platforms you have an account on (and of which you have accepted the terms and conditions, including those relating to the use of your data).
3. Type of processed data
For the purpose of creating your Guided Breathing account and providing you the Guided Breathing services you have requested, as well as giving you customer assistance, we process your personal data such as name (or nickname), email address, telephone number and, when you wish to purchase our products or services, your credit card and other billing information.
Also, to allow you to use Guided Breathing’s services and products, we store and process information on your location and that of your device.
To allow you to share the information you decide to disclose to the users of Guided Breathing’s services, we will use data relating to your location and the personal information that you will decide to post using certain features which will be activated exclusively upon your request.
In order to send you commercial information about our products and services and to submit proposals tailored to your tastes, we may use your email address, your name and some browsing data, provided you have previously authorized such processing.
4. Purpose and legal basis of processing – Data retention period
To provide you with Guided Breathing’s services and products, through our apps and our websites, to give you information and assistance for the activation of your account and on Guided Breathing’s services. The processing of your data is necessary to give you access to the apps and the websites of Guided Breathing and their functionalities, to respond to your requests and to assist you when you use our products and services.
During your use of our products we may collect information about your location, such as IP address, GPS location or other information sent from your mobile devices and laptops on which one of our Apps is installed. This information is mandatory so that we can provide you with our services, such as the indication of the shortest route, the reporting of obstacles, the synchronization of your data with other devices. Failure to provide such information may entail the impossibility to access our services. The information on your location will be collected only upon your authorization, which you will provide to us by authorizing the use of the GPS location at the moment of the activation request. If instead you will not authorize the use of the GPS location, our App will not have access to information related to your location and will not be able to operate with all its functionalities. At any time you can choose to enable or disable the collection of this information through the settings provided by your device or in the settings of the app.
The legal basis of this processing is the performance of the services you have requested, in accordance with the terms and conditions of Guided Breathing’s service that you have accepted, and the fulfilment of pre-contractual measures that you may have requested. The retention period of your data is equal to the period of activity of your account for the use of Guided Breathing’s services according to the terms and conditions of use that you accepted. The deletion of your account can occur either by your express request or after 24 months (i) from your last activity on the app or (ii) from the expiration of the service you had previously purchased (usually you use our services in a specific season and we believe that you do not intend to use these services anymore if for two seasons we do not detect any activity on your account).
To send you communications in connection with your purchase order. We may send you emails (or other types of messages, such as in-app messages) regarding your account or your purchase of Guided Breathing products and services. The legal basis of this processing is the performance of the agreement you become a party of when you accept the terms and conditions of Guided Breathing’s service and the fulfilment of pre-contractual measures that you may have requested. The retention period of your data is equal to the period required to process the purchase order and, if you have also an account, to the period of activity of your account for the use of Guided Breathing services, according to the terms and conditions of use that you have accepted.
To properly manage your customer account. We process your data for accounting, administrative and tax purposes, directly related to the business of Guided Breathing as required by the applicable legislation. The legal basis of this processing is the compliance with legal, statutory, obligations and the retention period is equal to that required by law (in particular by tax, anti-money laundering, banking and public security law). For internal administrative purposes, we may also share your data within the Guided Breathing companies group, located abroad, in compliance with the principles set by the GDPR for the transfer of personal data to companies located in a third country (in particular, we could communicate your data to mother companies or Guided Breathing affiliated operating in the United States and which have entered into with Guided Breathing standard data protection clauses approved by the European Commission). The legal basis of such processing is the legitimate interest of Guided Breathing in pursuing its corporate organizational purposes recognised by law. The retention period, where it is not required by law for a longer period (see the previous paragraph), is equal to the duration of your contractual relationship with Guided Breathing (therefore to the activity of your account (see above on the deletion of the account), to the processing of the purchase order or to the provision of assistance and statutory warranty).
To let you interact with customer care operators. We may use your e-mail address or telephone number, as well as the name and/or postal address, to assist you in case you need help using the app or in general for the use of Guided Breathing’s products and services. Also to provide you customer assistance, we may communicate your data to Guided Breathing’s parent companies or affiliated companies. The legal basis of this processing is the performance of the agreement which you have entered into with Guided Breathing when you have accepted the terms and conditions of use of Guided Breathing’s services and the compliance with the legal obligations regarding statutory due warranties and assistance to the consumer.
To allow you to interact with other users. Through the Community-function, which is activated only upon your request, you can leave comments or other information on your experiences which can be viewed by other users. The legal basis of this processing is the user’s consent. The retention period of your data is equal to the period of activity of your account for the use of Guided Breathing’s services, according to the terms and conditions of use that you have accepted. The retention period of your data is equal to the period of activity of your account for the use of Guided Breathing’s services according to the terms and conditions of use that you accepted.
We might also collect information regarding customer assistance or issues occurred to our service. To improve quality of customer care services, subject to applicable legislations, Guided Breathing may also record and listen conversations with customer care operators. The legal basis of this processing is the legitimate interest of Guided Breathing to improve the quality of the services provided to its customers. In addition, Guided Breathing might analyze any feedbacks provided voluntarily through surveys submitted to the client. The legal basis of this processing is the consent of the data subject.
In all the above-mentioned cases, the retention period of the data is equal to the period of activity of your account.
To improve the quality of our cartography and services. The data of users concerning the navigation, after being anonymized, can also be used to process information, including statistics, necessary to improve or correct our maps and services, thus contributing to the safety of navigation and quality of our products. The legal basis of the processing necessary to anonymize the data is the legitimate interest of Guided Breathing in the quality and safety of its products and services provided to users.
To prevent or assess unlawful conduct, to protect and enforce our rights. For example, we may use your data to prevent or prosecute torts and infringements, including of our – and third parties’ – intellectual/industrial property rights, or to prevent or prosecute cybercrimes or crimes committed through the internet. The legal basis of such processing is the legitimate interest of Guided Breathing to protect its rights and to prevent criminal offences. The retention period of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission.
To monitor and improve our products, services and websites. With your consent, we analyse your data to improve our approach towards you and our customers in general, through automated processings, including profiling.We do this so that we can make better decisions related to services, advertising, products and content based on greater awareness of how our customers use our services and to ensure you a customized user experience. For such purpose we may also collect the advertising identifier of your mobile device (IDFA – Identifier for Advertising – for iOS devices and ADID – Google Advertising ID – for Android devices) to enable us to always provide you with targeted and accurate ads based on your preferences and your interests. The legal basis for this processing is your consent. This consent can be revoked at any time by sending a request to email@example.com. This data will be retained as long as your account is active.
To obtain information on the use of the website. When you browse our website, even when you do so without being registered or having logged in, the software procedures and the computer system controlling the functioning of the web applications acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but due to their very nature they could, through processing and associations with data held by the Data Controller or by third parties, allow users to be identified.
In case of unregistered users, geographical location data will only be used in an anonymous form that does not in any way allow, even in combination with the Unique Device Identifier (UDID), the MAC address, the IMEI or IMSI codes or other customer codes, to trace, directly or indirectly to your identity. In any case, unregistered users who do not intend or cannot download the new app and who in any case do not read this Policy and do not express preferences on the processing of their data, will no longer be subject to the processing of personal data.
This category of data includes IP addresses or domain names of the devices used by users connecting to the application or to the websites, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code given by the server indicating the status of the response (successful, error, etc.), the visited sections of the website, the type of device used, the country from which you connect and other parameters related to the operating system and the user’s computer environment. Guided Breathing uses this information solely to allow navigation on its websites and to process the operations normally related to the use of the website and of the apps in connection to customer care activities. The legal basis of this processing is the legitimate interest of Guided Breathing to communicate with the public through telematic networks and to assist its own customers in order to improve products and services. The retention period of the information that could potentially allow the identification is 30 days from access to the website.
To obtain information on the use of the app. We may collect data relating the type of device that you are using, or the operating System version of your computer or device. We may also analyse how often you use the app and from where you downloaded it.
You can express your preferences on the methods through which we use data on mobile devices through the privacy settings page of your Guided Breathing apps.
For these purposes we use third parties’ tools:
Third party’s tool
Crashlytics – Firebase
Data collection for the analysis of abnormal events (e.g. crash) in order to improve the quality of the product and solve any problems.
Identification data of the mobile device on which the abnormal event occurred.
You can disable this feature via the privacy settings page of your Guided Breathing apps.
Among these tools there are some that we use to handle technical problems in the app, whose resolution requires the use and sharing of the identification data of the mobile device with our service providers. This function will only use your data if you have spontaneously activated and authorized it.
The legal basis of the processing is the legitimate interest of Guided Breathing to improve the quality of the services offered to its users and the security of its application. The retention period of the information used for this purpose is 3 months from the moment of collection.
In relation to the aforementioned purposes, the processing of personal data takes place using manual, IT and telematic tools with logics strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the same data in compliance with the law.
We collect data from users about their usage of our apps. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behaviour (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions.
Guided Breathing uses this data to improve the quality and functionality of our apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.
Google Analytics for Firebase is used on our mobile apps to better understand usage of our apps, to improve user experience, and to track migration of users to new versions of the apps. You can find out more information about how this analytics information may be used, how to control the use of your information, and how to opt-out of having your data used by Google Analytics by clicking here.
The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our apps so we can enhance the user experience and functionality of our apps.
5. Transfer of data
All data is safely stored and hosted in line with GDPR regulations at the facilities of KPN Internedservices, managed cloud – and hosting solutions.
Data processing for customers services and improvement of the products is done at the office of Guided Breathing BV; Danzigerkade 5, 1013 AP Amsterdam.
6. Recipients of the personal data
With other Guided Breathing’s users. If you activate the Community- function you can interact with other users, to whom the objects which you will insert or modify, your comments, your nickname, and the other information that you want to share will be visible. By default this feature does not reveal your nickname to other users, until you decide to make your nickname visible.
With service providers. Guided Breathing uses third-party services (cloud, analysis, profiling, messaging, app and website browsing functionalities and components of Guided Breathing’s products and services) that operate as data processors pursuant to agreements in compliance with art. 28 GDPR and in accordance with the provisions relating to the transfer of data to third countries, where such data are actually transferred. These subjects acquire only the personal data necessary to fulfil their functions and may use them only for the purpose of performing these services on our behalf or to comply with the law. The updated list of third-party suppliers, operating as data processors pursuant to art. 28 GDPR, is available by sending a request to firstname.lastname@example.org.
With judicial or administrative authorities. Where we believe we have to do so to comply with an order from the judge or from an authority, or to comply with legal obligations or in order to protect us or third parties judicially, we may disclose your data to the Judicial Authority or to a Governmental Agency in The Netherlands or the European Union.
The websites, the app and Guided Breathing’s services and products in general are not intended for minors under the age of 18, who shall not therefore provide personal data to Guided Breathing. In the event that Guided Breathing becomes aware that it has collected personal data from users under the age of 18, it will take the necessary steps to delete such information as soon as possible.
Updated on 23 November 2020