PRIVACY POLICY

BREATHINGROOM INC.

PRIVACY POLICY

Last Updated – July 22, 2014

BreathingRoom is a cloud-based application that facilitates discovery and use of professional workspaces for the business traveler through http://breathingroom.co/, breathingroom.in, or any other URL provided by BreathingRoom (collectively, the “Website”), and/or any other digital media platform accessed by its users (the “Platform” and together with the Website, the “BreathingRoom Service”). The BreathingRoom Service is owned and operated by BreathingRoom Inc., a Delaware corporation (“BreathingRoom”, “we” or “us”).

Your use of the BreathingRoom Service is subject to the terms and conditions set forth in this Privacy Policy (the “Privacy Policy”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE BREATHINGROOM SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND TO ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE BREATHINGROOM SERVICE.

We are committed to respect and protect the privacy of the personal information we obtain from you through the BreathingRoom Service and we have created this Privacy Policy to inform you about how we collect, use and share your personal information, and about our privacy practices in general.

We are always ready to address your questions and concerns regarding this policy and our privacy practices. If you would like to contact customer service, please contact us via support@breathingroom.co

We continually strive to find new ways to enhance your experience with the BreathingRoom Service and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices.  You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of the Privacy Policy for the most recent version.  If we make changes to this Privacy Policy, we will notify you here, by email, or by means of notice through the Website, the Platform, or any other part of the BreathingRoom Service.

1.         Terms of Service. Use of the BreathingRoom Service is subject to the terms of our Terms of Service, which is hereby incorporated and made part of this Privacy Policy. By using the BreathingRoom Service, you agree to be bound by our Terms of Service.

2.         Types and Uses of Collected Information.

We may disclose to third party services certain personally identifiable information listed below:
— information you provide us such as name, email, mobile phone number
— information we collect as you access and use our service, including device information, location and network carrier

BreathingRoom collects two types of information about you:

            a.         Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the BreathingRoom Service, including but not limited to creating an account, registering for a workspace, sending feedback, or otherwise participating in the BreathingRoom Service (collectively, “Identification Activities”), we may ask you to provide certain information about yourself.  If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain personal information about yourself, such as your name, address (including zip code), email address and/or telephone number. Depending on the Identification Activity, some of the information we ask you to provide may be identified as mandatory and some identified as voluntary.  If you do not provide mandatory information for a particular Identification Activity, you will not be permitted to engage in that Identification Activity with the BreathingRoom Service.  Depending on the Identification Activity, BreathingRoom may not re-ask you for Personally Identifiable Information if such are already stored with us.

We may use Personally Identifiable Information to provide products and/or services to you, administer sweepstakes and contests, enhance the operation of the BreathingRoom Service, improve our marketing and promotional efforts, analyze use of the BreathingRoom Service, improve the BreathingRoom Service, and tailor your experience with third parties as provided below in this Privacy Policy. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Terms of Service and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.

            b.         Non-Personally Identifiable Information. Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to the BreathingRoom Service or otherwise participating in the BreathingRoom Service, the URL of the website you visit after leaving the BreathingRoom Service, the type of browser you are using, your Internet Protocol (“IP”) address, or general and/or aggregated location data that does constitute Personally Identifiable Information. We, and/or our authorized Third Party Service Providers, may automatically collect this information when you visit or use the BreathingRoom Service through the use of electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy.

We use Non-Personally Identifiable Information to troubleshoot, administer the BreathingRoom Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third Party Service Providers to measure the overall effectiveness of our products and services.

3.         Release of Personally Identifiable Information.

The information is shared with third party service providers so that we can:
— personalize the app for you
— perform behavioral analytics

We will not sell or share your Personally Identifiable Information with other parties except as provided below:

            a.         Authorized Third Party Service Providers. BreathingRoom may provide products and services through third parties, including without limitation the professional workspaces which are provided by third parties and not BreathingRoom. These “Third Party Service Providers” perform functions on our or your behalf. You or We may share your Personally Identifiable Information with such Third Party Service Providers to fulfill orders, move data in or out of the BreathingRoom Service, analyze data, operate the BreathingRoom Service, troubleshoot and provide customer service.  We may also provide personal information to individuals and companies with whom we have business relationships and may share your information with Third Party Service Providers to accomplish our administrative tasks.  However, the use of your Personally Identifiable Information by such parties is governed by the privacy policies of such parties and is not subject to our control.

            b.         Remarketing. Remarketing is a way for us to connect with people, based upon your past interactions with the BreathingRoom Service. Third-party marketing vendors may be hired by BreathingRoom to perform remarketing services. As a result, third-party vendors, including Google, may show BreathingRoom ads on sites on the Internet. Third-party vendors may use cookies to serve ads based on a user’s prior visits to the BreathingRoom Service.  Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page at http://www.google.com/privacy_ads.html.

            c.         Acquisition. As with any other company, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy.

            d.         As Required by Law. We reserve the right to disclose your Personally Identifiable Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on us, enforce or apply this Privacy Policy, Terms of Service or other agreements or protect the rights, property or safety of the BreathingRoom Service, users of the BreathingRoom Service or others.

4.         Referrals. You may choose to invite friends to join BreathingRoom by sending invitation emails via an invite feature. BreathingRoom stores the email addresses you provide so that the respondents may be sent reminders of the invitations. BreathingRoom does not sell these email addresses or use them to send any other communication besides invitations and invitation reminders. Recipients of invitations may contact BreathingRoom to request removal of their information from our database.

5.         Release of Non-Personally Identifiable Information. We may disclose or share Non-Personally Identifiable Information with Third Party Service Providers and the general public. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) or use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our users to administer the BreathingRoom Service. We may also publish this aggregated information for promotional purposes. Such data is collected on our behalf, and is owned and used by us.

We may use Third Party Service Providers to serve ads when you participate in the BreathingRoom Service. These companies may use Non-Personally Identifiable Information about your visits and use of the BreathingRoom Service, and visits to other websites or locations in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.

6.         Third Party Advertising. Advertisements appearing on the BreathingRoom Service may be delivered to you by BreathingRoom or one of our advertising partners. Our advertising partners may set cookies. Doing this allows the advertising partners to recognize your computer each time they send you an advertisement. In this way, they may compile information about where you, or others who are using your computer or device, saw their advertisements and determine which advertisements are clicked. This information allows an advertising partner to deliver targeted advertisements that they believe will be of most interest to you.  BreathingRoom does not have access to or control of the cookies that may be placed by the third party advertising servers of ad partners.  This privacy statement covers the use of cookies by BreathingRoom and does not cover the use of cookies by any of its advertisers.

7.         Updating Information. If you are enrolled in the BreathingRoom Service, you may change any of your applicable Personally Identifiable Information by logging into your account and accessing the “My Profile” section of the BreathingRoom Service.  We encourage you to promptly update your Personally Identifiable Information if it changes, as out-of-date Personally Identifiable Information may negatively affect the quality of your BreathingRoom Service experience.

8.         Choices on Collection/Use of Information. You can always choose not to provide certain information, although a certain level of information may be required to engage and participate in the BreathingRoom Service.  If you are enrolled, you cannot opt-out of Administrative Emails. “Administrative Emails” relate to your activity on the BreathingRoom Service, and include but are not limited to emails regarding your account, requests or inquiries.  If you do not want to receive promotional emails from us, you may elect to opt-out of receiving promotional emails at any time after registering by e-mailing us at support@breathingroom.co or by hitting the “unsubscribe” button at the bottom of any of our e-mails.

9.         Security of Information. You can access your Personally Identifiable Information via the BreathingRoom Service with your password and username. This password is encrypted. We advise against sharing your password with anyone.  If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In the event that we believe that the security of your information may have been compromised, we may seek to notify you of that development. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to. We may encrypt certain sensitive information using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us.  However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies that do the same, we cannot guarantee the security of any information transmitted to or from or via the BreathingRoom Service, and we are not responsible for the actions of any third parties that may receive any such information.

10.      Data Tracking.

            a.         Cookies. To facilitate and customize your experience with the BreathingRoom Service, we may store cookies on your computer or other similar device through which you access the BreathingRoom Service. A cookie is a small text file that is stored on your computer or other device for record-keeping purposes that contains information about you. We use cookies to save you time while using the BreathingRoom Service, remind us who you are, and track and target your interests in order to provide a customized experience. Cookies also allow us to collect Non-Personally Identifiable Information from you, like which pages you visited, what links you clicked on, and how you used the BreathingRoom Service. We may use Third Party Service Providers to display advertisements on the BreathingRoom Service. As part of their service, they may place separate cookies on your computer or similar device. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by the BreathingRoom Service only and does not cover the use of cookies by any Third Party Service Provider.  Most browsers automatically accept cookies, however you may be able to modify your browser settings to decline cookies. Please note that if you decline or delete these cookies, some parts of the BreathingRoom Service may not work properly.

            b.         Other Tracking Devices. We may use other industry standard technologies like pixel tags and web beacons to track your use of the BreathingRoom Service, or we may allow our Third Party Service Providers to use these devices on our behalf.  When you access the BreathingRoom Service or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on the BreathingRoom Service, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our marketing partners for the same purposes.

            c.         How to Opt-Out of Third Party Tracking Technologies. Our advertising service vendors and other third parties may also use tracking technologies to serve you advertisements tailored to interests you have shown by browsing on the BreathingRoom Service and other sites, applications, destinations, and services you have visited, and to determine whether you have seen a particular advertisement before to avoid sending you duplicate advertisements, and for other lawful business purposes. In doing so, these third parties may collect non-personally identifiable data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of tracking technologies by third parties is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith. If you do not want the services that tracking technologies provide, you may be able to opt-out by visiting http://www.aboutads.info.

11.      Privacy Policies of Third Party Websites. This Privacy Policy only addresses the use and disclosure of information we collect from you via the BreathingRoom Service. Other websites or services that may be accessible through the BreathingRoom Service may have their own privacy policies and data collection, use and disclosure practices. If you use, link or visit any such website, we urge you review the website’s privacy policy. We are not responsible for the policies or practices of third parties.

12.      Email Choice/Opt-out. We will make commercially reasonable efforts to implement your email opt-out requests promptly, but you may still receive communications from us for up to fifteen (15) business days as we process your request.

13.      Privacy Settings.  As a user, you may have limited access to privacy settings. These settings help hide information you wish to share with other users and/or the public. It is up to you to select the appropriate privacy settings. If you don’t agree with the available privacy settings, please stop using the BreathingRoom Service.

14.      Public Areas.  We may provide areas on the BreathingRoom Service where you can publicly post information about yourself or can communicate with others such as on forums. This information may be accessible by other users and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any content or providing anything that could be deemed personal information.

15.      Notice of Privacy Rights to California Residents. California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“COPPA”) and the California Business and Professions Code. As required by COPPA, we will provide you with the categories of Personally Identifiable Information that we collect through the BreathingRoom Service and the categories of third party persons or entities with whom such Personally Identifiable Information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of Personally Identifiable Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or physical mail to the address found below. When contacting us, please indicate your name, address, email address, and what Personally Identifiable Information you do not want us to share with our marketing partners. The request should be sent to the attention of our legal department, and labeled “California Customer Choice Notice.” Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice.

16.      Children. If you are under the age of 18, you represent that you have the consent of a parent or legal guardian to use and access the BreathingRoom Service. If you become aware that your child has provided us with personal information without your consent, please contact us at support@breathingroom.co.

17.      Customer Service. For assistance or questions regarding this Privacy Policy or the BreathingRoom Service, you may contact us at support@breathingroom.co.