PRIVACY AND DATA SECURITY POLICY
Revision Date: 06/28/2022
Breadware Holding LLC dba Breadware (“Breadware”) respects the Licensee’s privacy and is committed to protecting it through Breadware’s compliance with this Privacy and Data Security Policy (“Policy”). As used in this Policy, “Licensee” means (i) the purchaser of the Software and/or (ii) the user of the Software and the organization the user represents. This Policy describes:
- The types of information that Breadware may collect or that the Licensee may provide when the Licensee registers with, accesses or uses Breadware’s cloud-based analytics services (“Services”).
- Breadware’s practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy applies only to information that Breadware collects through or in connection with Breadware’s Services, including information in email, text and other electronic communications sent through or in connection with Breadware’s Services.
This Policy DOES NOT apply to information that:
- Breadware collects from visitors on Breadware’s website.
- Breadware collects offline or from other websites, including any website that the Licensee may access through Breadware’s website.
- Breadware provides to or is collected by any third party.
Breadware’s website, other websites and third parties may have their own privacy policies, which Breadware encourages the Licensee to read before providing information on or through them.
Please read this Policy carefully to understand Breadware’s policies and practices regarding the Licensee’s information and how Breadware will treat it. If the Licensee does not agree with Breadware’s policies and practices, do not register with or use Breadware’s Services. By registering with or using Breadware’s Services, the Licensee agrees to this Policy.
Changes to This Policy
Breadware may modify this Policy from time to time. The Licensee’s continued use of Breadware’s Services after Breadware makes modifications to this Policy is deemed to be the Licensee’s acceptance of those modifications, so please check this Policy periodically for revisions. The date this Policy was last revised is identified at the top of the page.
Information Breadware Collects and How Breadware Collects It
Breadware collects information:
- Directly from the Licensee when the Licensee provides it to Breadware.
- Automatically when the Licensee uses Breadware’s Services.
Information Breadware Collects:
- When the Licensee signs up for Breadware’s Services, Breadware asks the Licensee to complete a registration form so that the Licensee can create an account. Breadware also provides the Licensee with an application programming interface (API) key so that the Licensee can connect to Breadware’s Services and upload information.
- When the Licensee registers for an account, Breadware collects certain profile information such as the Licensee’s first and last name, email address, project or business name and payment information.
- If the Licensee sends Breadware feedback, requests support, or otherwise interacts with Breadware, the Licensee may collect the personal information contained in any email, text, or other electronic communication that the Licensee sends to Breadware.
- Breadware may combine personal information submitted by the Licensee with information obtained from other sources.
- Breadware collects all information that the Licensee uploads to Breadware’s Services. Breadware has no control over what information Breadware uploads to Breadware’s Services. Breadware’s Services may use technology to automatically collect usage details and device information.
- Usage Details. When the Licensee accesses and uses Breadware’s Services, Breadware may automatically collect certain details about the Licensee’s access to and use of Breadware’s Services, including traffic data, location data, logs and other communication data and the resources that the Licensee accesses and uses on or through Breadware’s Services.
- Device Information. Breadware may collect information about the device and internet connection the Licensee uses to access and upload information to Breadware’s Services, such as the Licensee’s device type, operating system type, browser type, domain, system settings, and IP address, as well as the language the Licensee’s system uses and the country and time zone where the Licensee’s device is located.
How Breadware Collects It:
- Breadware collects information directly from the Licensee when the Licensee provides it to Breadware (i) through the use of forms, such as completing a registration form or survey, or (ii) by sending Breadware feedback, requesting support, or otherwise interacting with Breadware by telephone or by email, text, or other electronic communication.
How Breadware Uses the Licensee’s Information:
Breadware uses information that Breadware collects about the Licensee or that the Licensee provides to Breadware, including any personal information, to:
- Provide the Licensee with Breadware’s Services and any support or other service or information that the Licensee requests from Breadware.
- Fulfill any other purpose for which the Licensee provides it.
- Give the Licensee notices about the Licensee’s account, including for billing and collection.
- Carry out Breadware’s obligations and enforce Breadware’s rights arising under Breadware’s End User Licensing Agreement or any other contract between the Licensee and Breadware.
- Notify the Licensee when updates to Breadware’s Services are available and of changes to any products or services Breadware offers or provides though Breadware’s Services.
- Periodically send to the Licensee newsletters and communications promoting the use of Breadware’s Services. The Licensee may “opt-out” of such receiving such promotional communications as set forth below.
Breadware has no control over what information the Licensee uploads to Breadware’s Systems or how the Licensee uses such information, and Breadware will not access or use such information, other than in aggregated form for billing and financial reporting, except as may be necessary to provide the Licensee with support services or to comply with any court order, law, or legal process, including to respond to any government or regulatory request. The usage details that Breadware collects helps Breadware to improve Breadware’s Services.
Disclosure of the Licensee’s Information
Breadware may disclose aggregated information about Breadware’s Services or de-identified data derived from personal information without restriction. In addition, Breadware may disclose information, including personal information, that Breadware collects or that the Licensee provides:
- To Breadware’s subsidiaries and affiliates.
- To Breadware’s authorized Distributors or Resellers.
- To contractors, service providers and other third parties that Breadware uses to support Breadware’s business, who are generally bound by contractual obligations to keep personal information confidential and use it only for the purposes for which Breadware discloses it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Breadware’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Breadware about Breadware’s customers is among the assets transferred.
- To fulfill the purpose for which the Licensee provides it.
- For any other purpose disclosed by Breadware when the Licensee provides the information.
- With the Licensee’s consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce Breadware’s rights arising from any contracts entered into between the Licensee and Breadware, including Breadware’s End User Licensing Agreement, and for billing and collection purposes.
- If Breadware believes disclosure is necessary or appropriate to protect Breadware’s rights, property, or safety or that of Breadware’s customers or others.
Individuals from the European Union
- Legal Bases for Processing: Breadware processes the Licensee’s personal information for one or more of the following general permitted purposes in accordance with the corresponding legal basis.
|Where it is necessary to perform Breadware’s contract with the Licensee or to take steps at the Licensee’s request to enter into the contract
- to perform Breadware’s Services if the Licensee is a client.
|Where it is necessary for compliance with a legal obligation
- to protect Breadware’s and Breadware’s clients’ personal information, and other information, property, and assets,
- to cooperate with Breadware’s regulators and other public authorities (including by responding to their requests for information, undertaking internal investigations, and complying with Breadware’s reporting and other professional obligations), and
- to comply with any other obligation to which Breadware is subject under applicable rules and law.
|Where it is necessary for the purposes of Breadware’s or another party’s legitimate interests, except where these are overridden by the Licensee’s interests, rights, or freedoms
- to ensure compliance with Breadware’s internal policies;
- for general security and business continuity purposes;
- for business management and financial planning (including management of suppliers, business process improvement and quality purposes, management reporting and reviewing records, accounting and auditing, and corporate due diligence);
- for managing insurances, complaints, and potential and actual claims;
- to ensure the effective provision of Services to clients and enhance Breadware’s international business and cross-border offerings;
- for training and continuing professional development purposes;
- to organize corporate events and to carry out market research campaigns;
- to protect, manage, and improve Breadware’s Services and other services Breadware offers; and
- for any other legitimate purpose communicated to the Licensee at the time of collection of the Licensee’s personal information.
Breadware considers that Breadware’s legitimate interests and these uses are proportionate, and compatible with the Licensee’s interests, legal rights, or freedoms. Details of the balancing test undertaken in respect of such collection and use is available upon request.
|Where the Licensee provides consent
- To respond to the Licensee’s inquiries and requests for information about Breadware and Breadware’s Services,
- to the extent applicable laws in certain jurisdictions require the Licensee’s consent for advertising, marketing, and public relations purposes, and
- where the Licensee otherwise provides Breadware with the Licensee’s consent.
Please note that the Licensee may withdraw the Licensee’s consent to processing personal information at any time through the contact procedures provided below.
The Licensee’s Choices and Right to Access and Correct Personal information
If the Licensee receives newsletters or promotional communications from Breadware, the Licensee may indicate a preference to stop receiving further promotional communications from Breadware by following the unsubscribe instructions provided in the e-mail the Licensee receives.
The Licensee may review and change the Licensee’s personal information by visiting the Licensee’s account profile page. The Licensee may also send Breadware an email at firstname.lastname@example.org to request access to, correct or delete any personal information that the Licensee has provided to Breadware. Breadware may be unable to delete the Licensee’s personal information except by also deleting the Licensee’s account. Breadware may not accommodate a request to change information if Breadware believes the change would violate any law or legal requirement or cause the information to be incorrect.
Children under the Age of 13
Breadware’s Services are not intended for children under 13 years of age and Breadware does not knowingly collect personal information from children under 13. If Breadware learns that Breadware has collected or received personal information from a child under 13 without verification of parental consent, Breadware will delete that information. If the Licensee believes that Breadware might have any information from or about a child under 13, please contact Breadware at email@example.com.
Breadware maintains administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite these safeguards, due to inherent uncertainty in the use of the internet and information systems and the potential for unlawful attacks by third parties, Breadware cannot guarantee that the use of Breadware’s Systems will be completely safe or secure.
Information that Breadware collects and uses may be transferred, stored, and accessed globally to support Breadware’s Services. Breadware retains information for as long as it is needed or useful to provide and improve Breadware’s Services and comply with Breadware’s legal obligations, resolve disputes, and enforce Breadware’s rights under agreements.
To ask questions or comment about this Policy and Breadware’s privacy practices, contact Breadware at firstname.lastname@example.org.