Privacy Policy

The information we collect and how we use it Last updated February 2025 For the purposes of the Breadcrumb Privacy Policy (“Privacy Policy,”) “Personal Data” is defined as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular consumer or household.” We respect your privacy. This Privacy Policy describes how we collect and use Personal Data from you, and with whom we may share it. We may update or otherwise change it from time-to-time without prior notification to you, and you agree to be bound by the changes we make. It is our policy to maintain the confidentiality and security of Personal Data that we collect, maintain and utilize in serving the needs of our customers and visitors to the Breadcrumb website (“Website.”) You have the option of removing your information from our database so that you do not receive future communications from us. You can contact Breadcrumb via security@breadcrumb.ai to opt out of future communications. A. Information Collected and Received from You Below is the Personal Data we may collect from clients, although we do advise all clients to scrub any individually identifiable information before our applications process it: Category of Personal Data Collected Contact information - Name, email address Demographic information - Age, gender, date of birth Device and usage data - IP address, device ID, browser type, operating system, usage logs, cookies, and other analytics Location data - GPS coordinates, city and state information, time zone Behavioral data - Interaction with Breadcrumb Uploaded data - Documents, spreadsheets, and databases used for analytics B. Use and Disclosure of Personal Data We do not sell your Personal Data, and, except as set out in this Privacy Policy, we do not share it with others. We use your Personal Data to operate this Site, to deliver products and services you have requested, to manage your account, and to provide customer support. We may use your Personal Data to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your Personal Data will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may disclose your Personal Data under the following circumstances (a) to conform to the requirements of the law or comply with legal proceedings involving us, our affiliates or the Site; (b) to protect and defend our rights or property or the rights and property of our affiliates; (c) to act under exigent circumstances to protect the personal safety of users of Site, or the public; (d) in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets; and (e) with our trusted third parties we hire or work with to allow us to or provide our products and services to you. These third parties need access to your Personal Data in order to perform services on our behalf, such as web hosting, payment processing, email distribution, , product and feature support, customer support, information technology, and analytics services. C. Retention of Your Personal Data To meet our legal and regulatory obligations, we will hold your Personal Data while our services are ongoing and for a period of time after that for as long as needed to perform our services or otherwise engage with you and as long as required by applicable laws or regulations. D. Security Measures Breadcrumb takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Data Processing of Personal Data is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time. G. European Privacy Issues This section addresses specific concerns related to the Personal Data that the Website collects from EU residents, in line with requirements laid out in the EU’s General Data Protection Regulation (GDPR). Legal Basis for Processing Personal Data We may process your Personal Data under the following conditions: Consent: You have given your consent for processing Personal Data for one or more specific purposes. Performance of a Contract: Processing of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof. Legal Obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject. Vital Interests: Processing Personal Data is necessary in order to protect your vital interests or those of another natural person. Public Interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us. Legitimate Interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us. In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Your Rights We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to: Request Access to your Personal Data: The right to access, update, or delete the Personal Data we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your Account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This right also allows you to receive a copy of the Personal Data we hold about you. Request Rectification or Correction of the Personal Data: You have the right to have any incomplete or inaccurate Personal Data we hold about you corrected. Object to Processing of your Personal Data: You have the right to object to the processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing of your Personal Data and there is something about your situation that makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes. Request Erasure of your Personal Data: You have the right to ask us to delete or remove your Personal Data when there is no good reason for us to continue processing it. Request the Transfer of your Personal Data: You have the right to request the transfer of your Personal Data. We will provide to you, or to a third-party that you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw Your Consent: You have the right to withdraw your consent to the processing or use of your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Website. You may exercise your rights by contacting us through the avenues listed below. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, if you are in the EU, please contact your local data protection authority. Cross-Border Data Transfers To the best of our knowledge, the servers on which your Personal Data will be stored and processed are in the State of Washington, U.S.A. By submitting Personal Data to us, you agree that it may be stored and processed on servers located outside the European Union (EU). If you are within the EU, you consent to your Personal Data being exported and stored and processed on any of our servers in any location. H. State Privacy Issues Depending on what US state you live in, you may have the following rights with respect to your Personal Data. Right to Know and Access: You may have the right to know and access the Personal Data we have collected about you. We will provide to you your Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller. Right to Delete: You may have the right to request that we delete the Personal Data we have collected about you, subject to certain legal exceptions. Right to Correct: You may have the right to request that we correct any inaccurate Personal Data we have collected about you. Rights to Opt-Out of Targeted Advertising, Sale of Personal Data and/or Profiling: You may have the right to opt-out of our processing of your Personal Data for the purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. Please note we do not process Personal Data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects and therefore these opt out rights do not apply. Right to Appeal: You may have the right to appeal any of our responses with respect to your Personal Data privacy rights requests. Right to No Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights Exercising Your Rights In order to exercise any of your rights outlined in Sections G and H, please contact us via: security@breadcrumb.ai. Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Data. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Data or a person authorized to act on your behalf. We will only use the Personal Data you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority. J. Children’s Privacy We do not knowingly ask for or collect Personal Data from children under 13 years of age. If you believe a child under 13 has submitted Personal Data to us and you have authority to act on behalf of the child, please contact us to ask to have the information deleted. K. Contact Us We may contact you using the contact information you provide to us if there is a problem with your order or use of the Site. If you have questions about this Privacy Policy, please contact Breadcrumb via security@breadcrumb.ai.

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