Your Privacy Rights

Effective Date: December 2, 2025

This Privacy Policy describes the types of information gathered by Breeze Labs Inc. and its affiliates (“Breeze”, “us” or “we”) in the process of providing the services described in our Terms of Service (the “Terms”), available at https://www.breeze.cash/terms-of-service (the “Services”); how we use the information; with whom the information may be shared, what choices are available to you regarding collection; use and distribution of information; and how we protect the information you provide to us through the Services.

By using the Services, you hereby consent to allow us to process information in accordance with this Privacy Policy. Terms defined in the Privacy Policy that are not defined herein shall have the same definition as in the Terms.

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the revised Privacy Policy on our website (the “Site”) or otherwise making you aware of the changes as required by applicable law. Your continued use of the Services following our changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

1. Who Collects Your Information On Our Services?

We do. Under the General Data Protection Regulation (“GDPR”), Breeze is what is known as a “Controller” of the Personal Data that you provide us with. We collect information from you on the Services, and we are responsible for the protection of your information.

2. What Information Does Breeze Collect?

A. Personal Information. We collect certain personal information about you, which may be supplied when you register for the Services, when you create or update an account, when you use the Services, when you request the Services, and otherwise when you submit such information to us. The types of personal information we collect and save include:

  1. Contact and/or account information, such as your name, physical address, phone number, email address, and username, and other location information;
  2. Technical information collected in our logs, such as standard web log entries that contain your IP address, first- and third-party cookies, web beacons, page URL and timestamp.
  3. Financial information such as your payment card information, including the brand, card number, and expiration date; your bank account number; any information related to a digital wallet you provide to us, or other similar information in connection with the Services.

You may also provide us with information when you interact with us through phone, email, any online chat feature, submit a review or a post, or through other use of the Services. We may retain such information in order to provide you with the Services or improve the Services.

B. Non-personal Information. Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, when and how you use the Services, applications downloaded, search terms entered, and similar non-personal data.Non-personal Information. Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, when and how you use the App, applications downloaded, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Services may utilize web beacons, pixel tags, third-party cookies, embedded links, and other commonly used information-gathering tools. 


If non-personal information is paired with any of your personally identifiable information (“PII”), we will treat the non-personal information as if it were also PII.

C. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information, the date and time of any request you make, your language preference, pages you visit, the referring website, the website you go to immediately after visiting our Site, and the domain name of your Internet service provider.

D. Saved Payment Information. If you choose to save a payment method, we may collect and retain the information necessary to enable that payment method to be used for future transactions. This may also include authorization for recurring charges if you enroll in a subscription plan. Such information is collected and stored through our third-party service providers and is used only to process payments you authorize. You may remove a saved payment method or cancel a subscription at any time through your account settings or by contacting the applicable merchant.

E. Biometric Data.  We and our identity-verification service provider(s) may collect and process biometric information derived from the government-issued ID documents and selfies you submit (such as facial geometry) only for the purposes of verifying your identity, preventing fraud, and meeting our legal obligations.Biometric information is not sold, shared, or used for advertising, and it is not used to train algorithms or models.Our service providers store biometric information only for as long as necessary to complete identity verification or as required by law, after which it is permanently deleted. Unless a longer retention period is legally required, biometric information will be deleted within three years of your last interaction with the Services.Where required by applicable law, we will obtain your consent before collecting biometric information.

3. Why Is My Information Being Collected?

We accept and gather information to provide the Services to you and to refine the Services. We collect your personal information so that we can respond to your requests for information, to be added to our email lists, to enforce our Terms, or to otherwise provide the Services. Our third-party vendors (including Platforms) collect your PII to comply with our obligations under applicable laws and regulations including, but not limited to, Know Your Business (“KYB”) and Know Your Customer (“KYC”) regulations. We collect aggregate information to help us better design the Services. We also collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Services, calculate usage levels, and otherwise provide services to you.

4. How Do We Use the Information We Collect?

A. We use the personal information you provide for the purposes for which you have submitted it, including:

  1. Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, track usage trends, conduct experiments, offer, develop and improve the Services and other offerings, or perform research and analytics.
  2. Creating and Maintaining Your Account. We use your PII to create and maintain an Account for you in connection with the Services.
  3. Processing and Monitoring Transactions. We use your PII to process and monitor Transactions you make or attempt to make through the Services.
  4. Complying With Applicable Laws and Regulations. Our third-party vendors collect and verify your PII to comply with applicable laws and regulations and to reduce identity theft and fraud.
  5. Communicating With You About Our Services. We may use your PII to send you information about new Services and other items that may be of interest to you.
  6. Sending Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) process your transactions to purchase our Services; (c) provide you with information regarding the Services; (d) inform you of changes to this Privacy Policy, our Terms of Services, or our other terms, conditions, or policies; or (e) provide you with information on our other Services and products, or promotions related to the Services or our other Services and products.

B. We may use anonymous information that we collect to improve the design and content of our Services, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or Services. We may use any anonymous, aggregate information, which may include or be based on your information, without restriction.

5. Do We Share Your Personal Information?

We will share your personal information in accordance with applicable law: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law (including, but not limited to, our compliance with our obligations regarding KYB, KYC, and other applicable laws) or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) with persons or organizations with whom we contract to carry out operations or business activities or to provide or improve the Services; or (e) as otherwise necessary to provide the Services or to improve the Services.

We may also share aggregate information with others, including affiliated and non-affiliated organizations and their employees.

Finally, we may transfer your PII to a third party, or an actual or potential purchaser, buyer, or successor-in-interest, in relation to, or in the event of, an actual or potential merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

6. How Can You Access And Control Your Information?

After becoming a user of the Services, you may revise or edit your information through your Account, or by sending us an email to privacy@breeze.cash. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to privacy@breeze.cash. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request to do so to the extent permitted by applicable law. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing your information. You may also opt-out of any promotional emails via the unsubscribe link in any such promotional email.

7. How Do We Store and Protect Your Information?

A. Data Security
We use administrative, technical, and physical safeguards designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, firewalls, and other industry-standard security practices. While no method of transmission or storage is completely secure, we maintain safeguards appropriate to the nature of the information we process.
If you access the Services from outside the United States, you understand that your information will be transferred to and stored on servers located in the United States.

B. Data Storage
Personal Information that we collect is stored on secure servers and systems operated either by Breeze or by carefully selected third-party service providers who act on our behalf. Our service providers are required to protect PII and use it only for the purposes for which it is shared with them.

C. Data Retention
We retain PII only for as long as reasonably necessary to provide the Services, comply with legal and regulatory requirements, prevent fraud, resolve disputes, and enforce our agreements. Different categories of data are retained for different periods depending on why they were collected.

  1. Account Information (such as contact details and profile information) is kept while your account is active and as required for legal, tax, audit, or compliance purposes.
  2. KYC/KYB and Identity Verification Information, including government ID information processed by our verification vendors, is retained only for the period required to satisfy legal obligations, fraud-prevention requirements, or platform partner requirements.
  3. Biometric Information is retained only as described in the “Biometric Information” section of this Policy and deleted once the purpose of collection is complete or within the legally required timeframe.
  4. Payment-Related Information (including tokenized payment method data) is retained in accordance with policies regarding PCI-compliant payment processors.
  5. Technical Logs and Security Records are kept only for the period necessary to ensure the security, integrity, and performance of our Services and to detect, investigate, or prevent fraud or abuse.

When Personal Information is no longer required for these purposes, we will delete it or de-identify it in accordance with applicable law.

8. How Do We Use Cookies And Other Network Technologies?

A. To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your computer or mobile device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies

B. Our Services uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site, App, or the Services, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

C. Breeze or its service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some of our Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ computers or mobile devices. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

D. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site, App and the Services.

E. Do Not Track. At present, the Services do not specifically respond to browser do-not-track signals.

9. Collection of Information by Others.

This Privacy Policy is only applicable to our Services. If you obtain any additional goods and services from Platforms or other third-parties, you should check their privacy policies to learn how they collect, use, store and share information that you may submit to them or that they collect.

10. EEA Privacy Rights.

If you reside in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, you have certain rights regarding your “Personal Data” under the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”). For purposes of these laws, Breeze is the “Controller” of your Personal Data when you use the Services.

A. Legal Bases for Processing
We process Personal Data under one or more of the following legal bases:

  1. Performance of a Contract
    To provide the Services, create and manage your account, process transactions, and respond to your requests.
  2. Compliance with Legal Obligations
    To conduct identity verification, KYC/KYB checks, prevent fraud, maintain security, and comply with applicable laws and regulatory requirements.
  3. Legitimate Interests
    To improve and secure the Services, perform analytics, communicate with you about updates, and enforce our Terms. We balance these interests against your rights and reasonable expectations.
  4. Consent

    When required by law—for example, for certain categories of Sensitive Personal Data or where consent is needed for specific optional features. You may withdraw consent at any time by contacting us.

B. Your GDPR Rights
Individuals in the EEA, UK, and Switzerland have the following rights (subject to certain limitations in the law):

  1. Right of Access – You may request a copy of the Personal Data we hold about you.
  2. Right to Rectification – You may request correction of inaccurate or incomplete information.
  3. Right to Deletion – You may request deletion of your Personal Data when it is no longer needed or when processing is unlawful.
  4. Right to Restrict Processing – You may request that we limit the processing of your Personal Data under certain circumstances.
  5. Right to Data Portability – You may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
  6. Right to Object – You may object to processing based on legitimate interests, including certain forms of profiling.
  7. Right not to be Subject to Automated Decision-Making – We do not engage in automated decisions that have legal or similarly significant effects on you.

You may exercise these rights by contacting: privacy@breeze.cash.
We may request additional information to verify your identity before processing your request.

C. International Transfers
Your Personal Data may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. When we transfer Personal Data outside the EEA, UK, or Switzerland, we rely on:

European Commission Standard Contractual Clauses (“SCCs”), UK International Data Transfer Addendum, or Other legally recognized transfer mechanisms. These safeguards ensure your Personal Data receives a level of protection consistent with applicable law.

D. Complaints
If you believe we have processed your Personal Data unlawfully or inconsistently with this Policy, you may contact us at privacy@breeze.cash, or file a complaint with:

  1. Your local data protection authority in the EEA
  2. The UK Information Commissioner’s Office (ICO)
  3. The Swiss Federal Data Protection and Information Commissioner (FDPIC)
11. Children’s Information.

We do not knowingly collect any information from any minors, and we comply with all applicable United States privacy laws including the GDPR, the USA’s Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about our Site, wish to find out if your child has accessed our Services, or wish to remove your child's personal information from our servers, please contact us at privacy@breeze.cash. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at privacy@breeze.cash.

12. California Privacy Rights

This section applies only to residents of California. The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides California residents with specific rights regarding their “Personal Information” (“PI”). This section describes the categories of PI we collect, the purposes for which we use it, and your rights under California law.  When we use the term PI in this section, we mean 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.  This California Privacy Rights section also serves as our “Notice at Collection” under the CPRA.

A. Categories of Personal Information We Collect
In the past 12 months, Breeze has collected the following categories of Personal Information:

  • Identifiers

    Examples: name, username, email address, mailing address, phone number, IP address, device identifiers.
  • Customer Records Information

    Examples: account details, transaction history, payment method tokens (stored by our payment processors), and communications you send us.
  • Commercial Information

    Examples: records of digital goods or services purchased through the Services.
  • Internet or Other Electronic Network Activity Information
    Examples: device data, log files, browser information, cookies, usage data, referring/exit pages.
  • Geolocation Information

    Approximate location derived from your IP address.
  • Professional/Business Information

    If you are a business or platform partner, we may collect KYB information you provide.
  • Sensitive Personal Information (SPI)

    Only as required to verify your identity or prevent fraud, such as:
    1. Government-issued ID information (processed by our verification vendor)
    2. Biometric information derived from ID documents and selfies used solely for identity verification
    3. Account log-in information (username + hashed password)

B. Categories of Sources
We collect PI from:

  1. You, when you create an account or use the Services
  2. Your device/browser
  3. Identity verification vendors (for KYC/KYB)
  4. Payment processors
  5. Analytics providers
  6. Platforms

We do not collect PI from data brokers.

C. Purposes for Collecting and Using Personal Information
We use Personal Information for the following business purposes:

  1. Providing, maintaining, and improving the Services
  2. Creating and managing user accounts
  3. Processing transactions
  4. Identity verification, KYC/KYB checks, and fraud prevention
  5. Customer support and communications
  6. Debugging, analytics, and service enhancement
  7. Security, incident detection, and compliance with law
  8. Enforcing our Terms and preventing illegal or harmful activities

We do not use Sensitive Personal Information for inferring characteristics about you.

D. Disclosure of Personal Information
We may disclose the categories of PI listed above to:

  1. Service Providers (identity verification platforms, payment processors, analytics providers, hosting vendors, Platforms)
  2. Affiliates
  3. Professional advisers (legal, compliance, audit)
  4. Government authorities or law enforcement, when required
  5. Successors in connection with corporate transactions

We do not sell Personal Information and do not share Personal Information for cross-context behavioral advertising.

E. Retention of Personal Information
We retain each category of PI only for as long as reasonably necessary to:

  1. Provide the Services
  2. Meet legal, regulatory, fraud-prevention, and compliance requirements
  3. Maintain business records

Retention periods vary depending on the category of data and legal obligations. Biometric data is retained only for the period required to complete identity verification or as otherwise required by law.

F. Your Rights Under the CPRA
California residents have the following rights:

  1. Right to Know / Access

    You may request that we disclose the categories and specific pieces of PI we have collected about you.
  2. Right to Delete

    You may request deletion of your PI, subject to legal exceptions.
  3. Right to Correct

    You may request that we correct inaccurate Personal Information.
  4. Right to Opt Out of “Sale” or “Sharing”

    Breeze does not sell or share Personal Information (including for cross-context behavioral advertising).
  5. Right to Limit Use of Sensitive Personal Information
    SPI is used only for identity verification, fraud prevention, security, and legal compliance. Because we do not use SPI for any other purpose, this right does not apply.
  6. Right to Non-Discrimination

    We will not discriminate against you for exercising your CPRA rights.

G. Submitting Requests
You may submit access, deletion, or correction requests by emailing:
privacy@breeze.cash.

To protect your information, we will verify your identity before processing your request.
Authorized agents may submit requests on your behalf if permitted by law.

13. Nevada Privacy Rights

If you are a Nevada resident, we do not “sell” personal information as defined in the Nevada Privacy of Information Collected on the Internet from Consumers Act as amended by Nevada Senate Bill 220. Nonetheless, you may submit a request to prohibit such sales by contacting us at privacy@breeze.cash. Additional information on the categories of personal information collected and categories of personal information shared with third parties can be found in this Privacy Policy. If you would like to tell us not to sell your information in the future, please email us at privacy@breeze.cash with your name, postal address, telephone number, and email address with “Nevada Do Not Sell” in the subject line.

14. Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at privacy@breeze.cash.