BREEZOMETER PRIVACY POLICY

Last Updated: July 28, 2020

In order to ensure transparency and give you more control over your Personal Information (as defined below), this privacy policy (“Privacy Policy”) governs how we, Breezometer Ltd. (together, “Breezometer” “we”, “our” or “us”) use, collect, and store Personal Data (as defined below) we collect or receive from or about you ( “you”) such as in the following use cases:


  • When you browse or visit our website, http://www.breezometer.com ( “Website”)
  • When you make use of, or interact with, our Website
    • When you create an account and log in (API login) to the account dashboard
    • When you request an evaluation
    • When you subscribe to receive monthly updates about air quality and the internet of things
    • When we process your job application
    • When you contact us (e.g. customer support, need help, submit a request)
    • When you use the Livemap feature

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.


Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of content


This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.


1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific Personal Data we collectWhy is the Personal Data collected and for what purposes?Legal basisThird parties with whom we share your Personal DataRetention periodConsequences of not providing the Personal Data
When you browse or visit our Website
Cookies, analytic tools and log files. For more information, please read our cookies policyFor marketing, analytics and statistics purposes.Consent Legitimate interest (e.g., essential cookies)3rd party platforms such as for the following purposes:
  1. Google Analytics (analytic tool)
  2. Hubspot (CRM tool)
  3. LinkedIn (Ad Campaigns and referral traffic to site)
  4. Facebook (ad campaigns and referral traffic to site)
  5. Doubleclick (ad campaigns)
  6. Google (ad campaigns)
For more information, please read our cookies policyCertain Website features may not be available Read more about the purposes of each cookie here
When you make use of, or interact with, our Website
When you create an account and when you log in (API login) to the account dashboard
  1. Full name
  2. Work email address
  3. Password
  4. Company URL
  5. Any other information you may provide for us
  1. To be able to create an account
  2. To be able to log in to the account dashboard
  3. To be able to enjoy features available to registered users only
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.Legitimate interest (e.g. to log into the service).3rd party platforms such as for the following purposes:
  1. Hubspot Marketing Hub Professional - CRM and Marketing Automation
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.Cannot create an account Cannot log in Cannot enjoy all the features
When you request an evaluation
  1. Full name
  2. Work email address
  3. Company name
  4. Vertical
  5. Company URL
  1. To provide you with an evaluation of our product/services
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to provide an evaluation)3rd party platforms such as for the following purposes:
  1. Hubspot Marketing Hub Professional - CRM and Marketing Automation
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.Cannot provide you with an evaluation
When you subscribe to receive monthly updates about air quality and the internet of things
  1. Email addresses
  2. Full name
  1. To send you monthly updates with information about how air pollution can affect you and updates regarding how environmental insights can improve the health of billions.
Consent Legitimate interest (e.g. to allow you to post in our blog)3rd party platforms such as for the following purposes:
  1. Hubspot Marketing Hub Professional - CRM and Marketing Automation
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.Cannot email you our monthly update
When we process your job application
  1. Full name
  2. Email address
  3. Phone number
  4. Department/position
  5. CV and cover letter
  6. Any other information you choose to share with us
  1. To process your job application
  2. To review your application
  3. To assess you as a candidate
  4. To analyze your application
  5. To communicate with you in connection with your job application
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to process your job application)3rd party platforms such as for the following purposes:
  1. Hubspot Marketing Hub Professional - CRM and Marketing Automation
  2. Gsuit for scheduling interviews and contacting user
1-year after the process has concluded or until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.Cannot process your job application Cannot review your application Cannot assess you as a candidate Cannot analyze your application Cannot communicate with you in connection with your job application
When you contact us (e.g. customer support, need help, submit a request)
  1. Full name
  2. Email address
  3. Company URL and work email address
  4. Industry
  5. Any other information you choose to share with us
  1. To process your request
  2. To provide you with assistance
  3. To respond to your query
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to respond to a query sent by you)3rd party platforms such as for the following purposes:
  1. Hubspot Marketing Hub Professional - CRM and Marketing Automation
Until you send a deletion request or unsubscribe or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.Cannot process your request Cannot provide assistance Cannot respond to your query
When you use the LiveMap feature
  1. Geo-location data
  2. IP address
  1. To provide you with information about air quality and exposure in the place that you are located
  2. Provide alerts about fires around you.
Consent Legitimate interest (e.g. to allow you to access location specific information)3rd party platforms such as for the following purposes:
  1. Mapbox - map loads for web
  2. Openstreetmap-Nominatim - a tool for geocoding and reverse geocoding
  3. Sisense - Sisense Business Intelligence and Analytics software
IP address not stored Geolocation data not storedCannot provide you with air quality and exposure information Cannot send you location specific air quality alerts Cannot send you alerts about fires around you Cannot collect air quality data in order to update your personal exposure

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1 Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.


2.2 Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:


3.1 With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.


3.2 To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;


3.3 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;


3.4 In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or


3.5 Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Storage: We store our data in Hubspot CRM. The HubSpot platform is hosted in data center providers in the US - Amazon Web Services in the US-East-1 region.

Google Cloud Platform - data stored here is located in the US.


4.1 Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en


4.2 Internal transfers:Transfers within the Breezometer Group will be covered by an internal processing agreement entered into by members of the Breezometer Group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.


4.3 External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

5.1 Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

  • You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.


You can exercise your rights by contacting us at privacy@breezometer.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.


5.2 Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@breezometer.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@breezometer.com.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • Facebook Custom Audience
  • Lookalike Audience
  • Advertising Partners. Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

We reserve the right to remove or add new analytic tools.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

10.1 Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.


10.2 Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.


California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@medigate.io. Please note that we will respond to one request per customer each year, unless otherwise required by law

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@breezometer.com.