Privacy Policy

Last updated: 1 July 2026

At Breathfree3, we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share information about you when you use our platform and services ("Service").

This Policy complies with the EU General Data Protection Regulation (GDPR) (Regulation 2016/679) and the Dutch Implementation Act (Uitvoeringswet AVG), which apply to our processing of personal data.

This Privacy Policy is provided as a general guide and does not constitute professional legal or compliance advice. We recommend seeking independent expert guidance.

1. Who Is Responsible for Your Data?

Breathfree3 is the data controller responsible for your personal data. If you have any questions or concerns, please contact us:

Email: support@breathfree3.rolandb31.com
Country: Netherlands

2. What Data We Collect

2.1 Data You Provide to Us

Account information: Name, email address, password (stored in encrypted form), and business details when you register.
Billing information: Payment card details or payment account information. Note: full card details are processed and stored by our payment processor — we do not store your full card number.
Profile and content data: Any text, images, business information, or other content you upload or create using the Service (e.g., funnel content, brand details).
Communications: Messages you send us via email or support channels.

2.2 Data We Collect Automatically

Usage data: Pages visited, features used, clicks, session duration, and similar interaction data.
Device and technical data: IP address, browser type, operating system, device identifiers.
Cookies and similar technologies: See Section 9 (Cookies) below.

2.3 Data from Third Parties

If you connect a third-party account (e.g., social media, email marketing platform) to Breathfree3, we may receive limited data from that service in accordance with your settings and their privacy policies.

3. Why We Process Your Data and Our Legal Basis

Under the GDPR, we must have a lawful basis for processing your personal data. The table below explains what we do and why:

To create and manage your account — Legal basis: Performance of a contract (Article 6(1)(b) GDPR).
To process payments and manage billing — Legal basis: Performance of a contract (Article 6(1)(b) GDPR).
To provide, maintain, and improve the Service — Legal basis: Performance of a contract and legitimate interests (Article 6(1)(b) and (f) GDPR).
To provide AI-powered funnel building features — Legal basis: Performance of a contract (Article 6(1)(b) GDPR).
To send transactional emails (e.g., receipts, account notices) — Legal basis: Performance of a contract (Article 6(1)(b) GDPR).
To send marketing emails and product updates — Legal basis: Your consent (Article 6(1)(a) GDPR) or legitimate interests where permitted by Dutch electronic communications law (Telecommunicatiewet). You can opt out at any time.
To comply with legal obligations (e.g., tax, accounting records) — Legal basis: Legal obligation (Article 6(1)(c) GDPR).
To detect fraud and ensure security — Legal basis: Legitimate interests (Article 6(1)(f) GDPR).
To respond to your support queries — Legal basis: Legitimate interests and performance of a contract (Article 6(1)(b) and (f) GDPR).

4. Third-Party Processors

We share your personal data with trusted third-party service providers who process data on our behalf ("data processors"). They are contractually required to handle your data securely and only for the purposes we specify.

Payment processing: We use a third-party payment processor (such as Stripe or Mollie) to handle subscription billing. Your payment data is subject to their privacy policies and PCI-DSS security standards. We do not store full payment card details.
Email delivery: We use a third-party email service provider (such as Postmark, Mailgun, or similar) to send transactional and marketing emails.
AI functionality: Our AI-powered funnel building features are powered by third-party AI providers (such as OpenAI or similar). Content you provide to generate funnels may be processed by these providers. We ensure appropriate data processing agreements are in place.
Hosting and infrastructure: Our platform is hosted on third-party cloud infrastructure providers operating under appropriate data protection agreements.
Analytics: We may use analytics tools to understand how users interact with the Service.

Where third-party processors are located outside the European Economic Area (EEA), we ensure appropriate safeguards are in place (such as Standard Contractual Clauses approved by the European Commission) to protect your data in accordance with GDPR requirements.

5. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this Policy:

Account data: Retained for the duration of your subscription and for up to 2 years after account closure, to handle any post-termination queries or disputes.
Billing records: Retained for 7 years in accordance with Dutch accounting and tax law (Boek 2 BW).
Marketing consent records: Retained until you withdraw consent, plus a reasonable period to demonstrate compliance.
Support communications: Retained for up to 2 years after the query is resolved.
Usage and analytics data: Typically retained in aggregated or anonymised form after 12–24 months.

When data is no longer needed, we securely delete or anonymise it.

6. Your Rights Under the GDPR

As a data subject under EU/Dutch law, you have the following rights regarding your personal data:

Right of access (Article 15): You can request a copy of the personal data we hold about you.
Right to rectification (Article 16): You can ask us to correct inaccurate or incomplete data.
Right to erasure / "right to be forgotten" (Article 17): You can request deletion of your data in certain circumstances.
Right to restriction of processing (Article 18): You can ask us to restrict how we use your data in certain situations.
Right to data portability (Article 20): You can request your data in a structured, commonly used, machine-readable format.
Right to object (Article 21): You can object to processing based on legitimate interests, including direct marketing.
Right to withdraw consent (Article 7(3)): Where we process data based on your consent, you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to lodge a complaint: You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl.

To exercise any of these rights, please contact us at support@breathfree3.rolandb31.com. We will respond within one month of receiving your request, as required by GDPR.

7. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security reviews. However, no online service can guarantee absolute security.

8. Children's Privacy

The Service is not directed at children under 16 years of age. We do not knowingly collect personal data from children. If we become aware that we have done so, we will delete it promptly.

9. Cookies

We use cookies and similar tracking technologies on our website and platform. A cookie is a small text file stored on your device.

Types of Cookies We Use

Strictly necessary cookies: Essential for the Service to function (e.g., keeping you logged in). These do not require your consent.
Functional cookies: Remember your preferences and settings. Used with your consent.
Analytics cookies: Help us understand how users interact with the Service, so we can improve it. Used with your consent.
Marketing cookies: Used to show relevant advertising or track the effectiveness of marketing campaigns. Used with your consent.

When you first visit our website, we will ask for your consent to non-essential cookies through our cookie banner in accordance with the Dutch Telecommunications Act (Telecommunicatiewet) and GDPR. You can withdraw or change your cookie preferences at any time through the cookie settings link on our website.

You can also manage cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Service.

10. Links to Other Websites

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or prominent notice on the platform. The updated Policy will show the "Last updated" date at the top. We encourage you to review this Policy periodically.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Email: support@breathfree3.rolandb31.com
Country: Netherlands

Disclaimer: This Privacy Policy is provided as a general guide and starting framework only. It does not constitute professional legal, compliance, or data protection advice and has not been reviewed by a qualified lawyer or data protection officer. Breathfree3 strongly recommends that you engage an independent legal or privacy expert to review and finalise this Policy to ensure full compliance with applicable laws, including the GDPR and Dutch law, for your specific business circumstances.