FivePointFive is committed to protecting your privacy and legal rights. However, we normally need to process personal data about you in order to provide our apps and apps and services.

This Privacy Policy explains our policies and procedures regarding the collection, use, and sharing of your personal data when you use our apps and apps and services, and your rights in relation to it.

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1. Who we are

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The organisation that decides on how and why your personal data is processed (also known as the “Data Controller”) is:

FivePointFive Movement Limited

16 Great Queen Street

Covent Garden

London WC2B 5AH

United Kingdom

‍support@fivepointfive.com

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2. What types of personal data do we collect?

While using our apps and services, we may ask you to provide us with certain personal data as further explained below, which may include:

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2.1 Identification and account data:

When setting up your account we may ask for data that can be used to contact or identify you. This may include your:

We may also process data relating to your preferences and interactions with us, e.g.:

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2.2 Technical and Usage Data

Technical and usage data is collected automatically when you use our apps and services. Technical and usage data may include information relating to your device such as:

as well as information relating to your use of the services such as:

We also use cookies and similar technologies as referred to in Section 12 below.

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2.3 Health Data

With your consent, our services can integrate with various third-party health applications and wearable devices, including Apple Health, Apple Watch, WHOOP, and Oura Ring. These integrations allow us to access specific health data that you authorize, enabling personalized insights and tracking the positive impacts of breathwork exercises on your wellbeing.

We can collect and use the following types of data from your connected devices and health applications:

Provision of this data is always voluntary. However, without these metrics we may not be able to provide personalized feedback and insights on how breathwork exercises influence your physical well-being.

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3. Purposes for which we use your personal data

We may use personal data for the following purposes:

To provide and maintain our app and services: this includes the development and provision the services you have purchased, or other contracts with us through our apps and services.

To manage your account, registration, authentication, and access as a user of our apps and services: this enables us to give you access to functionalities of our apps and services reserved for registered users.

To contact you in relation to our apps and services: we may contact you by email, telephone, SMS, chat, or push notifications etc. with updates or service communications related to the functionalities, products or contracted apps and services, including security updates.

To manage your requests: to attend and manage your inquiries or customer services requests to us.

To process payments: we and our third party payment processors need to process your personal data in order to invoice, manage and collect payments for our apps and services.

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For the above purposes, our legal basis for the data processing is that it is necessary to perform our contract with you for our apps and services.

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To provide news, special offers and general information about other goods, apps and services and events which we offer that are similar to those that you have already purchased or enquired about. You always have the ability to opt not to receive such information.

For other purposes: We may use your information for purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our app and services, products, apps and services, marketing, and your experience.

Legal defence or actions: we may use your information where required to protect and defend our legal rights or property.

For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our app and services users is among the assets transferred.

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For these purposes, our legal basis for the data processing is that it is necessary for our legitimate interests in developing and managing our business, which do not conflict with your privacy rights and interests.

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Use of your Health Data: The health data we collect is used exclusively to:

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Our legal basis for process of data relating to your health is always your explicit consent. The provision to us of health data through third-party devices and applications is entirely voluntary and based on your explicit consent. Within our apps and services, you will find clear options to authorize the integration with your health data, manage your preferences, and revoke consent at any time.

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4. Sharing of your personal data

We may share your personal data with the following categories of recipients:

These recipients may be located inside and outside the UK, the European Union (with Iceland, Liechtenstein and Norway, the “EEA”), or Switzerland.

In the case of service providers, where they require access to data in order to assist us in providing our apps and services, they are not permitted to use such data for any other purpose. In each case we have in place written data processing contracts and where required additional safeguards that enable transfers from the UK, EEA or Switzerland to happen in a way that ensures that data is handled in accordance with similar standards to those applicable in those territories. These include: a decision from the relevant authorities indicating that the place of transfer or access has adequate data protection laws; and standard contract clauses approved by the relevant UK or EU authorities for other international transfers. A copy of these safeguards may be made available if we receive a valid request.

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5. Retention of your personal data

We will retain your personal data only for as long as is necessary for the purposes for which it was collected and as set out in this Privacy Policy, e.g. for as long as you have an account or a newsletter subscription with us. We may also need to retain and use your personal data to comply with our legal, recordkeeping and accounting obligations, resolve disputes, and enforce our agreements and policies.

We may retain technical and usage data for internal analysis purposes. As soon as possible, technical and usage data is retained in aggregated and anonymised form that cannot identify or be linked to any individual.

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6. Your Rights

At any time you can ask us to stop processing your personal data or to exercise other rights in relation to it, e.g.:

● to know what personal data about you we hold and access the personal data about you that we process

● to ask for errors in it to be corrected

● to ask for it to be erased (the “right to be forgotten”)

● if not erased (e.g. if it is required to be kept for legal reasons), then to ask us to restrict its processing

● to object to its processing for specific purposes

● to ask for a copy to take (or have us provide) to another data controller

● to limit use of sensitive personal data for any purposes that are not necessary to provide our apps and services.

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Under the laws applicable in your location you may have different or additional rights, e.g. to opt-out of any “sale” or “sharing” of your personal data with third parties or from targeted advertising. We do not sell or share your personal data with any third party for commercial purposes.

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We will not discriminate against you for exercising any of your legal  rights in relation to your personal data.

In general, provision of personal data is not necessary in order to access and use basic functionalities of our apps and services. However, managing your account and providing health-related insights and recommendations normally require the use of personal data, and some of these functionalities may not be available in full or in part if you do not provide data or have it deleted.

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Exercising your Rights:

Our app and services may give you the ability to update, correct or delete certain information about you, or delete your account, from within our apps and services. For any other requests, you should contact us as set out at the beginning of this Policy.

Where we process any personal data based on consent that you have given in the past, then you are always allowed to withdraw that consent at any time (though the processing that took place before withdrawal will still be legal).

Please note that in some circumstances we may not be able to fully comply with a request, e.g. where are required to retain data in order to comply with legal, accounting, tax, or recordkeeping obligations.

We are always available through the contacts at the beginning of this Policy to help resolve any issues or doubts you may have in relation to processing of your personal data. If you believe that your rights have not been respected at any time then you also have a right to complain to the Data Protection Supervisory Authority in your country to ask them for a resolution.

We may need to verify your identity in order to answer or action your request. Normally we would ask for a copy of an identify document that corresponds with personal data that we hold about you which we would use and retain only for this purpose and for as long as necessary in order to be sure that your request has been satisfactorily addressed.

You may designate an authorized agent to make a request on your behalf. To use an authorized agent, please provide us with written authorization or a power of attorney, and we may also require you to verify your identity directly with us.

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7. Additional information for California consumers

7.1 Personal Information Collected in the past 12 months

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7.2 Personal Information Sold or Shared in the past 12 months

We have not sold or shared Personal Information in the past 12 months.

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7.3 Personal Information disclosed for a business purpose in the past 12 months

We have disclosed the following categories of Personal Information for a business purpose in the past 12 months: (a) Identifiers; (b) Commercial information; (c) Internet or other electronic network activity information; (d) Geolocation Data; (e) Sensitive Personal Data; and (f) Professional or employment-related information.

These business purposes comprise:

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8. Children's Privacy

Our app and services are not intended for anyone under the age of 13. We do not knowingly collect personal data from anyone under the age of 13. If you are a parent or guardian and you believe that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 (or the legal age under applicable local laws) without verification of parental consent, we will take steps to delete that information.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, We may require your parent's consent before we collect and use that information.

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9. Links to Other Websites

Our app and services may contain links to other apps or websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. Their privacy policies and practices are not within our control and may differ from ours, so please review them when visiting those sites.

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10. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page or in any other convenient way e.g. through our apps.

It is recommended to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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11. Business contacts

If you are or work for someone that we deal with in our business, including suppliers of goods or services (or potential suppliers), investors (or potential investors), and any other business contacts such journalists or influencers, we may store and process personal data needed for managing our relationship with you or your organization which may include: your name, organization name, position, professional qualifications or interests, mailing address, website, telephone numbers, e-mail addresses, details of products and services, payment information, and information provided to us in the course of correspondence with you (e.g. by email, phone, or messaging). Our legal basis for this data processing is that it is necessary for our legitimate interests which are not outweighed by your privacy rights and interests. As this data always relates to your professional life, its processing should have minimal privacy impact. You have the same rights as other individuals which can be exercised by contacting us as set out at the beginning of this Policy, although we may need to continue to process data in order to maintain our relationship with your organisation and the delivery of products and services.

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12. Cookie Policy

We use cookies and similar tracking technologies to track the activity on our app and services and store certain information.

A cookie is a small piece of data sent from website or application and stored in a user’s device. Every time the user loads the website or application, the device can send information back to the server to indicate that it recognizes the user.

You can find more information about different types of cookies here: TermsFeed article.

Use of cookies helps us to improve our apps and services and to deliver a better and more personalized service by enabling us to:

Some cookies are essential in order to deliver the services you have requested or to set up communications with us. You may refuse to accept non-essential cookies and tracking when downloading opening the app. You can also remove cookies from your device within the applicable settings. If you clear all cookies then some features of our apps and services may not work as expected or at all, or you may need to accept some cookies when starting your next session.