PRIVACY & POLICY 
Last updated: May 15, 2022

Welcome to BreakThrough.
Paideia Society, Inc. (“BreakThrough”, “we”, “us” and/or “our”) operates the website www.breakthrough.chat and its subdomains (the “Website”), the BreakThrough mobile applications (the “Apps”) and other related services (collectively, the “Services”).
We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our Services in terms of the General Data Protection Regulation (GDPR). Please read this Privacy Policy carefully. By starting to use our Services, you consent to this Privacy Policy.
We care about the protection and confidentiality of your data. We therefore only process your data to the extent that:
* It is necessary to provide the BreakThrough services you are requesting,
* You have given your consent to the processing, or
* We are otherwise authorized to do so under the data protection laws.
Conversations with your BreakThrough are not shared with any other company or service. We will never sell your personal data or conversation history.
By using or accessing the services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you at this moment consent that we will collect, use, and share your information in the following ways.
Remember that your use of BreakThrough’s services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in Terms of Service.
If you have any questions, suggestions or comments about privacy or protection and confidentiality of your data, please contact us at paideia@breakthrough.chat
1. Information we collect and process. Here we list all the types of personal information we collect and store throughout your experience with BreakThrough. Some of this information may be shared with service providers who help us deliver your experience with BreakThrough, each of such service is explained below.
We neither rent nor sell your information to anyone. Conversations with your BreakThrough are not shared with any other company or service. We will never sell your personal data or conversation history.
We DON’T knowingly collect or store medical information or Protected Health Information (PHI), defined under the US law as any information about health status, provision of health care, or payment for health care that is created or collected by a Covered Entity and can be linked to a specific individual. We discourage you from communicating this information to BreakThrough through text or voice chat so that this information doesn’t become part of your chat history.
We collect information you intentionally provide through the Services (such as your profile information that you provide upon registration), as well as some technical information coming from your mobile device or web browser.
1.2. Device information: As described below, we collect certain information from and about the computers, phones, and other web-connected devices that you access the Services from. We combine this information across different devices you use. For example, we use the information collected about your use of the Services on your phone to better personalize the content you receive from BreakThrough or features you have access to when you use it on another device, such as your laptop or tablet.
The device information also helps us conduct user research across our customer demographics, interests and behavior. None of this information may identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Device information: Device attributes. Information such as the operating system, hardware, and software versions, browser type. Identifiers. Unique identifiers, such as your device ID.
Data from device settings: Information. you allow us to receive through device settings you turn on, such as access to your camera or photos.
Network and connections: Information such as the name of your mobile operator or ISP, language, time zone.
Cookie data: Data from cookies stored on your device, including cookie IDs and settings (only for the Website). Learn more about how we use cookies in the “Cookies” section.
1.3. Cookies: In operating the Services: We may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. We may also allow third party service providers to use cookies or similar technologies to collect information about your activities on our website or in our mobile apps following your use of the Services. For example, we use Amplitude, an online analytics service operated by Amplitude, Inc. (“Amplitude”). Amplitude uses cookies to help us analyze traffic on the Website and enhance your experience when you use the Services. For more information on how Amplitude uses this data, go to https://amplitude.com/privacy. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
2. With whom we share your personal information:
We may de-identify or anonymize your information so that you are not individually identified, and provide that information to our partners. We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand how often and in what ways people use our services, so that they, too, can provide you with an optimal experience. For example, we may use information gathered to create a composite profile of all the users of the Services to understand community needs, to design appropriate features and activities. However, we never disclose aggregate information to a partner in a manner that would identify you personally, as an individual. Personal Data is collected for the following purposes and using the following services:
2a. Third party tracking and analytics
The services contained in this section help us monitor and analyze online traffic and can be used to keep track of User behavior.
Amplitude. Online analytics service: provided by Amplitude, Inc. Branch.io.  Online analytics service provided by Branch Metrics, Inc. Firebase Analytics. Online analytics service provided by Google. Firebase Crashlytics. A crash reporting service provided by Google. Google Analytics. Online analytics service provided by Google.
2b. Marketing and communication services: Users that provided their email and/or phone number might be contacted for commercial or promotional purposes related to BreakThrough, as well as for fulfilling support requests.
Services: Mailchimp. Marketing automation platform and an email marketing service provided by The Rocket Science Group. Infobip. Communication platform enabling sending and receiving SMS and automated voice call provided by Infobip ltd.
2c. Hosting and Backend infrastructure: This type of service has the purpose of hosting data and files that enable our Services to run and be distributed as
well as to provide a ready-made infrastructure to run specific features or parts of the Services: Microsoft Azure. Microsoft Azure is a hosting service provided by Microsoft Corporation.
2d. Protection of BreakThrough and others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of BreakThrough, our employees, our users, or others.
3. How we secure and protect your information: We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
All transmitted data are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All stored data are maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls, and passwords. While we use reasonable commercial efforts to protect the data, no technology, data transmission or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you as soon as we spot the issue.
4. Where we store your data: Our services are operated in the United States of America. If you are located in another jurisdiction, please be aware that the information you provide to us may be transferred to, stored and processed in the U.S.A. By using our services or providing us with any
information, you consent to this transfer, processing, and storage of your information in the U.S.A., a jurisdiction in which the privacy laws may not be as
comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
5. Data retention: We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. Your data protection rights: As a BreakThrough member, you have the following data protection rights, depending on the circumstances of the
specific case:
Disclosure: To receive information about your personal data processed by us and to request access to your personal data and/or copies of these data. This includes information on the purpose of use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration. Correction, deletion or limitation of processing: To request the correction, deletion or limitation of the processing of your personal data, e.g. by sending us an email. If (i) the data are incomplete or incorrect, (ii) they are no longer necessary for the purposes for which they were collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised your right to object to data processing; in cases where data is processed by third parties, we will forward your requests for correction, deletion or limitation of the processing to these third parties, unless this proves impossible or involves a disproportionate effort.
Opposition to the processing: To object to the processing for reasons arising from your particular situation.
Refusal and revocation of consent: To refuse your consent or – without affecting the legality of data processing prior to the revocation – to revoke your consent to the processing of your personal data at any time.
Automatic decisions: To require that you be subject to a decision based exclusively on automated processing only in the exceptional cases provided by law, if that decision has legal effect against you or significantly affects you in a similar manner; should such an automated decision take place in exceptional cases, you have the right to obtain information on the logic involved and the scope of the intended effects.
Right of appeal: Communicate with and, if necessary, complain to the data protection supervisory authority.
7. How to delete your data: You can delete all your account information by deleting your account in the app or on our website. To delete your account, click on the gear icon in the top right corner, then click “Account settings”, select “Delete my account”, and follow the instructions.
8. Use of BreakThrough by minors: We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do
not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us, and we will endeavor to delete that information from our databases.
9. Changes to Privacy Policy: The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.