Privacy Policy
1. Privacy Notice
1.1 Who we are
BreezyTM (“Breezy”, “we”, “us”) is an early-stage technology company focused on well-being and
social-connection solutions. We operate the website https://breezy.love (the “Site”).
1.2 Scope of this Notice
This notice explains how we collect, use, store and share personal data when you:
- browse or interact with the Site,
- contact us by e-mail, form or social media, or
- participate in Breezy-led activities that relate to the Elifinity Impact Fund and its portfolio of partnering
ventures (collectively, the “Elifinity ecosystem”).
Important distinction – Elifinity Impact Fund and each portfolio company are independent data controllers.
Breezy shares limited personal data with them only for clearly defined collaboration purposes, as described
below. They provide their own privacy notices for any processing they carry out on their own behalf.
1.3 What personal data we collect
Category
Technical & Usage
Contact details
Communications
Examples
IP address, browser type, device IDs,
pages visited, time spent
Name, e-mail address, organisation, country
Messages, meeting notes, feedback
Source
Collected automatically via server logs and essential cookies
Provided voluntarily in contact forms or correspondence
You or representatives of the Elifinity ecosystem when you interact with Breezy
1.4 Legal bases for processing
Purpose
Operating, securing and improving the Site
Responding to enquiries
Collaboration within the Elifinity ecosystem
GDPR legal basis
Legitimate interests (Art. 6 (1)(f))
Consent (Art. 6 (1)(a))
Legitimate interests; balancing test available on request
revFADP justification
Art. 31
Art. 6
Art. 31
1.5 How we use your data
- Provide and maintain the Site.
- Respond to questions or meeting requests.
- Facilitate collaboration with the Elifinity Impact Fund and its portfolio ventures (e.g., scheduling joint
demo sessions, sharing anonymised performance metrics). - Detect, prevent and investigate security incidents.
1.6 Sharing & disclosure
We disclose personal data only:
Recipient
Service providers
(hosting, IT security, e-mail)
Elifinity Impact Fund &
portfolio ventures
Legal or regulatory
bodies
Why
To operate the Site
To coordinate ecosystem
activities in which you have
chosen to participate
Where required by law or to
protect rights
Safeguards
Data-processing agreements; access limited to necessity
Confidentiality undertakings; each partner acts as a separate controller and must provide its own privacy information
Only to the extent legally necessary
We never sell, lease or trade personal data.
Recipient
Service providers
(hosting, IT security, e-mail)
Elifinity Impact Fund &
portfolio ventures
Legal or regulatory
bodies
Why
To operate the Site
To coordinate ecosystem
activities in which you have
chosen to participate
Where required by law or to
protect rights
Safeguards
Data-processing agreements; access limited to necessity
Confidentiality undertakings; each partner acts as a separate controller and must provide its own privacy information
Only to the extent legally necessary
1.7 International transfers
Where data leaves Switzerland or the EEA we rely on adequacy decisions or the European Commission Standard
Contractual Clauses (SCCs) with additional safeguards when appropriate.
1.8 Data retention
We keep personal data only as long as necessary for the purposes above or to meet legal obligations, then
delete or anonymise it.
1.9 Security
Industry-standard technical and organisational measures protect the data, including encryption in transit,
least-privilege access controls and periodic security testing.
1.10 Your rights
Right
Access, rectification, erasure
Restrict or object
Data portability
Withdraw consent
Lodge a complaint
GDPR articles
15, 16, 17
18, 21
20
7 (3)
77
revFADP articles
25, 32
30
28
6 (6)
49
To exercise a right, contact us at privacy@breezy.love.
1.11 Supervisory authorities
- Switzerland – Federal Data Protection and Information Commissioner (FDPIC), www.edoeb.admin.ch
- European Union – Your local EU data-protection authority
1.12 Children
The Site is not directed to individuals under 16. We do not knowingly collect children’s data.
1.13 Changes to this notice
Updates will appear here with a new “Last updated” date. Significant changes will be signposted on the Site.
1.14 Contact
Data Protection Contact / DPO
BreezyTM
E-mail: privacy@breezy.love
Last updated: 1st August 2025
2. Internal GDPR-Compliance Rules (updated)
- Record of Processing Activities (RoPA) – Maintain a living inventory (Art. 30 GDPR / Art. 12 revFADP).
- Privacy by Design & Default – Embed data-minimisation and risk assessments at each product stage
(Art. 25 GDPR). - Data-Protection Impact Assessments (DPIA) – Required for any high-risk processing or advanced
analytics. - Third-Party Due Diligence & Contracts – Processors must give adequate guarantees; SCCs for extra-EEA
transfers. - Data-Subject Request Procedure – 30-day turnaround with ID verification.
- Incident Response & Breach Notification – 72-hour rule to FDPIC and, if applicable, EU authorities
(Arts 33–34 GDPR / Art. 24 revFADP). - Cookie & Tracking Compliance – Consent banner only if non-essential cookies are introduced; keep
auditable consent logs. - Training & Awareness – Annual privacy training for anyone with data access.
- Continuous Review – Audit security and privacy controls yearly or after major changes.
- Partner-Data Rule – Personal data may be shared with Elifinity Impact Fund and its portfolio ventures
only for agreed collaboration purposes, under written confidentiality, and never sold or disclosed
externally without a new legal basis and explicit consent. Each partner remains responsible for its own compliance.
© 2025 Breezy. All Rights Reserved.
