Privacy Policy

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Elite Breathing Ltd – Privacy Policy

Last Updated: October 2025

Introduction and Scope

This Privacy Policy explains how Elite Breathing Ltd (“we,” “us,” “our”), located at 3239 Green Lake Drive, Fort Collins, CO 80524, collects, uses, shares, and protects your personal information when you use the Elite Breathing mobile application (“App”). By using the App, you agree to the practices described here. We comply with applicable laws, including GDPR, CCPA, and COPPA. We may update this Policy; continued use means you accept the changes.

Information We Collect

We collect information you provide, data generated through App use, and data from third parties.

  • Personal Information: Name, email address, profile picture, age/minor status (under 18 or not), sport, position, level of play, and similar profile details.
  • Assessment and Progress Data: Breath assessments, protocol progress, breath snapshot, daily habits check, breath health screen data, bootcamp progress, quiz scores.
  • Journal and Content Data: Personal journal entries and notes. IMPORTANT: Journals and private messages are never used for advertising, model training, or public research.
  • Communication Data: Messages sent via the App, consultation booking information, and support communications.
  • Payment Information: Processed securely by Stripe. We do not store full card details.
  • Usage and Analytics Data: Feature usage, session duration, device info, IP address, crash/performance data. For users under 18, behavioral profiling and non‑essential tracking are restricted.
  • Location Data: General (country/region). No precise GPS collection.
  • Technical Data: App version, device specs, network info.

How We Use Your Information

  • Service Provision: Operate App features, generate personalized protocols, track progress, deliver educational content.
  • Personalization: Adapt content and recommendations. Users under 18 and institutions may opt out of non‑essential personalization.
  • Payment Processing: One‑time premium purchase through Stripe.
  • Communication: Notifications, reminders, important App updates, and support responses.
  • Consultations: Scheduling and managing complimentary consultations (Calendly).
  • Advertising: Ads may be shown only to adult users (18+) in the limited free version. Users under 18 do NOT see ads. School/team accounts do not see ads.
  • Analytics and Improvement: Analyze usage and improve functionality using aggregated/de‑identified data.
  • Legal Compliance: Meet legal/regulatory obligations (including FERPA where applicable).
  • Security/Fraud Prevention: Protect the App, our users, and our business.
  • Research & Development: Use de‑identified/aggregated data only. We never use journals, messages, or health screening data for model training or public research. Users and institutions can opt out of non‑essential R&D.

Legal Basis for Processing (GDPR)

  • Contract Performance
  • Legitimate Interests (improvement, analytics, security)
  • Consent (marketing, non‑essential tracking)
  • Legal Obligation
  • Vital Interests (where applicable)

Information Sharing and Disclosure

We may share information as follows:

Third‑Party Service Providers (used only for their stated purposes):

  • Coaches/Training Partners: Only when you explicitly choose to share. You control what is shared and can revoke access at any time (see 5A).
  • Legal Requirements: As required by law or to protect rights and safety.
  • Business Transfers: As part of mergers, acquisitions, or similar.
  • Consent: With your explicit consent or at your direction.
  • Aggregated/De‑Identified Data: For analytics, reporting, and research that cannot identify you.

We do not sell personal information for marketing purposes.

5A. Coach and School Data Sharing Controls
  • Shared by Default (when you connect to a coach/team): Assessments, assigned protocols and completion status, exercise progress, bootcamp progress/scores.
  • Not Shared by Default (requires opt‑in): Journals/notes, private messages, health screening/medical info, payment status.
  • Access Controls & Audit Logs: Role‑based least privilege; all access is auditable. You can revoke coach/team access at any time.
  • Transparency & Consent: Clear, granular disclosure and explicit consent before sharing.
  • Institutional Accounts: FERPA‑aligned protections apply when a school/university deploys the App (see Section 14).

Data Storage, Security, and Retention

We implement technical/organizational measures to protect your information:

  • Security Standards: Industry‑standard encryption, access controls, and safeguards aligned with GDPR and HIPAA‑level security practices.
  • Encryption: TLS in transit, AES‑256 at rest.
  • Access Controls & Monitoring: Strict access, authentication, logging, and continuous monitoring.
  • Data Minimization: Only collect/retain what’s necessary.
  • Retention:
  • Account Information: Retained while account is active and for 3 years after deletion for compliance.
  • Assessment/Progress Data: 7 years (for users under 18, retained for 3 years unless longer required by institutional contract).
  • Payment Records: 7 years (tax/accounting).
  • Communications: 3 years (support/legal).
  • Analytics Data: 2 years (aggregated form).
  • Consultation Recordings: 90 days by default (or per institutional contract). Users may request earlier deletion unless legally required to retain.
  • Institutional Contracts: Schools may negotiate custom retention schedules.

Upon account deletion, we remove personal information from active systems within 30 days (except where lawful retention applies).

Your Data Protection Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, port, object, and withdraw consent. We respond within applicable timelines (e.g., GDPR: 1 month, CCPA: 45 days). For under‑13 users, verifiable parental consent is required.

Cookies and Tracking Technologies

  • Essential Cookies: Required for functionality and security.
  • Analytics Cookies: For adult users; limited/essential only for minors. Can be disabled (adults).
  • Advertising Cookies: Only for adult users (18+) on the limited free tier; minors and school/team accounts do not receive advertising cookies.
  • Preferences: Save app settings and customizations.

International Data Transfers

We transfer data in compliance with applicable laws using adequacy decisions, Standard Contractual Clauses, internal safeguards, or consent where appropriate.

Children’s Privacy and Enhanced Minor Protections

  • Under 13: COPPA compliance with verifiable parental consent; minimal data collection.
  • Ages 13–17: Enhanced safeguards beyond COPPA: no personalized ads, no behavioral profiling, restricted data sharing (explicit opt‑in), stronger default privacy, shorter retention.
  • No Ads for Minors: Users under 18 do not see ads.
  • School/Team Accounts: Additional institutional protections apply (see Section 14).
  • Data Deletion: We promptly delete data improperly collected from minors.

Data Breach Notification

If a breach poses risk to rights/freedoms, we notify authorities within required timelines (GDPR: 72 hours) and affected users without undue delay, explaining the nature of the breach and mitigation steps.

Automated Decision‑Making

The App may use automated processing to generate protocols, make recommendations, analyze usage, and detect fraud. You may request human review of any decision that significantly affects you and contest such decisions.

Third‑Party Links and Services

Our Policy does not apply to third‑party services you access via links; review their policies before using them.

FERPA Compliance for Educational Institutions

When an educational institution deploys the App for students, we act as a “school official” under the institution’s control. We sign FERPA‑aligned Data Processing Addendums specifying:

  • The school is the data controller of education records;
  • Data is used solely for authorized educational purposes;
  • No use for advertising, marketing, or non‑educational profiling;
  • Appropriate safeguards are maintained;
  • Parents/eligible students can review/correct records through the institution;
  • Data is returned or deleted upon contract termination or request.

Changes to This Privacy Policy

We may update this Policy to reflect changes in practices, law, or functionality. We will notify you via in‑app notice, email, and/or by posting the updated Policy with a new “Last Updated” date. If you do not agree, you must stop using the App and may delete your account.

Contact Information and Data Protection Officer

Elite Breathing Ltd
Email: coachjoe@elitebreathing.com
Address: 3239 Green Lake Drive, Fort Collins, CO 80524, United States
Support Hours: Monday–Friday, 9:00 AM–5:00 PM MT (excluding holidays)

If you are unsatisfied with our response, you may lodge a complaint with your local data protection authority.

Thank you for trusting Elite Breathing to support your athletic performance and breathing wellness.