Privacy Policy

1. Introduction and White Label Identity Disclosure

Important disclosure regarding white-label deployments. Breez AI’s Services may be accessed through applications or websites operated by third-party grocery retailers (“Retailers”) under the Retailer’s own brand name or under a separate brand name designated by the Retailer. Regardless of the brand name or visual presentation under which the Services appear, Breez AI is a separate and independent company from any such Retailer. Breez AI is the data controller — or, depending on applicable law, a separate data controller or a service provider — with respect to the personal data it collects and processes in connection with the Services. This Privacy Policy governs Breez AI’s own data practices and is distinct from any privacy notice or policy published by the Retailer. Users should also review the Retailer’s privacy policy to understand the Retailer’s independent data practices.

2. Definitions

For purposes of this Privacy Policy:

“Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household. Personal Data includes, without limitation, identifiers such as name, email address, and account credentials; health and nutrition data; dietary preferences and restrictions; inferences drawn from any of the foregoing; and any other information that constitutes “personal information,” “personal data,” or an equivalent term under applicable law.
“Sensitive Personal Data” means a subset of Personal Data that warrants heightened protection under applicable law or under this Policy, as further described in Section 5 below.
“Services” means the AI-powered meal planning, recipe suggestion, nutrition analysis, calorie tracking, and related features and functionalities provided by Breez AI, whether accessed through Breez AI’s own interfaces or through a Retailer’s application or website. Services also may include outbound communications on behalf of Retailers and their third-party loyalty program providers about coupons and other offers to their customers and members. Often these services are provided on a “white-label” basis under the name and/or brands of the Retailer, loyalty program provider or other third parties as directed by the Retailer.
“Retailer” means any third-party grocery retailer that has entered into an agreement with Breez AI to embed or otherwise make available the Services within the Retailer’s digital properties. The definition of Retailer as used herein includes any loyalty program provider separately retained by a third-party grocery retailer.
“AI-Generated Inferences” means conclusions, predictions, recommendations, or other outputs produced by Breez AI’s artificial intelligence and machine learning systems based on data provided by or derived from a user’s interactions with the Services.

3. Scope of This Policy

This Privacy Policy applies to Personal Data collected by Breez AI in connection with the Services, including data collected through any Retailer-branded interface through which the Services are made available. It does not govern the data practices of any Retailer, loyalty program provider, wearable device manufacturer, or third-party health platform, each of which maintains its own privacy practices. Breez AI is not responsible for the privacy practices of those third parties.

4. Data We Collect

Breez AI may collect the following categories of Personal Data in connection with the Services:

4.1 Account and Contact Information

Breez AI may collect information you provide when creating an account or profile, such as name, email address, username, password, and, where applicable, billing information. Breez AI may also collect information you provide when contacting customer support.

4.2 Dietary Preferences, Restrictions, and Goals

Breez AI may collect information about your dietary preferences, eating habits, food dislikes, and nutritional goals, including information you enter directly into the Services or that is derived from your use of the Services. This may include preferences such as vegetarian, vegan, pescatarian, or other dietary patterns, as well as specific nutritional goals such as weight loss, weight maintenance, muscle gain, or management of a specific dietary condition.

4.3 Health Metrics

Breez AI may collect health-related metrics you choose to provide, such as height, weight, body mass index (BMI), age, biological sex, calorie targets, macronutrient targets, and other body composition or metabolic data. This information is used to personalize meal plans, recipe suggestions, and nutritional analysis.

4.4 Allergen and Intolerance Information

Breez AI may collect information about food allergies, food intolerances, and sensitivities you disclose when configuring your profile or using the Services. This category of data may include, for example, nut allergies, gluten intolerance, lactose intolerance, shellfish allergies, and similar conditions.

4.5 Religious and Cultural Dietary Practices

Breez AI may collect information about religious or cultural dietary practices that you voluntarily provide, such as kosher, halal, or other faith-based or culturally specific dietary requirements. This category of data is treated as Sensitive Personal Data and is subject to the heightened protections described in Section 5.

4.6 Meal Plan Inputs and Recipe Interactions

Breez AI may collect data about how you interact with the Services, including meal plans you generate or customize, recipes you view, save, rate, or share, ingredient substitutions you make, and feedback you provide about suggested content.

4.7 Purchase History Received from Retailer

Where you use the Services through a Retailer’s platform and have consented or where otherwise permitted under applicable law, the Retailer may provide Breez AI with data regarding your grocery purchase history. This data may include items purchased, purchase frequency, and spending patterns. Breez AI may use this data to personalize meal plans, recipe suggestions, and nutritional analysis.

4.8 AI-Generated Inferences

Breez AI’s artificial intelligence and machine learning systems may generate inferences about your health status, nutritional habits, lifestyle patterns, dietary compliance, risk factors related to food choices, and other characteristics based on the data you provide and your interactions with the Services. These AI-Generated Inferences are themselves Personal Data and, in many cases, Sensitive Personal Data. See Section 5.

4.9 Technical and Usage Data

Breez AI may collect technical information about your device and your use of the Services, including IP address, device identifiers, browser type and version, operating system, referring URLs, pages viewed, features used, time spent within the Services, and crash or error data.

4.10 Data Provided by Retailers and Loyalty Program Providers

In addition to purchase history described in Section 4.9, a Retailer or its contracted loyalty program provider may provide Breez AI with other information about you, such as account identifiers, loyalty program membership identifiers, reward balances, or demographic information, subject to the terms of the agreement between Breez AI and the Retailer and applicable law.

4.11 Contact and Consent Data for Outbound Communications

Where Breez AI sends personalised communications on behalf of a Retailer, Breez AI collects the recipient’s email address, name where available, loyalty identifier, and marketing consent status from the Retailer or its contracted loyalty programme provider. See Section 11.

5. Sensitive Personal Data

Certain categories of Personal Data collected in connection with the Services are inherently sensitive because they may reveal, or may be used to infer, information about an individual’s health, medical conditions, disabilities, or religious beliefs. Breez AI treats the following categories as Sensitive Personal Data:

Allergen and intolerance information, which may indicate underlying medical conditions or disabilities;
Religious and cultural dietary practice data, which may reveal religious affiliation or belief;
Health metrics, including weight, BMI, and calorie-related data, which may indicate medical conditions, health status, or disability;
AI-Generated Inferences related to health, metabolism, dietary compliance, or lifestyle, which may reveal or be used to infer medical or health information;
Data received from connected wearables or health applications that relates to a user’s health or physical condition; and
Dietary goal information that, taken together with other data, may indicate a medical diagnosis, treatment, or condition.

Breez AI applies heightened security and access controls to Sensitive Personal Data. Breez AI does not sell Sensitive Personal Data. Breez AI does not use Sensitive Personal Data for cross-context behavioral advertising unrelated to your dietary needs. However, Breez AI and its Retailer and loyalty program partners may use your dietary preference data — including religious, cultural, and health-related dietary preferences — to present product recommendations, offers, and targeted advertising that are directly relevant to and consistent with your stated dietary needs. For example, if you indicate that you follow a kosher diet, Breez AI and its partners may surface kosher-certified products and relevant offers. This use of dietary preference data for relevant food and grocery recommendations is a core feature of the Services. You may opt out of personalized advertising as described in Section 13 (Privacy Choices and Rights). Breez AI obtains consent before processing Sensitive Personal Data for purposes beyond those reasonably necessary to provide the Services, to the extent required by applicable law.

6. How We Use Personal Data

Breez AI may use Personal Data for the following purposes:

6.1 Providing and Personalizing the Services

Breez AI uses Personal Data, including dietary preferences, health metrics, allergen information, cultural or religious practices, and AI-Generated Inferences, to generate personalized meal plans, recipe suggestions, and nutritional analyses tailored to each user’s profile. AI and machine learning systems are integral to this personalization and are not optional features — they are core to how the Services function.

6.2 Nutrition Analysis and Calorie Tracking

Breez AI uses Personal Data to analyze nutritional content of meals and recipes, track caloric intake against user-defined targets, and provide feedback on nutritional balance and goal progress.

6.3 AI Model Training and Improvement

Breez AI may use user interaction data, dietary preference data, recipe feedback, and meal plan data to train, validate, and improve the artificial intelligence and machine learning models that power the Services. Where required by applicable law, Breez AI will seek appropriate consent before using Sensitive Personal Data for model training purposes. Users may have the right to opt out of certain uses of their data for model training; see Section 13 (Privacy Choices and Rights).

6.4 Communication and Support

Breez AI may use contact information to respond to user inquiries, provide customer support, and send transactional communications related to the Services. Breez AI also sends personalised marketing communications, including to Retailer loyalty members who may not hold a Breez AI account; the basis for those communications and the means of withdrawing consent are described in Section 11.

6.5 Safety and Allergen Alerts

Breez AI may use allergen and intolerance data to filter recipe suggestions and generate alerts regarding potentially unsafe ingredients.

6.6 Analytics and Service Improvement

Breez AI may use aggregated, de-identified, or pseudonymized data derived from user interactions to analyze usage patterns, identify features for improvement, and conduct internal research and development.

6.7 Legal Compliance and Protection of Rights

Breez AI may use Personal Data to comply with applicable legal obligations, respond to legal process, enforce its Terms and Conditions, and protect the rights, property, and safety of Breez AI, its users, and others.

6.8 Retailer-Directed and Partner-Directed Purposes

Where Breez AI operates as a service provider or processor on behalf of a Retailer or contracted loyalty program provider, Breez AI may process Personal Data for purposes directed by those parties, consistent with Breez AI’s contractual obligations and applicable law.

7. How We Share Personal Data

Breez AI may disclose Personal Data in the following circumstances:

7.1 Retailers and Loyalty Program Providers

Breez AI may share Personal Data with the Retailer through whose platform you access the Services, and with loyalty program providers contracted by that Retailer. Breez AI, the Retailer, and the loyalty program provider operate as three integrated partners in providing the full service experience — the Retailer provides the grocery platform and purchase context, the loyalty program provider manages rewards and engagement, and Breez AI provides the meal planning and nutrition intelligence. Where Breez AI sends outbound communications on behalf of a Retailer or their loyalty program provider, Breez AI may share data related to consumers’ interaction with such communications (such as open rate, interaction time periods, etc.) with the Retailer, loyalty provider or other third parties as directed by the Retailer. Data shared among these three parties may include user profile data, meal plan activity, recipe interaction data, dietary preferences, and AI-Generated Inferences, to the extent necessary to support the integrated experience. The Retailer’s and loyalty provider’s use of data they receive is governed by their own privacy policies and their agreements with Breez AI. See also Section 10 (Retailer and Partner Integration).

7.2 Service Providers

Breez AI may share Personal Data with third-party vendors, contractors, and service providers that perform services on Breez AI’s behalf, such as cloud hosting providers, data analytics vendors, customer support platforms, and communications service providers. These service providers are contractually required to use Personal Data only as directed by Breez AI and in accordance with this Privacy Policy.

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of Breez AI’s assets, Personal Data may be transferred to the acquiring or successor entity, subject to that entity’s commitment to honor this Privacy Policy or provide advance notice of any material changes.

7.4 Legal and Regulatory Disclosures

Breez AI may disclose Personal Data to comply with applicable law, regulation, or legal process, including in response to a court order, subpoena, or government inquiry, and to protect the rights and safety of Breez AI, its users, and others.

7.5 Aggregate or De-Identified Data

Breez AI may share aggregated or de-identified data that does not reasonably identify individual users with third parties for research, industry analysis, or other purposes, provided that Breez AI takes reasonable steps to prevent re-identification.

7.6 Limits on Use of Sensitive Personal Data

Breez AI does not sell Sensitive Personal Data. Breez AI does not disclose Sensitive Personal Data to third parties for cross-context behavioral advertising unrelated to a user’s dietary needs. Sharing of dietary preference data, including religious and cultural dietary practice data, with Retailer and loyalty program partners is limited to the purpose of presenting food and grocery recommendations, offers, and promotions that are directly relevant to and consistent with the user’s stated dietary needs and preferences.

8. Not Medical Advice

THE SERVICES ARE NOT A SUBSTITUTE FOR PROFESSIONAL MEDICAL, DIETARY, OR NUTRITIONAL ADVICE, DIAGNOSIS, OR TREATMENT. MEAL PLANS, RECIPE SUGGESTIONS, NUTRITIONAL ANALYSES, CALORIE ESTIMATES, AND OTHER OUTPUTS GENERATED BY THE SERVICES — INCLUDING THOSE PRODUCED BY ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING SYSTEMS — ARE PROVIDED FOR GENERAL INFORMATIONAL AND CONVENIENCE PURPOSES ONLY. NO INFORMATION PROVIDED THROUGH THE SERVICES SHOULD BE CONSTRUED AS MEDICAL ADVICE OR RELIED UPON AS THE BASIS FOR ANY MEDICAL, DIETARY, OR HEALTH-RELATED DECISION. USERS WITH MEDICAL CONDITIONS, FOOD ALLERGIES, OR OTHER HEALTH CONCERNS SHOULD CONSULT A QUALIFIED HEALTHCARE PROVIDER BEFORE MAKING DIETARY CHANGES.

9. Children’s Privacy

The Services are not directed to children, and Breez AI does not create accounts for, or knowingly collect Personal Data from, individuals under the age of 13. Breez AI does not offer or support account profiles for minors.

Adult users may provide household context for meal planning purposes — such as the number, ages, or food preferences of family members for whom they are cooking — and this information is collected and processed as the adult user’s Personal Data, not as data belonging to any child. For example, an adult user may indicate that they are cooking for two young children with specific dietary preferences, and Breez AI may use that household context to inform meal plan suggestions. Breez AI does not use household context information to identify, profile, or contact any child, and does not permit children to independently access, register for, or use the Services.

If Breez AI becomes aware that it has inadvertently collected Personal Data directly from a child under the age of 13, Breez AI will promptly delete that data. Parents or guardians who believe that a child has provided Personal Data directly to Breez AI may contact Breez AI using the information in Section 16 (Contact Us) to request deletion.

10. Retailer and Partner Integration — Bidirectional Data Flows

The Services are designed to operate as one of three integrated components of a broader grocery and wellness experience — together with the Retailer’s grocery platform and the Retailer’s contracted loyalty program provider. Users should understand how data flows among these three parties.

Data Breez AI receives from Retailers and loyalty program providers. The Retailer and its loyalty program provider may transmit to Breez AI information such as account identifiers, loyalty program status and reward balances, grocery purchase history, product browsing data, and demographic or household data. This data is used by Breez AI to enhance the personalization of meal plans and recipe suggestions, for example by surfacing recipes that incorporate items you commonly purchase or that align with your documented dietary patterns.

Data Breez AI shares with Retailers and loyalty program providers. Breez AI may transmit to the Retailer and its loyalty program provider information about your use of the Services, including meal plan activity, recipe interaction data, nutritional goal progress, dietary preferences, your interactions with communications sent by Breez AI and, where applicable, AI-Generated Inferences relevant to the integrated service experience. This data may be used by the Retailer or loyalty program provider for purposes such as personalizing product recommendations, delivering relevant offers, awarding loyalty points for health and wellness activities, or measuring the performance of the integrated Services.

Governing frameworks. The scope and conditions of data sharing among Breez AI, each Retailer, and each loyalty program provider are governed by written agreements. Users should review the relevant Retailer’s and loyalty program provider’s privacy policies for information about how those parties independently use data they receive. Breez AI is not responsible for the independent data practices of Retailers or loyalty program providers.

11. Outbound Communications and Marketing Email

11.1 Communications Breez AI Sends

Breez AI sends two categories of electronic communication: transactional and service communications, and personalised marketing communications containing recipe suggestions, meal plan ideas, grocery offers, coupons, and product recommendations. Personalised marketing communications may be sent on a recurring basis, for example weekly.

11.2 Recipients Who Do Not Have a Breez AI Account

Breez AI sends personalised marketing communications containing recipe suggestions, meal plan ideas, grocery offers, coupons, and product recommendations. Personalised marketing communications may be sent on a recurring basis, for example weekly.

11.3 Legal Basis and Source of Consent

For personalised marketing communications sent to Retailer loyalty members, consent to marketing contact is obtained by the Retailer or its contracted loyalty programme provider at the point of loyalty program enrolment, and is transmitted to Breez AI as a consent indicator alongside the member’s contact details. Breez AI does not independently obtain marketing consent from these recipients before the first communication.

Breez AI sends only to recipients whose consent indicator is affirmative at the time of sending, and re-checks that indicator against the source system before each send.

Breez AI does not purchase, rent, license, or otherwise acquire email addresses from data brokers, list vendors, or any source other than the Retailer and its contracted loyalty program provider, or direct provision by the individual.

11.4 Sender Identity

Personalised marketing communications are transmitted using email infrastructure and a sending domain controlled by Breez AI, and may be presented under the Retailer’s brand consistent with Section 1. Each communication identifies the sender and includes a valid physical postal address and a functioning unsubscribe mechanism.

11.5 Engagement and Attribution Data

Breez AI collects data about how recipients interact with its communications, including:

Whether a message was delivered, was undeliverable, or was reported as unwanted;
Whether and when a message was opened, which may be recorded by means of a tracking image embedded in the message;
Which links within a message were selected; and
Whether a purchase of a promoted product subsequently occurred, determined by matching subsequent loyalty purchase records against products featured in the communication (“attribution data”).

Engagement and attribution data is used to measure the effectiveness of the communications, to report performance to the Retailer and its loyalty program provider, and to improve future personalisation. Attribution data links a marketing communication to a subsequent grocery purchase and is therefore Personal Data; where the products concerned reveal dietary, religious, or health-related characteristics, it may constitute Sensitive Personal Data under Section 5.

Tracking pixels. Emails sent by Breez AI contain a small, invisible image, commonly called a tracking pixel or web beacon, that loads when the message is displayed and records that the message was opened, the date and time, and technical information transmitted by your email client, which may include IP address, approximate location, device type, and email client. Most email applications allow you to block images from loading, in which case no open is recorded; conversely, some providers load images on your behalf, which may record an open whether or not you read the message. Open data is therefore an approximation. You may stop all tracking associated with Breez AI marketing email by using the unsubscribe link in any such message.

11.6 Withdrawing Consent

Every personalised marketing communication contains a functioning unsubscribe link. No account, login, or password is required to use it. Unsubscribing takes effect promptly and in any event within the period required by applicable law, and Breez AI records the withdrawal so that no further marketing communication is sent to that address.

Unsubscribing from Breez AI communications does not cancel Retailer loyalty program membership and does not stop communications sent independently by the Retailer or its loyalty programme provider.

Recipients may also withdraw consent, or exercise any other right described in Section 13, by contacting Breez AI directly using the details in Section 16. Recipients who have no Breez AI account may exercise these rights, and Breez AI will not require account creation as a condition of doing so.

11.7 Undeliverable Addresses and Suppression

Where a communication is permanently undeliverable, Breez AI records that outcome and suppresses further sending to the address concerned. Suppression data is retained to prevent repeat sending.

11.8 Retention of Communication Data

Communication records, engagement data, and attribution data are retained for 12 months and thereafter deleted or de-identified. Suppression records are retained for as long as necessary to prevent further sending to an undeliverable or withdrawn address. Retention of these records is not tied to the existence of a Breez AI account, because a recipient may have none.

12. Data Security, Storage, and Retention

12.1 Security Measures

Breez AI implements technical, administrative, and physical security measures reasonably designed to protect Personal Data against unauthorized access, disclosure, alteration, and destruction. These measures include, without limitation, encryption of data in transit and at rest, access controls, and regular security assessments. No security measures are perfect or impenetrable, and Breez AI cannot guarantee the security of any information transmitted through the Services.

12.2 Data Storage

Personal Data collected by Breez AI may be stored and processed in the United States and, where applicable, in other countries in which Breez AI or its service providers operate. By using the Services, users acknowledge that their data may be transferred to and stored in countries outside of their country of residence, which may have different data protection laws.

12.3 Retention

Breez AI retains Personal Data for as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, and enforce agreements. The appropriate retention period for a given category of data depends on its nature and sensitivity, the purposes for which it was collected, and applicable legal requirements. Health and dietary data associated with an active user account is retained for the duration of the account, plus any legally required retention period thereafter. Upon account deletion, Breez AI will delete or de-identify Personal Data in accordance with applicable law and its data retention schedules, except where retention is required by law or necessary for legitimate business purposes such as fraud prevention or legal compliance. Where Breez AI holds data about an individual who does not have a Breez AI account, such as a Retailer loyalty member receiving communications under Section 11, retention is governed by Section 11.8 rather than by account duration.

13. Privacy Choices and Rights

Depending on applicable law and the nature of the data Breez AI holds about you, you may have some or all of the following rights:

Access and portability. You may request confirmation of whether Breez AI processes Personal Data about you and, if so, access to that data. You may also have the right to receive your Personal Data in a portable format.
Correction. You may request correction of inaccurate or incomplete Personal Data.
Deletion. You may request deletion of Personal Data that Breez AI holds about you, subject to exceptions for data that Breez AI is required or permitted to retain under applicable law.
Opt out of AI model training. Where required by applicable law, you may opt out of the use of your Personal Data for the purpose of training or improving Breez AI’s AI and machine learning models. To submit an opt-out request, contact Breez AI at Breez AI Corporation, 9225 Bay Plaza Blvd, Suite 417 (1173), Tampa, FL 33619; or [email protected].
Opt out of sale or sharing. To the extent Breez AI sells or shares Personal Data as those terms are defined under applicable law, you may have the right to opt out of such sale or sharing.
Withdraw consent. Where processing is based on consent, you may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.
Limit sensitive data processing. You may have the right to limit Breez AI’s processing of Sensitive Personal Data to uses necessary to provide the Services.
Non-discrimination. Breez AI will not discriminate against you for exercising your privacy rights.

To submit a privacy rights request, contact Breez AI using the information in Section 16 (Contact Us). Breez AI may need to verify your identity before processing certain requests. Breez AI will respond to verifiable requests within the time periods required by applicable law. Where a request is submitted through a Retailer’s platform, Breez AI may require that you contact Breez AI directly to exercise your rights with respect to data Breez AI controls.

14. Third-Party Links and Integrations

The Services may contain links to or integrations with third-party websites, applications, or services. This Privacy Policy does not apply to those third parties. Breez AI is not responsible for the privacy practices of third-party platforms, including Retailers, loyalty program providers, wearable device providers, or health application providers. Users are encouraged to review the privacy policies of any third-party services they access in connection with the Services.

15. Changes to This Privacy Policy

Breez AI may update this Privacy Policy from time to time. When Breez AI makes material changes, it will update the effective date at the top of the Policy and, where required by applicable law or where Breez AI determines it is appropriate, provide notice through the Services or by email. Continued use of the Services following the posting of an updated Privacy Policy constitutes acceptance of the changes to the extent permitted by applicable law.

Breez AI conducts a scheduled review of this Privacy Policy on a quarterly basis to assess whether updates are required in light of changes to applicable law, changes to the Services, or changes to data practices. The next scheduled review date is noted at the top of this document.

16. Contact Us

For questions about this Privacy Policy, to submit a privacy rights request, or to report a concern about Breez AI’s data practices, contact:

Breez AI Corporation
Attn: Privacy
9225 Bay Plaza Blvd, Suite 417 (1173)
Tampa, FL 33619
Email: [email protected]