Privacy Policy

Last updated: July 20, 2025

Beezer LLC ("Beezer," "we," "our," or "us") provides Breeze, a non-custodial protocol for digital asset automation, designed for integration into third-party platforms or direct access via API. This Privacy Policy describes how we collect, use, and process limited technical and transactional data in connection with your use of Breeze. This Privacy Policy is incorporated into and forms part of the Breeze Terms of Service.

Beezer acts primarily as a service provider or data processor on behalf of integration partners. We do not act as a data controller with respect to end- user personal information, unless explicitly stated otherwise. Accordingly, Beezer does not interface directly with end users and does not independently collect or profile end-user information. Integrated platforms are responsible for ensuring that any data shared with Breeze—such as identifiers, wallet addresses, or usage metadata—has been lawfully obtained and is shared in accordance with applicable privacy laws.

This Policy does not govern the privacy practices of third-party platforms that integrate or embed Breeze. Those platforms operate under their own privacy policies and are solely responsible for disclosing how they collect, use, and share user data, including any data routed through Breeze.

Data We Collect

Beezer minimizes data collection and processes only the information necessary to operate, secure, and improve Breeze. The categories of data we may collect include:

  • Wallet Address and Protocol Activity: When you use Breeze, we may receive the public blockchain address of your wallet and associated smart contract interactions. Beezer does not collect, access, or store private keys, seed phrases, or any credentials that could enable control of a wallet. All transaction authorizations are initiated by users and executed directly onchain through smart contract interfaces.
  • Usage Metadata: We collect technical metadata related to protocol interactions, including but not limited to API calls, endpoint requests, latency, error logs, gas usage, and execution timestamps. This data may include telemetry from smart contract calls required for system diagnostics and performance optimization. We do not use this metadata to build user profiles, track behavior, or link activity to specific individuals unless explicitly authorized and provided by an integration partner.
  • Partner-Provided Identifiers: If a third-party platform integrates Breeze and provides identifiers such as hashed user IDs, integration keys, or anonymized session tokens, we may log these strictly for analytics, debugging, or partner support. These identifiers are processed solely for operational purposes and are not used by Beezer to re-identify end users or cross-link behavior across platforms.

We do not collect names, email addresses, device fingerprints, IP addresses, or other traditional identifiers unless explicitly provided by an integration partner through pre-agreed data flows.

NO DIRECT USER PROFILING

Beezer minimizes data collection and processes only the information necessary to operate, secure, and improve Breeze. The categories of data we may collect include:

  • Beezer does not directly profile, track, or identify individual end users of platforms that integrate Breeze. We do not collect names, email addresses, IP addresses, device fingerprints, or other identifiers that would allow us to associate a wallet or activity with a natural person, unless that information is explicitly provided to us by a partner platform under their own privacy terms.
  • We do not use Breeze telemetry or transaction data to build behavioral profiles, target users, or perform automated decision-making. Any data collected is limited to what is operationally necessary to support protocol functionality — such as error logs, smart contract calls, and performance diagnostics.
  • To the extent that any telemetry or usage metadata could potentially be linked to an individual (e.g., by a partner platform), we rely on that platform to provide appropriate privacy disclosures and obtain any required user consents. Beezer does not aggregate or cross-correlate Breeze data across integrations for user-level analysis.

DATA SHARING

We do not sell or rent personal information. We may share limited technical or operational data in the following circumstances:

  • Service Providers and Infrastructure Partners: We may disclose operational data to trusted service providers and infrastructure vendors (such as cloud hosting platforms, node operators, and custody middleware) solely as necessary to maintain, operate, and secure Breeze. These providers are bound by contractual obligations, including confidentiality, data protection standards, and restrictions on downstream use.
  • Integration Partners: Where Breeze is deployed through third- party platforms, we may share telemetry, performance, or debugging data with those integration partners, pursuant to agreements that include privacy and security obligations. These partners are responsible for managing any personal data they collect and must ensure downstream disclosures are lawful and appropriate.
  • Legal and Regulatory Requirements: We may disclose data if required to comply with applicable laws, lawful subpoenas, court orders, or binding legal process. In such cases, we will, where permitted, notify the affected partner or user of the request before disclosure.
  • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets involving Beezer or Breeze, relevant data may be transferred as part of that transaction, subject to continued protection under this Policy.

We do not grant advertisers, analytics firms, or unrelated third parties access to Breeze telemetry or user-related data for behavioral profiling, marketing, or cross-platform tracking.

SECURITY

  • We implement industry-standard administrative, technical, and physical safeguards to protect data in transit and at rest. These include, but are not limited to, encryption, access controls, audit logging, infrastructure monitoring, and endpoint isolation. Access to any systems that process operational data is restricted to authorized personnel on a need-to-know basis and subject to strict authentication protocols.
  • Despite these measures, no system is completely secure. By using Breeze, you acknowledge that any data transmitted to or through the protocol may be subject to inherent risks associated with internet-based services, distributed ledger technologies, and third-party infrastructure providers.
  • You are solely responsible for securing your own wallet, private keys, recovery phrases, and any integration or API credentials used to interact with Breeze. Beezer does not store, control, or recover any wallet access mechanisms. We strongly recommend that you follow best practices for securing your digital assets and consult your platform provider regarding any additional security measures.

DATA RETENTION

  • We retain the data we collect only for as long as necessary to fulfill the purposes described in this Privacy Policy, including operating and improving Breeze, providing support, and complying with legal, regulatory, or contractual obligations. The specific retention period depends on the nature of the data and the context in which it was collected.
  • Operational and telemetry data (such as API logs and performance diagnostics) may be retained for a limited period to detect issues, optimize infrastructure, and maintain security. In some cases, we may retain de- identified or aggregated data indefinitely, provided it cannot reasonably be used to re-identify any individual or wallet.
  • Where data is provided to us by integration partners, we process and retain that data according to our agreements with those partners. If we receive a lawful request to delete data or if a partner instructs us to delete data under applicable law, we will comply, subject to verification and any overriding legal obligations.

YOUR RIGHTS

  • Depending on your location and applicable data protection laws, you may have rights regarding your personal information, including the rights to access, correct, delete, restrict processing of, or object to certain uses of that data. If you believe any data processed via Breeze relates to you, please first contact the third-party platform through which you accessed Breeze. If your request involves metadata directly collected by Beezer, you may contact us at legal@breeze.baby.
  • If you reside in the European Economic Area or the United Kingdom and have questions about your data rights or our processing activities, you may also contact our designated representative at legal@breeze.baby.
  • We will review all requests in accordance with applicable laws and may require additional information to verify your identity before responding.

INTERNATIONAL TRANSFERS

  • Breeze may be accessed globally, including from jurisdictions with different data protection laws than those in your home country. If you access Breeze from outside the United States, any data transmitted to or processed by Beezer may be stored or handled in the United States or other countries where Beezer or its infrastructure providers operate. These countries may not provide the same level of data protection as your jurisdiction.
  • Where required by law (such as under the General Data Protection Regulation or UK GDPR), we implement appropriate safeguards to ensure an adequate level of protection for international data transfers. This may include entering into Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner's Office, or ensuring our service providers are certified under recognized frameworks or legally valid mechanisms.
  • By using Breeze, you acknowledge that your information may be transferred and processed in jurisdictions outside of your country of residence, and that such transfers are necessary for the performance of Breeze's services.

CHILDREN'S DATA

Breeze is not intended for use by individuals under the age of 18. We do not knowingly collect, solicit, or process any personal information from children. If we become aware that personal data from a child under 18 has been inadvertently collected, we will take reasonable steps to delete that information as soon as possible. If you are a parent or legal guardian and believe that your child has provided personal information to us, please contact us at legal@breeze.baby so that we can investigate and address the matter promptly.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal obligations, or for other operational, legal, or regulatory reasons. When we make material changes, we will revise the "Last Updated" date at the top of this Policy and may provide notice through your integration platform, via in-app messaging, email (if available), or by posting a prominent notice on our website. You are responsible for reviewing this Policy periodically to stay informed of our data practices. Continued use of Breeze after any changes constitutes your acceptance of the revised Policy.

CONTACT US

  • If you have any questions or concerns about this Privacy Policy or how Beezer processes data in connection with Breeze, you may contact us at legal@breeze.baby. You may also reach us through any applicable contact forms or messaging interfaces provided by the third-party platform through which you accessed Breeze.
  • For privacy-related requests, please clearly specify the nature of your inquiry (such as access, deletion, or clarification), the name of the platform through which you used Breeze (if applicable), and any relevant wallet address or integration identifier. We may request additional information to verify your identity or authority before responding.
  • If you are a resident of the European Economic Area or the United Kingdom and wish to exercise your rights under applicable data protection laws, you may also contact our designated representative (see above).