Privacy policy

Sportswise Global Inc. dba Breakthru ("Breakthru," "we," "us," or "our") respects your privacy and is committed to being transparent about how we collect, use, share, and protect information.

Breakthru provides a technology platform that enables organizations to create and operate digital communities, programs, campaigns, missions, surveys, educational experiences, and other engagement opportunities (the "Services"). Organizations using Breakthru may include businesses, nonprofits, educational institutions, government entities, campaigns, advocacy organizations, and other organizations ("Customers").

Individuals generally access Breakthru through a Community operated or sponsored by one of our Customers. Breakthru may also help Customers identify, recruit, or invite individuals to participate in their Communities.

This Privacy Policy explains how information is handled when you use Breakthru.

Breakthru is intended only for individuals who are at least 13 years old. Individuals under 13 are not permitted to use the Services.

1. Our Privacy Principles

Breakthru was created to help organizations build meaningful relationships with their communities while giving individuals opportunities to participate, learn, share their perspectives, and take action.

Our approach to privacy is guided by several principles:

• We aim to be transparent about the information collected through Breakthru and how it is used.

• We do not sell identifiable personal information to data brokers or unrelated third parties.

• Organizations using Breakthru may access information generated within their own Communities, but generally do not receive information about your activity within another organization's Community through Breakthru.

• We use service providers where necessary to operate and improve the Services.

• We may use data to understand engagement, improve Breakthru, conduct research, develop technology, and generate aggregated or de-identified insights.

• We provide individuals with ways to request deletion of their personal information and control marketing communications.

• You may ask Breakthru not to use your identifiable personal information, image, likeness, or content for Breakthru's promotional or marketing purposes.

• We take additional care when our Services are used by teenagers and are not intended for children under 13.

2. Information We Collect

The information collected through Breakthru depends on how you use the Services and how the Customer operating a Community configures that Community.

Information You Provide

We may collect information such as:

• first and last name;

• email address;

• telephone number;

• date of birth or age;

• ZIP code or location information;

• school, college, employer, or organizational affiliation;

• profile information;

• profile photos and other images;

• social media profiles or handles;

• interests and preferences;

• demographic information;

• survey, poll, questionnaire, and form responses;

• mission and activity responses;

• messages and communications;

• photos, videos, files, or other content you submit;

• reward, incentive, or redemption information; and

• other information you choose to provide through the Services.

Not all Communities request the same information.

Sensitive Information

Depending on the Community you participate in and the questions or experiences a Customer chooses to offer, information collected through Breakthru may include information considered sensitive under applicable law.

This may include information concerning:

• physical or mental health and well-being;

• racial or ethnic background;

• political opinions, interests, affiliations, or activities;

• voting-related information;

• religious or philosophical beliefs;

• sexual orientation or gender identity;

• precise location, where enabled;

• information used for identity or age verification; or

• other information that may be considered sensitive under applicable law.

Customers generally determine which questions, surveys, missions, forms, and other experiences they make available within their Communities.

You should consider the nature of information requested before choosing to submit sensitive information.

Information About Your Activity

When you interact with Breakthru, we may collect information about your activity and engagement, including:

• Communities you join;

• missions or activities you view, start, or complete;

• surveys and polls you participate in;

• content you interact with;

• rewards or incentives earned;

• communications and engagement;

• dates and times of activity;

• interactions with Community features;

• referrals and invitations; and

• other behavioral and engagement information generated through your use of the Services.

Device and Technical Information

We and our service providers may automatically collect information such as:

• IP address;

• browser type;

• device type;

• operating system;

• device or advertising identifiers, where applicable;

• pages and features accessed;

• referring URLs;

• approximate location derived from an IP address;

• log and diagnostic information; and

• information collected through cookies and similar technologies.

We use this information to operate, secure, understand, and improve the Services.

3. How You Join Breakthru

Individuals generally join Breakthru through a Community associated with a Customer.

For example, a Customer may invite you through a link, QR code, email, text message, event, advertisement, social media campaign, or other outreach.

Breakthru may conduct marketing or recruitment activities on behalf of Customers to help them grow their Communities.

You may participate in more than one Breakthru Community.

Information associated with your overall Breakthru account may be maintained by Breakthru, but Customers generally receive access only to information associated with their own Community and not your activity within another Customer's Community.

4. Customers and Their Communities

Breakthru provides Customers with tools to design and manage their Communities.

Depending on the features a Customer enables, Customers may:

• create questions, surveys, polls, forms, and missions;

• determine what information participants are asked to provide;

• view participant profiles;

• view responses and engagement information;

• review Community activity and analytics;

• communicate with participants;

• export information from their Community;

• integrate Breakthru with their own systems, databases, or software; and

• otherwise use information available through their Community as permitted by their agreement with Breakthru and applicable law.

Accordingly, when you provide information or participate in activities within a Customer's Community, that Customer may be able to access that information.

A Customer may have its own privacy policy, notices, terms, or data practices. Breakthru does not control how a Customer independently uses information after the Customer receives or exports it from Breakthru.

Customers are responsible for their independent use of personal information and for complying with applicable laws and their agreements with Breakthru.

5. Information Visible to Other Community Members

Some Breakthru Communities include social, messaging, profile, or community features.

Depending on how a Customer configures its Community and how you configure available privacy settings, information visible to other participants may include:

• your first and last name;

• profile photo;

• profile information;

• social media profiles;

• posts or submissions;

• photographs;

• messages or chat content; and

• other information you choose to make available through Community features.

You should use care when posting information that may be visible to others.

The visibility of information may differ between Communities depending on the features enabled by the Customer.

6. How Breakthru Uses Information

We may use information collected through the Services to:

• provide and operate Breakthru;

• create and maintain accounts;

• provide Customers with their Communities;

• deliver missions, surveys, content, communications, and other experiences;

• administer rewards and incentives;

• personalize experiences;

• provide customer service and technical support;

• measure engagement and program performance;

• understand how individuals and Customers use Breakthru;

• develop, test, maintain, and improve our products, services, technologies, and features;

• develop analytics, insights, research, and benchmarks;

• understand trends, interests, preferences, and behaviors;

• conduct research and statistical analysis;

• develop and improve models, algorithms, artificial intelligence systems, and other technologies, subject to applicable law;

• create aggregated or de-identified information;

• prevent fraud, abuse, misuse, and security incidents;

• protect Breakthru, our Customers, users, and others;

• enforce our Terms and agreements;

• comply with legal obligations;

• communicate with you about the Services;

• send marketing or promotional communications where permitted; and

• carry out other purposes disclosed to you when information is collected or otherwise permitted by law.

7. Aggregated, De-Identified, and Derived Information

Breakthru may analyze information collected through the Services and create aggregated, statistical, derived, or de-identified information.

For example, we may analyze information across Communities to better understand how different groups engage with particular issues, experiences, programs, or content.

We may use aggregated, de-identified, statistical, and derived information for purposes including:

• analytics;

• research;

• benchmarking;

• understanding trends and behaviors;

• developing insights;

• measuring program effectiveness;

• improving Breakthru;

• developing new products and services;

• artificial intelligence and machine learning development;

• reports and publications; and

• other business or commercial purposes.

We may retain and use aggregated, statistical, derived, or de-identified information as permitted by applicable law.

Where required by applicable law, we will maintain de-identified information in de-identified form and will not attempt to re-identify it except as permitted by law.

8. We Do Not Sell Identifiable Personal Information to Data Brokers

Breakthru does not sell identifiable personal information to data brokers or unrelated third parties for their independent use.

We believe there is an important distinction between selling an individual's identifiable personal information and using aggregated or de-identified information to understand trends, conduct research, develop insights, or improve our business.

Accordingly, this commitment does not prevent Breakthru from using, disclosing, licensing, or otherwise making available aggregated or de-identified information in accordance with this Privacy Policy and applicable law.

Certain privacy laws define terms such as "sale" or "sharing" more broadly than their ordinary meaning. Where those laws apply, additional rights and disclosures may apply as described below.

9. How We Disclose Information

We may disclose information in the following circumstances.

Customers

We disclose information to the Customer operating the Community in which you participate as described in this Privacy Policy.

Service Providers

We use third-party companies and service providers to help operate Breakthru.

These providers may support functions such as:

• cloud hosting and infrastructure;

• data storage;

• analytics;

• communications and email;

• SMS and messaging;

• security and fraud prevention;

• customer support;

• identity and age verification;

• rewards and payments;

• software integrations;

• artificial intelligence and machine learning;

• content creation; and

• other technology and operational services.

These providers may process information as necessary to provide services to Breakthru.

Integrations

A Customer may connect its Breakthru Community with third-party services or systems.

When information is transferred to a Customer's third-party integration at the Customer's direction, that Customer and the third-party provider may have their own privacy practices governing the information.

Legal, Safety, and Security Purposes

We may disclose information if we reasonably believe disclosure is necessary to:

• comply with applicable law, regulation, subpoena, court order, or legal process;

• respond to lawful requests from government authorities;

• investigate fraud, security incidents, or misuse;

• enforce our agreements or policies;

• protect the rights, property, or safety of Breakthru, our Customers, our users, or others; or

• establish, exercise, or defend legal claims.

Business Transactions

If Breakthru is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, information may be disclosed or transferred as part of that transaction, subject to applicable law.

10. Artificial Intelligence

Breakthru uses artificial intelligence and AI-enabled service providers in connection with certain features of the Services.

For example, Breakthru currently provides AI-enabled tools that can help Customers create content, missions, and Community experiences.

Breakthru may develop additional AI-enabled functionality over time.

Where we use personal information in connection with artificial intelligence or machine-learning technologies, we will do so in accordance with this Privacy Policy and applicable law.

Our practices concerning AI may evolve as our technology develops. If we materially change how we use personal information with AI systems, we may update this Privacy Policy or provide additional notice where appropriate or required.

11. Rewards and Age Verification

Certain Breakthru Communities may allow participants to earn or redeem rewards, including cash or cash-equivalent rewards.

Certain reward features may require age or identity verification.

Breakthru may use a third-party verification provider to perform this process. The provider may request information such as a government-issued identification document and a selfie or similar verification information.

Government identification documents and verification selfies used for this process are submitted to and processed by the third-party verification provider rather than stored by Breakthru.

Breakthru may receive information from the provider concerning the outcome of the verification and other information necessary to administer the applicable feature.

The verification provider's processing of information may also be governed by its own privacy policy.

12. Marketing Choices and Use of Your Information

Breakthru or a Customer may communicate with you in connection with your participation in the Services, subject to applicable law.

Marketing Communications

You may opt out of receiving marketing or promotional communications from Breakthru at any time by:

• using the unsubscribe link included in our marketing emails; or

• contacting us at info@joinbreakthru.com.

You may also request to stop receiving marketing text messages by following the opt-out instructions provided in the message or contacting us at info@joinbreakthru.com.

Opting out of marketing communications will not prevent Breakthru from sending communications that are necessary to operate the Services, including account, security, reward, transactional, administrative, or other service-related communications.

Use of Your Information in Breakthru Marketing

You may contact us at info@joinbreakthru.com if you do not want Breakthru to use your identifiable personal information, including your name, profile information, image, likeness, photographs, content, submissions, or similar identifiable information, for Breakthru's promotional or marketing purposes.

We will honor such requests as reasonably practicable and as required by applicable law.

This choice does not restrict Breakthru's use of aggregated or de-identified information that does not reasonably identify you, including for analytics, research, benchmarking, insights, product development, reports, or other purposes described in this Privacy Policy.

Marketing by Customers

Customers operating Communities on Breakthru may communicate with participants in their Communities and may independently use information they receive through their Communities, subject to their agreements with Breakthru and applicable law.

If you wish to stop receiving marketing communications sent independently by a Customer, you may need to opt out through that communication or contact the Customer directly.

You may also contact Breakthru at info@joinbreakthru.com if you have questions about communications you receive in connection with a Breakthru Community.

13. Cookies and Similar Technologies

Breakthru and our service providers may use cookies, pixels, software development kits, local storage, and similar technologies to operate and understand the Services.

These technologies may be used to:

• maintain sessions and account functionality;

• remember preferences;

• understand use of the Services;

• measure performance;

• diagnose technical issues;

• improve functionality;

• prevent fraud and enhance security; and

• measure the effectiveness of outreach or marketing.

Your browser or device may provide controls that allow you to limit certain cookies or technologies. Disabling certain technologies may affect the functionality of the Services.

Where required by applicable law, we will provide additional choices or obtain consent concerning particular technologies.

14. Data Retention and Deletion

We retain personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with our contractual obligations, protect our legitimate interests, and satisfy applicable legal requirements.

When a Customer requests deletion of Customer-associated personal information, or when information is otherwise scheduled for deletion, Breakthru generally deletes or de-identifies the applicable information from active systems within 30 days, subject to reasonable exceptions.

We may retain certain information for longer when necessary for:

• legal or regulatory obligations;

• security and fraud prevention;

• resolving disputes;

• enforcing agreements;

• financial or transaction records;

• backup and disaster-recovery systems; or

• other legitimate purposes permitted by law.

Information maintained in backup systems may remain until overwritten or deleted through our normal backup cycle.

Breakthru may retain aggregated or de-identified information as permitted by applicable law.

15. Your Privacy Choices and Rights

Depending on where you live, you may have rights concerning your personal information.

These may include the right to:

• request access to personal information;

• request correction of inaccurate information;

• request deletion of personal information;

• obtain certain information about how personal information is used or disclosed;

• obtain a copy of certain personal information;

• withdraw consent where processing is based on consent;

• opt out of certain uses of personal information where required by law;

• request that Breakthru not use your identifiable personal information, image, likeness, photographs, content, or submissions for Breakthru's promotional or marketing purposes; and

• appeal certain decisions concerning a privacy request where applicable.

You may request deletion of your Breakthru information or submit another privacy request by contacting:

info@joinbreakthru.com

We may need to verify your identity before completing certain requests.

Your rights may vary depending on your location, the nature of the information, our relationship with the Customer operating your Community, and applicable law.

If Breakthru processes certain information on behalf of a Customer, we may direct your request to that Customer or assist the Customer in responding.

16. Additional U.S. State Privacy Rights

Residents of certain U.S. states may have additional rights under applicable state privacy laws.

Depending on the law and circumstances, these may include rights relating to:

• access;

• correction;

• deletion;

• portability;

• targeted advertising;

• sale or sharing of personal information;

• profiling; and

• processing of sensitive information.

Breakthru will honor applicable privacy rights as required by law.

Some state privacy laws use broad definitions of terms such as "sale," "sharing," "targeted advertising," and "sensitive data." Our practices and your rights under those laws will be determined according to the applicable statutory definitions rather than only the ordinary meaning of those terms.

You may submit a request at info@joinbreakthru.com.

We will not unlawfully discriminate against you for exercising applicable privacy rights.

17. Users Ages 13 to 17

Breakthru is designed to support Communities that may include teenagers.

We recognize that teenagers deserve particular care and transparency regarding their personal information.

If you are between 13 and 17, you should carefully consider the information you choose to share through Breakthru, particularly sensitive information and information that may be visible to a Customer or other Community members.

Customers are responsible for configuring and operating their Communities in compliance with applicable law, including laws that may impose additional requirements concerning teenagers or sensitive information.

Breakthru may apply additional safeguards, restrictions, consent requirements, or privacy controls for teenage users where appropriate or required by law.

18. Children Under 13

Breakthru is not intended for and may not be used by children under 13 years of age.

By creating or using a Breakthru account, you represent that you are at least 13 years old.

Breakthru generally relies on the age information and representations provided by users unless additional verification is required for a particular feature.

We do not knowingly seek to collect personal information from children under 13.

If we learn that an individual under 13 has used Breakthru or provided personal information through the Services, we may suspend or terminate the account and will take appropriate steps to delete the child's personal information in accordance with applicable law.

If you believe a child under 13 has provided personal information to Breakthru, please contact us immediately at:

info@joinbreakthru.com

19. Security

Breakthru uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no system, network, transmission, or method of electronic storage can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should notify us if you believe your account has been compromised.

20. Third-Party Services and Links

The Services may contain links to or integrations with third-party websites, applications, platforms, or services.

Breakthru is not responsible for the privacy practices of third parties that independently determine how they process information.

We encourage you to review the privacy policies of third-party services before providing information to them.

21. International Users

Breakthru is based in the United States and the Services are primarily intended for use in the United States.

If you access the Services from another country, your information may be transferred to, processed, and stored in the United States or other jurisdictions in which Breakthru or our service providers operate.

Where required, we will implement appropriate measures relating to international transfers of personal information.

22. Changes to This Privacy Policy

Breakthru and our Services will continue to evolve.

We may update this Privacy Policy from time to time to reflect changes in our Services, technologies, data practices, legal requirements, or business operations.

When we update this Privacy Policy, we will update the "Last Updated" date at the top of this page.

If we make material changes, we may provide additional notice where appropriate or required by law.

Your continued use of the Services following an update will be subject to the updated Privacy Policy, except where applicable law requires additional notice or consent.

23. Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, want to request deletion of your information, want to opt out of Breakthru marketing, want to request that your identifiable information not be used in Breakthru marketing, or believe a child under 13 has accessed Breakthru, please contact us:

Sportswise Global Inc. dba Breakthru
Email: info@joinbreakthru.com

We take privacy seriously and welcome questions about how information is handled through Breakthru.