This Privacy Policy is made to explain how We, at The Breakfast, collect, use, share and transfer information We have about the User and choices User has regarding this information.
For convenience, We use the following terms:
The Breakfast website
Here is the link: thebreakfast.app, means all its content and links (together called the "Website");

The Breakfast mobile application, App
The app available on the App Store;

Services
Together Website and App, includes accessing, browsing, registering, support correspondence, chats, product and services information;

We, The Breakfast, Our, Us
Refers to "The Breakfast Application, LDA", registration number 515 165 786, registered under the address: Avenida do Atlântico, Nº 16, Escritório 2.11 1990-019 Lisboa, incorporated under the laws of Portugal;

User, You
The User, registered within the Services and uses Services;

Personal Data
Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
We encourage You to read this Privacy Policy carefully before using the Services.
We tried to make it as simple and comfortable to read, as the ABC-book. Users can access, print, download and save this Privacy Policy at any time. The Privacy Policy will be permanently accessible on the Website, in the App and periodically renewed. By providing any of the information about Yourself, as well as accessing the Services You acknowledge and agree that You have read, fully accept, and abide by this Privacy Policy. If You don't agree to the terms of this Privacy Policy or the Terms of Service, You must not use the Services.

In case You have any questions relating to the terms, contained in this Privacy Policy or the Terms of Service, You can contact Us via email: support@thebreakfast.app. Your question will be responded during 7 (seven) days. Feel free to contact Us at any time convenient for You with any queries. We are here to help!
Our General Position Regarding Personal Data
We do understand the importance of the data privacy and never collect information, over the minimum needed in order for You to interact with the Services. The protection of information, that You have provided to Us is of our top priority so We maintain necessary administrative, physical and technical safeguards, which include measures for preventing unauthorized access, use, modification, deletion and disclosure of information by Our personnel or third parties. Before sharing received Personal data with any of Our third party service providers, We will ensure that the third party maintains, at a minimum, reasonable data practices for maintaining the confidentiality and security of data and preventing unauthorized access.

We process Personal Data on the following legal basis: (1) with Your consent; (2) as necessary to provide Services; and (3) as necessary for Our legitimate interests in providing the Services where those interests do not override Your fundamental rights and freedom related to data privacy.
What Personal Data We do Collect and When
1. We collect data when You directly provide it to Us ("Your Data") while You:

A. Register an account;

B. Provide information about Yourself in The Breakfast profile;

C. Contact Our customer service team;

D. Chat with other Users, responding to breakfast requests.

In this case we collect information, including but not limited to:

— Your first and last name;
— Your email address;
— Your password;
— Your location, mainly city;
— Link to Your social profile (Facebook, Instagram, blog/website);
— Your photo;
— The content of Your chats with other Users (We do not read them, these are just stored on our servers);
— The content of the communication with Our support team;
— General information about You, Language You are fluent in, Your interests and reasons You want to meet people.

2. We collect other data when You use the App ("Other Data via the App"):

A.
Your login time, which we collect when You access the App for the first time during one day;

B. Details of Your device: Your IP address — a numerical code to identify Your device, which can provide information about the country, region or city where You are based, the unique device ID, App version;

C. Time when You open and close the App and duration, when it is opened on Your main screen;

D. The errors, which may occur during Your use of the App;

E. Information on what You have viewed in the Аpp, actions You have taken and information on bugs and crashes is also sent to Us.

3. We collect other data when You use the Website ("Other Data via the Website"):
When You use Our Website, simply browsing through it, We personally do not collect the information. All We do — We are plugging Google Analytics to gather statistical information for Our legitimate interest and analysis on how to promote Our Services. The information We receive is in aggregated (and anonymized) way, so We cannot identify the person. The information We collect:

A. Device information, such as IP address, operating system, geolocation, mobile operator (including the phone number);

B. Your browsing history of the content You have visited, time You've spent on the Website, when You open and close it, including information on how You were referred to Our Website via another source.
Why We Collect
1. We collect Your Data for the reasons as follows.
The Breakfast is the community of open-minded and driven people who love to talk, care to listen and have a general interest in other humans. That is why, We always ask You to provide actual and true information about You, thus You and Your breakfast companion will have an inspiring conversation.

A. We want The Breakfast to be used for its initial purpose — connecting people via breakfast, thus We collect information such as Your first and last name, information about You, Your photo and profile link just to be sure that You are a real person, and Your profile on the App corresponds to You, although, We can never guarantee this to Our Users;

B. We will send You notifications regarding new requests for breakfast at Your location;

C. If You contact Us, we may use Your Data to respond. We may send You service, technical and other administrative emails and messages to respond to any questions and requests You may have;

D. We may also contact You to inform about changes in Our Services and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and You may not opt out of them. In addition, We may sometimes send emails about new features, promotions or other news about The Breakfast. These are marketing messages so You can control whether You want to receive them;

E. For security and fraud prevention and to ensure that Our App is safe, secure and used in line with Our Terms of Service.


2. We collect Your Other Data when You use the App and Website, for the reasons as follows:
The Breakfast tries to make the Services as user friendly and useful as possible, so We are using the Other Data to develop the Service and fix the bugs and errors as well as to come up with new features, provide security, analyze and monitor trends.

A.
To provide, update, maintain, fix and protect Our Services;

B. To improve our marketing, We use a similar technology to cookies to confirm whether You have opened a marketing email or clicked on a link in the email;

C. Personalising Our services for You: remembering Your settings, recognising You when You log into Your account on different devices;

D. For statistical purposes, such as analysing the performance of Our site and Apps and to understand how visitors use them;

E. To detect, investigate, and prevent activities that may violate Our policies, be fraudulent, or be illegal.
Who Can See The Breakfast Profile Information
Your first name, profile picture, information You provided about Yourself will be made public on The Breakfast for other registered Users and this will be the identity by which You are known on the Services. The Breakfast Users who are logged in via the App can see all of the information You have put in Your profile, when You make an announcement for breakfast. Always think carefully about the information You put in Your profile. As it is Your responsibility to decide what information You want to make available to other The Breakfast Users. Your Last Name can be seen by the Users only in chat, available one hour before confirmed breakfast and ever since.
Some Permissions for The Breakfast
When You use the App, We will also ask for the following permissions to access particular functions of Your mobile device:

A. We ask for permission to access Your location information;

B. We ask for permission to access Your photo library, so that You can add Your own pictures for Your profile; and

C. We ask for permission to send You notifications, for example if someone wants to have breakfast with You. You can choose whether to receive notifications on Your mobile device via the Apps.
What We don’t Collect and Why
Don’t worry, We can’t read data off Your hard disk or read cookie files created by other sites.

The Breakfast don’t need the information, that it cannot use in ways that are not compatible with the purposes for which it was collected or subsequently authorized by the User. We will not sell Your email address, nor do We provide it to advertisers or mass marketers. In other words, You will not receive junk mail based on information You submit directly to The Breakfast.
How We Process and Where We Store
Almost all the information that the User provides to Us, including Personal and Other Data is stored on Amazon Web Services (AWS), only the correspondence via emails is stored on Google since we are using Google G Suite. As long as We have many Users from Russian Federation, We store their Personal Data on servers in the Russian Federation called SmartApe, according to the Federal law of July 27, 2006 N 152-ФЗ On personal data.

Prior to engaging of these third party processors, The Breakfast performed due diligence to evaluate their privacy, security and confidentiality practices. Data We collect may be transferred to, stored and processed in any other country in which We or Our Processors maintain facilities. In the light of the rules of General Data Protection Regulation (GDPR), We try Our best to ensure that transfers of Personal Information to a third country or an international organization are subject to appropriate safeguards.

Given the nature of communications and information processing technology, The Breakfast cannot guarantee that data, during transmission through the Internet or while stored on Our systems or otherwise in Our care, will be absolutely safe from intrusion by others.
What is Stored on the User Device
We store cached data — data on interaction with the App, as it is not updated too often, when storing in the User's device, it can be displayed faster in the App. This includes: User picture; delivery filter settings; information about the current meeting; current authorization data. As with most technology services delivered over the Internet, Our servers automatically collect information when You access or use the App and record it in log files on Your device. This log data includes App version, when the App was launched, when was closed, Your actions in the App, crash reports and operation system, technical messages. This is needed to support the normal functioning of the App on Your device with minimum service errors.
How and When We Share
The Breakfast may share the Personal Data with the third parties, but only in compliance with applicable law. We do not transfer Personal Data to non-agent third parties. The Breakfast will cooperate with all legitimate local, state, national, and international law enforcement agencies. We may engage third party companies or individuals as service providers to support Our Services. These third parties may, for example, provide virtual computing and storage Services (as described above).

We may also use third-party website analytics tools that collect automated information about visitor traffic on Our sites to help Us analyze how Users interact with and use the Websites, compile reports on the Websites' activity, and provide other Services related to our Websites' activity and usage (as described above). Though we make every effort to preserve User privacy, we may need to disclose Your information to third parties in order to comply with a legal obligation such as a subpoena, warrant, judicial or administrative order, or as otherwise required by applicable law. We may also disclose information where We, in good faith, deem it appropriate or necessary to enforce or prevent a violation of Our Terms of Service, Privacy Policy, to address fraud, security or technical issues, to respond to an emergency, or to otherwise protect Our Services.
The Breakfast Correspondence
Correspondence sent to Us including emails and letters will be stored on Google G Suite with access limited to Our authorised staff members. Email correspondence is free format text and cannot be encrypted, therefore it is not a secure means of communication. Please do not send sensitive information, such as passwords or credit card information, via email. Although We collect and store the content of Your chats with other Users, We do not read those, unless We have particular request from responsible governmental bodies.
Your Password
You can only login to The Breakfast account and Our service with Your email and password. To protect the confidentiality of Your Personal Data, You must keep Your password confidential and never disclose it to any other person. Please notify Us immediately if You believe Your password has been misused. Please note, We will never ask You to disclose Your password.
Changes of Information
You control the Personal Data that You provide to Us in connection with the Services. However certain fields may be required for the provision of Services, we endeavor to retain Your Personal Data for as long as Your account is active or as needed to provide You with Services. We will also retain and use Your Personal Data as necessary to comply with Our legal obligations, resolve disputes, and enforce our agreements. You may access and update Your Data by logging into Your profile, choosing "Your profile" and "Edit profile" sections. You must make sure that You update Your information as soon as possible with all relevant changes.
Age Limitations
To the extent prohibited by applicable law, The Breakfast does not allow use of Our Services by anyone younger than 18, or other age, as it is stated by applicable law. If You learn that anyone younger than applicable legal age has unlawfully provided Us with Personal Data, please contact Us immediately and We will take all necessary steps to delete such information.
The Right To Be Forgotten
You can ask Us to erase Your Personal Data from Our Services if it is no longer necessary for the purpose for which it was submitted, You withdraw consent or You believe Your fundamental rights to data privacy and protection outweigh Our legitimate interest in continuing the processing. We may retain an anonymous history of User actions and profile (without Personal Data). Within 1 (one) month from Your request of deletion of information, The Breakfast deletes all information it posses about You. Please contact Us at: support@thebreakfast.app.
Right to Request Data, We Have about You
We can provide You with the information We maintain about You, namely: (1) profile data; (2) log data: all User actions in the system, data on his movements in chronological order; (3) User metrics that optimize the issue relevance that the system calculates based on the data. We promise to do our best and to process with the request during 1 (one) month.
Changes to This Policy
As the laws and standards evolve, as well as Our Services, We may, at Our sole discretion, revise this Privacy Policy and periodically update this document with the changes. We encourage You to review our Privacy Policy to stay informed. If We make changes that materially alter Your privacy rights, We will provide additional notice via email or through the Services. If You disagree with the changes to this Privacy Policy, You should stop using the Services and deactivate Your account and let Us know.
Governing Law
These Privacy Policy is governed by and construed in accordance with the laws of Portugal. All disputes arising out of or in connection with this Privacy Policy, shall be finally settled by arbitration according to the Rules of Arbitration of the Commercial Arbitration Center of the Portuguese Chamber of Commerce and Industry (Commercial Arbitration Center), by one or more arbitrator(s) appointed in accordance with the Arbitration rules. The language of arbitration shall be English. The place of arbitration shall be Lisbon.
Warranty
We take reasonable and appropriate measures to protect the Data We collect through the Services, including the implementation and maintenance of organizational, technical and administrative procedures to prevent unauthorized or unlawful access, disclosure or destruction. Users of the Services must also do their part in protecting the data, systems, networks and service they are utilizing. You are responsible for choosing a secure password when We ask You to set up a password to access parts of Our Website or Apps. You should keep this password confidential and You should choose a password that You do not use on any other website. Please always be sure You are not disclosing Your password and login details for Your account to someone else. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. As a result, while We strive to protect Your Data, We cannot ensure or warrant the security of any information You transmit to Us, and You use the Services and provide Us with Your information at Your own risk.

If by any chance You have reason to believe that Your Personal Data is no longer secure (for example, Your password may has been compromised), please immediately write to Us at support@thebreakfast.app.
We expressly disclaim any representation or warranty, whether express or implied, with respect to any breaches of security, damage to Your device, or any loss or unauthorized use of Your registration information or other data.
Right to Lodge a Complaint
You may contact the Inspector General for the protection of Personal Data, lodge a complaint or ask for explanations regarding basic principles of data privacy.

Portuguese: Comissão Nacional de Protecção de Dados.

Contact information:
Office of the Inspector General for the Protection of Personal Data Av. D. Carlos I, 134 — 1.º 1200−651 Lisboa.

The Office is open from Monday to Friday from 9:30 to 12:30 and from 14:00 to 18:00.
www.cnpd.pt

Telephone: (+ 351) 21 392 84 00
Fax: (+ 351) 21 397 68 32
e-mail: geral@cnpd.pt