Privacy policy

BREGGZ — PRIVACY POLICY

Last Updated: May 11, 2026
Effective Date: May 11, 2026

1. INTRODUCTION

1.1. Breggz Hearables B.V. ("Breggz," "we," "us," or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website (www.breggz.com), purchase our Products, or otherwise interact with us.

1.2. Breggz Hearables B.V. is the data controller responsible for your personal data.

1.3. Registered Address: Breggz Hearables B.V., Keizersgracht 165, 1016 DP Amsterdam, the Netherlands
KvK Number: 83777903

Contact Email for Privacy Matters: privacy@breggz.com

1.4. This Privacy Policy applies to all individuals worldwide, including those located in the European Economic Area (EEA), the United Kingdom (UK), the United States of America (USA), and any other country from which you access our services.

1.5. We comply with:

The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679);
The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018;
The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA);
Other applicable US state privacy laws, including the Maryland Online Data Privacy Act, Virginia CDPA, Colorado CPA, Connecticut CTDPA, and others as enacted;
The Dutch Telecommunications Act (Telecommunicatiewet) for cookies and electronic communications;
Other applicable data protection and privacy laws worldwide.

2. WHAT PERSONAL DATA WE COLLECT

2.1. We collect and process the following categories of personal data:

(a) Information You Provide Directly or results from your activities

Identity Data: First name, last name, title.
Contact Data: Email address, postal/delivery address, telephone number.
Account Data: Username, password (encrypted), account preferences.
Transaction Data: Payment details (processed securely by third-party payment providers — we do not store full card numbers), order history, purchase amounts, currency, date and time of transactions.
Communication Data: Correspondence with our customer service team, feedback, reviews, survey responses.
Voice Data: Data relating to the sound of your voice, such as for voice control functionalities, exclusively when using the Breggz app.

(b) Information Collected Automatically

Technical Data: IP address, browser type and version, operating system, device type, screen resolution, time zone setting, and language preferences.
Usage Data: Pages visited, clickstream data, referring URLs, duration and frequency of visits, products viewed, search queries on our site.
Location Data: Approximate geographic location based on IP address.
Cookie and Tracking Data: Information collected via cookies, pixel tags, and similar technologies. See Section 8 below.

(c) Information from Third Parties

Payment Processors: Transaction confirmation data from providers such as Klarna, iDEAL, Apple Pay, Bancontact, Stripe, PayPal, Adyen.
Shipping Partners: Delivery status and tracking information.
Analytics Providers: Aggregated website usage data from services such as Google Analytics.
Marketing Partners: Information about interactions with our advertisements on third-party platforms.
Social Media: If you interact with us on social media platforms, we may receive publicly available profile information.

2.2. If you use the Breggz app, we may process:

Hearing Data: Data on your hearing abilities, exclusively when using the Breggz app.

When you use certain functionalities within the Breggz app, we may collect information relating to your hearing abilities to carry out these functionalities. As the use of Hearing Data may reflect health information, we will process Hearing Data with your explicit consent. Your consent is voluntary. You can withdraw your consent at any time. If you withdraw your consent, you are no longer able to use the corresponding functionalities of the app, such as the personalisation of your sound profile.

Hearing Data is not shared with advertisers, data brokers, insurers, or similar parties. We only share Hearing Data with cloud infrastructure processors, the supplier of the Breggz app, or the supplier of the specific functionality related to the Hearing Data. These parties are bound by a data-processing agreement.

3. HOW AND WHY WE USE YOUR PERSONAL DATA

3.1. We process your personal data for the following purposes and on the following legal bases:

Purpose	Categories of Data	Legal Basis (EU/UK GDPR)
Processing and fulfilling your Orders	Identity, Contact, Transaction	Performance of a contract
Managing your account	Identity, Contact, Account	Performance of a contract
Processing payments	Transaction	Performance of a contract; Legal obligation
Delivering Products and providing shipping updates	Identity, Contact, Transaction	Performance of a contract
Communicating with you about your Order or account	Identity, Contact, Communication, Account	Performance of a contract
Providing customer support	Identity, Contact, Communication, Account	Performance of a contract; Legitimate interest
Fraud prevention and security	Identity, Contact, Technical, Transaction, Account	Legitimate interest; Legal obligation
Website analytics and improvement	Technical, Usage, Cookie	Legitimate interest, with consent for non-essential cookies
Marketing communications (email, SMS)	Identity, Contact	Consent. You may opt out at any time.
Personalising your experience on our Website	Technical, Usage, Account	Consent or Legitimate interest
Complying with legal and regulatory obligations	May include all Data categories, whichever is applicable	Legal obligation
Responding to legal claims and proceedings	May include all Data categories, whichever is applicable	Legal obligation; Legitimate interest
Performance of activities / providing you App services	Identity, Contact, Hearing Data, Technical Data	Performance of a contract; Explicit consent, which you may withdraw at any time, in case of Hearing Data

3.2. Marketing Communications: We will only send you marketing communications where you have given your explicit, freely given opt-in consent. You may withdraw your consent at any time by clicking the "unsubscribe" link in any marketing email, updating your account preferences, or contacting us at privacy@breggz.com.

3.3. Legitimate Interest: Where we rely on legitimate interest, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms.

4. WHO WE SHARE YOUR DATA WITH

4.1. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

Payment Processors: e.g. Klarna, iDEAL, Apple Pay, Bancontact, Stripe, PayPal, Adyen — to process your payments securely.
Shipping and Logistics Partners: e.g. DHL, UPS, FedEx, PostNL, Royal Mail, USPS — to deliver your Orders.
Website Hosting and Infrastructure Providers: HubSpot, Shopify, AWS, Cloudflare — to operate our Website.
Analytics Providers: HubSpot, Google Analytics — to understand Website usage. Data is aggregated/anonymised where possible.
Customer Service Platforms: HubSpot, tawk, Tidio, Crisp, WhatsApp, Zendesk, Intercom, Lyro, Freshdesk, Help Scout, Mention, Brand24, Mentionlytics, Hootsuite, Brandwatch — to manage customer enquiries.
Email Marketing Platforms: HubSpot, Mailchimp, Klaviyo — to send marketing communications with consent.
Professional Advisers: Accountants, auditors, legal counsel — where necessary for business operations or legal compliance.
Law Enforcement and Regulatory Bodies: Where required by law or to protect our legal rights.

4.2. We do not sell your personal data to third parties.

4.3. We require all third-party service providers to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. INTERNATIONAL DATA TRANSFERS

5.1. As Breggz is based in the Netherlands and serves customers globally, your personal data may be transferred to, and processed in, countries outside your country of residence, including countries outside the EEA and the UK.

5.2. Where we transfer personal data outside the EEA or the UK, we ensure an adequate level of protection through one or more of the following safeguards:

Transfers to countries with an adequacy decision from the European Commission or the UK Secretary of State;
Standard Contractual Clauses (SCCs) approved by the European Commission;
UK International Data Transfer Agreements (IDTAs) or the UK Addendum to the EU SCCs;
Other appropriate safeguards as required by applicable law.

5.3. USA Transfers: For transfers of personal data to the United States, we rely on the EU-U.S. Data Privacy Framework where the recipient is certified and, in case of UK data subjects, has opted into the UK-specific extension to the Framework, or on Standard Contractual Clauses where not.

5.4. You may request a copy of the relevant safeguards by contacting privacy@breggz.com.

6. DATA RETENTION

6.1. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.

6.2. Specific retention periods:

Data Category	Retention Period
Order and transaction data	7 years from the date of the transaction (Dutch fiscal/legal requirements)
Account data	Duration of your account, plus 2 years after closure
Marketing consent records	Duration of consent, plus 1 year after withdrawal
Customer service communications	3 years from the date of the last communication
Website analytics data	26 months. Anonymised/aggregated data may be retained longer.
Cookie data	As specified in our Cookie Policy. See Section 8.
Voice Data	Duration of your account and deleted within a reasonable period after closure
Hearing Data	We will delete your data if you withdraw your consent in the app, if your account is deleted, or if you have not been actively using the app for a reasonable period of time.

6.3. When we no longer need your personal data, we will securely delete or anonymise it.

7. YOUR RIGHTS

7.1. Rights Under the EU GDPR and UK GDPR

If you are in the EEA or the UK, you have the following rights:

Right of Access: You may request a copy of the personal data we hold about you. We are permitted to provide you with an overview of your data and are not obligated to provide a copy of the documents or communications that include your personal data.
Right to Rectification: You may request correction of inaccurate or incomplete personal data.
Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where there is no reason for continued processing, such as when there is no legal obligation to continue the processing.
Right to Restriction of Processing: You may request that we restrict processing of your personal data in certain circumstances.
Right to Data Portability: You may request to receive your personal data in a structured, commonly used, machine-readable format and have it transmitted to another controller.
Right to Object: You may object to processing based on legitimate interests, including direct marketing.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects.

To exercise any of these rights, contact us at privacy@breggz.com. We will respond within one month, or, if we extend the response term and notify you within the first month, within two months in case of complex or a high number of requests. We may require proof of identity in order to fulfil your request.

If you are unsatisfied with our response, you have the right to lodge a complaint with a supervisory authority:

Netherlands: Autoriteit Persoonsgegevens (https://autoriteitpersoonsgegevens.nl)
United Kingdom: Information Commissioner's Office (ICO) (https://ico.org.uk)
Other EU Member States: Your local data protection authority.

7.2. Rights Under US Privacy Laws

California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the purposes of collection, and the categories of third parties to whom we have disclosed your personal information, covering the preceding 12 months.
Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
Right to Correct: You may request correction of inaccurate personal information.
Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioural advertising. Breggz does not sell personal information. We do not share personal information for cross-context behavioural advertising.
Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to only what is necessary for performing our services.
Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

To submit a request: Email privacy@breggz.com or use the form on our Website. We will verify your identity and respond within 45 days, extendable by an additional 45 days where necessary.

Categories of Personal Information Collected in the Prior 12 Months:

Identifiers, including name, email, postal address, phone number, and IP address.
Commercial information, including purchase history and Products purchased.
Internet/electronic network activity, including browsing history on our Website and device information.
Geolocation data, approximate and derived from IP address.
Inferences drawn from the above categories.

We do not sell or share personal information as defined under the CCPA/CPRA.

Other US States

Residents of Virginia, Colorado, Connecticut, Maryland, and other states with enacted privacy legislation may have similar rights as those set out above in this paragraph 7.2, including the right to access, correct, delete, and opt out of targeted advertising or data sales. To exercise these rights, contact privacy@breggz.com.

7.3. Rights for International Customers

If you are located outside the EEA, UK, or USA, you may have rights under the data protection laws of your jurisdiction. We will respond to requests in accordance with applicable local law. Please contact privacy@breggz.com with any requests.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1. Our Website uses cookies and similar technologies. A cookie is a small text file placed on your device when you visit our Website.

8.2. We use the following types of cookies:

Type	Purpose	Duration	Consent Required
Strictly Necessary	Essential for Website operation, e.g. session management, shopping cart, security	Session / up to 1 year	No, required for the Website to function
Functional	Remember your preferences, e.g. language, region	Up to 2 years	Yes
Analytics / Performance	Understand how visitors use our Website, e.g. Google Analytics	Up to 26 months	Yes
Marketing / Advertising	Deliver relevant advertisements and measure their effectiveness	Up to 2 years	Yes

8.3. Consent: When you first visit our Website, we will present a cookie consent banner allowing you to accept or decline non-essential cookies. You may change your cookie preferences at any time through the cookie settings link in the banner at the bottom of our Website.

8.4. Do Not Track / Global Privacy Control: We honour Do Not Track (DNT) signals and Global Privacy Control (GPC) signals sent by your browser. When we detect a GPC signal, we will treat it as a valid request to opt out of the sale or sharing of personal information, where applicable under CCPA/CPRA and similar US state laws.

8.5. You may also manage cookies through your browser settings. Note that disabling cookies may affect the functionality of our Website.

8.6. For further details, please see our Cookie Policy. A regularly updated cookie list, including name, provider, purpose and duration, is accessible via the cookie settings link in our banner at the bottom of our Website.

9. SECURITY

9.1. We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

Encryption of data in transit (SSL/TLS) and at rest;
Secure payment processing through PCI-DSS-compliant third-party providers;
Access controls and authentication measures;
Regular security assessments and monitoring;
Staff training on data protection practices.

9.2. While we take all reasonable precautions, no data transmission over the internet or electronic storage system is completely secure. We cannot guarantee the absolute security of your data.

10. CHILDREN'S PRIVACY

10.1. Our Website and Products are not directed at children under the age of 16, or the applicable minimum age in your jurisdiction. We do not knowingly collect personal data from children under 16. If we learn that we have inadvertently collected personal data from a child under 16, we will delete that data as soon as practicable.

10.2. If you are a parent or guardian and believe your child has provided us with personal data, please contact privacy@breggz.com.

11. THIRD-PARTY LINKS

11.1. Our Website may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to those third-party services. We encourage you to read the privacy policies of any third-party sites you visit.

12. CHANGES TO THIS PRIVACY POLICY

12.1. We may update this Privacy Policy from time to time. When we make material changes, we will notify you by posting the revised policy on our Website with an updated "Last Updated" date and, where appropriate, by email.

12.2. We encourage you to review this Privacy Policy periodically.

13. DATA PROTECTION OFFICER / PRIVACY CONTACT

13.1. For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

Privacy Contact / Data Protection Point of Contact
Breggz Hearables B.V.
Keizersgracht 165, 1016 DP Amsterdam, the Netherlands
Email: privacy@breggz.com

13.2. If Breggz appoints a Data Protection Officer (DPO) in the future, their details will be published here.

14. UK REPRESENTATIVE

14.1. For the purposes of the UK GDPR, our representative in the United Kingdom is:

To be appointed. In the interim, please contact privacy@breggz.com.

15. EU REPRESENTATIVE

15.1. As Breggz Hearables B.V. is established in the Netherlands, an EU Member State, no separate EU Representative is required under Article 27 of the GDPR.