Privacy policy

Last Updated: June 16, 2026

1. SCOPE AND INTRODUCTION

Coptiq Inc. and Coptiq Co. Ltd (collectively, "Breezm," "we," "us," or "our") operate the Breezm services. This Privacy Policy applies to our website and our two mobile applications available on the Apple App Store (together, the "Apps"):

- Breezm AI Fit Finder (the "AI App"): a free, ad-supported app that uses artificial intelligence to generate styled images and eyewear recommendations.
- Breezm: Eyewear Made For You (the "Commerce App"): a shopping app that allows users to scan their face and purchase custom-fit eyewear.

This Privacy Policy describes how we collect, use, and disclose your personal information when you visit our website or use either App. By accessing or using our services, you acknowledge that you have read and understand this Privacy Policy.

In this Privacy Policy, "personal information" means information that identifies or can reasonably be linked to you, such as your name, email, order history, device identifiers, or facial measurements when they are linked to you. It does not include data that has been de-identified or aggregated so that it cannot reasonably be used to identify you.

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2. DATA COLLECTION: BREEZM AI FIT FINDER (THE "AI APP")

The AI App allows you to generate images and receive style recommendations without creating a user account.

a. No directly identifying information collected

In the AI App, we do not collect your name, email address, phone number, or physical address. You are not required to log in or register to use the AI App.

b. Device ID and usage data

The AI App assigns a random "App Device ID" (or similar device identifier) to your installation. We also collect limited technical information such as device type, operating system version, app version, language, and in-app events (for example, screens visited, feature usage, crashes). This information helps us operate, secure, and improve the AI App and is generally used for analytics, security, and operational purposes rather than to directly identify individual users.

c. Facial data and AI processing

When you use the AI App, you may upload a selfie in order to:

- receive style and size recommendations for glasses, and/or
- generate AI-powered visual changes (for example, hairstyle or outfit changes).

Raw facial images and depth/3D sensor data captured by your device are processed locally on your device to detect your face and extract de-identified measurements and other numerical descriptors. These raw facial images and raw TrueDepth/Structure scan data are not sent to Breezm's servers and are discarded on your device after the on-device processing is complete.

For glasses style and size recommendations, only de-identified extracted data (such as facial measurements and related numerical descriptors that are not linked to your name or email) are sent to Breezm's servers.

For AI-powered selfie transformations (such as hairstyle or outfit changes), your selfie image and associated prompts are transmitted to third-party AI image-processing providers. These providers process the image on their own servers to generate the requested visual output. We require these providers to retain this data only for a limited period (for abuse monitoring and service quality) and to delete it after that period. They are prohibited by contract from using your data to train their models for unrelated purposes.

In some jurisdictions, facial measurements and related data may be considered biometric or sensitive information. Where required by law, we process this information only with your consent and solely to provide style and fit recommendations and related features in the AI App.

d. Advertising data

The AI App is supported by mobile advertising. If you grant permission via Apple's AppTrackingTransparency (ATT) framework, we may share device identifiers (such as the IDFA) and usage data with advertising partners (such as Google AdMob) so they can show and measure personalized ads. If you decline tracking permission, you may still see non-personalized ads based on contextual information (for example, content of the app, approximate region), but we will not track you across apps or websites.

e. Deletion for the AI App

Because we do not collect your name or email in the AI App, we cannot identify your records on our servers by your real-world identity. We can only locate your records using your App Device ID.

To request deletion of data associated with a specific AI App installation, you must:

- Open the AI App, look up your App Device ID from tapping on [Terms of Service] link from the initial screen, and
- Email us at contact@breezm.com with that App Device ID and a clear deletion request.

If you delete the AI App from your device before submitting a request, your App Device ID will change on reinstallation and we will no longer be able to associate remaining de-identified data on our servers with you. Any remaining de-identified AI App data that cannot be linked back to an App Device ID is retained only until our retention limit (described below) and then deleted or irreversibly de-identified.

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3. DATA COLLECTION: BREEZM COMMERCE APP (THE "COMMERCE APP")

The Commerce App supports the purchase of custom-fit physical eyewear and therefore requires more information to fulfill orders.

a. Contact and order information

When you proceed to checkout in the Commerce App or on our website, we collect:

- Name
- Email address
- Billing and shipping address
- Phone number (if you choose to provide it)
- Order details, such as items purchased, quantities, pricing, discounts, returns, and exchanges.

This information is collected and processed via our commerce partner, Shopify, and is linked to your order history and facial fit data so that we can manufacture and deliver your custom eyewear and assist you with re-orders and support.

We do not store full payment card numbers or security codes (CVV); these are processed by Shopify and its payment processors.

b. Facial data for manufacturing and fit

To create custom-fit eyewear, the Commerce App captures facial measurements and 3D scan data using your device's camera and depth-sensing technologies, such as Apple's TrueDepth camera and the Structure SDK.

Raw Structure and TrueDepth data (for example, depth maps and sensor readings) are processed on your device in real time. This raw sensor data is not sent to Structure.io and is not stored on Breezm's servers. It is discarded on-device after we derive facial measurements and 3D mesh information.

From this on-device processing, we derive:

- facial measurements (such as face width, nose height, nose length, temple distance), and
- 3D mesh or similar geometric data necessary to manufacture frames and lenses that fit your face.

Unlike in the AI App, these measurements and 3D mesh data in the Commerce App are linked to your email address, contact information, and order history. This linkage is necessary to manufacture, deliver, and support your custom eyewear and to support future re-orders.

We primarily use facial data from the Commerce App for:

- processing, manufacturing, fitting, and delivering your orders,
- storing your fit profile to support accurate re-orders and customer support,
- quality assurance and fit-related service improvements,
- fraud prevention, security, and operational integrity, and
- related business and operational purposes consistent with this Privacy Policy.

We do not sell or rent facial data or biometric information for monetary compensation.

In some jurisdictions, these measurements and 3D mesh data may be considered biometric or sensitive information. Where required by law, we process them only with your consent and for the Commerce App purposes described above.

c. Location and IP data

We process your IP address to determine your general geographic location (at the country level). This service is powered by IPinfo. We use this data solely to verify shipping eligibility and comply with local regulations regarding the sale of prescription lenses. We do not store this data to track your precise location.

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4. FACIAL DATA AND TRUEDEPTH / STRUCTURE SDK COMPLIANCE

Across both Apps, we strictly limit how we use facial data collected via Apple's TrueDepth API and the Structure SDK:

- Raw TrueDepth and Structure sensor data are processed on your device and discarded after we derive the necessary measurements and 3D mesh data.
- We do not send raw TrueDepth or Structure sensor streams to our servers or to Structure.io.
- We do not use facial data for user authentication (such as replacing Face ID) or for surveillance.
- We do not sell or rent facial data or biometric information for monetary compensation.

For the AI App, de-identified extracted data (such as numerical measurements) may be sent to Breezm's servers for style and size recommendations. For the Commerce App, facial measurements and 3D mesh data are sent to Breezm's servers and linked to your email and order history for the purposes described in Section 3(b), including manufacturing, fulfillment, fit support, quality assurance, security, and related operational purposes.

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5. HOW WE SHARE INFORMATION

We may disclose information to the following categories of third parties:

a. AI and image processing providers (AI App)

We share uploaded images with AI service providers (such as LightX or OpenAI) solely to generate the requested image outputs. These providers retain data for a limited period to monitor for abuse and service quality, and are contractually prohibited from using your data to train their own models or for marketing purposes. These providers may process your data on servers located in the United States or other countries. Where required by law, we use appropriate safeguards (such as contractual data protection terms) to protect your information during these transfers.

b. Commerce and fulfillment partners (Commerce App)

We share your name, email address, billing and shipping address, order details, and facial fit data with Shopify (our e-commerce platform) and with logistics and fulfillment partners to process payments, manufacture your custom eyewear, and ship your products.

c. Relationship with Shopify

Our online store is hosted and powered by Shopify. Shopify collects and processes personal information about your access to and use of the store to provide and improve the Services. Information you submit through the store is transmitted to and shared with Shopify, and may be processed in countries outside of where you reside (for example, in the United States or Canada). To provide certain enhanced commerce features (such as fraud prevention and cross-merchant analytics), Shopify may use information about your interactions with our store along with information from other merchants. In those cases, Shopify is responsible for that processing and for handling related privacy-rights requests.

For more information about how Shopify uses your personal information and any rights you may have with respect to Shopify, please see the Shopify Consumer Privacy Policy at https://www.shopify.com/legal/privacy and the Shopify Privacy Portal at https://www.shopify.com/legal/privacy/dpa.

d. Advertising, Analytics, Attribution, and Marketing Partners

We may use third-party advertising, analytics, attribution, affiliate marketing, and marketing technology providers to help us operate, improve, analyze, and promote our Services.

These providers may include providers such as Google, YouTube, Meta (including Facebook and Instagram), Shopify, AppsFlyer, affiliate marketing networks, analytics providers, advertising partners, and similar service providers.

Depending on the Services you use, your device settings, and applicable law, these providers may collect or receive information such as:

- device identifiers (including IDFA, GAID, app instance identifiers, cookies, and similar identifiers),
- IP address,
- browser and device information,
- operating system and app version,
- referral URLs and campaign identifiers,
- approximate geographic information,
- app usage information,
- conversion and purchase events,
- interactions with advertisements or content,
- crash reports and performance data.

We and our service providers may use this information to:

- operate and improve the Services,
- measure app and website performance,
- analyze usage trends and customer engagement,
- personalize content and advertisements,
- measure the effectiveness of advertising campaigns,
- attribute installs, purchases, or other conversions to marketing campaigns or referral sources,
- create audience segments and advertising campaigns,
- prevent fraud, abuse, and unauthorized activity,
- support affiliate and referral programs,
- maintain security and reliability.

Some of these providers may use cookies, SDKs, pixels, local storage, APIs, or similar technologies to collect and process information across websites, apps, and devices.

Where required by applicable law or platform requirements, we will request appropriate consent before enabling certain advertising or tracking technologies. For example, on Apple devices, tracking activities that rely on advertising identifiers may be subject to Apple's AppTrackingTransparency framework.

You may be able to limit certain tracking activities by:

- adjusting your device privacy or advertising settings,
- disabling cookies in your browser,
- using browser privacy controls such as Global Privacy Control (GPC),
- declining AppTrackingTransparency permissions on supported devices,
- using opt-out tools provided by third-party advertising or analytics providers.

For more information about how third-party providers process information, please review their respective privacy policies.

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6. DATA RETENTION

a. Facial data

We retain facial data (including facial measurements, 3D mesh data, and extracted de-identified descriptors) for up to six (6) years from the date of collection, or until you request deletion, whichever comes first.

For the AI App, if you request deletion via email with your App Device ID, we will delete or de-identify data associated with that ID within 30 days.

For the Commerce App, if you request deletion of your account, we will delete data associated with your email address within 30 days, except where we are required to retain it for legal, tax, or compliance purposes.

If you uninstall the AI App or delete your Commerce App account, any remaining de-identified data on Breezm's servers is retained only in de-identified or aggregate form until the end of the retention period, after which it is deleted or irreversibly aggregated.

b. All other personal information

We retain your personal information (excluding facial fit data) for as long as necessary to:

- fulfill your orders and provide customer support and re-orders,
- comply with legal obligations (such as tax and accounting records),
- resolve disputes and enforce our agreements, and
- support legitimate business purposes.

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7. LEGAL BASIS FOR PROCESSING (GDPR / UK GDPR)

Where required by applicable law (such as GDPR or UK GDPR), we process your personal information on the following legal bases:

a. Contract

We process your contact information, payment information, and facial data in the Commerce App as necessary to fulfill our contract with you (to manufacture and deliver your custom eyewear).

b. Legitimate interests

We process technical information (device type, OS version, usage events) and de-identified facial data to operate, secure, and improve our Apps and services.

c. Consent

In the AI App, we process facial data only with your explicit consent. In the Commerce App, where required by law, we process facial measurements and 3D mesh data as sensitive/biometric information only with your explicit, informed consent. We also rely on consent for marketing communications and ATT-style tracking (where you grant permission in device settings).

d. Legal obligation

We may disclose information if required by law, such as to comply with a subpoena or legal process, or to protect our rights, privacy, safety, and security of our users, or the public.
Depending on applicable law and user location, processing may be based on consent, legitimate interests, or contractual necessity.

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8. YOUR RIGHTS AND CHOICES

We strive to use service providers and integrations that support applicable privacy and data protection requirements, including GDPR, CPRA/CCPA, and PIPEDA. You retain the right to access, rectify, or delete your data associated with these services at any time by contacting our privacy team.

Depending on where you live, you may have some or all of the following rights with respect to your personal information (subject to legal limits and exceptions):

a. Right to access or know

You have the right to request access to the personal information we hold about you.

b. Right to delete or erasure

You have the right to request deletion of personal information we maintain about you. For the AI App, please email contact@breezm.com with your App Device ID. For the Commerce App, please visit Menu > My Orders > Settings > Remove Account or contact us.

c. Right to correct or rectify

You have the right to request correction of inaccurate personal information we hold about you.

d. Right to data portability (Limitations Apply)

You have the right to request a copy of the personal information you have explicitly provided to us (such as your contact details, shipping address, and order history) in a structured, machine-readable format.

PLEASE NOTE: This right does not extend to our proprietary facial measurements, 3D meshes, fit parameters, or derived facial data. These data points are generated using our unique internal algorithms for manufacturing purposes and are not interoperable with other service providers.

e. Right to opt out of targeted advertising and sales/sharing

Depending on where you live, you may have the right to opt out of:

- personalized advertising based on your online activity with different merchants (under CCPA/CPRA or state privacy laws),
- the "sale" or "sharing" of your personal information as defined by applicable law.

You can opt out by:

- clicking the opt-out link in our marketing emails,
- adjusting your device's advertising settings, or
- using your browser's privacy signals (such as Global Privacy Control) where supported.

f. Right to object or restrict processing (UK/EEA)

If you are in the UK or European Economic Area, you may have the right to object to or request restriction of our processing of your personal information for certain purposes.

g. Right to withdraw consent (UK/EEA)

If we rely on consent to process your personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.

h. Right to lodge a complaint

If you are in the UK or European Economic Area and believe we have violated your rights, you may lodge a complaint with your local data protection authority. A list of supervisory authorities is available from the European Data Protection Board at https://edpb.ec.europa.eu/.

i. Global Privacy Control

If you visit our website with the Global Privacy Control (GPC) opt-out preference signal enabled, where required by law we will automatically treat this as a request to opt out of targeted advertising and other data practices for that browser or device.

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9. CHILDREN'S PRIVACY

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at contact@breezm.com so that we can delete it.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we "sell" or "share" (as those terms are defined in applicable privacy laws) personal information of individuals under 16 years of age.

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10. SECURITY

We use industry-standard technical and organizational measures to protect your data against unauthorized access, use, alteration, or destruction. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security. Information sent over the internet may not be secure in transit; please avoid sending highly sensitive information over unencrypted channels.

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11. INTERNATIONAL TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence, such as the United States, where our servers and service providers are located. When we transfer personal information from the European Economic Area or the United Kingdom to countries outside those regions, we rely on recognized transfer mechanisms such as the European Commission's Standard Contractual Clauses or UK-approved equivalents, unless the destination country has been determined to provide an adequate level of protection.

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12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our practices or for operational, legal, or regulatory reasons. When we do:

- We will post the revised policy on this page and update the "Last Updated" date above.
- Where required by law, we will provide additional notice (for example, via prominent notice on the Services or by other appropriate means).

Your continued use of the Services after any changes become effective means you accept the updated policy.

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13. CONTACT US

If you have questions about this policy or our privacy practices, or if you would like to exercise any of your rights, you can contact us at:

Email: contact@breezm.com

Postal Address:
Coptiq Inc. / Breezm
526 7th Avenue, 8th Floor
New York, NY 10018
United States

For purposes of applicable data protection laws, Breezm is the data controller of your personal information in connection with the Services.

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