Privacy Policy

1. About This Policy

This Privacy Policy (the “Policy”) describes the information Bree Technologies, Ltd. collects about you, how we use and share that information, and the privacy choices we offer. This Policy applies to information we collect when you register for Bree, access or use our website, mobile applications, products, and services (collectively, the "Services"), or when you otherwise interact with us.

The terms “Bree,” “we,” “us,” or “our” mean Bree Technologies, Ltd. “You” or “your” means an individual who visits or uses our Services. The term "Site" includes (1) all websites and all devices or mobile applications operated by Bree that collect personal information from you and that link to this Privacy Policy; (2) pages within each such website, device, or mobile application, any equivalent, mirror, replacement, substitute, or backup website, device, or mobile application; and (3) all pages within each such website, device, or mobile application.

“Bank Connection Providers” means third-party services we use to connect to your financial institution and retrieve your financial data, such as Plaid Inc. (“Plaid”) and Flinks Technology Inc. (“Flinks”).

2. Information We Collect and Disclose

We collect personal information about you for a variety of purposes, including to provide and improve the Services, verify your information, prevent fraud, and communicate with you. During the past 12 months, we have collected the following categories of personal information:

• Personal Identifiers, such as a full name, postal address, email address, online usernames and account login information
• Professional or employment-related information.
• Commercial information, such as products or services purchased, obtained, or used.
• Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics.
• Financial information, such as bank account and debit card information (including account or card details and transaction history) and related account metadata made available through your use of the Services.
• Communications with us, such as support messages, chatbot transcripts, and related metadata.

During the past 12 months, we have also disclosed the categories of personal information listed above for our business purposes as set out in Section 4 (How We Share Your Information). We have not, however, sold personal information to third parties.

2.1 Third Party Credentials, Bank Connection Providers, and Other Account Information

When you use certain Services, you may choose to connect your financial institution account using a Bank Connection Provider. Depending on your financial institution and the connection method, you may be asked to provide your online banking credentials or other information through the Bank Connection Provider’s interface so that the Bank Connection Provider can retrieve account and transaction information from your financial institution. You recognize that your relationship and any services provided by the Bank Connection Provider are solely between you and the Bank Connection Provider. Bree is not responsible for the acts or omissions of any Bank Connection Provider.

Bree receives and uses the information made available through the Bank Connection Provider to provide and improve the Services, including verifying your accounts and assessing eligibility, preventing fraud, and displaying information to you. This may include information such as financial institution name, account details, transaction history, connection status, and related metadata.

By using our Services and choosing to connect a financial institution account using a Bank Connection Provider, you authorize Bree and the applicable Bank Connection Provider to access and transmit information from your financial institution on your behalf. Your personal and financial information may be transferred to, stored by, and processed by the Bank Connection Provider in accordance with its privacy policy (Flinks, Plaid).

Bree does not ask you for, and our customer support teams will never request, your online banking password.​

2.2 Information Collected by Cookies and Web Beacons

We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon.

2.3 Technical and Navigational Information

We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.

2.4 Device ID

When you use our mobile applications or the mobile versions of our Site, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the "Device ID"). Device IDs allow app developers, and others to uniquely identify your device for purposes of storing application preferences and other data.

3. How We Use Your Information

We may use the information you provide about yourself to fulfill your requests for our products, programs, and Services, to respond to your inquiries about our Services, and to offer you other products, programs, or services that we believe may be of interest to you.

We may use your information to complete transactions you request, to verify the existence and condition of your accounts, or to assist with a transaction. For example, we may use the account information you provide or that we collect from Third-Party Sites to confirm your accounts are valid and to access funds from your accounts in connection with fulfillment of the Services.

3.1 Use of AI and Automated Tools

We may use automated tools, including artificial intelligence and machine learning, to help operate, secure, and improve the Services. This may include using these tools to (a) detect, investigate, and prevent fraud or other suspicious activity; (b) protect the security of our users, Sites, and Services; (c) improve operational quality, including quality assurance and internal review; and (d) provide

customer support features such as chatbots and support automation (for example, to help answer questions, route requests, or take actions you request where available).

We do not rely on AI tools to make final decisions in isolation where a decision has a significant impact on you. Where appropriate, decisions may be reviewed by a human. If you have any questions about our use of AI tools, you may contact us at support@trybree.com.

4. How We Share Your Information

We may share personal information about you as follows:

• With service providers that help us operate, maintain, secure, and improve the Services (for example, hosting, analytics, customer support tools, fraud prevention, and customer support automation, including chatbot and AI-based tools). These providers may process personal information on our behalf and are subject to contractual obligations to protect any such personal information and to use it solely to provide services to Bree.
• In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
• To comply with law and legal processes, including responding to subpoenas, court orders, or other lawful requests.
• To protect rights, safety, and security, including to investigate, prevent, defend against, or take action regarding suspected fraud, violations of our Terms of Use, illegal activities, or threats to the legal rights or physical safety of any person, or to the security of our network, Sites, or Services.
• To respond to claims that any posting or other content violates the rights of third parties.
• In an emergency, to protect the health and safety of our Sites’ users or the general public.
• As otherwise required by law.

Where feasible, we limit the personal information shared to what is necessary for the specific purpose and to meet our obligations under law. We may use de-identified or aggregated data where appropriate.

5. How We Secure Your Information

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. Examples of measures we have taken to protect your information include, but are not limited to:

• The use of industry standard encryption while transmitting and storing information.
• Passwords are only known by you. No employee, contractor or Third-Party Site has access to your Bree password. We will never ask for your password through our customer service teams.

6. Note on Communication

We may provide you with information and summaries of your accounts and Services through email. We may also allow you to subscribe to email newsletters and from time to time may transmit emails to you promoting Bree or third-party goods or services.

Subscribers have the ability to opt out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as information and summaries of your accounts and Services.​

7. How to Update Your Information

If you wish to access personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information through our Site. Alternatively, you can send an email that includes your contact information to support@trybree.com to request any corrections to your personal information.

You may also email us if you wish to deactivate your Services, but even after you deactivate your Services, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

8. How We Update Our Privacy Policy​

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our Terms of Use and Privacy Policy at any time via links on www.trybree.com. You agree to accept electronic communications and/or postings of revised versions of this Policy on www.trybree.com and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.