Legal

Privacy

Effective: October 20, 2026

Welcome to our website. This Privacy Statement describes the types of information that Breakthrough Sales Corp. or its subsidiaries or affiliates (“Breakthrough,” “we” or “us”) collects from and about our customers and their corporate representatives (our “Customers”) on our website, www.breakthroughsales.io (collectively, the “Services”). Our Services and the services we provide are aimed at companies and their representatives and not at individual consumers or households.

Your privacy is important to us. This Privacy Statement is for informational purposes and sets forth our policy with respect to the collection, use and disclosure of business information that we collect when engaging with prospective and existing Customers and their representatives (the “Customer Representatives”) and from Customers' employees or others who are authorized to use the Breakthrough products and services (the “Authorized Users”) when we provide our services. By using the Services, or engaging us to provide our services, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement. Breakthrough is a controller of Customer Representative Data and acts as a processor, or “service provider,” with respect to Customer Data it receives and processes on behalf of its corporate Customers.

Breakthrough provides an AI-enabled platform that helps business-to-business companies capture, organize, and apply institutional knowledge to support their sales and go-to-market operations.

Use of Artificial Intelligence. Breakthrough's platform uses artificial intelligence and machine learning technologies to process, analyze, and organize information provided by Customers in connection with their sales and go-to-market activities. Breakthrough acts as a service provider and processor with respect to the Customer Data it processes through these AI features; Breakthrough does not use AI to interact directly with, or make automated decisions about, individual consumers on its own behalf.

Breakthrough collects identifiable information from and about Customer Representatives, including Customer employees whose information is shared with Breakthrough by our Customer in order for Breakthrough to market and sell its services (the “Customer Representative Data”). Breakthrough also collects information about those who have access to Breakthrough's products or services on behalf of one of our Customers (“Authorized User Data”) as well as information that our Customers submit, upload, or otherwise transmit to Breakthrough for processing on their behalf — including recordings and transcripts of sales and business meetings, CRM records, internal business documents, and information about our Customers' own corporate customers, prospects, and contacts (the “Submitted Data,” as defined in our Terms of Service). The Submitted Data, together with the Authorized User Data, is referred to in this Privacy Statement as the “Customer Data.” When Breakthrough collects and uses Customer Data on behalf of its Customers in order to provide our services, which is governed by our agreements with our Customers, Breakthrough is generally a processor, or “service provider” and not a controller, of that Customer Data.

Breakthrough does not receive consumer household information from its Customers, nor does it sell or share Customer Representative information with third parties (excluding subprocessors).

By accessing or using the Services, you consent to the information collection, disclosure and use practices described in this Privacy Statement. Certain features or services referenced in this Privacy Statement may not be offered on the Services at all times. Please also review our Terms of Service, which governs your use of the Services, and which is accessible at https://app.breakthroughsales.io/terms-and-conditions.

Breakthrough is not currently subject to those US state consumer privacy laws that exempt business-to-business activities, including but not limited to: the Colorado Privacy Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Florida Digital Bill of Rights, Indiana Data Privacy Law, Iowa Data Protection Act, Kentucky Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Data Privacy Act, New Jersey Data Protection Act, Oregon Consumer Privacy Act, Rhode Island Data Privacy Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act. Breakthrough also does not currently meet the threshold requirements of the California Consumer Privacy Act.

Your Privacy Rights

If you are a Customer Representative, Authorized User or corporate customer and would like to exercise your rights or opt-out of Breakthrough processing your information on behalf of a Customer because your employer has a contractual relationship with us, you may need to contact your employer to exercise your rights, which may include sharing your information with our subprocessors, please contact your employer directly in order to exercise your privacy rights.

Even though Breakthrough does not meet the thresholds of the above states, Breakthrough does recognize Customer Representatives’ rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales, if applicable
Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

We will only use personal information provided in a verifiable consumer opt-out request to verify the requestor’s identity or authority to make the request. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer opt-out request related to your personal information.

You do not need to create an account with us to exercise your opt-out rights. We will only use and retain personal information provided in an opt-out request to review and comply with the request. Please note that if your information was collected on behalf of or by a Customer, you must submit your request directly to that Customer.

To the extent Breakthrough's AI-enabled services are used by Customers that operate in the European Union or European Economic Area, those Customers, as deployers of Breakthrough's platform, are responsible for ensuring that their use of Breakthrough's AI features complies with applicable requirements under Regulation (EU) 2024/1689 (the EU AI Act) and any other applicable law, including obtaining any required consents and providing any required notices to their own employees, customers, and contacts whose information is processed through the platform. Breakthrough supports its Customers' compliance obligations by providing relevant technical and operational information about its AI features upon request. If you are a visitor from the UK, EEA or Switzerland, please click here to review your additional privacy rights.

Breakthrough relies on its Customers to have obtained all necessary authorizations, consents, and legal bases required to share information about their own corporate customers, prospects, and other contacts with Breakthrough for processing. Breakthrough uses such information solely in accordance with each Customer’s written instructions and has no direct relationship with, or obligation to, the individuals whose data is contained in Customer Data.

Information Collection

Customer Representatives

If you access our services through your employer, the use of your information by Breakthrough is subject to our agreement with them.

We collect personal information about Customer Representatives in a range of forms, including personal business information, when they choose to provide it to us. Personal information (or personal data) means information about an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when Customer Representatives contact us with inquiries or otherwise contact us.

We collect business contact information from Customer Representatives or other Customer employees including name, address, email address, telephone number, mobile telephone number or geolocation information or any other information they provide while using our Services on behalf of a Customer, such as login or password. We may also receive information from our Customers in connection with providing the Services, including data about their sales activities, customer interactions, and other information related to their go-to-market operations.

We may only be able to change how we share personal information of Customer Representatives in accordance with our agreement with our Customers or our Customer’s instructions. The Customer decides how the information you provide is collected and used, including what is shared with us for our use. Your use of the Services are subject to this privacy statement and Terms of Service, as well as the contract with our Customer. If you have questions about the collection and use of your information, please contact the Customer, who may be your employer.

If Customers make purchases through the Services, they may provide certain payment information, such as payment card or other financial account information, and billing address. A third-party payment processor collects and processes that information directly from our Customers in order to process payments on our behalf; we do not collect or retain your payment information.

The Services are designed for business-to-business use and are not intended to collect sensitive or special categories of personal information about Customer Representatives, Authorized Users, or any other individuals. Customers should not share such information with Breakthrough, and any such information shared with us will be handled only in accordance with our agreements with our Customers.

If a Customer Representative provides us with the name of their company, we may use the name of the company (but not other information) on a list of current or former customers for promotional purposes.

If you use a third party service to link to us or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services.

Authorized User Notice

If you are an employee or service provider of one of our Customers (or of a wholly or majority-owned subsidiary of a Customer) who has been authorized by that Customer to access Breakthrough's products or services, you are considered an “Authorized User” under our Customer’s contract with us. We collect Authorized Users’ personal information on behalf of our Customers and our Customers decides how the information is collected and used, including what is shared with us for our use. Your device activities are subject to our privacy statement and terms of use, as well as the contract with our Customer. If you have questions about the collection and use of your information on a Services as part of services we provide to a Customer, please contact the Customer, who may be your employer.

On behalf of our Customers, we collect information from and about Authorized Users, including your first name, last name, email address, user name, device identifiers (including employee name), internet activity information such as website URLs and domains, IP addresses and other metadata from websites, characteristics of websites and browsing activity, and general geographic location or any other information required to collect while using the services that we provide to a Customer. We may only be able to change how we share personal information of Customer Representatives in accordance with our agreement with our Customers or our Customer’s instructions. We expect our Customers to notify Authorized Users about the types of information we collect on our Customers' behalf. All use of our Services are subject to our Acceptable Use Policies. Please do not share information with us if you do not want us to process it on behalf of your employer.

Customer Data

In providing the Services, Breakthrough receives and processes Customer Data on behalf of its Customers. This Customer Data includes recordings, transcripts, text, and other content and materials submitted by Customers in connection with their use of the Services — including sales and business meeting recordings (which may include information about meeting participants who are not employees of the Customer), CRM records, and internal business documents — and other materials shared by its Customers for processing. Breakthrough uses artificial intelligence and machine learning to process this information and generate knowledge resources about its Customer’s customers on each Customer’s behalf. These resources may be made accessible through or integrated with third-party AI-based tools and interfaces, as directed by each Customer.

Note-Taker Recordings and Transcripts

As part of the Services, Breakthrough may receive access to recordings, transcripts, or automated summaries generated by note-taking tools or similar technologies used in connection with sales calls, meetings, or other interactions (collectively, “Recordings”). Recordings may include the names, voices, and images of meeting participants, as well as associated metadata such as attendee lists, meeting titles, and any notes or annotations captured in connection with those meetings. On behalf of and in accordance with our agreements with our Customers, Breakthrough and its Service Providers may process Recordings and retain such information for purposes such as providing the Services, quality assurance, customer support, improving the safety and performance of the Services, complying with applicable legal obligations, and enforcing our agreements.

Where required by applicable law, our Customers are responsible for providing appropriate notice to, and obtaining any necessary consents from, individuals who participate in recorded sessions. Breakthrough does not independently obtain consent from participants on behalf of Customers and relies on its Customers to comply with applicable recording consent laws and regulations. Breakthrough does not sell Recordings and uses and shares them only as described in this Privacy Statement and in accordance with our Customer’s written instructions and contractual requirements.

Google User Data

If you connect a Google account to Breakthrough, we request only the access needed for the feature you turn on:

Google Meet (read-only): your meeting records, participant names and transcripts, used to import call transcripts into your workspace.
Google Calendar events (read-only): the calendar event linked to a meeting (title and attendee names and email addresses), used to identify who spoke on the call.
Gmail: to send the emails you write in Breakthrough from your Gmail account; to read your send-as addresses and email signature; to read the threads of emails sent through Breakthrough to detect replies and bounces; and to read up to 20 of your sent emails from the last 90 days to learn your writing style for the drafts you create in Breakthrough.
Google Drive (only files you choose or Breakthrough creates): to read the documents you select from your Drive, for example to build your sales playbook, and re-read them to keep the imported content current; and to create and update the documents you export from Breakthrough. We can’t see any other files in your Drive.
Basic profile (name and email address): used to identify the connected account.

We use this data only to provide and improve the user-facing features you enabled. We do not use it for advertising and do not sell it. People at Breakthrough don’t read it except with your permission, for security, or where the law requires. We do not use Google user data to develop, improve or train generalized AI or machine-learning models. We share it only with service providers that help run the Services, under confidentiality obligations.

Breakthrough’s use and transfer of information received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.

Imported transcripts, documents and writing samples are kept in your workspace until you or your administrator delete them. Google access tokens are deleted when you disconnect Google or Google Meet in Settings → Integrations. You can also revoke access at any time at myaccount.google.com/permissions. To have imported data deleted, email privacy@breakthroughsales.io.

Information Collected From Other Sources

We may obtain information about prospective customers and Customer Representatives from other sources, including from websites and social networks that individuals use to connect with our Customers. This information may include purchase or browsing history, anonymous identifier, demographic information, interests, and publicly-observed data, such as from social media and online activity that we may review or analyze for our internal customer acquisition or support purposes or in order to provide a service to our Customers.

Information Obtained from Third Parties

If we receive Customer Data about you from or on behalf of our Customers, we will only use that information for the specific reason for which it was provided to us.

Information Use

We may use the information we collect from and about Customer Representatives, including in connection with the Services, as follows:

Manage our accounts and records;
Measure and report on usage of the Services;
Analyze the effectiveness of our Services and deliver the requested responses or functionality;
Assess the needs of your business to determine suitable products;
Send you requested product or service information;
Provide customer service and communicate with individuals that are, or who represent, customers, vendors, or web users related to transactions;
Send you a newsletter and marketing communications;
Respond to your questions and concerns;
Improve the content and functionality of our Web site and marketing efforts;
Conduct research and analysis;
Display content based upon your interests;
Comply with applicable laws and our contractual obligations to our Customers, including to respond to requests from public and government authorities;
Legal and regulatory compliance and internal control evaluations and audits (including where conducted by our internal and external audit service providers);
Obtain legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business;
Negotiate, conclude, and perform contracts with vendors;
Enforce this Privacy Statement;
Protect our rights, privacy, safety or property, and/or that of you or others.
Develop new programs, products or services
Security, credit or fraud prevention purposes;
Protect the security or integrity of the Services, our business, and other assets, including for security, credit, or fraud prevention purposes; and
Provide you with notices via email, text, or other methods of communication, such as updates or changes that we may make to the Services; and
As described to you at the point of data collection or in our Agreement with our Customer.

In addition, on behalf of and at the direction of its Customers, Breakthrough may process information about how a Customer's corporate customers or prospects engage with and respond to that Customer's offerings, and may associate such engagement patterns with a professional role, employer, and other professional attributes, in order to help the Customer develop profiles of its target buyer personas. This profiling is performed solely as a service provider acting on each Customer's instructions; it is not performed for Breakthrough's own purposes, and profiles developed for one Customer are not used for any other Customer's account.

Breakthrough may use aggregated, de-identified, or anonymized data derived from Customer Data for any purpose, including research, development, and improvement of the Services and AI-enabled features, consistent with the licenses granted under the Terms of Service. Breakthrough may also analyze Submitted Data, including through machine learning and AI techniques, in order to provide, develop, and improve the Services. Breakthrough retains all ownership in and to all system performance data, machine learning algorithms, and aggregated or de-identified results derived from such analysis; Customers retain all ownership of their Submitted Data. To the extent that Submitted Data is used to grow, enrich, or verify the Output Data (as defined in our Terms of Service) included in the Breakthrough Database, such use is conducted only in aggregated or de-identified form, and Breakthrough will not publicly refer to or associate any Customer with such Submitted Data, consistent with the Terms of Service.

This paragraph does not apply to Google user data, which is governed by the "Google User Data" section above.

Information Sharing

We may share Customer Representative information as further described below. We may also share certain Customer Data that we receive from our Customers with our Service Providers or subprocessors, in order to provide our services to our Customers.

We may contract with third parties to perform functions related to the Services and services we provide to our Customers. These third parties will have access to only that Customer Representative information and Customer Data needed to perform their business functions, but may not use or share that information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us and/or to support the services we provide to our Customers.

Solely to the extent necessary to perform the Services as described, we will disclose your Personal Information to service providers, such as vendors, technical agents, subcontractors and consultants, to perform certain business-related functions that help make the Services and our offerings available and functional (e.g., website hosting, maintenance, user experience improvements, and email delivery services). We may share the information we collect from and about Customer Representatives:

(1) with third parties that we believe may provide promotional materials, and goods and services that may be of interest to you;

(2) with our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us, including as part of our agreement with our Customers. As part of providing the Services, Breakthrough uses third-party foundational artificial intelligence and machine learning models (the “AI Tools”) to process Customer Data and generate knowledge resources on behalf of our Customers. Breakthrough does not currently fine-tune or build its own foundational AI models. The AI Tools will not use identifiable Customer Data or Customer Representative Data information to train their underlying models or platforms except for use by our Customers;

(3) as necessary if we believe that there has been a violation of this Privacy Statement, our Terms of Service, our Acceptable Use Policies, or of our rights, or the rights of any third party;

(4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

(5) to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and

(6) as described to you at the point of collection or in our Agreement with a Customer.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Information We Automatically Collect and cookie policy

As is true of most websites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. We also collect Service Metadata, which includes information collected or inferred in the course of delivering emails to Customer Representatives or otherwise providing the Services, such as information about email deliverability and system operations.

We and our third party service providers, including advertisers, analytics, and third party content providers, such as Google Analytics, may automatically collect certain information from you as a Services visitor or Customer Representative whenever you access or interact with the Services. This information may include, among other information:

the browser and operating system you are using
the URL or advertisement that referred you to the Services
the search terms you entered into a search engine that led you to the Services
areas within the Services that you visited, and
other information commonly shared when browsers communicate with websites.

When service providers receive this information, they are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

We may use cookies, web beacons, pixel tags, log files, or other technologies to automatically collect certain information when you use our Services or interact with our emails and online or mobile advertisements.

For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, browser type, operating system, device model, software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Services. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Services. If such information is linked to your Personal Information, we will treat it as Personal Information under this Privacy Statement.

We also may collect information about your use of the Services including the date and time you access the Services, the areas or pages of the Services that you visit, the amount of time you spend using the Services, the number of times you return, whether you open forward or click-through emails and ads, and other usage data so that we can understand the statistical use trends of our Services in order to make improvements. This information may be stored and used with your personal information attached to it. For more information on our use of cookies, click our Cookie Policy.

We may also use third-party tools or services, such as Google Analytics and Microsoft Clarity, to assist us with analyzing and improving the Services. These service providers may use cookies or other automatic information collection technologies to collect information about your use of the Services over time and across different websites, apps, or other online services. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business, and their own use of information is governed by their respective privacy policies.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay, so we can improve our website and market our products and services. Clarity records the pages you view and how you interact with them, such as clicks, taps, mouse movements and scrolling, and hides the text you type into forms on our website. Clarity runs only if you accept Statistics cookies. Microsoft receives data for Microsoft Advertising only if you accept marketing cookies. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement at https://www.microsoft.com/privacy/privacystatement.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

Tracking Options, EEA/UK/Switzerland and California Do Not Track Disclosures.

We strive to provide you with choices regarding the personal information you provide to us.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our services.

We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about Customer Representatives and Customer Data may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.

Your California Privacy Rights

Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: privacy@breakthroughsales.io. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Legal Requirements

We may disclose Customer Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Breakthrough, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Children

Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of 18.

Links to Other Websites

This Privacy Statement applies only to the Services. The Services may contain links to third-party sites or applications, including social media sites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications. The links to third-party sites from the Services does not imply that we endorse or have reviewed the third-party sites.

Data Security

The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You. While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. To the extent you use any Beta Services (as defined in our Terms of Service), those services are provided on an as-is basis without security commitments or warranties of any kind, as further described in our Terms of Service. E-mail sent to or from the Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Data Storage and Retention

Customer information is stored on our Service Providers’ servers in the United States. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with use of the Services, or to fulfill any legal or contractual obligations we may have.

Access to Your Personal Information

You may also send us an email at privacy@breakthroughsales.io to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe doing so would violate any law or legal or audit requirement or cause the information to be incorrect.

Changes to Our Privacy Statement

We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Services. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

How to contact us

If you have questions about this privacy statement, or if you believe that this Services are not following its stated Privacy Statement, please contact us at privacy@breakthroughsales.io.

Data Protection Representative Contact Information if you are located in the EEA, UK or Switzerland:

Prighter EU Rep GmbH

Address: Schellinggasse 3/10, 1010 Vienna, Austria
Phone: +43 1 9974124
Email: office@prighter.com
https://app.prighter.com/portal/breakthrough

Visitors from the EEA, UK or Switzerland

If you are a resident of the EEA, UK or Switzerland, we are a data controller when we collect Customer Representative Data and a data processor when we receive and process Customer Data on behalf of our Customers, who are the data controllers. The Services are designed for business-to-business use and are directed exclusively to companies and their representatives. Breakthrough does not knowingly collect or process special categories of personal data, as defined under GDPR Article 9, and our Customers are responsible for ensuring that any information they share with us does not include special categories of personal data unless a lawful basis for processing such data has been established.

When acting as a data controller with respect to Customer Representative Data, our legal basis for collecting and using your personal data is: (i) performance of or steps taken prior to entering a contract with our Customer; (ii) our legitimate interests in marketing and providing our Services to business customers, where those interests are not overridden by your data protection rights; or (iii) compliance with a legal obligation. When acting as a data processor with respect to Customer Data, we process personal data solely on documented instructions from our Customers, who are the data controllers and are responsible for establishing the legal basis for that processing.

Access your personal data or information;
Delete, or request deletion of, your personal data or information;
Object to or restrict processing of your personal information;
Request portability of your personal information;
Complain to your local data protection authority at any time;
Object to automated decision making; and
Update your personal data or information.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights. If we are the data controller, you can contact us to exercise these rights. If we are the data processor, you must contact the controller to exercise these rights:

Access your personal data or information;
Delete, or request deletion of, your personal data or information;
Object to or restrict processing of your personal information;
Request portability of your personal information;
Complain to your local data protection authority at any time;
Object to automated decision making; and
Update your personal data or information.

To withdraw consent or exercise these rights, please contact our Privacy Officer at privacy@breakthroughsales.io.

If we ask you to provide personal data to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal data is required and if not, the consequences of not sharing your personal data with us.

Similarly, if we collect and use your personal information in reliance on our or a third party's legitimate interests and those interests are not already listed above (see “Information Use” section), we will let you know what those legitimate interests are.

Breakthrough processes personal data in the United States. If you are located in the EEA, UK, or Switzerland, please be aware that your personal data may be transferred to and processed in a country that does not provide the same level of data protection as your home country. Where required, Breakthrough relies on appropriate transfer mechanisms, such as the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, to ensure that any such transfers are made in compliance with applicable law.

To withdraw consent or exercise these rights, please contact our Privacy Officer at privacy@breakthroughsales.io or our European or UK Representative:

Prighter EU Rep GmbH

Address: Schellinggasse 3/10, 1010 Vienna, Austria
Phone: +43 1 9974124
Email: office@prighter.com
https://app.prighter.com/portal/breakthrough