Breathing Digital Privacy Policy


–     2019


BREATHING DIGITAL is committed to safeguarding the confidentiality and privacy of information entrusted to it, including any personal information (sometimes referred to as “personally identifiable information” or “PII”) collected through its websites. Your continued use of this website constitutes your agreement with this Privacy Policy and any subsequent updates.


The purpose of Collecting Personal Information

On certain areas of its websites, BREATHING DIGITAL allows you to provide personal information so that we may fulfil your requests for information or otherwise allow you to interact with us. For instance, personal information may be used to fulfil your requests for BREATHING DIGITAL publications, to allow you to publish comments on BREATHING DIGITAL’s website content, or to facilitate its receipt and processing of your enquiries through the contact us form.


What types of personal information are collected?

 BREATHING DIGITAL collects personally identifiable information when you submit such information through its websites. For instance, BREATHING DIGITAL collects your name, e-mail address and other personally-identifiable information you provide as “comments” when you submit an inquiry through the “Contact Us” page.

In addition, BREATHING DIGITAL may collect certain types of information that you do not visibly enter, such as your IP address, browsing patterns on its websites, click stream data, and HTP protocol elements. This tracking information is stored in anonymous, aggregated and non-personal format, and is used to understand and analyse trends, to administer the websites, and to learn about user behaviour on the websites. However, BREATHING DIGITAL may use IP addresses to help identify you

when BREATHING DIGITAL feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, clients or others, or when required by law or for law enforcement purposes.

Use of Cookies

BREATHING DIGITAL may use cookies on its websites to improve performance and enhance your user experience. This policy explains generally how cookies work.

BREATHING DIGITAL has installed a visible cookies usage disclaimer as soon as you enter the address. The disclaimer is shown at the bottom of the Home/Landing page.

(a)   What are Cookies?

 A cookie is a small text file containing small amounts of information that a website puts on a user’s computer (or mobile device) when you visit a website and is used by the website to send information to your browser and for the browser to return information to the website.

– You can find more information about cookies

at: and For a video about cookies, please visit

The information your browser sends to BREATHING DIGITAL’s websites is used for authentication and identification of your session and allows BREATHING DIGITAL to display the correct information on the website. BREATHING DIGITAL matches the cookie against your details so it can distinguish you from other users as you browse the site, which helps it to provide you with a good user experience. Most browsers enable a user to disable cookies. If you do so, however, this site may not function correctly.


Logging: BREATHING DIGITAL records and stores details of the pages visited so that it can generate usage statistics (mainly to be used on Google Analytics – click to read

Google Analytics official Privacy Policy). Except as otherwise provided in this Privacy Policy, BREATHING DIGITAL does not sell or share any information gathered by other companies.

Cookie storage: This website uses cookies which are persistent and non-persistent (session-based). While many of the cookies used on this website only last for the duration of your use of this website (session-based cookies), other cookies are persistent, i.e., stay in one of your browser’s subfolders until you delete them manually or your browser deletes them.

(b)  What types of cookies may be used here?

First party cookies – First party cookies are set by the website you are visiting and they can only be read by that site.

Session cookies – Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server’s pages. These are temporary cookie files, which are erased when you close your browser, and when you restart your browser and go back to the site that created the cookie, the website will not recognise you. You will have to log back in (if login is required) or select your preferences/themes again if the website uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser.

Persistent cookies – Persistent cookies are employed to store user preferences. These files stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file. For Information on session and persistent cookies, see here. Third party cookies – Third party cookies are set by a different organisation to the owner of the website you are visiting. For example, the website might use a third party analytics company that will set its own cookies to perform this service (for example, as described below, this website uses Google Analytics).

(c)  What cookies does this website use?


A list of all the cookies used on this site by category is detailed below.

Note: This website does not use any cookies which retain personal information about you after your session ends.

The table below provides additional details on the specific cookies used on BREATHING DIGITAL’s website:



File Name










Persistent cookies

Country code (used to store the default country of the user)
_session_id Session cookies Hexidecimal hash (used to handle the session)
wco_data Session cookies Hexidecimal hash (used to handle the session)
    atuvc Third party cookies Addthis (marketing information)
    utma Third party cookies Google Analytics (used for usage statistics)
    utmb Third party cookies Google Analytics (used for usage statistics)
    utmc Third party cookies Google Analytics (used for usage statistics)
Google Analytics (used for usage statistics)
    utmz Third party cookies


This website also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to help the website analyse how users use the site. The information generated by a Google Analytics cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may

also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

By continuing to use this website you give your consent for BREATHING DIGITAL to use cookies as detailed above. If the way BREATHING DIGITAL uses cookies changes significantly (e.g. a new cookie is added with different functionality), BREATHING DIGITAL will inform you by email and this document will be updated.


(d)  What if I don’t want cookies to be set?

 By using BREATHING DIGITAL’s website you agree that BREATHING DIGITAL can place cookies on your device as explained above. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies from being placed on your device, you can change your browser settings to do this. All these changes share the same principle but differ in application from a browser to another.

Disclosure of Personal Information to Third Parties

BREATHING DIGITAL will not transfer, disclose, sell, distribute, or lease your personal information to third parties other than as described in this Privacy Policy unless BREATHING DIGITAL has your permission or is required or permitted by law. BREATHING DIGITAL may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third- party contractors, consultants and/or vendors engaged by BREATHING DIGITAL to provide services related to its website may have access to such personal information (these third parties must first agree to maintain the strict confidentiality and restrictions on use and disclosure of such information and provide the same level of data security as provided by BREATHING DIGITAL).


Information Security

BREATHING DIGITAL has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction.

Despite BREATHING DIGITAL’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of BREATHING DIGITAL’s ability, access to your personal information is limited to those who have a need to know.


International Hosting and Transfer of Information

Consistent with the other sections of this Privacy Policy, BREATHING DIGITAL may transfer certain personally-identifiable information across geographical borders to BREATHING DIGITAL offices, personnel, or third-parties located throughout the world. BREATHING DIGITAL may also store such information in a jurisdiction other than where you are based. By providing personally-identifiable information on an BREATHING DIGITAL’s website, you are consenting to this transfer and/or storage of your data across borders.



If you have submitted personal information to BREATHING DIGITAL, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting us through the contact us form. BREATHING DIGITAL will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

We aim to respond to all enquiries related to modifying, deleting or accessing data within 48 hours of receiving the enquiry.



BREATHING DIGITAL’s websites are not intentionally designed for or directed at children under the age of 13. It is BREATHING DIGITAL’s policy never to knowingly collect or maintain information about anyone under the age of 13.



BREATHING DIGITAL websites may contain links to other sites, including websites maintained by BREATHING DIGITAL affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that BREATHING DIGITAL provides links to third-party websites, such links do not constitute an endorsement, sponsorship, or recommendation by BREATHING DIGITAL of the third parties, the third party websites, or the information contained on those websites, and BREATHING DIGITAL is not responsible or liable for your use of such third party websites.


Changes to this Policy

BREATHING DIGITAL reserves the right to make changes to this Website Privacy Policy from time to time. BREATHING DIGITAL will notify you by posting amendments to the Privacy Policy on this website.

Types of Personal Information Collected and Purpose for Collection

BREATHING DIGITAL will comply with the General Data Protection Regulations Principles in respect of such personal data. Some types of Personal Information may be subject to additional privacy-related requirements and policies. For example:

Personal Information from Client Engagements: BREATHING DIGITAL provides professional consulting services to its clients. BREATHING DIGITAL’s clients may send Personal Information to it for processing on their behalf as part of the consulting

services they have purchased and agreed to. For example, BREATHING DIGITAL may receive Personal Information such as name, email address, employment information, or financial data. BREATHING DIGITAL uses any such Personal Information to perform services for its clients and to administer and manage its relationships with its clients.

In the event that a client engagement involves a transfer of Personal Information, the relevant clients are responsible for providing appropriate notice, where required, to the individuals whose Personal Information may be transferred to BREATHING DIGITAL, including providing individuals with certain choices with respect to the use or disclosure of their Personal Information, and obtaining any requisite consent.

BREATHING DIGITAL handles such Personal Information in accordance with its clients’ instructions.


Personal Information from BREATHING DIGITAL Website Use: BREATHING DIGITAL may collect Personal Information when you choose to access and use BREATHING DIGITAL’s websites.


Personal Information regarding BREATHING DIGITAL Employees: BREATHING DIGITAL may transfer Personal Information regarding BREATHING DIGITAL personnel. This Personal Information may include, without limitation, business contact information, employee ID, job role and reporting line, demographic information, work history, compensation and performance ratings. BREATHING DIGITAL uses such information to administer and manage its business.


Choice and Accountability for Onward Transfer

BREATHING DIGITAL will not transfer, disclose, sell, distribute, or lease your Personal Information to third parties other than as described in this Privacy Policy unless it has your permission or is required or permitted by law (including to meet national security or law enforcement requirements). BREATHING DIGITAL may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied, collected, or received. Similarly, third-party contractors, consultants and/or vendors engaged by BREATHING DIGITAL to assist it in providing its services may have access to such Personal Information (these third parties must first agree to

maintain the strict confidentiality of such information and provide the same level of data security as provided by BREATHING DIGITAL). BREATHING DIGITAL remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles.


Questions and Comments

If you have questions or concerns regarding this policy or BREATHING DIGITAL’s Personal Information processing policies, please contact BREATHING DIGITAL through the contact form.