Privacy notice – Breathe App

12.15.2023

1. Intro

This document describes how Polestar processes your personal data when you use the Polestar Breathe application (the "Breathe App").

2. When do we process your personal data?

Breathe App
Purpose To provide the Breathe App services.
Categories of personal datainstallation ID, car model and model year, which country you reside in, information on whether the car is standing still or moving, downloads, resets and uninstalls of the Breathe App, Breathe App updates, operating system updates, data regarding the notifications you receive, breathing techniques used, engagement and frequency, screen views, when and which excercise is initiated and completed or when it is aborted.
Legal basisThis data processing is used for us to fulfil our contract with you as a part of your use of our service (GDPR, article 6.1 (b)).
RetentionUntil it has been anonymized or until you withdraw your consent.
Controller(s)Polestar Performance AB
Purpose To receive insights into how the Breathe App is used and to improve user experience. The processing does not include any automatic decision making, such as profiling.

Categories of personal data

installation ID, breathing techniques used, and engagement frequency, screen views, when and which excercise is initiated and completed or when it's aborted.

Legal basisYour consent (GDPR, article 6.1 (a)). You can deny sharing your data for app analytics and still use the app features.
RetentionUntil it has been anonymized or until you withdraw your consent.
Controller(s)Polestar Performance AB

3. How we disclose your personal data and who we disclose it to?

Our processors supporting delivery of the Breathe App, which are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place:

  • Google Ireland Limited and its sub-processors, data center Europe-west1 (Belgium); data transfer also to Google LLC, USA, under the Standard Contractual Clauses adopted by the European Commission, available here. We use Google Firebase services for app analytics to better understand user behavior and to improve the usability and reliability of the Breathe App. You can deny sharing your data for app analytics and still use the app features.

4. Transfer of your personal data

We transfer personal data to the following countries outside of the United States: the EU/EEA and the United Kingdom.

In providing its services Polestar may transfer the personal data to service providers outside of EU/EEA or back into the US. Under EU privacy law this constitutes a reverse transfer. Transfers to the United Kingdom are carried out pursuant to its adequacy decision. For transfers to other countries outside of EU/EEA that do not have an adequacy decision, we use EU Model Clauses entered into by all relevant third parties (article 46 of the GDPR). In addition, we take additional technical and organizational security measures when needed, such as encryption (TLS) and pseudonymization.

5. Information Security

To protect your personal information from loss, theft, and unauthorized access, use, or disclosure, we have implemented technical, administrative, and physical security measures including encryption of transmitted and stored data, and access right concepts. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable.

6. Your rights

You have specific legal rights granted by the General Data Protection Regulation and privacy laws in the United States relating to the personal data we process about you. 

You can withdraw your consent or object to our processing of your data, access the data we hold about you, ask for rectification or restriction of your data, request to have your data ported to another entity, request that we delete your data, and finally you can file a complaint with a data protection supervisory authority. If you are a resident of California, Colorado, Nevada, Utah, Virginia, or Connecticut, you have the right to opt-out of the sale of your personal information to third parties

To exercise any of your rights, fill in this web form, call our toll-free number at (800) 806-2504 or contact us as described in this policy. For requests submitted via telephone or email, other than a request to opt out of sale/sharing, you must provide us with name, e-mail address, zip code and residency to allows us to reasonably verify that you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for requests to access, delete, or know with the information provided, we may ask you for additional pieces of information.  

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual. 

If you have any objections or complaints about the way we process your personal data, please let us know and we will try to help. 

6. Contact information

Polestar Performance AB is a Swedish legal entity with company registration number 556653-3096, with mailing address Assar Gabrielssons Väg 9, 405 31 Gothenburg, Sweden, and visiting address Polestar HQ, Assar Gabrielssons Väg 9, 418 78 Göteborg. 

7. Changes to our Privacy Notice

We reserve the right to change this privacy notice from time to time. We will inform you of any changes by posting the updated privacy notice on the website. If we make any material changes to our privacy notice, we will send a notification by e-mail. We encourage you to contact us if you have any questions about the privacy notice or about how we process your personal data.