Privacy Policy

Last Updated: January 1, 2026

Zentro® Website and Mobile Application Privacy Policy

Summary

The following Zentro® Website and Mobile Application Community Privacy Policy (“Privacy Policy”) sets forth our policy with respect to the collection, use, sharing and storage of your personal information and other information that we collect from you when you: (a) access and/or use the Zentro® website located at www.zentrointernet.com (the “Site”); and/or (b) access, download and/or use the Zentro® mobile application (the “App”).  The Site and App are properties of Everywhere Wireless, LLC d/b/a Zentro (“Company” “we,” “our” or “us”).

Capitalized terms not defined herein shall have the meaning set forth in the Zentro® Mobile Application End-User License Agreement and Website Terms and Conditions (“Terms”).

Background

This Privacy Policy covers our treatment of personal information and other information that we collect when you: (a) access and/or use the Site; (b) download, attempt to download and/or use the App and associated Software, as made available on the iPhone® and iPad®, as well as Android® and other mobile devices, where and to the extent available (collectively, “Mobile Devices”) by and through the Apple® App Store, the Google Play® store and other applicable venues, where and to the extent available (collectively, “Download Venues”); (c) access certain text, images, video, audio, reviews, testimonials, and other content and information relating to the Company Offerings as made available by: (i) Company (collectively, “Company Content”); and/or (ii) third parties (“Third-Party Content,” and together with the Company Content, the “Content”); (d) rent routers and other Internet-related equipment and/or obtain a paid subscription to our Internet and wireless Internet service (“Wi-Fi”), either on an individual basis or for a multi-unit commercial and/or residential building (collectively, “Company Services”), which also gives you access to our customer online/mobile portal (“Company Portal”); (e) register to receive our email newsletter (“Newsletter”), which contains updates and promotions associated with various Company Services; (f) register for the Refer-a-Friend Program (which is subject to the Refer-a-Friend Program Terms, which can be accessed here) (“Refer-a-Friend Program”); (g) access links to the Company social media pages/accounts appearing on third-party social media websites (collectively, “Social Media Pages”), such as Facebook®, LinkedIn® and Yelp® (collectively, “Social Media Websites”); (h) utilize the messaging functionality and other interactive features associated with the Site, App and Company Services (“Interactive Services”); (i) access certain promotions, contests and/or sweepstakes offered by Company by and through the Site, App and otherwise, from time to time (collectively, “Promotions”); (j) request information regarding and/or submit information in connection with employment opportunities available with Company (“Career Opportunities”); (k) utilize the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Company (collectively, the “Contact Services,” and together with the Site, App, Content, Company Services, Company Portal, Newsletter, Refer-a-Friend Program, Social Media Pages, Interactive Services, Promotions and Career Opportunities, the “Company Offerings”); and/or (l) otherwise affirmatively consent to this Privacy Policy and/or the Agreement.

Please note, if you are a resident of, or physically located in, the United Kingdom or a European Union Member State, you are not permitted to use the Site, App and/or Company Offerings.

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by calling us at: 866-923-0982; emailing us at: accesssupport@zentrointernet.com; or sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE COMPANY OFFERINGS.

Apple®, Apple App Store®, iPhone® and iPad® are registered trademarks of Apple, Inc. (“Apple”). Facebook® is a registered trademark of Meta Platforms, Inc. (“Meta”).  Android® and Google Play® are registered trademarks of Google, Inc. (“Google”).  LinkedIn® is a registered trademark of LinkedIn Corporation (“LinkedIn”).  Yelp® is a registered trademark of Yelp, Inc. (“Yelp”).  Please be advised that Company is not in any way affiliated with Apple, Meta, Google, LinkedIn or Yelp, and the Company Offerings are not endorsed, administered or sponsored by any of the foregoing entities.

State Specific Privacy Rights

Residents of the States of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, businesses organized under the laws of the State of California, as well as California-based employees of, and California residents who submit job applicants to, Company (collectively, “Covered Users”), are afforded additional rights pursuant to applicable state law. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights as a Covered User.

1. Your California Privacy Rights

Shine the Light.  If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: support@zentrointernet.com; or send us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: support@zentrointernet.com; or send us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.  Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”).  In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to delete the personal information we have collected about you, and the right to opt-out of our sale of your Personal Information, as well as the right to know what Personal Information about you we have collected, whether your Personal Information was shared with third-parties in the preceding year and, if so, what categories of Personal Information were shared, as well as the categories of third parties with whom we shared that Personal Information.  Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under as a Covered User.

The California Privacy Rights Act (“CPRA”).  In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CPRA, including the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, the right to correct personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to know how long we retain your sensitive and non-sensitive personal information, the right to know what sensitive personal information about you we have collected, whether your sensitive personal information was shared with third-parties in the preceding year and, if so, what categories of sensitive personal information were shared, as well as the categories of third parties with whom we shared that sensitive personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the CPRA as a California State resident.

Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising.  As required by California Online Privacy Protection Act (“CalOPPA”), we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a Site/App user has activated the “do-not-track” setting on her/his browser; provided, however, that you may have certain rights with respect to the use of automated technologies to deliver targeted advertising to you, as well as to create profiles about you using your personal information.

2. Your Colorado Privacy Rights

If you are a resident of the State of Colorado, certain privacy-related rights may apply to you in accordance with the Colorado Privacy Act (“CPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the CPA as a Colorado State resident.

3. Your Connecticut Privacy Rights

If you are a resident of the State of Connecticut, certain privacy-related rights may apply to you in accordance with the Connecticut Data Privacy Act (“CTDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the CTDPA as a Connecticut State resident.

4. Your Delaware Privacy Rights

If you are a resident of the State of Delaware, certain privacy-related rights may apply to you in accordance with the Delaware Personal Data Privacy Act (“DPDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the DPDPA as a Delaware State resident.

5. Your Indiana Privacy Rights

If you are a resident of the State of Indiana, certain privacy-related rights may apply to you in accordance with the Indiana Data Privacy Law (“IDPL”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the IDPL as an Indiana State resident.

6. Your Iowa Privacy Rights

If you are a resident of the State of Iowa, certain privacy-related rights may apply to you in accordance with the Iowa Data Protection Act (“IDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the IDPA as an Iowa State resident.

7. Your Kentucky Privacy Rights

If you are a resident of the State of Kentucky, certain privacy-related rights may apply to you in accordance with the Kentucky Consumer Data Protection Act (“KCDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the KCDPA as a Kentucky State resident.

8. Your Maryland Privacy Rights

If you are a resident of the State of Maryland, certain privacy-related rights may apply to you in accordance with the Maryland Online Data Privacy Act (“MODPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the MODPA as a Maryland State resident.

9. Your Minnesota Privacy Rights

If you are a resident of the State of Minnesota, certain privacy-related rights may apply to you in accordance with the Minnesota Consumer Data Privacy Act (“MNCDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the MNCDPA as a Minnesota State resident.

10. Your Montana Privacy Rights

If you are a resident of the State of Montana, certain privacy-related rights may apply to you in accordance with the Montana Consumer Data Privacy Act (“MCDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the MCDPA as a Montana State resident.

11. Your Nebraska Privacy Rights

If you are a resident of the State of Nebraska, certain privacy-related rights may apply to you in accordance with the Nebraska Data Privacy Act (“NDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the NDPA as a Nebraska State resident.

12. Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email address, telephone number and Social Security Number, and includes the Information described below in the “Personal Information Collected” section.

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at: support@zentrointernet.com; or send us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

13. Your New Hampshire Privacy Rights

If you are a resident of the State of New Hampshire, certain privacy-related rights may apply to you in accordance with SB 255-FN (“NHDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the NHDPA as a New Hampshire State resident.

14. Your New Jersey Privacy Rights

If you are a resident of the State of New Jersey, certain privacy-related rights may apply to you in accordance with the New Jersey Privacy Act (“NJPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the NJPA as a New Jersey State resident.

15. Your Oregon Privacy Rights

If you are a resident of the State of Oregon, certain privacy-related rights may apply to you in accordance with the Oregon Consumer Privacy Act (“OCPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the OCPA as an Oregon State resident.

16. Your Rhode Island Privacy Rights

If you are a resident of the State of Rhode Island, certain privacy-related rights may apply to you in accordance with the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the RIDTPPA as a Rhode Island State resident.

17. Your Tennessee Privacy Rights

If you are a resident of the State of Tennessee, certain privacy-related rights may apply to you in accordance with the Tennessee Information Protection Act (“TIPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the TIPA as a Tennessee State resident.

18. Your Texas Privacy Rights

If you are a resident of the State of Texas, certain privacy-related rights may apply to you in accordance with the Texas Data Privacy and Security Act (“TDPSA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the TDSPA as a Texas State resident.

19. Your Utah Privacy Rights

If you are a resident of the State of Utah, certain privacy-related rights may apply to you in accordance with the Utah Consumer Privacy Act (“UCPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the UCPA as a Utah State resident.

20. Your Virginia Privacy Rights

If you are a resident of the State of Virginia, certain privacy-related rights may apply to you in accordance with the Virginia Consumer Data Protection Act (“VCDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our Privacy Provisions for Covered Users below #PrivacyProvisionCoveredUsers for a more complete description of your rights under the VCDPA as a Virginia State resident.

Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

Personal Information Collected

Use and Sharing of Personal Information

Non-Personal Information Collection and Use

Security of Your Personal Information

Children’s Privacy

Opt-Out/Unsubscribe

Deleting, Modifying and Updating Your Information

Changes to this Privacy Policy

Contact Us

Privacy Provisions for Covered Users
 

Personal Information Collected

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you register for certain of the Company Offerings. The information that we may request when you attempt to access the Company Offerings, may include, but is not limited to: (a) full name and, where applicable, Entity name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) credit/debit card information, bank account information for ACH payments or other Payment Method information (where purchasing Company Services); (f) the property type, and number of units, where you reside/your Entity is located; (g) your resume, and information pertaining to your work authorization status and desired salary (where utilizing the Career Opportunities); and/or (h) any other information requested by us on the applicable registration Form.

Further, users who are potential prize winners in a Promotion may be required to provide some or all of the following: (i) Social Security Number; (ii) picture proof of identification, which may include a driver’s license, passport, voting card or similar government issued identification; and (iii) any other information requested by Company in connection with the prize verification/award process (collectively, “Prize Winner Data”).

We may also collect your personal information when you otherwise agree to the terms of this Privacy Policy, but do not complete the applicable registration process in full.

For purposes of this Privacy Policy, items (e), (i) and (ii) in the preceding paragraphs will be considered “Sensitive Information.”

Use and Sharing of Personal Information

If you otherwise provide express consent in connection with any Company Offerings, we may share your personal information with third parties for the marketing purposes detailed in connection with the consent requested.  Further, your personal information may also be collected automatically on the Site by third parties who use such information for marketing purposes, including for targeted advertising displayed to you on third party websites, as further detailed below.  Such third parties include Extole, Inc. (“Extole”), Google, LinkedIn, Meta, Zoho Corporation (“Zoho”) and ZoomInfo Technologies LLC (“ZoomInfo”).  Please see the “Behavioral Tracking” section below for more information about the data collection and usage policies of these entities.

Other than as set forth in the preceding paragraph, Company will never sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes.

Where you register to access any of the Company Offerings, we use the personal information that you make available to personalize your experience with the Site and App, facilitate your purchase of applicable Company Services, facilitate the provision of the applicable Company Offerings to you and for verification purposes. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Company Offerings, and to keep you informed of our other products and/or services, as well as third-party products and/or services, that we think may be of interest to you.

In addition, if you identify yourself to us by sending us an email or some other communication with questions or comments, we may use such information (including personal information) to respond to your questions or comments, and we may file your questions or comments for future reference.

The personal information that you submit to Company remains your property, but by making that personal information available to Company, you grant Company the right, subject to applicable state and federal law, to use that personal information to send you communications that contain offers from Company and certain third party partners that Company believes may be of interest to you. If you wish to stop receiving future communications from us, please see the Opt-Out/Unsubscribe section below.

We may permit our third-party agents, service providers, vendors and subcontractors to access your personal information, but they are only permitted to do so in connection with performing services for us and/or to facilitate our provision of the Company Offerings. They are not authorized to use that personal information for their own benefit.

We may also supplement the information that we collect with information from other sources to assist us in evaluating and improving the Company Offerings, and to determine your preferences so that we can tailor the Company Offerings to your needs.

By submitting your personal information by and through the Company Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations.  As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls (including text alerts via SMS text messages) from Company delivered via automated technology, to the telephone number(s) that you provided.  Please note that you are not required to provide this consent in order to obtain access to the Company Offerings, and your consent simply allows Company to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes.  Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Company of the Phone Number Change via e-mail at: support@zentrointernet.com, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information (including Sensitive Information): (i) in the event that we believe that the Company Offerings are being, or have been, used in violation of the Terms or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; (iii) if we are sold, merged or acquired (collectively, “M&A Transactions”) (including where we share your personal information in connection with the due diligence process associated with a potential M&A Transaction); or (iv) if we are the subject of bankruptcy proceedings; provided, however, that if we are involved in an M&A Transaction or bankruptcy proceeding, you will be notified via email and/or a prominent notice on the Site and in the App of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

Credit Card and Debit Card Transactions

Company utilizes third-party service providers to provide credit and debit card payment processing services. If you choose to purchase Company Services with a credit card or debit card, the credit or debit card information provided will be shared with our contracted third-party payment processing service provider(s).  Company requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).

Social Media Websites; Interactive Services

If you engage in any interaction with Company, other users or any third-party via the Interactive Services and/or by and through any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Interactive Services and/or Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; (b) your IP address may be read, collected and/or used by other users of these websites/services; and (c) where Company responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Company’s Social Media Pages.  We are not responsible for the personal information that you choose to submit via Interactive Services and/or any Social Media Websites.

Your interactions with the Social Media Pages are governed by the privacy policies of the applicable Social Media Websites.  We encourage you to review the privacy policies and settings of the Social Media Pages with which you interact to help you understand those Social Media Websites’ respective privacy practices.  If you have questions about the security and privacy settings of any Social Media Pages that you use, please refer to the applicable Social Media Website’s privacy notices or policies.

Non-Personal Information Collection and Use

Mobile Device, Geolocation and App Usage Information

We may collect certain non-personally identifiable information about you and your Mobile Device when you access the App and/or visit certain App pages.  This non-personally identifiable information includes, without limitation, the following information pertaining to your Mobile Device and your use of the App: (a) Mobile Device platform type; (b) Mobile Device identifier; (c) SDK version; (d) API key (identifier for the App); (e) App version; (f) the model type, manufacture and Android version of the Mobile Device; (g) your App session start/stop time and date; and (h) the actions taken while utilizing the App.  We use the non-personally identifiable information identified in this paragraph to improve the design and content of the Company Offerings and to enable us to personalize your App experience.  We also may use this information in the aggregate to analyze Company Offerings usage, alter existing Company Offerings and/or develop new or different Company Offerings.  You understand and agree that we may send push notifications about the Company Offerings to you by and through your Mobile Device.

IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage, as well as to offer you products and services.

Cookies

When an end-user visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable end-user’s computer or other device. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Company Offerings, including for storing user preferences, improving ad selection and tracking Site-user trends (such as pages opened and length of stay at the Site).

Without limiting the foregoing, when you visit the Site, we may use both a session and a persistent Cookie. This Company-placed Cookie may contain information (such as a unique user ID) used to track your usage of the Site and in some cases, your e-mail address. A Web beacon allows us to capture certain additional types of information about a visitor’s actions on the Site, such as a visitor’s Cookie number, the time, date, duration and number of page views, a description of the page where the Web beacon is placed, and details about any items that were purchased.

These Cookies allows us to recognize you when you return to the Site and provides you with access to your account information. If you save your information on the Site or order from us, we may also use Cookies to monitor and maintain information about your use of the Site.

The Site also uses Cookies to help keep track of items you put into your shopping cart, including when you have abandoned your cart. This information is used to determine when to send cart reminder messages via e-mail or, where authorized, SMS.

We may use Flash Cookies (also known as Local Stored Objects) or other similar technologies. A Flash Cookie is a small data file placed on a computer using Adobe Flash technology that may be installed on your computer or downloaded by you to your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, personalize and store your settings. They help us improve the Site by measuring which areas are of greatest interest to visitors. We do not use Flash Cookies for marketing or behavioral targeting purposes. Flash Cookies are different from browser Cookies and the Cookie management tools provided by your browser will not remove Flash Cookies. You should learn how to manage privacy and storage settings for Flash Cookies. If you disable Flash Cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the Site; provided, however, that certain functions of the Company Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking

N/A

Extole®

Without limiting the foregoing, we may use various web analysis and marketing tools as made available by Extole.  Extole may collect some or all of the following information by and through the Extole tracking technology: (a) city and country of the user; (b) device type (desktop, Mobile Device, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site/App pages visited; (f) time spent on each Site/App page; (g) navigation path through the Site/App; (h) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “Extole Data”).  Extole shares the Extole Data with us.

We may combine Extole Data with your personal information, and we and/or Extole may use Extole Data to serve you targeted ads after you leave the Website.  Extole’s Privacy Policy, including information pertaining to Extole’s use of Extole Data and how to manage your Extole privacy preferences, can be found here.

Google®

We may also use the “Google Analytics®” and “Google Ads®” tracking and targeting tools, as made available by Google, on the Site and in the App.  Google may collect some or all of the following information by and through the Google Analytics® tracking technology: (a) city and country of the user; (b) device type (desktop, Mobile Device, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site/App pages visited; (f) time spent on each Site/App page; (g) navigation path through the Site/App; (h) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “Google Data”). Google shares Google Data with us.

We may combine Google Data with your personal information, and we and/or Google may use Google Data to serve you targeted ads after you leave the Site.  Google’s ability to use and share the Google Data and other information collected about your visits to (and use of) the Site is restricted by the Google Analytics® Terms of Service, available here, and the Google Privacy Policy, available here. You may learn more about how Google collects and processes data specifically in connection with these tools here. You may prevent your data from being tracked and/or used by Google by downloading and installing the Google Opt-out Browser Add-on, available here.

LinkedIn®

We may also use web analysis tools under the LinkedIn Insight® brand, as made available by LinkedIn.  LinkedIn may collect some or all of the following information by and through the LinkedIn tracking technology: (a) first and last name, email address and telephone number; (b) device type (desktop, Mobile Device, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site/App pages visited; (f) time spent on each Site/App page; (g) navigation path through the Site/App; (h) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); (i) actions taken with respect to email received, such as whether you receive, open and/or respond to same; and (j) exit pages (collectively, “LinkedIn Data”).  LinkedIn shares LinkedIn Data with us.

We may combine LinkedIn Data with your personal information, and we and/or LinkedIn may use that LinkedIn Data to serve you targeted ads after you leave the Website.  LinkedIn’s Privacy Policy, including information pertaining to LinkedIn’s use of LinkedIn Data and how to manage your LinkedIn privacy preferences, can be found here.

Meta®/Facebook®

We may also use web analysis tools called Meta Ads® and Meta Pixel®, as made available by Meta.  Meta may collect some or all of the following information by and through the Meta Ads® and Metal Pixel® tracking technologies: (a) traffic data from Facebook® users who visit the Site/App; (b) demographic information of Facebook® users who visit the Site/App; (c) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); (d) attribution for purposes of Facebook® ad conversion; and (e) click-through rates from the Site (collectively, “Meta Data”).  Meta shares Meta Data with us.

We may combine Meta Data with your personal information, and we and/or Meta may use that Meta Data to serve you targeted ads after you leave the Site.  Information pertaining to Meta’s use of Meta Data and Facebook’s® Privacy Policy can be found here.

Zoho®

We may also use various web analysis and marketing tools as made available by Zoho.  Zoho may collect some or all of the following information by and through the Zoho tracking technology: (a) city and country of the user; (b) device type (desktop, Mobile Device, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site/App pages visited; (f) time spent on each Site/App page; (g) navigation path through the Site/App; (h) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “Zoho Data”).  Zoho shares the Zoho Data with us.

We may combine Zoho Data with your personal information, and we and/or Zoho may use Zoho Data to serve you targeted ads after you leave the Website.  Zoho’s Privacy Policy, including information pertaining to Zoho’s use of Zoho Data and how to manage your Zoho privacy preferences, can be found here.

ZoomInfo®

We may also use various web analysis and marketing tools as made available by ZoomInfo.  ZoomInfo may collect some or all of the following information by and through the ZoomInfo tracking technology: (a) city and country of the user; (b) device type (desktop, Mobile Device, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site/App pages visited; (f) time spent on each Site/App page; (g) navigation path through the Site/App; (h) actions taken on the Site/in the App (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “ZoomInfo Data,” and together with the Extole Data, Google Data, LinkedIn Data, Meta Data and Zoho Data, the “Third Party Tracking Technology Data”).  ZoomInfo shares ZoomInfo Data with us.

We may combine ZoomInfo Data with your personal information, and we and/or ZoomInfo may use ZoomInfo Data to serve you targeted ads after you leave the Website.  ZoomInfo’s Privacy Policy, including information pertaining to ZoomInfo’s use of ZoomInfo Data and how to manage your ZoomInfo privacy preferences, can be found here.

General Do Not Track

Although end-users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers, we do not honor or alter our behavior when an end-user has activated the “do-not-track” setting on her/his browser.  In addition, end-users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.  To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Live Chat/Chat Bots

Company utilizes third-party service providers to provide live chat and automated chat services (collectively, “Chat”) to users on the Site.  These third party Chat service providers, including Gorgias, Inc. (“Gorgias”) through its live Chat offering, may collect and/or store the following information: (a) content of the Chat conversations; (b) the time spent during each Chat session; (c) the number of Chat interactions; (d) the Site pages visited during each Chat session; (e) ratings and feedback provided by users after Chat sessions; and (f) any expression of interest and/or intent with respect to obtaining the Company Offerings (collectively, “Chat-Related Data”).  Gorgias and other third-party Chat service providers will share the Chat-Related Data with Company; provided, however, that these third-party Chat service providers are not permitted to utilize or share Chat-Related Data (including user personal information collected via Chat conversations) for any purpose other than: (i) to provide the Chat services on the Site; and (ii) to assist Company with its marketing and customer service functionality associated with the Chat services.  Please see our “Privacy Provisions for Covered Users” below #PrivacyProvisionCoveredUsers for details regarding our use and sharing of personal information.

Cross Device Tracking

Company tracks end-users’ use of the Company Offerings across various devices, including the end-user’s personal computer and Mobile Device, in order to optimize and personalize the Company Offerings experience. Company may collect certain of the end-user’s personal information across various devices.

Geolocation Tracking

Company does not use geolocation technology to track users’ locations.

Aggregate Data

Company reserves the right to transfer and/or sell aggregate or group data about users of the Company Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of Company Offerings users as a group, without disclosing personally identifiable information.

Third-Party Websites

This Site and App may contain links to third-party owned and/or operated websites including, without limitation, the Social Media Websites.  Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Company does not have any responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our end-users’ personal information. When end-users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). The privacy of your personal information is very important to us. When our registration process asks end-users to submit Sensitive Information (such as Social Security Number and credit/debit card information), and when we transmit such sensitive information, that information is encrypted and is protected with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information in are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site and/or App is at your own risk.

All of our end-users’ personal information, not just the sensitive information mentioned above, is restricted in our offices. Only employees or third party agents who need the personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Children’s Privacy

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information by and/or through the Site or App.  Company does not knowingly solicit or collect information from visitors under eighteen (18) years of age.

If you are a parent or a guardian, you are responsible for exercising supervision over your children’s online activities. If you are the parent or guardian of a child under the age of eighteen (18) and you believe that your child has submitted personal information by and through the Site or App without your authorization, please contact us at: support@zentrointernet.com.

Opt-Out/Unsubscribe

To opt-out of receiving e-mail communications from us, you can follow the instructions at the end of the applicable e-mail message or e-mail us at: support@zentrointernet.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Company Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Company Offerings-related and inquiry response-related messages from Company, you must cease requesting and/or utilizing the Company Offerings and cease submitting inquiries to Company, as applicable.

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: support@zentrointernet.com.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Company Offerings. If you wish to continue using the full complement of Company Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site and/or accessing the App from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site, accessing the App and/or otherwise communicating electronically with us, you consent to such transfers.  Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site and in the App that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify end-users by: (a) sending the modified policy to our end-users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy, please e-mail us at: support@zentrointernet.com; or send us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

Privacy Provisions for Covered Users

These Privacy Provisions for Covered Users (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above.  These Provisions apply solely to residents of the States of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, as well as California-based employees of, and California residents who submit job applicants to, Company  (collectively, “Covered Users”).

We adopt these Provisions in compliance with the CCPA, CPRA, CPA, CTDPA, DPDPA, IDPL, IDPA, KCDPA, MODPA, MNCDPA, MCDPA, NDPA, NHDPA, NJPA, OCPA, RIDTPPA, TIPA, TDPSA, UCPA and VCDPA (collectively, “Applicable State Laws”).  Any terms defined in Applicable State Laws have the same meaning when used in these Provisions.

Users with disabilities who wish to access these Provisions in an alternative format can contact us by emailing us at: accesssupport@zentrointernet.com; calling us at: 866-923-0982; or sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Covered User or device (“personal information”). In particular, we have collected the following categories of personal information from Covered Users within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated Covered User information.
• Information excluded from the scope of Applicable State Laws, such as:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

• Directly from our Covered Users. For example, online registration forms that our Covered Users submit to us related to the products and/or services that we offer by and through the Site/App. (Categories A, and B)
• Indirectly from our Covered Users. For example, through information we collect from our Covered Users in the course of providing our products and/or services to them. (Categories A, and B)

Retention of Personal Information and Sensitive Personal Information

We retain all categories of your personal information and sensitive personal information (including the information set forth in the “Personal Information Collected” section above) that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information including:

• Date of collection.
• Frequency of consumer interaction with us.
• Last interaction the consumer had with us.
• Whether the purpose of collection has been completed.

Notice of Financial Incentive

The Refer-a-Friend Program is offered by Company to users who refer prospective customers that purchase Company Services on the Site/in the App. Company offers certain discounts and other rewards (“Rewards”) to users who participate in the Refer-a-Friend Program and generate successful referrals.

In order to participate in the Refer-a-Friend Program, you must submit your email address on the registration form made available on the Refer-a-Friend Program page of the Site/in the App.  Company uses this personal information to improve its Company Offerings.  Participation in the Refer-a-Friend Program is optional and you may cease participating at any time.  Users may continue to use their Rewards after they cease participating in the Refer-a-Friend Program.

The value of the consumer personal information provided in order to participate in the Refer-a-Friend Program is based upon our reasonable, but sole, determination of the estimated value of such information.  We calculate this value by considering, without limitation, estimates regarding anticipated revenue that we may generate from such information, anticipated expenses which may be incurred in the collection, storage, use and sharing of such information in the operation of our business, and other relevant factors, as permitted under Applicable State Laws (“Valuation Criteria”).  Using the Valuation Criteria, we estimate the value of personal information we request from users who participate in the Refer-a-Friend Program, in part, by comparing the amount spent by an average customer who purchases our Company Services.

Use of Personal Information

We may use or disclose the personal information that we collect (including: (a) full name and, where applicable, Entity name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) credit/debit card information, bank account information for ACH payments or other Payment Method information (where purchasing Company Services); (f) the property type, and number of units, where you reside/your Entity is located; (g) your resume, and information pertaining to your work authorization status and desired salary (where utilizing the Career Opportunities); (h) Third Party Tracking Technology Data; and/or (i) Prize Winner Data) for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with a job application or your request for information regarding the products and/or services featured on the Site and/or through the App, we will use that personal information to better provide you with the requested information. (Categories A and B)
• To provide you with information, products or services that you request from us. (Categories A and B)
• To create, maintain, customize and secure your account with us. (Categories A and B)
• To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A and B)
• To deliver relevant Site/App content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A and B)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Terms applicable to the Site and App. (Categories A and B)
• To improve the Site/App and better present their respective contents to you. (Categories A, B, C, D, F, I and L)
• For customer service purposes and to respond to inquiries from you. (Categories A and B)

• For testing, research, analysis and product development. (Categories A and B)

• As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Categories A and B)
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A and B)
• As described to you when collecting your personal information or as otherwise set forth in Applicable Privacy Laws. (Categories A and B)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A and B)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing/Selling Personal Information

Subject to your right to opt-out of such sharing, we may share your personal information from Categories A and B (including: (a) full name and, where applicable, Entity name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) credit/debit card information, bank account information for ACH payments or other Payment Method information (where purchasing Company Services); (f) the property type, and number of units, where you reside/your Entity is located; (g) your resume, and information pertaining to your work authorization status and desired salary (where utilizing the Career Opportunities); (h) Third Party Tracking Technology Data; and/or (i) Prize Winner Data) with third parties for the business purposes set forth above.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract.

Please note, we do not collect information from Covered Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of any Covered users, regardless of age. Without limiting the foregoing, we have not shared or sold the personal information of Covered Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months other than for the business purposes listed above.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A       Identifiers.
Category B       Personal information categories listed in Applicable State Law.

We disclose your personal information (including: (a) full name and, where applicable, Entity name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) credit/debit card information, bank account information for ACH payments or other Payment Method information (where purchasing Company Services); (f) the property type, and number of units, where you reside/your Entity is located; (g) your resume, and information pertaining to your work authorization status and desired salary (where utilizing the Career Opportunities); (h) Third Party Tracking Technology Data; and/or (i) Prize Winner Data) with third parties for the business purposes set forth above) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

• Our affiliates. (Categories A and B)
• Service providers. (Categories A and B)
• Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (A and B)
• Third parties, such as Extole, Google, LinkedIn, Meta Zoho and ZoomInfo (but not Sensitive Personal Information)

In the preceding twelve (12) months, we have sold the following categories of personal information (including Third Party Tracking Technology Data), but not Sensitive Information or resume-related information, to third parties:

N/A

In the preceding twelve (12) months, we have sold the above referenced categories of personal information (but not Sensitive Personal Information) for marketing purposes to the following third parties: Extole, Google, LinkedIn, Meta Zoho and ZoomInfo.

Your Rights and Choices

Applicable Privacy Laws provide Covered Users with specific rights regarding their personal information. This section describes your rights under Applicable Privacy Laws and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties.  To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable Covered User request to us by either:

• Clicking here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of receipt of your request.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking Here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of receipt of your request. Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease sharing your Personal Information with third parties.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws or federal law), Category D (Commercial Information), Category I (Professional or employment-related information) and/or Category L (Sensitive Personal information), to those uses which: (i) are necessary to perform the services or provide the products requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site and/or App, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site and/or App; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a product, service or device that is owned by, manufactured by, manufactured for, or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned by, manufactured by, manufactured for, or controlled by, Company.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws or federal law), Category D (Commercial Information), Category I (Professional or employment-related information) and/or Category L (Sensitive Personal information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking Here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of receipt of your request.  Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease using your Sensitive Personal Information/sharing your Sensitive Personal Information with third parties (and direct our service providers and contractors to do the same).

Right to Opt-Out of Automated Decision Making Technology (“ADMT”)/Consumer Rights Related to ADMT

For purposes of these Provisions, “ADMT” means any form of technology that processes personal information and uses automatic computation to replace human decision-making or substantially replace human decision-making, when making a Significant Decision regarding you. For purposes of these Provisions, “Significant Decision” means a decision that results in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services.

You have the right to opt-out from the use of ADMT to make Significant Decisions by Company, as detailed below.   Where you opt-out from the use of ADMT, we will contact you directly in order to make the applicable Strategic Decision. We shall not retaliate against, or disadvantage, you in any way for exercising rights set forth in this section.

Further, you have the right to request that we disclose certain information to you about our ADMT activities that have resulted in Significant Decisions that concern you, if applicable. Once we receive and confirm your verifiable Covered User request, we will disclose to you:

• The specific purpose and outcome of any ADMT-based Significant Decisions that concern you, if applicable.
• The reason that the ADMT activity resulted in the applicable Significant Decision, such as the parameters affecting the ADMT output.
• What actions you can take, if any, that would result in a different ADMT decision in the future.
• The specific pieces of personal information we collected about you that were used in the ADMT-derived Significant Decision and, if the ADMT-derived Significant Decision was based on inaccurate data, the right to correct same.
• How we plan to use ADMT in the future.

To exercise your right to opt-out of our use of ADMT to make Significant Decisions that concern you and/or to exercise any other right relating to our use of ADMT as set forth above, please submit a verifiable Covered User request to us by either:

• Clicking Here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all ADMT opt-out/consumer rights requests as soon as practicable, but in all cases within fifteen (15) days of receipt of your request.

Right to Opt-Out of Targeted Advertising

You have the right to opt-out from Targeted Advertising conducted by Company.  For purposes of these Provisions, “Targeted Advertising” means displaying advertisements to you where the advertisements are selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests.  You have the right to opt-out from Targeted Advertising. To exercise your right to opt-out of our Targeted Advertising, please submit a verifiable Covered User request to us by either:

• Clicking Here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all Targeted Advertising opt-out requests as soon as practicable, but in all cases within fifteen (15) days of receipt of your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable Covered User request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Covered User request, we will delete (and direct our service providers, contractors and third parties to whom we shared your personal information, to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers, contractors and third parties to whom we sold/shared your personal information, to:

1. Complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech rights, ensure the right of another Covered User to exercise her/his free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, but only if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with Covered User expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.  Where we correct inaccurate personal and/or sensitive personal information, we shall instruct all service providers and/or contractors that maintain such personal and/or sensitive personal information in the course of providing services to us to make the necessary corrections in their respective systems.

Exercising Access, Data Portability, Right to Correct and Deletion Rights

To exercise your access, data portability, right to correct and/or deletion rights described above, please submit a verifiable Covered User request to us by either:

• Clicking here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

The verifiable Covered User request must:

• Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.  Making a verifiable Covered User request does not require that you create an account with us.  We will only use personal information provided in a verifiable Covered User request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable Covered User requests within forty-five (45) days of the receipt thereof.  If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request.  The response that we provide will also explain the reasons that we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Covered User request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If we deny any Covered User access/right to know, data portability, right to correct and/or deletion rights request, you may submit an appeal of our decision within thirty (30) days of your receipt of our notice of denial by e-mailing us at: support@zentrointernet.com; or sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

Opt-Out Preference Signal Processing

Right to Opt-Out of Profiling/Consumer Rights Related to Profiling

For purposes of these Provisions, “Profiling” means any form of automated processing performed on your personal data to evaluate, analyze or predict personal aspects related to you or your economic situation, health, personal preferences, interests, reliability, behavior, location and/or movements. You have the right to opt-out from any Profiling that may be conducted by Company, as detailed below.

Further, you have the right to request that we disclose certain information to you about our Profiling activities that have produced legal effects, or similarly significant effects, that concern you, if applicable. Once we receive and confirm your verifiable Covered User request, we will disclose to you:

• Any Profiling decisions we have made about you that have produced legal effects, or similarly significant effects, that concern you, if applicable.
• The reason that the Profiling activity resulted in the applicable decision.
• What actions you can take, if any, that would result in a different Profiling decision in the future.
• The specific pieces of personal information we collected about you that were used in the Profiling and, if the Profiling was based on inaccurate data, the right to correct same.

To exercise your right to opt-out of this Profiling and/or to exercise any other right relating to Profiling as set forth above, please submit a verifiable Covered User request to us by either:

• Clicking Here
• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.

We endeavor to act on all Profiling opt-out/consumer rights requests as soon as practicable, but in all cases within fifteen (15) days of receipt of your request.

Authorized Agents

Covered Users may permit an Authorized Agent to exercise any rights granted under Applicable State Laws as set forth above.   In order to utilize an Authorized Agent, you must provide the Authorized Agent with written permission from you to act on your behalf for these purposes.  When you use an Authorized Agent to submit a request to delete, request to correct or a request to know, we may require the Authorized Agent to provide proof that you gave the agent signed permission to submit the subject request.  We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the Authorized Agent permission to submit the request.

For California residents, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Covered User request related to your personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Applicable State Laws. Unless permitted by Applicable State Laws, we will not:

• Deny you products or services;
• Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you with a different level or quality of products or services;
• Retaliate against any employee, job applicant or independent contractor; and/or
• Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

Changes to these Privacy Provisions

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the homepages of the Site and App.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Applicable State Laws, please do not hesitate to contact us by either:

• Emailing us at: support@zentrointernet.com; or
• Sending us U.S. Mail to: Zentro, 420 North May Street, Chicago, IL 60642.