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Privacy Policy

We value your privacy.
This Privacy Policy applies to your usage of all software and services provided by Zello.

Welcome to Zello. Zello, Inc. ("Zello," "we," "us," or "our") provides push-to-talk, "walkie-talkie" services for mobile devices (such services, together with the Sites and the App, the "Services") to individual users ("Users"). The Services also include Zello Work, which is made available to organizations ("Customers") for use with their end users ("End Users"). We provide the Services through our Zello applications (each an "App" and together the "Apps") and we provide information about the Services through our website available at https://zellowork.ru and other Zello websites (each a "Site" and together the "Sites").

This Privacy Policy explains what Personal Data (defined below) we collect in connection with or through the Services, how we use and share that data, and your choices concerning our data practices. This Privacy Policy does not apply to any third-party applications or software that may integrate with the Services or any other third-party products, services or businesses, nor does it apply to Personal Data relating to Customers' End Users that we process in the course of providing our Services to our Customers. Such information is processed pursuant to our agreements with our Customers.

By providing us with your Personal Data or accessing or using the Services you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services or provide us with your Personal Data. Before you access or use the Services or submit any Personal Data to Zello, please review this Privacy Policy carefully and contact us at privacy@zello.com if you have any questions.

INFORMATION WE COLLECT

When you contact us or interact with the Services, we collect information that alone or in combination with other information could be used to identify you ("Personal Data") as follows:

Personal Data That You Provide

User Information: If you are a User, we collect the following type of information that you provide in connection with your use of the Services. Certain information about you is also logged automatically in our systems, as described in the "Information Collected Automatically" section below.
- Account Information: When you sign up for a Zello account, we collect certain Personal Data about you, including your username, password, email address, IP address, and a device identifier generated through the App (which is separate from and not related to any advertising identifier generated by your device's operating system). You may also choose to provide your phone number to enable us to verify your identity mitigate spam and abuse.
- Your Content: When using our Services and in accordance with the consent process provided by your device, you can allow the App to access (i) your contacts, so you can invite your friends to join Zello; (ii) your camera/photos, so you can create or post a profile picture or send photos to other Users through the Services, and (iii) your location, if you would like to share it with other Users on the Services (please also read the "Information Collected Automatically" section below for further information about how we process location information). You may also grant permissions for our App to access the microphone on your device in order to transmit your audio to other Users on the App.
- Information You Provide Through Our Support Channels: If you choose to submit information regarding a problem you are experiencing with the Services to our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. We will collect the information associated with this request in order to address your problem.

Information Collected from Site Visitors: We collect information that you provide when you interact with our Sites, such as when you request content, register for an event, contact our sales team or otherwise communicate with us. Certain information about you is also logged automatically in our systems, as described in the "Information Collected Automatically" section below. The information we may collect from you described below.
- Requesting Information or Content: We collect certain Personal Data about you if you voluntarily provide us with such information when you engage in certain activities on our Sites, such as fill out web forms to ask to be contacted by our sales team or request a demo, ask to download content (such as brochures, studies or guides), register for a webcast or other event, post comments on pages or our blog, or subscribe to emailing lists. The specific Personal Data collected during these interactions will vary based on the purpose of the form or the nature of your request, but it will generally include your name, email address and phone number (for example, we will ask you to provide your phone number if you want a member of our sales team to call you). We may also ask you for additional information to help us understand you better as a customer like your company name, or your role at your company.
- Information We Collect Through Our Social Media Pages: We maintain pages through social media services like Facebook, Twitter, YouTube, and Instagram ("Social Media Pages"). We may collect Personal Data from you when you interact with our Social Media Pages, including Facebook, LinkedIn and Twitter. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analysis regarding the use of our Social Media Pages.

Zello Work Customers: If you are a Zello Work Customer, we may collect certain Personal Data about you or your End Users as described below. Certain information about you is also logged automatically in our systems, as described in the "Information Collected Automatically" section below. The information we may collect from you described below.

Account Registration: If you register with the Services through our Sites or through a separate subscription agreement with us, then as part of such registration we will ask you to provide certain Personal Data, including your name, your company name, your email address and password. If you create an account or log into the Services using third-party services, we will receive your name and email address as permitted by your profile settings on the third-party service in order to authenticate you. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with our Services.
Paying for Our Services: When you purchase a subscription to our Services, you will provide our third party payment processor Zuora with billing details such as credit card information, banking information and/or a billing address. If you have questions about how Zuora protects such information, please read Zuora's services agreement and privacy policy.
Contact our Sales Team or Customer Support Team: You may provide your Personal Data, like your contact information, to a member of our sales or customer support team when you communicate with them. If you contact our sales or customer support teams, those teams keep a record of that communication, including your contact details and other information you share during the course of the communication. We store this information to help us keep track of the inquiries we receive from you and from Customers generally so we can improve our Services and provide training to team members. This information also helps our teams manage our ongoing relationships with our Customers.
Personal Data Collected on Behalf of Customers: While providing Zello Work, we will collect certain Personal Data relating to End Users on behalf of our Customers. Our use of information on behalf of our Customers is governed by our contract with the applicable Customer and the Customer's own privacy policies. We are not responsible for the privacy policies or privacy practices of Customers or other third parties. We have no direct relationship with the End Users whose Personal Data we process on behalf of Customers. If you are an End User of one of our Customers and would no longer like your data to be used by one of our Customers through the Services or you would like to access, correct or request deletion of your data, please contact the Customer that you interact with directly (e.g. your employer).

Information Collected Automatically: When you visit, use and interact with the Services, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Sites or use the App, peak hours of visits, which page(s) are visited on our Sites, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Sites (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log data: Information ("log data") that your browser automatically sends whenever you visit the Sites. Log data includes your Internet Protocol ("IP") address (so we understand which country you are connecting from when you visit the Sites), browser type and settings, the date and time of your request, and how you interacted with the Sites.
- Cookies and similar technologies: Please see the "Cookies and Other Technologies" section below to learn more about how we use cookies and other technologies.
- Device information: Includes name/type of the device accessing the Services, operating system, browser you are using, device settings, application IDs, unique device identifiers and crash data. Information collected may depend on the type of device you use and its settings.
- Usage information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
- Location information: If you have enabled location services for the App on your mobile device, we may collect your precise location information based on city, state, zip code, country, latitude and longitude. We may also derive your approximate location from the IP address of your mobile device. Location information is used for purposes of enabling you to share your location with other Users through the Services. If you opt-in to have background location on in our App, we will collect data about your location when you are not using the App and when the App is closed (as permitted by your device settings). If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the App's access to your location data.

HOW WE USE INFORMATION

We use Personal Data for the following purposes:

To provide our Users and Customers with the Services and related customer support, process transactions, manage your account and respond to your requests. This processing is necessary to perform our contract we are about to enter into or have entered into with our Users or Customers.

As necessary for certain legitimate business interests, which include the following:

To respond to inquiries, comments, feedback or questions;
To verify the identities of Users to mitigate spam and abuse of the Services;
To connect Users to the most geographically proximate server and provide more relevant, localized content;
To allow Users to share their location with other Users of the Services, to invite friends to join them on the Services, and to allow them to post or share photos through the Services;
To send administrative information to you, for example, information about the App or Services, and changes to our terms, conditions, and policies;
To contact you by email to tell you about information we believe will be of interest to you, such as information about products and services, features, surveys, newsletters and upcoming events. If we do, where required by law, we will only send you such marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails, texts or telephone calls by following the instructions contained in each communication we send you or by contacting us as explained at the bottom of this Privacy Policy. If you opt-out from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Services and products and to respond to your requests;
To analyze App and Site usage so we can provide, maintain and improve the content and functionality of the App and Sites. For example, we regularly fix bugs and User or Customer experience issues. We use cookies and similar technologies to analyze how users interact with our App and Sites. And that analysis can help us improve the App and Sites. If you are an individual in the European Economic Area or the United Kingdom, we will obtain your consent before using cookies and similar technologies for analytics purposes.
To conduct analytics to inform our marketing strategy and enable us to enhance and personalize the experience we offer to our Users or Customers;
To prevent fraud, criminal activity, or misuses of our App and Sites and to ensure the security of our IT systems, architecture and networks; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, Customers, or other third parties

With your consent, if required by the applicable law, which you may withdraw at any time using your account settings and other tools;

To contact you by email to tell you about information we believe will be of interest to you, such as information about products and services, features, surveys, newsletters and upcoming events. If we do, where required by law, we will only send you such marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving promotional communications by following the instructions contained in each communication we send you or by contacting us as explained at the bottom of this Privacy Policy. If you opt-out from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Services and products and to respond to your requests.

There may be other occasions where Personal Data is processed for purposes which will be explained at that time. We will provide further notice to you of any additional processing and, if required, ask your consent to that processing.

If you are an individual in the European Economic Area or the United Kingdom, please see the "European Individuals" section below for additional information about our processing activities, including what we mean by legitimate interests and your rights in relation to that processing.

SHARING AND DISCLOSURE OF INFORMATION

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

Other Users: When you connect to a communication channel, your username will be visible to other Users connected to the same channel. We do not record, monitor, or store the voice communications you send through the Services, but you acknowledge and agree that Users connected to channels through which you share voice communications may save, replay, and share your communications through the voice history feature of the Services.
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with service providers, including hosting, cloud services and other information technology services providers; email communication software providers, advertising and marketing service providers; customer relationship management, customer engagement, and customer feedback services; payment processors; identity verification services; and analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
The Public: Our Sites offer publicly accessible blogs (such as https://blog.zello.com). You should be aware that any information you provide on these Sites – including, if you have a Zello account, profile information associated with the account you use to post the information – may be read, collected, and used by any member of the public who accesses these Sites. Please consider the sensitivity of any information you input into these Sites. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.

DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

CHILDREN

The Sites and the Services are not directed to children who are under the age of 13. Zello does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Zello through the Sites or Services please contact us at privacy@zello.com and we will endeavor to delete that information from our databases.

EUROPEAN INDIVIDUALS

Scope. This section applies to individuals in the European Economic Area and the United Kingdom (UK).

Data Controller. Zello is the data controller of Users' Personal Data and Personal Data obtained through the Sites and Social Media Pages. Zello is the data processor of Personal Data provided or otherwise made available to us by Customers or End Users through the Services, which we process on Customers' behalf pursuant to our contract with the applicable Customer. You can find our contact information, and the contact information of our representative in the EEA/UK for purposes of the General Data Protection Regulation, in the "Contact Us" section below.

Legal Bases for Processing. This Privacy Policy (the paragraph "How We Use Personal Data") describes the legal bases we rely on for the processing of your Personal Data. Please contact us if you have any questions about the specific legal basis we are relying on to process your Personal Data.

As used in this Privacy Policy, "legitimate interests" means our interests in conducting our business and developing a business relationship with you. This Privacy Policy (the paragraph "How We Use Personal Data") describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Your Rights. Subject to applicable law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or 'block' the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  - If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
  - If we are processing your Personal Data for direct marketing.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
Please contact us at privacy@zello.com and to exercise your rights or request additional information on how to exercise your rights.

LINKS TO OTHER WEBSITES OR SERVICES

The Services may contain links to other websites or services not operated or controlled by Zello ("Third Party Services"). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Services directly for information on their privacy practices and policies.

COOKIES AND OTHER TECHNOLOGIES

We and our partners use cookies, device identifiers and other similar technologies to operate and administer our Services, make it easier for you to use the Sites during future visits, and gather usage data on our Services.

Cookies and other similar technologies can be stored on your computer or device for different periods of time. For example, some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). Our Sites uses cookies and similar technologies from the third parties described below. For more details on cookies please visit All About Cookies.

Pixel tags or "clear" gifs are small images on a web page or in an email. When you visit the Sites or view one of our emails, we will use pixel tags, from the third parties described below, to track your activity on our Sites (for example, to know when content has been shown to you) and to personalize your experience. We also use pixel tags to determine what types of email your browser supports.

Type of Technologies Used

The following chart sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

CATEGORY

WHO SERVES THE COOKIE

OPT OUT

Strictly necessary:

Used to provide users with services available through the Sites and to use some of their features, such as the ability to log-in and access secure areas. These cookies are essential for using and navigating the Sites.

Cloudflare:

We use a Cloudflare cookie to ensure the security of the Sites. This cookie expires in 30 days. Cloudflare Privacy Policy

Because these cookies are strictly necessary to deliver the Sites, users cannot refuse them.

Functionality:

Used to enhance the performance and functionality of the Sites. These cookies are not essential for using and navigating the Sites. However, without these cookies, you will not be able to use certain functionalities offered on our Sites.

HubSpot:

We use a cookie (hubspotutk) to keep track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts. We also use a cookie (messagesUtk) to recognize visitors who chat with us via the chatflows tool. For more information, please read HubSpot cookie description here.

You can prevent your data from being collected by HubSpot by turning off cookies in your browser (please see the "Cookie Choices" section below for more information).

Analytics / Performance:

Used to recognize and count the number of Sites visitors and to gather statistics regarding how visitors move around the Sites (including number of page views, number of visitors, and time spent on each page). This helps us improve the way our Sites work and your experience on it, for example by making sure you can find what you need easily.

Google Analytics:

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), which uses cookies to analyze how visitors use our Sites. The information generated by these cookies may be transmitted to and stored by Google on servers in the United States. We use the information to compile reports and to help us improve the Sites. Privacy Policy

Google Analytics Opt Out

To opt out of Google Firebase, please visit the Google Analytics for Firebase policy.

You can prevent your data from being collected by these technologies by turning off cookies in your browser (please see the "Cookie Choices" section below for more information).

Zello:

We use analytics cookies to run experiments on the Zello Work console, and to distinguish first time visitors to the Sites. These cookie expires in 30 or 60 days. Please contact us at privacy@zello.com if if you would like to receive more information.

Amplitude:

We use Amplitude, an analytics service provided by Amplitude Inc. This tool collects technical information, such as the type of your device. In addition, Amplitude tracks location data (e.g. country) and internal data (e.g. language, server upload time, session ID) that occur when using our Apps. Amplitude helps us understand how you use our Apps so we can improve the experience. Learn more here: Privacy Policy

Firebase:

We use the Firebase service from Google LLC in order to derive application behavioral analytics, including by collecting identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS). We use that information to see how Users interact with our Sites and the Apps. To learn more about how Google uses data when you use our Sites or Apps please read here.

Advertising/Targeting

We use cookies and pixels from third parties that allow us to enable visitors to our Sites to share content on social networks such as LinkedIn, Facebook or Twitter. These cookies and pixels enable such parties to serve ads to you based on your visit to our Sites and also allow us to analyze the performance of our ads. We do not control these technologies and cannot prevent these sites or domains from collecting information on your use of this content. You should check the relevant third party website and privacy policies for more information and how to opt out, as described in this section.

HubSpot:

We use a marketing automation and analytics tool provided by HubSpot, Inc. This tool is used to help us analyze how you interact with the Services and enables us to personalize user experience, including through marketing communications. The HubSpot cookies/pixels collect Personal Data submitted by you via web forms, including name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Data may also include information about your computer (such as operating system), geographical location (as indicated by publicly available IP address records), browser type, referral source, length of visit, and pages viewed. Learn more about HubSpot's practices and cookie duration here.

HubSpot:

You can prevent your data from being collected by HubSpot by turning off cookies in your browser (please see the "Cookie Choices" section below for more information).

DoubleClick:

We use DoubleClick for serving targeted advertisements that are relevant to users across the web. Targeted advertisements may be displayed to users based on previous visits to a website. These cookies/pixels measure the conversion rate of ads presented to the user. Learn more about these cookies and their duration here: Privacy Policy.

DoubleClick Opt-out

LinkedIn:

LinkedIn sets cookies on the Sites to allow interaction with LinkedIn from our Sites and to enable behavioral advertising and analytics by LinkedIn. Learn more about these cookies and their duration here: Privacy Policy.

LinkedIn:

You should check LinkedIn's website for more information on how to opt out, at this link.

Facebook:

Facebook, Inc. provides technologies that enable us to serve users with ads on Facebook based on their visit to and interaction on the Sites. Facebook's pixels allow user behavior to be tracked after they have been redirected to our Sites by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. Learn more about these technologies and their duration here: Privacy Policy

Facebook:

You can modify your Facebook Ad settings to restrict advertisements. Navigate to Settings/Adverts in your Facebook account to adjust your preferences. Learn more about the different types of Facebook cookies here.

Twitter:

We use Twitter share buttons on the Sites. Twitter may use cookies to better understand how you interact with their services, to monitor aggregate usage by Twitter users and web traffic routing to their services. Learn more about these cookies and their duration here: Privacy Policy.

Twitter:

You should check Twitter's website for more information on how to opt out, here: Privacy Policy.

G2 Crowd:

G2 Crowd: Used to track visitors and conversion when you use the company review website and related services provided by G2.com, Inc. Learn more about these cookies and their duration here.

G2 Crowd:

You should check G2's website for more information on how to opt out, here: Cookie Policy.

Capterra:

Used to track visitors and conversion when you use the company review website and related services provided by Capterra Inc. Learn more about these cookies and their duration here.

Capterra:

You should check G2's website for more information on how to opt out, here.

ZoomInfo:

Used to analyze how visitors use our Sites. Learn more here.

ZoomInfo:

You should check G2's website for more information on how to opt out, here.

Cookie Choices. If you are an individual in the European Economic Area or the United Kingdom, you can decide whether to accept or reject cookies other than strictly necessary cookies. You can exercise your cookie preferences when you first arrive at our Sites. You will see a notice about our use of cookies, providing you with the opportunity to learn more and to choose which types of cookies you wish to allow to access your device before accepting cookies. Our lawful basis for setting cookies other than strictly necessary cookies is your consent, which you can provide in the way described above. We may also rely on another lawful basis for our subsequent processing of your personal data collected through cookies, such as our legitimate interest in conducting statistical analysis, as described in this Privacy Policy.

Moreover, on most web browsers you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser's settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites.

[Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative's online resources at http://www.networkadvertising.org and follow the opt-out instructions there or if you are located in the EEA or the UK, visit the European Interactive Digital Advertising Alliance's Your Online Choices opt-out tool here.

If you access the Sites on your mobile device, you may not be able to control tracking technologies through the settings.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Sites and use that information to send targeted advertisements. [Our Sites currently does not respond to "Do Not Track" ("DNT") signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.] [OR] [We make reasonable commercial efforts to recognize and support "Do Not Track" signals.]

SECURITY

You use the Services at your own risk. We comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. For example, we use available technology and other techniques to implement systems like firewalls, and/or encryption to secure data transfers. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services, or e-mail. Please keep this in mind when disclosing any Personal Data to Zello via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained in the Services or third party websites.

YOUR CHOICES

Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to create an account for or use some features of the Services, we may be unable to provide you with the Services. You can also contact us to access, update, correct, or remove your Personal Data from the Sites.

CHANGES TO THE PRIVACY POLICY

The App, the Sites, the Services, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use the App, the Sites, or the Services, or by providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

INTERNATIONAL TRANSFER

Zello is based in the United States. If you are accessing the Services from the EEA, the UK or other regions with laws governing data collection and use, please note that we may transfer your Personal Data to the United States for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Transfers of your personal data to Zello to the United States are necessary to perform the agreement we have entered into, or are about to enter into, with you.

CONTACT US

If you have any questions about our Privacy Policy or the information practices of the App or the Sites, please feel free to contact us at privacy@zello.com.

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