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Zalpha Mobile Privacy Policy

1. Introduction

This “Privacy Policy” describes the privacy practices of Privo Mobile Inc. doing business as ZalphaTM Mobile (“Company,” “we,” “our,” or “us”) in connection with our goods and services and the www.zalphamobile.com website and any other website (collectively, the “Site”) that we own or control and which posts or links to this Privacy Notice (collectively, “Services”). This Privacy Policy also explains the rights and choices available to individuals with respect to their information. This Privacy Policy includes our Children’s Privacy Policy below.

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Please read this Privacy Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, you should not use our Services. We cannot provide them without collecting personal information from you subject to this Privacy Policy.  By accessing or using our Services, you acknowledge this Privacy Policy applies to you.

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2. Children’s Privacy 

When a parent or legal guardian procures our mobile Services for a child, we will have access to that child’s personal information when they use the Zalpha mobile phone for kids. Please review the Children’s Privacy Policy at the end of this Privacy Policy regarding information we collect from and about the child and how we use it. You may also click here to go straight to the Children’s Privacy Policy or scroll down to Section 14 below. Children themselves may not register for an account to use our Services and the Site is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13 via the Site.

 

This Privacy Policy regards information we collect and use relative to adults unless otherwise specifically indicated. Please review the Children’s Privacy Policy below regarding personal information relative to children.

 

3. Personal Information We Collect

 

  • Information You Provide Us: We may collect information that personally identifies you such as your name, email address, shipping address, service address, and phone number or other data (“personal information”) when you use our Services or otherwise interact with us. You may choose to provide us with your personal information when you make a purchase on our Site, when you contact us or when you sign up to receive updates on our offerings. To make a purchase on the Site, you are required to provide your payment information to our designated third party payment processor available at check out. You may have a choice of which payment processor you want to use at check out. We do not collect your payment information.

  • Information We Automatically Collect: When you visit the Site, we may automatically collect certain information about your device accessing the Site, including information about your web browser, IP address, time zone, and some of the cookies and similar technologies that are installed on your device. Additionally, as you browse the Site, we may collect information about the individual web pages or details that you view, what websites or search terms referred you to the Site, and other information about how you interact with the Site. See the “Cookies & Similar Technologies” section below regarding how and what information we automatically collect via such technologies.

  • Information We Collect from Third Parties: If you register a Spotify account for your child using the Zalpha mobile phone, we may receive confirmation from Spotify that you have a Spotify account. Creating and using the account is subject to Spotify’s terms and conditions, which we do not control. Learn more at www.spotify.com.

 

4. How We Use Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time and point of collection of your personal information:

  • To provide, operate, maintain, troubleshoot and improve our Services;

  • To fulfill any orders you place using our Site;

  • To establish and maintain your account on the Site;

  • To communicate with you about our Services, including by sending you announcements and administrative messages;

  • To personalize your experience with the Services and communicate with you;

  • To provide support and maintenance;

  • To respond to your requests and your feedback to us;

  • To provide you with marketing communications;

  • To help us advertise our Services and display advertisements to you;

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

  • To comply with legal obligations;

  • To secure our Services, investigate and resolve issues, enforce our user terms, and defend our rights and users; and

  • Other purposes with your consent.

 

5. How We Share Personal Information

 

  • We do not share your personal information with third parties without your consent, except as described in this Privacy Policy, including for the purposes described above.

  • We may share your personal information with our owners, managers and affiliates for purposes consistent with this Privacy Policy.

  • We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate (such as the mobile network on which our phones operate, professional advisors, customer support, hosting, analytics, email delivery, marketing, shipping and fulfillment, and database management services) for purposes of helping us operate and making our Services available.

  • We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, insolvency, or dissolution.

 

6. Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your device used to access the Site) and similar technologies (“Cookies”) to provide you with certain functions on our Site, for example, saving your cart contents at checkout. This section explains how we use Cookies and how you can control them.

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  • How We Use Cookies: We use Cookies to track how you use our Site by providing us with usage statistics across Site users. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Site. Information supplied to us using Cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be. We may combine the information we collect from Cookies with personal information that we have collected from you to learn more about how you use our Services, and to manage, troubleshoot and improve them.

  • Types of Cookies We Use: We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

    • Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorization Cookies for our Site.

    • Functional: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.

    • Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.

    • Targeting: These Cookies are used to deliver relevant information related to our Site to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our Site. Some of these types of Cookies on our Site are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our Site.

    • Cookies Set by Third-Party Websites: To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Site. We currently use, and may in the future use, content from third-party websites such as YouTube, Vimeo, Shopify, Facebook, LinkedIn, and X (f/k/a Twitter). You may be presented with Cookies from these third-party platforms. Please note that we do not control these third-party Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using Cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these Cookies are used and how you can control them.

    • Social Sharing: We also may embed social sharing icons throughout our Site. These sharing options are designed to enable users to easily (and optionally) share content from our Site with others using a variety of different social networks. The Site may collect information such as the web pages you visited and IP addresses, and may set Cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access.

  • How to Control and Delete Cookies: Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific and sometimes your other device settings may also impact how Cookies are used. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments. May resources provide information about Cookies and how to use and disable them. Here, for example, is one: http://www.allaboutcookies.org. Please note that if you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Site may not operate properly, and you may not have access to our all of our Services available through the Site. We are not be responsible for your inability to use our Services or any degraded function you may experience that may be caused by your settings and choices regarding Cookies.

 

7. Do Not Track Requests to Us and Tracking Across Other Sites: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not have the ability to respond to “Do Not Track” or similar signals to our Site. We and our service providers may track which website you visited prior to our Site and where you navigated afterward. Third parties other than our service providers do not have permission to track your online activity from us, but we cannot control all third-party activity online.

 

8. Links to Third-Party Content: The Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

 

9. Data Security: You need to create a strong password to secure your online account with us and keep your log-in credentials confidential. You also need to teach your child using the Zalpha mobile phone how to secure the phone and limit unauthorized access to the phone. Please report any unauthorized access to your account or the phone to us right away, provided any activity via your account and the phone, whether or not authorized, is your responsibility. We use commercially reasonable measures to secure our Site and Services but, unfortunately, the transmission of information via the internet is not completely secure. We cannot and do not guarantee the security of your personal information. We do not process payments ourselves. We do use reputable third party payment processors who are expected to appropriately secure your payment data.

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10. Note To International Users: Our Services are for persons resident in the United States and we do not knowingly make available mobile service to users outside of the United States. If you access a Site or other Service from any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your use of the Site or Service, which are governed by US law, you are transferring your Personal Information to the United States and you consent to that transfer.

 

11. California’s Shine the Light Law: California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of the information you provide through the website to third parties for their direct marketing purposes. To make such a request, please contact us at the information provided below.

 

12. Updates to This Privacy Policy: We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our Services. We will post changes to our Privacy Policy on the Site. Please review any changes. If we make material changes, we may take other measures to inform you of the changes, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Notice, you should discontinue your use of the Services.

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13. Contact Us: For questions about this Privacy Policy, contact us at: privacy@zalphamobile.com. For other matters, see Contact Us | Zalpha Mobile and choose the contact option that best meets your needs.

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14. Children’s Privacy Policy: This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“children”). This policy is in accordance with the United States Children’s Online Privacy Protection Act and describes our practices in the United States regarding personal information of children. We will also treat the information of other kids who are minors under 18 (“kids” or “minors”) similarly.  

 

  • The Information We Collect from Children, How We Use It, and How We Communicate with Parents/Guardians About It

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While we expect that kids will not use our Site, which is directed to their parents and legal guardians, we recognize that in using the Zalpha mobile phone, which allows users to send and receive text messages, make voice calls, listen to voice mail messages, and take and store photos, all of which are Services enabled via software, including online software, we will collect personal information of kids for purposes of making such Services available.

 

We may collect the following personal information from kid users of the Zalpha mobile phone merely in the ordinary course of making the mobile phone service available when they disclose or create this personal information: the number associated with the Zalpha phone, their name, age, birth date, location, voice, and images, as well other personal details the child may disclose in use of our Services. If the user is interacting with their peers using our phone, we may collect similar information from their peers.

 

We also collect the following persistent identifiers: mobile phone number, IP address or other mobile device identifier of the Zalpha phone such as the IMEI (International Mobile Equipment Identity number), and/or the ICCID (Integrated Circuit Card Identification or sim card identifier).

 

We expect that if a minor user needs to troubleshoot their phone, that they will ask a parent to contact our customer support. In the event the minor contacts us directly, we will obtain their name and telephone number associated with their Zalpha phone to help troubleshoot the phone. We may also have an email address for the minor. If the adult making a support request consents to our accessing data stored locally on the phone in order to troubleshoot the device, we may have access to local files in addition to information transmitted over our network.

 

In the event the Zalpha phone is returned to us to troubleshoot or for any other reason we encourage users to wipe the phone of data. In the event we were to turnover the phone to the manufacturer or a service provider to assist with a device issue, we would confirm the phone is wiped of data prior to sharing the phone for such purpose.

 

  • When Information Collected from Children is Available to Others

 

The personal information of kids is collected and used primarily to provide use of all phone functionality to them (excluding Spotify, which we do not control and requires a separate Spotify account set up for the kid by their parent or legal guardian). We will also otherwise share the personal information of kids as indicated in Section 5 of our Privacy Policy above, on the same basis as for adults, provided that we do not market or advertise to kids via email or via their Zalpha phones or collect payments from them.

 

Our mobile network is provided using national third-party mobile phone infrastructure and the underlying service provider for our mobile network has access to all data that crosses through its systems in order to make mobile services available and as necessary to comply with applicable laws. That data includes the persistent identifiers associated with the Zalpha phone described above (e.g., mobile phone number, IP address and other mobile device identifier). The persistent identifiers are used by us and the carrier to provide the kids with access to Zalpha phone features they request, customize and improve the same as well as the phones themselves, understand how our users are using our Services, and generate reporting across our users that does not identify individual users, unless required by applicable laws.

 

For questions regarding third party access to personal information of children, contact us at: privacy@zalphamobile.com. For other matters, see Contact Us | Zalpha Mobile and choose the contact option that best meets your needs.

 

  • Parental Choices and Controls

 

You may have your child cease use of our Services at any time and can refuse to permit us to collect further personal information from your child, which would mean that they will not be able to use the Zalpha phone on our network or any other network going forward.

 

If you suspend our Services but continue to use the Zalpha phone (physical device) as an “unlocked” phone that you take to another mobile network for service, we may continue to receive information from the device (e.g., battery life and usage information) though we would not be actively monitoring the phone for a user who is not a current user. Our software imposing child-friendly limits on the phone to make it a Zalpha phone will automatically become inactive if the phone is unused for a year or longer. If you desire to have the software uninstalled sooner, please contact us.

 

You can also ask us to delete records associated with your child’s Zalpha phone account when you terminate Services with us and we will cease active use of the records and delete them except to the extent we are required to retain the records to comply with legal obligations, in which event the records will be deleted once the legal obligation ceases.

Children's Privacy Policy
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