This Policy covers only the Services identified above, and does not apply to information which you may send us by other means. Other ZAP sites, locations, and services, whether online or offline, may have their own privacy policies, and you should consult those accordingly.

The Services may contain links to external sites, locations, or other third-party services, including those embedded in advertisements or sponsor information, which are not owned or controlled by ZAP. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the respective privacy policy for each third-party service you use for details about how any third party may handle your information.

If you do not agree with the terms of this Policy, please do not provide any personal information to ZAP or use our Services. Some of our Services can only be offered if you provide or allow us to collect your personal information in accordance with this Policy.

ZAP reserves the right to make changes to this Policy from time to time to reflect company and customer feedback, or as we modify or expand our Services. ZAP encourages you to periodically review this Policy to be informed of how ZAP is handling your information. Our Policy’s effective date will always be set forth at the beginning of the Policy. Any changes will be immediately incorporated into this Policy.

Any change to this Policy is effective immediately. Your continued use of the Services after any changes are made constitutes your acceptance of any new terms in the Policy, as revised. If any changes are unacceptable to you, you should cease all use of the Services.

Personal information is generally defined as information that, by itself or in combination with other information, identifies or is reasonably capable of being associated with a particular individual, device, or household.

When you access or use our Sites or other Services, ZAP collects personal information such as (but not exclusive to) your e-mail address, name, home or work address, or telephone number. ZAP also collects demographic information such as (but not exclusive to) your ZIP code, age, gender, preferences, professional/employment information, educational background/records, credit/debit card information for payments, family and financial information, interests and favorites.

There is also information about your computer hardware, device, and software that is automatically collected by ZAP. This information can include: your IP address, browser type, domain names, access times, and referring web site addresses. This information is used by ZAP to operate the Services, to maintain the quality of the Services, and to provide general statistics regarding use of the Services.

Please keep in mind that if you directly disclose personal information or other sensitive data through public message boards on the Sites or through other Services, this information may be collected and used by others. ZAP reserves the right, but does not have any duty or obligation, to read any of your public or private online communications while using our Services.

Depending on where you reside, some personal information that you provide on or through ZAP’s Services may be considered sensitive personal information. ZAP does not knowingly collect any sensitive personal information, which is typically defined under privacy laws to include social security numbers, driver’s license or passport numbers, or sensitive private information about an individual such as a person’s race, ethnicity, national origin, sexual orientation, transgender or nonbinary status, health, finances, biometric information such as fingerprints or genetic information, precise geolocation, citizenship or immigration status, information pertaining to a known minor, or status as a victim of a crime. To the extent you directly provide any sensitive personal information to ZAP or make it available through our Services, you consent to ZAP processing such sensitive personal information in accordance with and as described in this Policy, and as necessary to provide the Services in accordance with your instructions.

If you choose to provide the personal information of students or other third-party individuals on or through ZAP’s Services, then you agree to ensure, to the best of your knowledge and ability, that you have obtained all necessary and appropriate permissions before providing us with the other person’s personal information and will comply with applicable law and any other relevant requirements for privacy protection. For example, you agree that you have provided appropriate notices and obtained consent as necessary so that ZAP may use the relevant personal information to provide the Services or otherwise in accordance with this Policy.

ZAP collects and uses your personal information to operate the Sites and deliver the Services you have requested. ZAP also uses your personal information to inform you of other products or services available from ZAP and its affiliates. ZAP may also contact you via surveys to conduct research about your opinion of current Services or of potential new services that may be offered. Also, ZAP may use the personal information and other data you provide on or through the Services to:

• set up and manage user accounts and profiles;
• personalize content available through the Services;
• satisfy contractual or legal obligations;
• provide ongoing technical support related to your account;
• contact you if there are issues with your account or your use of our Services;
• respond to questions, inquiries, requests, or comments;
• resolve disputes and enforce our contractual rights;
• send you updates and other communications regarding ZAP’s Services;
• contact you with announcements, updates, or offers regarding the Services;
• communicate with you regarding additional uses of your personal information beyond the scope of this list or this Policy;
• improve the content and general administration of the Sites and other Services;
• perform internal operations related to the Services (e.g., support and fraud
  prevention);
• troubleshoot software issues and operational problems with the Services;
• conduct data analysis and testing about interactions with our Services, such as the traffic on our Sites; and/or monitor usage of the Sites in order to improve the content and functioning of the Services.

ZAP does not use your personal information in automated decision-making or for profiling purposes. Other data that you provide or which is collected from you through your use of the Services could be processed through components powered by artificial intelligence orsimilar machine learning models or algorithms (collectively, “AI”) to: (1) summarize and evaluate such data; (2) analyze historical data for trends and for comparison purposes; (3) build and improve tools to assist with searches you conduct through our Services; and/or (4) construct additional questions for an applicant using our Services, or otherwise supplement or improve interactions through the Services. Any data that we request from you directly is de-identified before it is processed through any AI tools.

ZAP keeps track of the locations and pages our customers visit within AMP, our Sites, and other Services, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising for customers whose behavior indicates that they are interested in a particular subject area.

By providing to ZAP the personal information and other data referenced above, you agree that we may use such data in accordance with the terms of this Policy. 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 notice and, to the extent required under applicable law, obtaining your consent.

To maintain and operate the Sites or certain other Services, ZAP uses “cookies” to analyze how you interact with our Services, to help personalize your online experience, and for other purposes as described in this Policy. A cookie is a file or tracking technology that collects information about your computer, device, or browser (including your IP address in some instances) and your activity while using our Services.

For example, there are certain cookies which must be used for security and identity verification purposes to confirm you are eligible to use our Services, to prevent unauthorized access to our Services, and to ensure the Services function properly (Essential Cookies). Essential Cookies cannot be disabled. Otherwise, key features of our Services would be unavailable.

Other cookies provide convenience features to save you time, such as cookies which allow ZAP to recognize your browser when you have returned to our Sites or to a specific web page (Functional Cookies). For example, if you personalize certain pages or sections of the Sites or other Services, or if you register to set up an account with the Sites or other Services, Functional Cookies help ZAP recall your log-in information, choices, settings, and preferences on subsequent visits. When you return to the same area of our Services, the information you previously provided can be retrieved due to Functional Cookies, so you can easily use the features that you customized.

Additional Cookies may be used to analyze your use of the Sites, and to track web traffic and how users interact with our Sites so that we can better understand and improve your experience with our Services (Analytical Cookies).

Finally, other cookies may be used for advertising and marketing purposes to send you promotional content based on your browsing activity before, during, and after you visit or use our Sites or other Services (Marketing Cookies).

ZAP does not currently sell personal information to third parties for monetary consideration, but when you use the Sites, certain third parties may use Functional, Analytical, or Marketing Cookies and other automatic information collection technologies to track how you use our Services. These third parties may include advertisers, online ad networks, analytics service providers (such as Google Analytics and AWS), your mobile device manufacturer, and your mobile service provider. These third parties may use the information they collect from you when you use our Sites to provide you with personalized or targeted advertising content that is based on your apparent interests and browsing behavior. To the extent any of this sharing or third-party access may be considered a “sale” of your personal information under applicable privacy laws and regulations, or if you otherwise have the right to opt-out of sharing for targeted advertising purposes, you may exercise choices regarding such sharing or third-party access as described in the “Your Rights and Choices” section, below.

You also may have the ability to accept or decline certain cookies through your browser or device settings. Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features and other intended operations of the Services you visit or use.

ZAP does not sell, rent or lease its customer lists to third parties for monetary consideration. ZAP may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, ZAP may share data: (1) with third-party analytics and AI providers to help us perform statistical analysis and to supplement or improve interactions through the Services; (2) with email marketing vendors and mailing or shipping providers to send you email, postal mail, or to arrange for deliveries or (3) with customer service providers to provide customer support. All such third parties are prohibited from using your personal information except to provide these Services for or on behalf of ZAP, and they are required to maintain the confidentiality of your information.

ZAP does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

ZAP will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on ZAP or in connection with the Services; (b) protect and defend the rights, property, or safety of ZAP; and (c) act under exigent circumstances to protect the personal safety of users of ZAP, or other members of the public.

In addition to the practices described above, we may also use or disclose the personal information we collect:

• As otherwise described to you at or before the point when we collect your personal information; or
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or to transfer 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.

Depending on where you reside, you may submit requests related to certain rights or choices that you may have under applicable law (subject to certain exceptions) with regard to ZAP’s collection, use and sharing of your personal Information on or through the Services, such as rights or choices to:

• Request details about what personal information we have collected, used, disclosed or sold about you, if applicable, including –
  • The categories and sources of personal information that we collected about you;
  • Whether we sold, shared, or disclosed your personal information or used your personal information for profiling or automated decision-making purposes;
  • Our business or commercial purpose for collecting, selling, or sharing your personal information;
  • The recipients of your personal information; or
  • The specific pieces of personal information that we collected about you (also called a data portability request), unless the disclosure of such information is prohibited by law.
• Request the deletion of personal information we collected or maintain about you, subject to applicable legal exceptions.
• Opt-out of the sale of your personal information (if personal information is sold), or any sharing that could result in you receiving targeted advertising based on your online activity.
• Opt-out of any processing of your personal information for the purposes of creating a profile based on your interests or behavior which is used in such a way that would produce legal ramifications or similarly significant real-world effects on you (if applicable).
• Opt-out of any automated decision-making activities made with respect to your personal information (if applicable).
• Limit processing of your sensitive personal information for purposes of inferring characteristics about you (if applicable).
• Submit an appeal to a regulatory authority if we reject your request or if you believe we have violated applicable privacy law(s).
• Request that we correct inaccurate personal information we have collected and maintain about you, subject to applicable exceptions.
• Not receive discriminatory treatment in terms of the services and prices offered on or through our Services, because you exercised these rights regarding the collection, use and sharing of your personal information.

If you would like to submit requests to access, review, edit, delete, or have us properly dispose of any copies of the personal information that ZAP collected about you (subject to any applicable legal exceptions), if you would like to opt-out of receiving further information or limit what we share, or if you would like to exercise the above rights in any other way, please contact us at info@zapsolutions.com or call us at +1 412 697-2065.

You may be able to opt-out of ZAP sharing your personal information with certain entities identified in this Policy for purposes of targeted advertising by sending us an email at the address above, unless the sharing of your personal information is necessary to perform a legitimate business purpose permitted under applicable law.

To learn about other ways to opt-out of certain kinds of tracking that occur when you browse the internet generally and may lead to targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select through these advertising industry-provided opt-out tools or services are browser- and device-specific, and there is no guarantee that these opt-out tools will prevent all targeted advertising.

ZAP will do its best to accommodate any request to delete or properly dispose of any copies of your personal information, but we cannot guarantee we can eliminate all personal information from the specified uses beyond what is required under applicable law. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information. Therefore, please be as specific as possible in any request to delete or dispose of copies of your personal information. If the request relates to information that ZAP needs to make certain Services function properly for you, you may not be able to use those Services properly moving forward.

If you choose to delete certain portions of your personal information, it may affect your ability to use certain ZAP Services. If the request relates to information that ZAP needs to make certain Services function properly for you, you may no longer be able to use those Services. Any removal of content by ZAP does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.

You may grant an authorized agent written permission to submit requests regarding your personal information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity directly as the subject of the personal information at issue.

You are permitted to submit a request to know information twice within a 12-month period. Each request must provide sufficient information so we reasonably can verify that you are the person who is the subject of the personal information at issue (or an authorized representative of such person). Any request you submit also must include enough detail so that we can properly understand, evaluate, and respond to it.

ZAP is required to verify the identity of any person or entity that requests the disclosure or deletion of personal information. For most requests, ZAP will ask you to provide information that matches at least two pieces of personal information we store about you before responding to your request. If you would like to request the specific pieces of your personal information that ZAP has collected, or if you would like us to delete highly sensitive information, you will need to provide information that matches at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the person whose personal information you are requesting.

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 the personal information relates to you. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. Making a request does not require you to create an account with us. We do not charge a fee to process or respond to your 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 you wish to appeal a decision we have made in response to your privacy request or if you would like to otherwise submit a formal complaint, please reach out to the attorney general’s office or data protection board in the state where you reside. You may be able to submit a complaint online from your attorney general’s website. For California residents, please submit a complaint through the California Privacy Protection Agency website.

ZAP reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain portions of your personal information.

By using the Services, you agree that ZAP may send you promotional emails about other ZAP products, services, and features you may find useful. If you would like to opt-out of receiving promotional emails from ZAP, please follow the opt-out instructions at the bottom of the email or send ZAP a detailed email at info@zapsolutions.com.

ZAP uses, implements, and maintains industry standard physical, technological, and procedural safeguards and security measures which are reasonably designed to help secure your non-public personal information from unauthorized access, loss, use, or disclosure. When personal information is transmitted to other web sites or online services, such transmission is protected through the use of encryption protocols (TLS/SSL).

While ZAP takes the issue of protecting your personal information seriously, you should exercise discretion in what information you disclose and/or transmit to the Sites or through any of our other online Services. ZAP cannot guarantee that information sent over the internet is fully secure. The transmitted information may be intercepted by others before it reaches ZAP. If you are concerned about sending information to ZAP over the internet, please send the information by mail or call us to make other arrangements. ZAP is not responsible for the security of information transmitted online.

For each category of collected personal information described in this Policy, ZAP retains each such collected category for a reasonable amount of time to fulfill the stated purpose for which the applicable information was collected. The retention periods for each category of collected personal information will depend on the relative sensitivity of the data at issue, and whether the applicable personal information is subject to retention due to contractual or legal requirements. For example, with respect to contact information like your email address and other data that could be used to identify or communicate with you, we may maintain that data to the extent you continue to have an ongoing relationship with us or our Services. Similarly, demographic information may be retained for as long as you maintain an ongoing relationship with us. Cookie-related data such as IP addresses and other technical identifiers related to the devices you use generally will only be stored for as long as there is a reasonable basis for such data to be retained.

ZAP also will retain collected information connected to business records for periods of time required by law, which may be longer than the timeframes described above. If ZAP determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law.

As a courtesy, the Sites and certain other Services may contain links to other third-partyweb sites, mobile applications, or other online services, including those embedded in advertisements or sponsor information, which may be of interest or use to you. These external third-party services are not owned or controlled by ZAP. ZAP assumes no responsibility for the availability or security of these third-party services. The addition of any links is not to be construed as an endorsement of any such third-party services. ZAPencourages you to review the privacy statements or policies of any third-party web sites or other online services you choose to link to from ZAP’s Services so that you can understand how those external third-party services collect, use, and share your personal information or other data. The privacy and security policies of third-party services may differ from those practiced by ZAP. ZAP is not responsible for the privacy statements, policies, or other content on third-party web sites outside of ZAP’s Services. ZAP is not responsible for the privacy practices and data collection policies for such third-party services. ZAP is not providing any guarantee with respect to any products, information, or recommendations provided by linked third-party services. ZAP is not liable for any failure of products or services advertised on or through those third-party links.

ZAP also may allow interaction between the Services and certain social media providers. This may include the “Like” button or other plugins that allow you to share information with persons outside of the Services. Please consult the privacy policies of any third-party social media platforms before using them to make sure you are comfortable with the level of sharing. You may have certain choices regarding the extent to which these third-party platforms and services collect and use your personal information.

ZAP’s Services are intended for individuals 16 years of age and older. Our Services are not directed at, marketed to, nor intended for, children under 16 years of age. ZAP does not knowingly collect, process, or sell any information, including personal information, from children under 16 years of age.

If ZAP learns that it has collected any information regarding a person younger than 16 years of age, ZAP will delete or destroy the information immediately.

If there is concern that information regarding a person younger than 16 years of age was somehow collected by ZAP, any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request to ZAP by using the contact details provided at the end of this Policy.

In the preceding 12 months, we have collected personal information from the sources identified, above, and used and shared personal information with the categories of recipients for the business and commercial purposes described in this Policy.

California residents may learn about how to exercise their rights under California law in the “Your Rights and Choices” section, above.

In the past 12 months, ZAP has not:

• knowingly collected the personal information of children younger than 16 years old;
• used personal information for profiling or to make automated decisions; or
• provided any financial incentives with respect to the collection of personal information.

If you provide information to ZAP from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding use of the Services, and related data collection. You also agree and acknowledge that by providing any data, including personal information, through the Services, that such information will be transmitted to, and stored in, the United States.

ZAP welcomes your questions and comments regarding this Policy. If you have any questions or concerns about this Policy or the Services, please contact ZAP at info@zapsolutions.com.

ZAP intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact us and we will use commercially reasonable efforts to promptly determine and remedy the problem.