Effective as of (01/10/24)

This privacy policy (the “Privacy Policy”) applies to the ZUUL mobile application (the “App”) and ZUUL website (“Website”), each of which are owned and operated by ZUUL SYSTEMS LLC, a Delaware limited liability company (“Zuul,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the App and/or Website collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Service. By visiting and/or using our App and/or Website, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

1. INFORMATION WE COLLECT OR RECEIVE

In the course of operating the App and/or Website, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

A. Information you provide

This may include:

• User profile: We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with your personally identifiable information (collectively, the “Personal Information”). Personal Information may include your name, birth date, gender, height, weight, photograph, signature, email address, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers and government-issued identification cards (e.g., driver’s license, identification cards, passports, etc.). We do not collect any Personal Information from you when you use the App or Website unless you provide us with the Personal Information voluntarily. This also includes the preferences and settings that you enable for your Zuul account.
• Demographic data: We may collect demographic information about you, including through user surveys. In some countries, we may also receive demographic information about you from third parties.
• User content: We may collect information that you submit when you contact Zuul customer support, provide ratings or compliments for other users, or otherwise contact Zuul.
• Address book or calendar: If you permit the App to access the address book on your device, we may collect names and contact information from your address book for purposes such as facilitating social interactions through our services. If you permit the App to access the calendar on your device, we may collect calendar information such as event title and description, your response (Yes, No, Maybe), date and time, location, and number of attendees.

B. Information created when you use our services

This may include:

• Location Information: Depending on the Zuul services that you use, and your App settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi.
• We may collect location information when the App is running in the foreground. In certain regions, we may also collect this information when the App is running in the background of your device if this collection is enabled through your App settings or device permissions.
• You may use the App without enabling us to collect your location information. However, this may affect the functionality available on your App.
• Usage information: We collect information about how you interact with our services. This includes information such as access dates and times, App features or Website pages viewed, App or Website crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Statement below. We collect transaction details related to your use of our services, including the type of services you requested or provided, date and time the service was provided, amount charged, and payment method.
• Device Information: We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.
• Communications data: We enable users to communicate with each other and us through the App, Website, and other services. To provide this service, Zuul receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Zuul may also use this information for customer support services, for safety and security purposes, to improve our products and services and for analytics.

C. Information from other sources

This may include:

• User feedback.
• Users requesting services for or on your behalf.
• Users or others providing information in connection with claims or disputes.
• Zuul business partners through which you create or access your Zuul account, such as payment providers, social media services, or apps or websites who use Zuul’s Application Programming Interface (“API”) or whose API Zuul uses.
• Insurance providers.
• Financial services providers.
• Publicly available sources.
• Marketing service providers.

Zuul may combine the information collected from these sources with other information in its possession.

D. Children

The App is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App or Website, unless that child’s parent or guardian has informed us, in writing, that the child is permitted to use the App or Website. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

2. HOW WE USE YOUR INFORMATION

Zuul uses the information it collects for various purposes including:

1. Providing services and features

Zuul uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:

• Create and update your account.
• Verify your identity.
• Process or facilitate payments for those services.
• Enable features that allow you to share information with other people.
• Enable features to personalize your Zuul account.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

2. Safety and security

We may use your data to help maintain the safety, security and integrity of our services and users. This includes, for example:

• Using device, location, profile, usage and other information to prevent, detect, and combat fraud. This includes processing of such information, in certain countries, to identify practices or patterns that indicate fraud. This may also include information from third parties. In certain cases such incidents may lead to deactivation by means of an automated decision making process. Users in the EU have the right to object to this type of processing; see below for more information

3. Customer support

Zuul uses the information we collect (including recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to:

• Direct your questions to the appropriate customer support person
• Investigate and address your concerns
• Monitor and improve our customer support responses

4. Research and development

We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, and develop new features and products.

5. Communications among users

Zuul uses the information we collect to enable communications between our users.

6. Communications from Zuul

Zuul may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events. Zuul may also use the information to serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as a Zuul user. Users in the EU have the right to object to this type of processing; see below for more information.

7. Legal proceedings and requirements

We may use the information we collect to investigate or address claims or disputes relating to your use of Zuul’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

3. COOKIES

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Zuul uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services. Please see our Cookie Statement for more information regarding the use of cookies and other technologies described in this section, including regarding your choices relating to such technologies.

4. INFORMATION SHARING AND DISCLOSURE

Zuul may share the information we collect:

1. With other users

• For example, if you are a host of an event, we may share your Personal Information with your invitees or with third parties in charge of providing entrance to your residence or event.

2. At your request

This includes sharing your information with:

• Other people at your request. For example, we may share your location with a friend at your request.
• Zuul business partners. For example, if you requested a service through a partnership or promotional offering made by a third party, Zuul may share your information with those third parties. This may include, for example, other apps or websites that integrate with our APIs, or those with an API or service with which we integrate, or business partners with whom Zuul may partner with to deliver a promotion or a specialized service.

3. With the general public when you submit content to a public forum

We love hearing from our users — including through public forums such as blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.

4. With the owner of Zuul accounts that you may use

If you use a profile associated with another party we may share your information with the owner of that profile.

5. With Zuul subsidiaries and affiliates

We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Zuul processes and stores information in the United States on behalf of its international subsidiaries and affiliates.

6. With Zuul service providers and business partners

Zuul may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

• Payment processors and facilitators.
• Cloud storage providers.
• Marketing partners and marketing platform providers.
• Data analytics providers.
• Research partners, including those performing surveys or research projects in partnership with Zuul or on Zuul’s behalf.
• Vendors that assist Zuul to enhance the safety and security of its apps.
• Consultants, lawyers, accountants and other professional service providers.
• Homeowners associations, condominium associations and other similar entities and their respective agents (e.g., security companies)

7. For legal reasons or in the event of a dispute

Zuul may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing your information with law enforcement officials, government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect Zuul’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With your consent

Zuul may share your information other than as described in this policy if we notify you and you consent to the sharing.

5. INFORMATION RETENTION AND DELETION

Zuul requires user profile information in order to provide its services, and retains such information for as long you maintain your Zuul account. Zuul retains certain information, including location, device and usage information, for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide Zuul’s services, enable customer support, enhance the user experience or other operational purposes, Zuul takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

You may request deletion of your account at any time through the Privacy Settings in the Zuul app, or via Zuul’s website. Following such request, Zuul deletes the information that it is not required to retain. In certain circumstances, Zuul may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Zuul will delete your account as described above.

Zuul may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if Zuul shuts down a user’s account because of security incidents, Zuul may retain certain information about that account to prevent that user from opening a new Zuul account in the future.

6. CHOICE AND TRANSPARENCY

A. PRIVACY SETTINGS

The Privacy Settings menu in the App gives users the ability to set or update their location and contacts sharing preferences, and their preferences for receiving mobile notifications from Zuul. Information on these settings, how to set or change these settings, and the effect of turning off these settings are described below.

• Location Information
• Location data helps improve our services.
• You may enable/disable, or adjust, Zuul’s collection of your location information at any time through the Privacy Settings menu in the Zuul app, or via the settings on your mobile device. If you disable the device location services on your device, your use of the App may be affected.
• Notifications: Account Updates
• Zuul provides users with updates related to your account. These notifications are a necessary part of using the App, and cannot be disabled. However, you may choose the method by which you receive these notifications through the Privacy Settings menu in the App.
• Notifications: Discounts and News
• You may enable Zuul to send you push notifications about news from Zuul. You may enable/disable these notifications at any time through the Privacy Settings menu in the Zuul app.
• Address Book / Contacts
• You may enable Zuul to periodically sync with the address book /contacts information on your mobile device, and store your contacts information on our servers. This includes the names, phone numbers, emails addresses and other information that you store in your address book contacts.
• You may enable/disable contacts syncing at any time via the Privacy Settings menu in the Zuul app. If you disable contacts syncing, you will not be able to use features that use your contacts information.
• Calendar Syncing
• You may enable Zuul to access and store the calendar data on your mobile device. Your calendar data might include event titles; responses (Yes, No, Maybe); start and end time of event; associated location descriptions; and number of attendees. We use this information to suggest destinations based on your calendar events and to customize your Zuul experience.
• You may enable/disable Calendar Syncing at any time through the Calendar Shortcuts menu under the Settings menu of the Zuul app. If you disable Calendar Syncing, you will not be able to use features that use your calendar information.

B. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the App wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the App seeks before you first use the App, and your use of the App constitutes your consent.

C. EXPLANATIONS, COPIES AND CORRECTION

You may request that Zuul:

• • Provide a detailed explanation regarding the information Zuul has collected about you and how it uses that information.
  • Receive a copy of the information Zuul has collected about you.
  • Request correction of any inaccurate information that Zuul has about you

.

You can make these requests by contacting Zuul at Adam@zuulsystems.com.

You can also edit the name, phone number and email address associated with your account through the Settings menu in the App. You can also look up your history in the App.

D. MARKETING OPT-OUTS

You may opt out of receiving promotional emails from Zuul [add link to an unsubscribe page]. You may also opt out of receiving emails and other messages from Zuul by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

UPDATES

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the Zuul apps or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.

CONTACT

If you have questions about this Privacy Policy, please e-mail us at Adam@zuulsystems.com with “Privacy Policy” in the subject line or mail us at the following address: Zuul Systems, LLC, c/o Agents and Corporations, Inc., One Commerce Center, 1201 Orange Street, Suite 600, Wilmington, Delaware 19801.