Privacy Policy

This Privacy Policy explains how Zing Coach Inc. (further will be referred as “we” or “us”) collects, stores, uses and protects your personal data in connection with your use of our website https://zing.coach/ (or its related pages) and our application Zing Coach (the “App”, and together with the website referred to as the “Services”). This policy also explains the rights you have in respect of your personal data and the practices we implement to protect your privacy.

1. Personal Data We Collect

Personal data that you provide:

• General details. This includes your name, email, your age, account credentials, subscription details, transaction history. You may also choose to provide information about your gender.
• Communication information. If you communicate with us, we collect your name, contact information, and contents of any messages you send.
• Social Media Information. We have pages on social media sites like Instagram. When you interact with our social media pages, we will collect the personal data that you choose to provide to us. Additionally, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
• Health and well-being data. When you use the Services, you may choose to input personal data about you, such as your weight; height; body mass index (BMI, a value derived from the mass and height of a person); your physical parameters; information about your workout habits; any injuries you may have. With your consent, you may also allow us to connect to third-party services, such as Apple HealthKit or Google Health Connect, to enable us to import information about your health and activities into the App. Such imported data may include information about your fitness activities, weight, height, BMI, calories burnt, heart rate, number of steps/distance traveled, data about your menstrual cycles (if applicable). We will process these data to provide you with App functionality and features. Importing such data is subject to the Google Health Connect and Apple HealthKit privacy policies and terms.
• AI Assistant conversations. When you use our AI Assistant in the App, we store the conversations. 
• Body Scan photos. With your consent, you may allow us to use your Body Scan photos for the purpose of Services improvement: for example, to train the models that power AI Body Scan feature. You can withdraw your consent any time by contacting us at support@zing.coach, and we will stop using your future Body Scan photos for that purpose.

Personal data that we receive automatically from your use of the Services:

• Log data. It means the information that your browser automatically sends whenever you use our website, or whenever you access the App. It includes the IP address, browser type, date and time of your access.
• Usage details. It includes the features you use and your actions within the Services, as well as your time zone, country, dates and times of access, operating system information.
• Device information. It includes model and type of your device, unique device identifiers, and operating system information.
• Movements during the workout. This means that we mark your image with certain dots to give you feedback about your results during the workout. These data are processed on your device. After the workout, we store the information about the marked dots to our servers to analyze if the technology works well and if the users fit into the screen. To avoid any doubt, we do not get access to the actual videos of your workout, but just to the dots marking your movements. These dots may be considered biometric data in some jurisdictions. We will destroy these data as soon as the purpose of data collection is satisfied.
• AI Body Scan information. When you request a body composition report, we analyze the photos of your body that you choose to upload, including the information we get from the analysis, like your body position, orientation, topology, and other elements of the photo. We use this information only for the purpose of the body composition report and delete the photos and the information right after we generate the body composition report. Upon your explicit consent, however, we may store your photos and the information we get from the photos for up to one month and use them to improve our body composition function.
• Details about your in-app purchases. This may include, for example, details of the time you made certain purchases and your subscription details.
• Cookies and similar technologies. We use cookies and similar technologies to operate and administer the Services and improve your experience there. For details, please read Section “Cookies, Software Development Kits, and Other Tracking Technologies” below.

Personal data that we receive from other sources:

We receive information from our trusted partners, such as security partners to protect against fraud, abuse, and other security threats to our Services or marketing vendors who provide us with information about potential customers of our business services.

All the information above is your personal data, and we call it this way throughout the privacy policy.

2. Purposes of Processing

We process your personal data for the following purposes: 

• To provide you with and maintain our Services: It includes the creation of a personalized workout plan for you or making adjustments to it; communication with AI Assistant, which is powered by GPT API (developed by OpenAI); making Body Scans.
• To improve and develop our Services and new features and conduct research.
• To check if your age allows you to use the App.
• To provide you with customer support and respond to your inquiries.
• To send you service emails, including security alerts or transaction confirmations.
• Upon your consent, where required, to send you marketing information about our Services, promotions, insights. You can opt-out from receiving marketing emails by following the “Unsubscribe” link in the email or by contacting us at support@zing.coach.
• To integrate data between the Website and the App in connection with onboarding users.
• Upon your consent, where required, to find audiences similar to our users. For this processing, we may share, among others, details of your use of the App (e.g., the fact that you work out with the App), your device information, and details of your subscription purchase with our third-party advertising partners like AppsFlyer. 

• To prevent misuse of our Services and to ensure the security of our IT systems, architecture, and networks.
• To comply with legal obligations and protect the rights, privacy, safety, or property of our users, us, our affiliates, or any third party.
• To anonymize your personal data.

Aggregated or de-identified information. We aggregate or de-identify your personal data so that it can no longer be used to identify you and use this information to: 

• conduct scientific research, or 
• analyze the effectiveness of the Services,
• improve and add features to our Services, and
• for such other similar purposes.

From time to time, we may share or publish aggregated information like general user statistics with third parties, including research institutions. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to re-identify the information unless required by law.

We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our services as described in this Privacy Policy. We will also not use information received through your use of the Apple HealthKit or Google Health Connect framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

4. Additional U. S. State Disclosures

4.1. Category of personal data: Identifiers, such as name, unique personal identifier, online identifier, IP address, email address, or account name

Categories of sources from which collected: Directly from you or automatically when you use the Services

Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• To customize our product and service offerings to you, for example, offering pricing personalization and discounts. 

• To communicate with you, such as to notify you about changes to the Services or any products or services we offer or provide through the App, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiries 
• To conduct research, analytics and monitor performance and other metrics regarding the Services and your use of the Services.

• To improve, test, and monitor the effectiveness of the Services.
• To provide personalized content and information to you in relation to the App, and so that we, and third parties on which we rely, can advertise to you. 
• To send marketing and promotional communications to you.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.2. Category of personal data: Characteristics of Protected Classifications, such as gender

Categories of sources from which collected: Directly from you

Business or Commercial Purpose for Collecting Personal Information:

• To present to you with the App and its contents and any other information, products or services that you request from us.  
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• To parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.

• In response to legal requests and for purposes of preventing harm.

4.3. Category of personal data: Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies

Categories of sources from which collected: Automatically when you use the Services

Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• To customize our product and service offerings to you, for example, offering pricing personalization and discounts. 

• To communicate with you, such as to notify you about changes to the Services or any products or services we offer or provide through the App, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiries 
• To conduct research, analytics and monitor performance and other metrics regarding the Services and your use of the Services.
• To improve, test, and monitor the effectiveness of the Services.

• To provide personalized content and information to you in relation to the App, and so that we, and third parties on which we rely, can advertise to you. 
• To send marketing and promotional communications to you.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.

• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.4. Category of personal data: Internet or other electronic network activity information, such as information regarding interaction with an app or advertisement

Categories of sources from which collected: Automatically when you use the Services

Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• To customize our product and service offerings to you, for example, offering pricing personalization and discounts. 
• To communicate with you, such as to notify you about changes to the Services or any products or services we offer or provide through the App, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiries 
• To conduct research, analytics and monitor performance and other metrics regarding the Services and your use of the Services.

• To improve, test, and monitor the effectiveness of the Services.
• To provide personalized content and information to you in relation to the App, and so that we, and third parties on which we rely, can advertise to you. 
• To send marketing and promotional communications to you.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.5. Category of personal data: Geolocation data, such as the state or country associated with your IP address

Categories of sources from which collected: Automatically when you use the Services

Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• To customize our product and service offerings to you, for example, offering pricing personalization and discounts. 

• To communicate with you, such as to notify you about changes to the Services or any products or services we offer or provide through the App, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiries.
• To conduct research, analytics and monitor performance and other metrics regarding the Services and your use of the Services.
• To improve, test, and monitor the effectiveness of the Services.
• To provide personalized content and information to you in relation to the App, and so that we, and third parties on which we rely, can advertise to you. 
• To send marketing and promotional communications to you.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.6. Category of personal data: Visual, information, such the photos you upload to the App

Categories of sources from which collected: Directly from you

Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To generate body composition reports.
• To improve, test, and monitor the effectiveness of the Services.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• To parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.7. Category of personal data: Inferences drawn from the information listed above to create a profile about a user reflecting their preferences, characteristics and other attributes

Categories of sources from which collected: Directly from you or automatically when you use the Services

‍Business or Commercial Purpose for Collecting Personal Information:

• To present you with the App and its contents and any other information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• To customize our product and service offerings to you, for example, offering pricing personalization and discounts. 
• To communicate with you, such as to notify you about changes to the Services or any products or services we offer or provide through the App, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiries.
• To conduct research, analytics and monitor performance and other metrics regarding the Services and your use of the Services.
• To improve, test, and monitor the effectiveness of the Services.
• To provide personalized content and information to you in relation to the App, and so that we, and third parties on which we rely, can advertise to you.
• To send marketing and promotional communications to you.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

4.8. Category of personal data: Information that may be sensitive personal data, such as gender, health and wellbeing information

Categories of sources from which collected: Directly from you or from such other sources that you connect to the Services

Business or Commercial Purpose for Collecting Personal Information:

• To present to you with the App and its contents and any other information, products or services that you request from us.  
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to the Services.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.

Categories of Third Parties and Other Entities To Whom We May Disclose:

• To our affiliates, contractors, vendors and service providers to process in accordance with our instructions.
• to parties involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of a service to another provider.
• In response to legal requests and for purposes of preventing harm.

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Sharing personal data for cross-context behavioral advertising. We may share the following categories personal information with third-party ad-tech providers and others throughout the online advertising ecosystem for purposes of cross-context behavioral advertising:

• Identifiers  
• Categories of personal information described in Cal. Civ. Code Section 1798.80(e)  
• Commercial Information  
• Internet or other electronic network activity information  
• Geolocation data  
• Inferences drawn from personal information such as preferences, characteristics and behaviors.

You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Other Rights: Notice to California Consumers. You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to third parties for those third parties’ direct marketing purposes.

5. Personal Data Retention

We retain your personal data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing (e.g., for resolving disputes, for safety and security reasons, or for complying with our legal obligations).

If you choose to deactivate your account, we retain your personal data for no longer than one month in case you decide to re-activate the Services. We also retain some of your information (General details, Details about in-app purchases, Communication information, your consent logs) as necessary to comply with our legal obligations, to resolve disputes and/or to enforce our agreements.

We may also anonymize your personal data (so that it can no longer be associated with you) for scientific research or statistical purposes, as well as for the purpose of Services improvement and development. In this case, we may use this information indefinitely without further notice to you.

6. Privacy Rights

We want to make sure that you are fully aware of all your data protection rights and the ways you can exercise them. These rights may differ across countries. 

If you are EU, EEA or UK resident, you have the right to:

• Access your personal data and information relating to how it is processed.
• Transfer your personal data to a third party (right to data portability).
• Correct your personal data (through the App settings or by requesting us).
• Request deletion of your personal data.
• Restrict how we process your personal data (for example, in cases where you contest inaccuracy).
• To object to processing of your personal data for direct marketing at any time.
• To object to how we process your personal data when our processing is based on our legitimate interests.
• Withdraw your consent – where we rely on consent as the legal basis for processing at any time. 
• Lodge a complaint with the data protection authority. You have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authorities here, and the UK’s supervisory authority (ICO) here.

Note that these rights may be limited: for example, if you ask us to delete information that we are required to retain by law or where we have compelling legitimate interests to keep.

If you are a resident of countries other than EU, EEA or UK:

Depending on location, individuals may have certain statutory right in relation to their personal data. For example, you may have the right to: 

• Request the categories of personal data collected about you.
• Request the categories of sources from which your personal data is collected.
• Request the commercial purpose for collecting your personal data.
• Request the categories of third parties to whom personal data is disclosed, and the categories of personal data disclosed.
• Request the specific pieces of personal data collected about you.
• Request that personal data collected about you be deleted.
• Request that your inaccurate personal data be corrected.
• Request that we do not sell or share your personal data.

How to exercise the rights:

You can exercise some of the rights above through the App settings. If you are unable to exercise your rights through the App, please submit your request through support@zing.coach.

If you make a request, typically we would perform it within one month. If we need any more time to help you exercise any of your rights, we will let you know.

If your request is vague or unclear, we may engage into a conversation with you to understand your request better. We may also refuse to act on manifestly unfounded and excessive requests.

We can ask you to prove your identity while exercising your data protection rights. This is made to ensure that you are indeed entitled to receive certain information and that no rights of third parties are violated by your request. If we can’t verify your request, we will not act on your request.

You may submit a request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may be required to independently verify your identity.

7. Security Measures

We take the protection of your personal data very seriously and we take reasonable and appropriate measures to protect them from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

Among others, we utilize the following information security measures to protect your personal data:  

1. Encryption of your personal data in transit and in rest.
2. Systematic vulnerability scanning and penetration testing.
3. Protection of data integrity.
4. Organizational and legal measures. For example, our employees have different levels of access to your personal data and only those in charge of data management get access to your personal data and only for limited purposes required for the operation of the application. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your personal data.  

Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information won’t be intercepted while being transmitted to us. In case your personal data got compromised due to a security breach, we will act promptly to identify the cause and take all reasonable steps to remedy the breach. We will inform you of the incident, if necessary, in connection with the applicable legislation.

If you want to report a security incident related to our Services, please contact us at support@zing.coach.

8. Children

Our Services are not directed at, or intended for, children under 18 years old.

If you are aware of anyone under 18 using the Services, please contact us at support@zing.coach and we will take the required steps to delete such information and/or delete the account.

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9. Sharing of Your Personal Data

In some situations, we engage other companies to process your personal data on our behalf. We refer to these companies or service providers as “processors.” 

Processors are companies that help us run the Services, support our communication with you, or perform other App-related activities. They process certain personal data on our behalf to accomplish the goals related to the App functions and deliver the Services and associated activities. We remain responsible for any acts or omissions of our processors, and we enter into data processing contracts with them to the extent required by applicable law.

Here are some of the main processors we rely on:

• Infrastructure & security

Amazon Web Services, Inc. (USA)

Auth0, Inc. (USA)

Hetzner Online GmbH (Germany)

Firebase (USA)

• Email & in-app communication

SurveyMonkey, Inc. (USA)

TypeForm (Spain)

SendGrid (USA)

• Push messages

Braze, Inc. (USA)

• AI Assistant communications

OpenAI LLC (USA)

• Analytics tools

Amplitude, Inc. (USA)

Firebase (USA)

EPPO (USA) 

Meta Events Manager (USA)

• User onboarding and data integration 

AppsFlyer, Inc. (USA)

• Services promotion

AppsFlyer, Inc. (USA)

• Customer support

Zendesk, Inc. (USA)

• Payments

Apple, Inc. (USA) 

Adyen N. V. (the Netherlands)

Stripe, Inc. (USA)

Verify, Inc. (USA)

• Subscriptions management

RevenueCat, Inc. (USA)

Google (USA)

• Affiliates

Palta People Ltd. (Cyprus) – technical maintenance and customer support.

Palta UK Ltd. (UK) – technical maintenance and customer support.

Palta Poland sp. z o. o. (Poland) - technical maintenance and customer support

Palta Software Ltd (Cyprus) – data analytics, subscription management, AI models training. 

Transfers of personal data outside of the European Union, the European Economic Area, and the United Kingdom. Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on the UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.

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10. Cookies, Software Development Kits, and Other Tracking Technologies

When you use our Services, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your use of our Services. We also use third-party analytics tools like AppsFlye, Amplitude, Meta Events Manager, Firebase, and Eppo to help us measure traffic and usage trends of our Services, as well as for other purposes. Such analytics tools collect information via third-party SDKs incorporated into the App, which includes information about features of the App you visit or use, your actions in the App, and information about your subscription. Such information may be used to provide content, advertising, or functionality. For the avoidance of doubt, we do not use health and wellbeing data for advertising purposes.

Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of the App over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so as to limit such technologies. You can visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info to learn more about this interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program, and http://www.aboutads.info/appchoices for information on the DAA’s mobile app opt-out program. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests.

For users in the European Economic Area, United Kingdom, and United States. You can manage the collection and processing of Personal Data via cookies, SDKs, and other tracking technologies by contacting us at support@zing.coach. 

You may find that some parts of the App may not function properly if you have refused cookies or similar tracking technologies, and you should be aware that disabling cookies or similar tracking technologies may prevent you from accessing some of our content. Your choices are typically device and browser-specific.

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11. Your Choices About Our Communications

If you are using our Services, you may receive electronic communications from us (e.g., by posting in-app notices, via push notifications or emails). We send some of these communications to you, such as those related to your subscriptions, technical and security notices, and updates to the Privacy Policy and Terms of Use, where necessary to perform our contract with you to provide the App or otherwise based on our legitimate interest in contacting you.

If required by law, we will ask for your consent to send you promotional and marketing emails, in-app communications, and push notifications about new products, features, or offers related to our Services.

Marketing & Promotional Emails. If you wish to stop receiving our promotional and marketing emails, you can do so by following the “Unsubscribe” links in any marketing email sent to you.

Push Notifications. If you wish to stop receiving push notifications, you can do so through your mobile device settings by tapping “Settings” -> “Notifications” -> Choose Zing Coach -> press the toggle to allow or forbid push notifications from the App.

12. Changes to Our Privacy Policy

The date this privacy policy was last reviewed is indicated at the top of the page. We may modify or update this privacy policy from time to time. Some changes do not require your consent: for example, when we add a new purpose of processing that is compatible with the existing purposes, or the new processing activity that falls under the users’ reasonable expectation. However, if the changes made may pose risk to your rights and freedoms (for example, by including a new purpose of the processing that is not compatible with the existing purposes of processing, a new legal basis, or a new category of personal data to be collected or a new data subject, all of which are not reasonably expected by the users), we will ask for your consent to those changes separately from this privacy policy. If you did not receive a request for your consent to the changes or refused to give consent, those changes will not apply to you. That fact can negatively affect some of our Services provided to you if those Services inevitably include consent to the changes.

Link to the privacy policy, March 1, 2024

Link to the privacy policy, Nov 6, 2023

Link to the privacy policy, June 12, 2023

Link to the privacy policy, May 9, 2022

Link to the privacy policy, March 1, 2021‍

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13. Contact Us

Zing Coach, Inc.

Email: support@zing.coach

Our DPO: privacy@palta.com (please, indicate in the email subject that you are a Zing user).

EU representative:

DPOEU LTD

Email: info@dpoeu.eu

UK representative:

Palta UK Ltd

Email: privacy@palta.com (please indicate in the email subject that you are a Zing user).