Zing Coach App Privacy Policy
Effective as of March 01, 2021
Introduction
This Privacy Policy explains how Palta Labs Inc («Company» or «we» or «us») collects, stores, uses, transfers and discloses Personal Data from our users («you») in connection with the Zing Coach mobile application, zing.coach website («Website») and related services (collectively, the «App»).


We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional Personal Data from you.


Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our Website and the App for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

1. Personal data and information we collect from you
Personal data you provide to us
General Information.
When you sign up to use the App, we may collect Personal Data about you such as:
● Name;
● Gender;
● Date of birth;

Health and Well-being.
When you use the App, you may choose to provide personal information about your health and well-being such as:
● Weight;
● Height;
● Body type (“peach" or “apple");
● Other information about your health, well-being, and related activities, including personal life (collectively, “Personal Data").

You also may give us the consent and ability to import into the App Personal Data about your health and activities from third-party services such as Apple HealthKit. Such imported Personal Data may include sports activities, weight, calories burnt, heartbeat rate, number of steps and/or distance traveled, and other data about your health. In order for us to process any Personal Data under this category we will explicitly ask your consent on the registration screen.
Information we collect automatically
When you access or use the App, we may automatically collect the following information:

Device Information:
● Hardware model;
● Information about the operating system and its version;
● Unique device identifiers (e.g. IDFA);
● Mobile network information;
● Device storage information.

Location Information:
● IP address;
● Time zone;
● Information about your mobile service provider.

App usage data, including, among others:
● Frequency of use;
● Areas and features of our App you visit;
● Your use patterns generally;
● Engagement with particular features.

Data from external sources. We may use third-party tools like AppsFlyer that provide us some of your attribution data that we further utilize to customize and personalize your App experience. We may also use such data for statistical purposes and analytics.

If the information covered by this Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as «Personal Data».
YOUR CONSENT
By creating a profile in the App, you explicitly consent that:
I. WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.
II. PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. WEIGHT, HEIGHT, BODY TYPE AND OTHERS). DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN INFORMATION ABOUT YOUR GENERAL HEALTH (E.G. WEIGHT, BODY MEASUREMENTS, AND OTHERS).

III. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY.
PLEASE NOTE THAT WE WILL NEVER SHARE YOUR EXACT AGE OR ANY DATA RELATED TO YOUR HEALTH WITH ANY THIRD PARTIES.
2. How we use your personal data and information
As any compliant organization we will not collect and use your Personal Data without letting you know or having any reasons for that whatsoever. So, for any purpose of processing your Personal data we need to have some valid ground, or so-called “legal basis”.

Depending on a case, we will process your Personal data based on the following legal basis:
Your consent. Your permission to process the Personal Data that you provide to us on the registration screen or at any other appropriate moment if necessary;
Your contractual relations with us. We may need to process some Personal Data for making the App and its services available for access, installation and further use;
Legitimate interest. We may process some of your personal data to pursue commercial interests and wider societal benefits;
Legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.
We may use your information, including your Personal Data, for the following purposes:
a. to analyze, operate, maintain and improve the App, to add new features and services to the App;
b. to customize content, insights and patterns you see when you use the App;
c. to suggest changes in your fasting protocol and eating patterns;
d. to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;
e. to customize product and service offerings and recommendations to you, including third-party products and offerings (except data from Apple HealthKit);
g. to send you technical notices, updates, security alerts and support and administrative messages;
h. for billing (invoicing), account management and other administrative purposes, if applies;
i. to respond to your comments, questions and requests and provide customer service;
j. to monitor and analyze trends, usage and activities in connection with our App;
k. to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence, as well as for any other automated decision-making processing);
l. for scientific and academic research purposes; and
m. for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

No sale of Personal Data. We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy. We will not use the information gained through your use of the HealthKit and other frameworks for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section 2 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy («data minimization principle»).
3. Your rights
Modification, correction and erasure
You are able to modify, correct, erase, and update your Personal Data by writing us at support@zing.coach. Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.
Access
The App gives you the ability to access and update Personal Data within the App and your account settings. You have a right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by simply writing us at support@zing.coach.
Rectification of Personal Data and Restriction of Processing
You are responsible for ensuring the accuracy of your Personal Data that you submit to the App. Inaccurate information will affect your experience when using the App and tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data by contacting us at support@zing.coach. You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
Right to object processing of your Personal Data
You can object processing your Personal Data and stop us from processing your Personal data, simply write us at support@zing.coach. Please be aware that erasing some Personal Data inserted by you may affect your possibility to use the App and its features.
How to exercise your privacy rights
Сontact us at support@zing.coach to exercise any of your privacy rights.

We will exercise them within 30 days after receipt. It may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.
What else?
Notice about automated decision-making
We may use automated decision-making tools (e.g. neural networks) that process your Personal Data in order to provide you proper Services (for example, suggesting new fasting protocols or providing insights). Normally, such automated decision-making works more precisely, if you insert more Personal Data about your meal/liquid intake details, fasting times, physical activities that our neural networks can work with. Our neural networks process this information in order to track particular dependencies and correlations in your eating patterns and provide you more personalized information about your lifestyle.
Notification requirements
We commit to notify you (within reasonable period of time) and your data protection authority (within the timeframe specified in applicable law) about any personal data breaches in the App.
Data Protection Authorities
Subject to applicable laws, you may have a right to lodge a complaint with your local data protection authority about any of our activities (related to your privacy rights, among others) that you think are not compliant with applicable law. However, if you think that we do something incorrectly, let us know first at support@zing.coach. We care about your privacy and want to make sure that we did everything to address any of your concern.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. We may also refuse manifestly unfounded and excessive (repetitive) requests.

Subject to applicable laws, we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.

Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.
4. Sharing your personal data and information
Third parties processing your Personal Data
We will not share your Personal Data with any third parties except as specified below.
Processing to find new Zing Coach users and stay in touch with you
We may share some of your non-health Personal Data with AppsFlyer, a mobile marketing platform, that handles your Personal Data in accordance with our instructions. By using AppsFlyer and its integrated partners we are able to reach you and people like you on various platforms and spread the word about the App to help more women to stay in control with their health and well-being. If we need to share your Personal Data with other platforms for this purpose, except as defined herein, we will ask for your consent. If this is required by law, we will secure your consent to share your non-health data with AppsFlyer and its integrated partners.

Here is a step-by-step illustration of how we work with AppsFlyer and its integrated partners:
1. You become a Zing user and we start sharing Personal Data, strictly limited to the following set:
a) Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Customer-issued user ID and other similar unique technical identifiers
b) Your age group
c) Your subscription status
d) The fact of application launch.

2. Zing App sends your data to AppsFlyer, which analyzes it and provides us reports and insights on how to optimize our promotional campaigns.

3. At the same time, AppsFlyer sends your data to some of its integrated partners (e.g. Pinterest, Google Ads, Apple Search Ads, FB marketing network, and a couple of others) to find you or people like you on different platforms, including social media websites. These integrated partners analyze your data and show relevant information about the App to people who might be potentially interested in it or remind you about revisiting the App, if you stopped using it a while ago.

4. This is how you and new users find out more about Zing, get accurate cycle predictions, learn about the meaning of their bodies’ cues and receive credible information about their health. You contribute to the growth of the Zing community by providing your consent to use the Zing app.

Read more about AppsFlyer here and its integrated partners here.

Opt-out options. You can withdraw your consent or opt-out, whatever applies in your case, from sharing of your Personal Data in accordance with this subsection anytime by using one of the following options:
  1. By contacting us at support@zing.coach;
  2. By adjusting your device settings in iOS or Android in order to stop sharing your IDFA or Android Advertising ID.
PLEASE NOTE THAT WE WILL NEVER SHARE YOUR EXACT AGE OR ANY DATA RELATED TO YOUR HEALTH WITH ANY THIRD PARTIES.
OPT-OUT OPTIONS. YOU CAN WITHDRAW YOUR CONSENT TO SHARING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS SECTION ANYTIME BY USING ONE OF THE FOLLOWING OPTIONS:
1. BY CONTACTING US AT support@zing.coach;
2. BY ADJUSTING YOUR DEVICE SETTINGS IN ORDER TO STOP SHARING YOUR IDFA WITH ANY THIRD PARTIES. IN SUCH CASE NO THIRD PARTY WILL BE ABLE TO UTILIZE YOUR PERSONAL DATA IN ACCORDANCE WITH THIS SECTION OF THE PRIVACY POLICY.

b. Aggregated Information. We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, including with our partners or research institutions. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users.

c. Special Circumstances. We will not share any of your Personal Data to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (i) in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements); (ii) when disclosure is required to maintain the security and integrity of the App, or to protect any user's security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has input the Personal Data; (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.
Any information (including Personal Data) you share in any online community area or online discussion is by design open to the public and is not private. You should think carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.
If you mistakenly post Personal Data in our community areas and would like it removed, you can send us an email as listed below to request that we remove it. In some cases, we may not be able to remove your Personal Data, e.g. for technical reasons.

e. Third party (onward) transfers and Privacy Shield compliance. In the context of an onward transfer, if you provided us your explicit consent for such transfer, we have responsibility for the processing of Personal Data we receive under the Privacy Shield or generally from the EU and Swiss residents and subsequently transfer to a third party acting as an agent on our behalf. We remain liable under the Principles (as defined below) and GDPR if our agent processes such Personal Data in a manner inconsistent with the Principles and GDPR, unless we prove that we are not responsible for the event giving rise to the damage. For any onward transfer we commit to execute a formal agreement with any receiving party or processor acting on our behalf.
If we receive Personal Data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the Personal Data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
Processing to make the App run
We engage processors that perform particular operations with your Personal Data for us.

Processors are companies that help us run the App, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. Processors act only in accordance with our instructions and process only such amount of Personal Data as we instruct them to process. We remain fully liable for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.

Here is the list of our main processors:
5. Retention of your personal data
We will retain your Personal Data as long as your account is active or needed to provide you services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can remove your Personal Data as specified in Section 3 of this Privacy Policy.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
6. Personal data you elect to share with third parties
You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your Personal Data. For example, for the EU residents' Personal Data we make reasonable efforts to ensure that such third parties are GDPR compliant and have GDPR compliant privacy policies in place.
7. Security
We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:
a. Encryption of your Personal Data in transit and in rest;
b. Systematic vulnerability scanning and penetration testing;
c. Protection of data integrity;
d. 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 App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
e. Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of "privacy by design", "privacy by default" and others. We also commit to undertake privacy audit in case of Company's merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won't be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
8. Children's privacy
General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 16 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 16. If you are aware of anyone under 16 using the App, please contact us at support@zing.coach and we will take required steps to delete such information and (or) delete his or her account.
9. Third party links
Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service.
10. Privacy of payments
To process payments for particular features and functions of the App we may engage third-party payment providers.

We use Apple for processing of payments in connection with our subscriptions offered on App Store. Please note that we never collect and we are not responsible for the collection or security of banking, financial, and payment information. Such information is processed and stored by Apple only. Apple can be contacted through their website: https://www.apple.com.
11. Communication with you
We may contact you from time to time via email or through other means (like popups or push notifications) to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you.

Opt-out options. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails or notifications will not end the transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, we may ask some users to provide their consent for such communications.

Please note that we may contact you with our information about products, services, offers, promotions, rewards, and events offered by us and others via third-party platforms (like social media). See more in section Processing to find new users and stay in touch with you. Please note that you can always opt-out from such communication and usage of your Personal Data by contacting us at support@zing.coach.
12. Storage and international Personal Data transfers
The Company is based in the United States, and Personal Data we collect is governed by U.S. law. Please be advised that U.S. law and laws of other countries may not offer the same protections as the law of your jurisdiction.

In addition, you agree that Personal Data collected may be stored and processed in Canada and the United States, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of Personal Data outside of your country.
13. Data protection officer
To communicate with our Data Protection Officer, please email at support@zing.coach.
14. Contact us
If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

General
If you have any questions or concerns about your privacy, you may contact our US representative:
Zing Coach Inc., Inc., 512 Lucerne Ave., Lake Worth, FL 33460
Email: support@zing.coach

EU, UK and Swiss residents
You may contact our EU representative:
DPOEU LTD, Office 902, Oval, Krinou 3, Ayios Athanasios, 4103, Limassol, Cyprus
Email: info@dpoeu.eu