1. WHO WE ARE AND WHAT IS THE PURPOSE OF THIS DOCUMENT

ZenMinutes SRL, with registered office in Bucharest , Sector 1, Montreal Square, No. 10, World Trade Center Building, Main Entrance, Office 2.11 bis, Et. 2, postal code 11469, registered at the Registry Commerce under no. J40/24266/2023, having fiscal code 49299666, is the data controller with respect to the data you of a personal nature ( hereinafter " ZenMinutes " or the " Operator "), as described below .

This document explains why and how we process the personal data of people who use ZenMinutes products/services (hereinafter " Users "), made available by the Operator through the website https://www.zenminutes.com/ and/ or the ZenMinutes mobile application (hereinafter " ZenMinutes Platform" ), in the following situations:

• when Users use the communication services ELECTRONIC made available on the Platform ZenMinutes , respectively TAKING SOME call international made by Voice Over IP (VoIP) technology and / or by other methods ( in continued “ The Services ZenMinutes ”);
• then When Users have agreed to receive messages commercial from the side ZenMinutes ;
• if Users send ZenMinutes requests/reports/suggestions/evaluations regarding the ZenMinutes Platform and/or the ZenMinutes services ;
• in the context of the development of the contractual relationship between Users and ZenMinutes ;
• in any other situations permitted by law and/or provided by this document.

The processing of personal data is done by the Operator in accordance with Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter " GDPR ").

"Personal data" means any information relating to an identified or identifiable natural person, and an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, a identification number, location data, an online identifier, or to one or more specific elements of his physical, physiological, genetic, psychological, economic, cultural or social identity

2. PURPOSES, BASIS OF PROCESSING AND CATEGORIES OF PERSONAL DATA WE PROCESS

We process the following categories of personal data, for the purposes and on the grounds described below:

2.1 We process your personal data pursuant to art. 6 (1) lit. b) of the GDPR to fulfill the following purposes:

2.2 We process your personal data pursuant to art. 6 (1) lit. f) of the GDPR to fulfill the following purposes:

carrying on the right of opposition yourself you can oppose whenever WORKING based on the legitimate interest pursued by ZenMinutes or by third parties , described in point 2.2 above , for reasons related to the situation you specify , sending us an email to the address help@ZenMinutes.com or by any other means available on the Platform ZenMinutes (eg, contact form).

2.3 We process your personal data pursuant to art. 6 (1) lit. c) of the GDPR to fulfill the following purposes:

2.4 We process your personal data pursuant to art. 6 (1) lit. a) from the GDPR to fulfill the following purposes:

2.5 To the extent that the data results from browsing the Platform ZenMinutes , collected through cookies and similar technologies can be considered personal data within the meaning of the GDPR, we process this data according to the Cookies Policy. For more details, please see our Cookies Policy.

3. THE NEED TO PROVIDE DATA

The failure to provide data for processing purposes mentioned in 2.1, 2.2 ( regarding notifications / requests / suggestions / evaluations ), 2.3 ( regarding exercising rights ) doesn't allow us to provide the services requested by you , respectively to answer notifications / requests / assessments OR your suggestions

4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA

4.1. Categories of Recipients

We disclose your data to the following categories of recipients, if and as applicable:

• our service providers involved in the activity of the Platform, such as: our providers in Romania for technical support, programming, maintenance services regarding the ZenMinutes Platform, the provider in Ireland for services for processing payments made by Users, the provider in Germany for provision of servers where they are stored the data of the supplier from Lithuania for various services , such as security , billing , routing traffic , monitoring in real- time activity on the Platform ZenMinutes , analysis the activity made by Users in Platform ZenMinutes , the issue SOME based reports review aforesaid , to the US supplier for sending SMS with the PIN necessary Created A account / logins in account , communication network providers electronics ( ie internet access ) that have access to VoIP traffic or other services contracted by us based on our legitimate interest to organize our activity appropriately [Art. 6 (1) (f) of the GDPR] .
• to our auditors, consultants, lawyers or other providers of specialized professional services, if necessary for their provision of the services contracted by us, considering our legitimate interest in contracting these services [Art. 6 (1) (f) of the GDPR];
• confidentially and in compliance with other requirements provided by law, to third parties with whom we may discuss/negotiate changes in associates, corporate structure or similar transactions that may affect ZenMinutes, to the extent necessary to carry out the necessary activities related to of the transaction in question, considering our legitimate interest and that of third parties in this regard [Art. 6 (1) (f) of the GDPR];
• public authorities and institutions, if we have a legal obligation in this regard or at their express request, if permitted by law [Art. 6 (1) (c) of the GDPR].

4.2 International data transfers.

The use of the services of some of our providers involves or may involve international data transfers. For example, the use of online payment services or the use of SMS transmission services involves the transfer of data, mainly to the United States of America.

When the use of our providers' services involves international data transfers, the personal data concerned will be subject to appropriate transfer mechanisms pursuant to Art. 45 and Art. 46 of the GDPR (e.g. transfers to countries ensuring an adequate level of protection or standard contractual clauses). Please contact us if you would like us to provide you with a copy of the aforementioned standard contractual clauses (if they have been concluded).

Regarding the transfer of data to the United States of America mentioned above, we inform you that following the adoption by the European Commission of the Decision on the adequacy of the level of protection for secure data flows between the EU and the USA, personal data may circulate securely from the EU to US businesses participating in the framework, without the need to put additional data protection safeguards in place.

5. HOW WE PROTECT YOUR DATA

We implement technical and organizational measures to ensure the security of personal data, including:

• Dedicated physical and electronic security measures. We adopt and review our physical and electronic security measures to protect against unauthorized access and other potential threats to their security.
• Specific technical measures. We use technologies to ensure the security of the personal data we process and we verify that the security technology used is appropriate for the level of risk.
• Staff training We train our employees and collaborators on the legislation and best practices in the field of personal data processing.

Although we take all reasonable measures to ensure the security of your data, ZenMinutes cannot guarantee the absence of any security breach or the impossibility of penetrating the security systems. In the unfortunate event that such a breach does occur, we will follow legal procedures to limit the effects and inform the data subjects

6. HOW LONG WE KEEP YOUR DATA

Your personal data will be kept only for the period necessary to fulfill the purposes mentioned in Section 2

The data associated with your existing account on the ZenMinutes Platform will be kept as long as you have an active account on the Platform. If you request to delete your account, your personal data will be deleted, unless there is another exception provided by law (e.g. we have a legal obligation to keep your payment data).

The data is kept for the duration necessary to resolve the notifications/requests submitted by you, as a User, in relation to the ZenMinutes Platform and/or Services and those submitted by you, as a data subject, in accordance with the legal period for which we are obliged to keep them.

The data related to the payments received from you, which represent financial-accounting documents, are kept for the period established by the tax legislation.

In the case of data processing based on your consent (S4 above), we will retain your personal data for as long as we have your consent, unless ZenMinutes may process the personal data on the basis of another legal basis or another exception provided by law would occur.

For example, if you have given us your consent to send you commercial communications of interest to you via SMS and you withdraw your consent in this regard, ZenMinutes will no longer send you commercial communications. However, it is possible that the phone number will still be kept by ZenMinutes for the fulfillment of another purpose (e.g., you have an active account on the ZenMinutes Platform).

ZenMinutes will not delete the data from its own databases if there is another legal basis for their storage and processing, in compliance with the applicable legal data protection provisions, for example, if it is necessary to establish, exercise or defend a right in court or there is another exception provided by law.

7. DATA SOURCE

7.1 The User who has an account on the ZenMinutes Platform can allow the Operator to access the phone number of the people in the User's phonebook, including you, as the person who will be called by the User.

The operator is processing your number. phone number, if the User wishes to initiate a call to you in the context of using the ZenMinutes Services. The processing of your contact data is necessary for ZenMinutes to fulfill its obligation of information and transparency towards the User by displaying the cost of the call in advance, before its initiation.

Thus, the User will decide (ie whether to initiate the call or not) knowingly, since the cost of the call (rate/minute) differs depending on the destination country of the call.

7.2 The User can use the Zenminutes Services by downloading the ZenMinutes App from Google Play and/or Apple Store. At the time of downloading the ZenMinutes app, Google Ireland Limited " Google " and Apple Inc. " Apple " processes certain data regarding the device / browser used by the User , such as IP address , model of the device , variant the application used , unique ID .

More details can be found in the Privacy Policy for Google and Apple.

8. YOUR RIGHTS

According to the law, you have the following rights related to the processing of your personal data that we carry out:

• Right of access: you can obtain confirmation from us that we are processing your data. of a personal nature, as well as information regarding the specifics of the processing such as: the purpose, the categories of personal data processed, the recipients of the data, the period for which the data are kept, the existence of the right to rectification, deletion or restriction of processing. This right allows you to obtain a copy of the processed personal data free of charge, as well as any additional copies for a fee.
• The right to data rectification : you can ask us to amend your data. incorrect personal data or, as the case may be, to complete the data that is incomplete.
• The right to erasure : you can request the erasure of your data. of a personal nature when: (i) they are no longer necessary for the purposes for which we collected and process them; (ii) you have withdrawn your consent for the processing of personal data and we can no longer process them on the basis of other legal grounds; (iii) personal data are processed against the law; respectively (iv) the personal data must be deleted according to the relevant legislation.
• Withdrawal of consent : you can withdraw your consent at any time regarding the processing of personal data processed on the basis of consent, without this affecting in any way the processing carried out prior to the withdrawal.
• The right to object : you can object at any time to processing based on our legitimate interest, for reasons related to your situation. specific.
• Restriction : You can request the restriction of the processing of your data. of a personal nature if: (i) you dispute the correctness of the personal data, for a period that allows us to verify the accuracy of the data in question; (ii) the processing is unlawful and you you object to the deletion of your personal data, requesting instead the restriction of its use; (iii) the data are no longer necessary for us to process, but you you request them from us for a court action; respectively (iv) if you have objected to the processing, for the period of time in which it is checked whether our legitimate rights as an operator prevail over your rights. as a data subject.
• The right to portability : you can ask us, under the law, to provide you with your data. personal data that you have provided to us in a structured, frequently used and machine-readable form (for example in CSV format). Also, if you expressly request us, we can transmit your data. personally to another entity, if technically possible.
• The right not to be subject to an automated individual decision-making process , including the creation of profiles.
• The right to file a complaint with the National Authority for the Supervision of Personal Data Processing :you have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing (www.dataprotection.ro) if you consider that v - the rights were violated:

To exercise one or more of the rights set out above or to ask a question about these rights or about our processing of your personal data, please contact us:

by regular post mail at address: Bucharest , Sector 1, Piața Montreal, No. 10, World Trade Center Building, Main Entrance, Office 2.11 bis, Et. 2, zip code 11469.

by email to the email address : help@ZenMinutes.com ;

by any other means available on the Platform ZenMinutes (eg, contact form).

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