Version: 1.2

Effective from: 25 May 2018

This is the privacy policy of ZenMinutes.com, a division of ZenMinutes SRL, a corporation duly organized and existing under the laws of Romania, with registered office located at World Trade Center, 10 Montreal Sq., 2nd Floor, 011469 Bucharest, ROMANIA, registered with the Trade Register under number J40/24266/2023, having VAT code RO49299666 (“ZenMinutes”, “us”, “our” or “we”) which describes how we receive, collect and use information from you in connection with our website www.zenminutes.com (or such other sites that are provided by ZenMinutes from time to time) (the 'Site'), the ZenMinutes mobile application software (the 'App'), and other products and services provided by ZenMinutes from time to time on the Site or in the App (all of the foregoing, collectively, the 'Services').

ZenMinutes cares about your privacy. ZenMinutes's Privacy Policy describes our information practices, including the types of information we receive and collect from you, how we use and share this information, and your rights in relation to the processing of information about you. The Privacy Policy sets out the legal bases for our processing of personal information about you, including the collection, use, processing, and sharing of such information, as well as the transfer and processing of such information to Romania and other countries globally where we have or use facilities, service providers, regardless of where you use our Services.

Harm To ZenMinutes Or Our Users. You must not (or assist others to) directly, indirectly, through automated or other means access, use, copy, adapt, modify, prepare derivative works based upon, distribute, license, sublicense, transfer, display, perform, or otherwise exploit our Services in impermissible or unauthorized manners, or in ways that burden, impair, or harm us, our Services, systems, our users, or others, including that you must not directly or through automated means:
(a) reverse engineer, alter, modify, create derivative works from, decompile, or extract code from our Services;
(b) gain or attempt to gain unauthorized access to our Services or systems;
(c) interfere with or disrupt the safety, security, or performance of our Services;
(d) create accounts for our Services through unauthorized or automated means;
(e) collect the information of or about our users in any impermissible or unauthorized manner;
(f) sell, resell, rent, or charge for our Services in an unauthorized manner;
or (g) create software or APIs that function substantially the same as our Services and offer them for use by third parties in an unauthorized manner.

Keeping Your Account Secure. You are responsible for keeping your device and your ZenMinutes account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our Services.

Availability Of Our Services. We are always trying to improve our Services. That means we may add or remove our Services, features, functionalities, and the support of certain devices and platforms. Our Services may be interrupted, including for maintenance, repairs, upgrades, or network or equipment failures. Events beyond our control may affect our Services, such as events in nature and other force majeure events.

Other

• We reserve the right to assign this contract in whole or in part to any third party without further notice to you; said assignment not to relieve you from your obligation to complete the terms and conditions of this contract should be assigning default.
• Except as contemplated herein, our Terms do not give any third-party beneficiary rights.
• If we fail to enforce any of our Terms, it will not be considered a waiver.
• We reserve all rights not expressly granted by us to you. In certain jurisdictions, you may have legal rights as a consumer, and our Terms are not intended to limit such consumer legal rights that may not be waived by contract. Also, in certain jurisdictions, you may have legal rights as a data subject, and our Terms are not intended to limit such rights that may not be waived by contract.
• We always appreciate your feedback or other suggestions about ZenMinutes and our Services, but you understand that you have no obligation to provide feedback or suggestions and that we may use your feedback or suggestions without any obligation to compensate you for them.

Information We Collect

ZenMinutes must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Services, including when you install, access, or use our Services. We also collect usage information such as ip address, call history, order history, account related activity log.

Information You Provide

Your Account Information. You provide your mobile phone number, phone model, phone operating system, name, address and email address to create or use a ZenMinutes account. You provide us, all in accordance with applicable laws, the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. By registering you give your consent for us to collect, use and store the information.

By making any card payment within the App or on our Site you also consent for us to collect, use and store the following information:
- Address
- Expiry date of card

Your usage. We collect information about how you use our Products, and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, from where your using and where you’re calling.

Information about transactions made on our Products. If you use our Products for credit purchases, we collect information about the purchase or transaction. This includes payment information, tokenized information regarding the payment method you used. Important notice: Your full card information is not stored by us, for more information, please check My Pay Privacy Policy (Part II of this document). We only collect, use and store partial credit card number (e.g.: your last 4 digits) and expiry date.

In addition to using this information to be able to provide you with the Services that you request, we use, store and/or may disclose the above listed information as follows:

• To verify your identity (your phone number will be used as ZenMinutes user ID).
• To manage your ZenMinutes account, deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of the Service.
• To solicit information from you, including through surveys.
• To contact you via email, SMS, telephone call or otherwise for the purpose of informing you about new products, services or promotions offered by ZenMinutes (you can opt-out of such emails by clicking on the unsubscribe link, withhold your consent to receive an SMS or send an email to help@zenminutes.com with STOP SMS in subject line in order not to receive future SMSs).
• To contact you via telephone call to inform you about different payment methods and, if applicable, assist with registration of your credit card with our Payment Processor.
• If you live in the European Union, for the purpose of providing correct VAT invoices (we are required to do so by law).
• For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Services, detecting and protecting against error, fraud or other illegal activity.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities.

Address Book
When you first install the App on your device, you will be asked to allow us access to your address book. If you consent, we will have access to contact information in your address book on the devices you use for the Services (only names and numbers) and we will store it and use it for the following purposes:

• Correctly formatting the phone numbers for international calling.
• Correctly display the name of each contact as it appears in your address book when a call is received through the App.
• Sync your contacts in the address book on your device with the App.
• For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Services, detecting and protecting against error, fraud or other illegal activity.
• To analyze what new products, services or promotions that may be relevant for you.

Usage Information
In accordance with telecommunications market practice, ZenMinutes collects certain usage statistics, including but not limited to, the phone numbers and/or other identification details of the calling and receiving party, the start time, call duration, call quality, outages (“Call Details”) and maintains a call detail record (“CDR”) for each call that is routed through the system. The Call Details are collected and the CDR maintained for billing purposes and for the purposes of improving the Services and to fulfill our obligations under applicable laws. We may also collect and store information about your usage of, and interaction with, the Services, including calls, messages, posts, information relating thereto, usage of the Service by geographies, device and connection information IP address, device capability, bandwidth, web browser software, referring website, statistics on page views, network type and traffic to and from our Site or App. Furthermore, we may also collect a list of the installed apps on your device (on an anonymous basis). Such information may be collected by using inter alia cookies (if accepted by you – in order to learn more about our use of cookies click here), ad identifiers and other applicable tracking tools.

In order to comply with Romanian legislation, we need to keep your usage information for at least 5 (five) years from the date you stopped using our services.

How We Use Information

We use the information we have (subject to choices you make) to operate, provide, improve, understand, customize, support, and market our Services. Here's how:

• We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing, and customizing our Services. We understand how people use our Services and analyze and use the information we have to evaluate and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
• We verify accounts and activity, and promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our Terms, and to ensure our Services are being used legally. Preventing cheating, crime or fraud (we may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention).
• To personalise and optimise our Services, promotional content and advertising to you. For example, we may use the information we collect through cookies, ad identifiers and similar technologies to show you ads you may be interested in.
• To create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services.
• As otherwise expressly set out in this Policy or as required by law.

We do not sell your information to anyone else.

How we Use Google Analytics

We use Google Analytics or any other such analytics service provider in relation to both the Site and the App in order to collect data, track, create and receive reports of statistics relating to usage thereof.

Google Analytics is a web analytics solution which compiles and analyzes certain information about usage of a website or app. It may add cookies to your computer or device or read existing cookies when you visit our Site or interacting with certain parts of our App. In order to learn more about how Google uses such data please visit https://policies.google.com/privacy. By using our Site or the App, you declare your consent to Google’s use of the data collected about you in the manner and for the purposes described above.

Furthermore, when you are using our App, we may also automatically record your Google Advertising ID (if you are using an Android device), for advertising or analytics purposes. The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has a Google Advertising ID, we may collect and use it for advertising and user analytics purposes. If your device does not have Google Advertising ID, we may use other persistent identifiers. If you have a Google Account and/or an Android device, you can opt out of targeted advertising on your device. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select 'Ads' and check the box 'Opt out of interest-based ads'. In addition, or as an alternative, you may reset your device’s Android advertising ID, which will result in your device being disassociated from ad targeting profiles based on the Android advertising ID in effect prior to reset. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select 'Ads' and selecting 'Reset advertising ID'. Note that Android settings menus may vary among device manufacturers and these instructions may not be accurate for your device. You should consult Google’s settings and instructions for the most current settings information.

In addition, we may interact with your phone's SMS inbox for the purposes of service activation, placing incoming international messages and reading the contents of the activation SMS sent to you by us.

How we use Facebook Pixels

The Facebook pixel is a piece of code that goes on our website and connects to our Facebook adverts in order to tell us which actions people take as a result of your adverts.

The Facebook pixel help us to:

• Track our adverts' performance.
• Measure return on investment.
• Unlock powerful targeting capabilities.
• Run more efficient advertising campaigns.

Sharing Information

We will only share your data with third parties (for example, our group companies or suppliers):

• With your consent (including as set out in this Policy).
• As reasonably necessary in order to provide the Services to you (for example, by providing information to suppliers we may use to fulfill the Services or to communicate with you).
• Where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your information to our payment processors).
• Where such third party's assistance is deemed necessary to enable us to inform you about new products, services, promotions or different payment methods and, if applicable, assist with registration of your credit card.
• Where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it.
• When you submit information by interacting with our social media channels (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on the Site and social media channels.
• As we reasonably believe is permitted by law or regulation.
• In order to comply with any legal obligation, or in order to enforce or apply the ZenMinutes Terms of Service and/or any other agreement with you; or to protect the rights, property, or safety of ZenMinutes, our users, or others.
• In the event that there is a sale of the assets of ZenMinutes or corporate restructuring, or as a result of a change of control of ZenMinutes or one of its group companies, or in preparation of any of these events. Any third party to which the assets or ZenMinutes (or any group company) is transferred to will have the right to continue to use the information that you provide to us in the manner set out in this Policy.

In addition, we may use external advertising companies to serve ads when you have visited the Site and/or downloaded the App. These companies may use information (but not information that includes your name, address, email address or telephone number) about your visits to the Site and other websites in order to provide advertisements about goods and services of interest to you.

Your details may be stored and processed in Romania, Germany or any other country in which ZenMinutes or its affiliates, subsidiaries or agents maintain facilities. By using the Services, you consent to any such transfer of the information outside your country.

Transfer of information outside your country

We may, for the purposes set forth herein, transfer, process and store your information in Berlin, Germany or any other country in which ZenMinutes or its affiliates, subsidiaries, suppliers or agents maintain facilities. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to and processed in a country outside of the EEA, which may not provide the same level of protection for personal data as within the EEA, By using the Services, you consent to any such transfer of the information outside your country.

These data transfers are necessary to provide the Services set forth in our Terms and globally to operate and provide our Services to you. We utilize standard contract clauses approved by the European Commission, and may rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the European Economic Area to the United States and other countries.

Communications, notifications etc.

We may send you messages about updates, faults, alerts and other types of issues relating to technical aspects and/or the usability of the App and other parts of the Services.

We may occasionally ask you to provide information on your experiences of using the App or other parts of the Services which will be used to improve the quality and provision of the Services. You are under no obligations to provide any such information. Any and all information which is voluntarily submitted by you in relation to any survey that you take part in is used for the purposes of reviewing this feedback and improving the Services.

ZenMinutes may from time to time contact you by phone, SMS or through any other appropriate information channel to keep you up to date with news about ZenMinutes and the Services, including new products, campaigns, promotions and payment methods.

You can stop the delivery of promotional messages from ZenMinutes by following the specific instructions in promotional messages or by our customer support at help@zenminutes.com. These communication choices do not apply to mandatory service communications that are considered part of the Services, which you may receive periodically unless you delete the App.

Promotional SMS messages to US Customers In addition to the provisions on communications, notifications etc. set forth in the section above the following shall apply in relation to SMS messages between ZenMinutes and customers residing in the USA. ZenMinutes may occasionally send promotional SMS to you. If you want to stop receiving SMS from us or join again, just let us know by sending an email to help@zenminutes.com and we will stop or start sending promotional SMS to you according to your request. As always message and data rates may apply for any messages sent to you from ZenMinutes and from ZenMinutes to you.

US mobile carriers supported: AT&T, U.S. Cellular, MetroPCS, Sprint, Virgin Mobile, Cricket, Carolina West, Cellcom, C Spire, Cincinnati Bell, Verizon Wireless, Boost and T-Mobile®. TMobile is not liable for delayed or undelivered messages.

Third Party Sites

Our Site or App may contain links that will let you leave our Site or App and access a website of a third party. Please note that such linked websites are not under the control of ZenMinutes and that such websites have their own privacy policy governing such thrird party's treatment of personal data. Our Privacy Policy applies solely to personal information that we acquire from you through our Site, our App, your use of our Services and/or your relationship with ZenMinutes.

Security

Protecting user privacy and personally identifiable information is a top priority for ZenMinutes. We make substantial efforts to ensure the privacy of all personally identifiable information collected by us in relation to the provision of the Services to our customers. Although we cannot guarantee that the information will not be subject to unauthorized access, loss or misuse we have physical, electronic, and procedural safeguards in place to protect the information.

Changes to the Policy

We are constantly innovating and looking for new ways to improve our Services. We therefore reserve the right to update or modify this Policy at any time with or without notice to reflect such improvements or any other changes to our business. We will post the revised Policy on www.zenminutes.com so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. You agree that your continued use of the Services after we publish a revised Policy constitutes your acceptance of the revised Policy. If you do not agree with the terms of the Policy, you should not use the Services.

Accessing Your Personal Information

If you would like to view, correct, complete or remove your personal information or if you have any other questions in connection with this Policy, please contact us at help@zenminutes.com.

How The General Data Protection Regulation Applies To Our European Region Users

Our Legal Bases For Processing Information
We collect, use, and share the information we have as described above:

• as necessary to fulfill our Terms;
• consistent with your consent, which you can revoke at any time;
• as necessary to comply with our legal obligations;
• occasionally to protect your vital interests, or those of others;
• as necessary in the public interest; and
• as necessary for our (or others') legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

How You Exercise Your Rights
Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications.

You also have the right to object to and restrict certain processing of your data. This includes:

a) the right to object to our processing of your data for direct marketing, which you can exercise by using the 'unsubscribe' link in such marketing communications; and
b) the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right contacting us at dpo@zenminutes.com

We will consider several factors when assessing an objection including: our users' reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

Managing And Deleting Your Information

We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.

If you would like to manage, change, limit, or delete your information, we allow you to do that through the following tools:

• You can view the information about you inside your online Account.
• You can alter part of the information we store inside your online Account. You can also change how we use some information under Notification Settings inside your online Account or in the App. Some information cannot be modified; please contact the Data Protection Officer for ZenMinutes at dpo@zenminutes.com should you require further clarifications.
• Deleting Your ZenMinutes Account. You may delete your ZenMinutes account at any time (including if you want to revoke your consent to our use of your information) by sending an email to dpo@zenminutes.com. Some information in your Account may not be possible to delete.

The right to be forgotten

If you would like to be forgotten please contact our Data Protection Officer at dpo@zenminutes.com. Please note that there is some information, such as, but not limited to, usage information, which we cannot legally delete.

Law And Protection

We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, ZenMinutes, or others, including to prevent death or imminent bodily harm.

Updates To Our Policy

We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our Services.

Contact Information

The Data Protection Officer for ZenMinutes can be contacted at dpo@zenminutes.com

If you have questions about our Privacy Policy, please contact us.

You have the right to lodge a complaint with ZenMinutes 's lead supervisory authority, The Romanian Data Protection Commissioner, or your local supervisory authority.

How We Process Your Information

Under European law, companies must have a legal basis to process data. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the General Data Protection Regulation (the 'GDPR').

We process data as necessary to perform our contracts with you.

If you choose not to provide certain data, the quality of your experience using ZenMinutes may be impacted.

When we process data you provide to us as necessary to perform our contracts with you, you have the right to port it under the GDPR.

Cookie Policy

We use cookies (small text files placed on your device) and similar technologies to provide our websites and online services and to help collect data. The cookie is installed through a web browser request from a browser (eg Internet Explorer, Chrome) and is completely 'passive' (does not contain software, viruses or spyware and can not access the information on the user's hard drive).

What are Cookies used for?
Cookies allow us, among other things, to store your preferences and settings; enable you to sign-in; and analyze how our websites and online services are performing.

What Cookies Do We Use?
We use two types of cookies: per session and fixed. The latter are temporary files that remain in the user's terminal until the end of the session or closing the application (the web browser). Fixed files remain on the user's terminal for a while in the Cookie's parameters or until they are deleted manually by the user.

How are cookies used by this site?
A visit to this site may place cookies for purposes of:

• Site performance cookies
• Visitor analysis cookies
• Cookies for Geo Targeting
• Recording cookies
• Cookies for advertising
• Advertiser cookies

Does Cookies contain Personal Data?
Cookies themselves do not require personal information to be used and, in most cases, do not personally identify Internet users. Personal data collected through the use of Cookies can only be collected to facilitate certain user functions. Such data is encrypted in a way that unauthorized people cannot access them

Deleting Cookies
You can set your browser not accept cookies and you can also remove cookies stored in your browser. However, some functions of our website might not function as a result.

Denying or disabling cookies does not mean you will not receive online advertising - just that it will no longer be able to keep track of your preferences and interests highlighted by your browsing behavior.

Examples of important uses of cookies (which do not require authentication of a user through an account):

• Content and services tailored to user preferences - product categories and services.
• Offers tailored to users' interests - retaining passwords.
• Retrieve Child Protection Filters for Content on the Internet (family mode options, safe search functions).
• Limit ad serving frequency - limit the number of impressions of an ad for a particular user on a site.
• Provide more relevant advertising for the user.
• Measurement, optimization, and analytics features - such as confirming a certain level of traffic on a website, what type of content is viewed, and how a user reaches a website (eg through search engines, directly from other websites etc.). Websites run these analyzes of their use to improve sites for the benefit of users.

Security and privacy issues

Cookies are NOT Viruses! They use plain text formats. They are not made up of pieces of code so they cannot be executed or can auto-run. Consequently, they cannot duplicate or replicate on other networks to run or replicate again. Because they cannot perform these functions, they cannot be considered viruses.

Cookies can still be used for negative purposes. Because it stores information about user preferences and browsing history, both on a particular site and on several other sites, cookies can be used as a form of Spyware. Many anti-spyware products are aware of this and consistently mark cookies to be deleted in anti-virus / anti-spyware removal / scanning procedures.

In general, browsers have built-in privacy settings that provide different levels of cookie acceptance, shelf life, and automatic deletion after the user has visited a particular site.

Other security issues related to cookies:

Since identity protection is very valuable and is the right of every internet user, it is advisable to know what issues can create cookies. In order to transmit constant information in both ways between the browser and the website, if an attacker or unauthorized person intervenes during the data transmission, the information contained in the cookie can be intercepted.

Although very rarely, this can happen if the browser connects to the server using an unencrypted network (eg an unsecured WiFi network).

Other cookie-based attacks involve bad cookie settings on servers. If a website does not require the browser to use only encrypted channels, attackers can use this vulnerability to prevent browsers from sending information through insecure channels. Attackers then use the information for the purpose of unauthorized access to certain sites. It is very important to be careful in choosing the most appropriate method of protecting personal information.

Tips for safe and responsible cookie-based navigation.

• Customize your browser settings for cookies to reflect a comfortable level for your cookie security.
• If you do not mind cookies and you are the only person using your computer, you can set expiration dates to store your browsing history and personal access data.
• If you share your access to the computer, you can consider the browser setting to delete the individual navigation data either
• If you share your computer access, you can consider the browser setting to delete your individual browsing data each time you close your browser. This is a way to access sites that place cookies and delete any business information when you close the browsing session.
• Install and constantly update your antispyware applications.
• Make sure your browser is always up-to-date.

Cookies are everywhere and cannot be avoided if you want to enjoy access to the best and greatest websites on the Internet - local or international. With a clear understanding of how they work and the benefits they bring, you can take the necessary security measures so you can browse with confidence on the internet.

Disabling and refusing to receive cookies can make some sites unfeasible or difficult to visit and use. Also, refusing to accept cookies does not mean you will not get / see online advertising anymore.

It is possible to set up the browser so that these cookies are no longer supported or you can set the browser to accept cookies from a particular site. But for example, if you are not registered using cookies, you will not be able to leave comments.

All modern browsers offer the ability to change cookie settings. These settings are usually found in your browser's 'options' or 'preferences' menu.