ZP BETTER TOGETHER PRIVACY POLICY
Date: November 1, 2021

ZP Better Together, LLC (referred to as “ZP Better Together,” “Company,” “we,” “our,” or “us”), is committed to protecting our users’ and visitors’ privacy. This Privacy Policy explains how we collect, use, share, and disclose personal information about you when you interact with us or use our websites, products, and services, including your use of the CloudVP Application (“CloudVP”).

1. Personal Information We Collect

We collect and use personal information about you to facilitate your use of our products and services and for our business and commercial purposes. “Personal information” for the purposes of this policy means any information that could help us directly or indirectly identify you.

Information that does not identify an individual is not personal information. This includes aggregate consumer information, meaning information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or, as applicable only to California residents, to any household.

Depending on how you interact with us, we may collect the following categories of personal information about you:

• Identifiers and similar information such as your name, phone number, email address or IP address.
• Commercial information, including records of products or services obtained, or considered including statistics on your usage of our services (e.g., minutes of use). •
• Internet or other electronic network activity information, including information regarding your interaction with our website; your type of computer and type of web browser; and your usage of our services (e.g., telephone numbers or IP address called and date, time, and duration of call).
• Geolocation information.
• Audio, electronic, visual, or similar information.

2. Sources of Personal Information

We may collect personal information directly from you or others acting on your behalf when you choose to: (i) use or register for CloudVP offered by ZP Better Together; (ii) send an email, fill out online forms, or engage in other transactions or interactions with ZP Better Together; or (iii) view or use our website, regardless whether you register or submit any personal information, in which case we will collect certain personal information and aggregate information through cookies or other web devices. We also may collect personal information from other sources as permitted by law, including our sub-brands ZVRS and Purple, regulatory authorities, third parties we interact with to provide you services, or public websites or publicly available sources like government records.

In order to access certain ZP Better Together services, you have to complete an application or other registration form(s) and provide certain information reasonably necessary for us to provide the products and/or services you requested. We may collect the following types of information when you register for CloudVP, submit requests, and when you use our products or services: your name, your email address(es), your phone number(s), your IP address(es), and your usage of our services (including quantity, technical configuration, type, destination, location, and amount of use). The information gathered from your use of our services may be considered Customer Proprietary Network Information (“CPNI”).

3. Purposes for Collecting and Using Personal Information

ZP Better Together may collect or use your personal information for various business or commercial purposes, including to provide you with our products and services and to respond to your questions. We also use the information we collect for statistical analysis of users' behavior, for product development, for content improvement, to ensure our products and services remain functioning and secure, and to investigate and protect against any illegal activities or violations of our Terms of Service https://www.zvrs.com/about/product-agreement/ and https://purplevrs.com/product-agreement  ZP Better Together may also use personal information in connection with federal or other legal requirements, such as responding to a subpoena or court order, or providing information as required by Federal Communications Commission (“FCC”) regulations.

Personal information that visitors voluntarily provide to ZP Better Together (e.g., names, email addresses, and phone numbers) may be added to ZP Better Together’s databases and used for future calls and mailings regarding website updates, new products and services, upcoming events, and status of orders placed online.

With regard to the purposes for collecting and using personal information categorized as CPNI, please see below Section 8, “Collection, Use, and Sharing of Customer Proprietary Network Information (CPNI).”

4. Disclosure of Personal Information

We may disclose information, including personal information, about you to: (i) businesses that provide services to us in connection with those services; (ii) regulators, other government agencies, or law enforcement as required or permitted by law, including the FCC and its service providers; (iii) our sub-brands, ZVRS and Purple, Privacy Policy; (iv) other parties in connection with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; and (v) other parties at your direction or with your consent or as otherwise required or permitted by law.

As indicated above, pursuant to FCC regulations we may disclose certain information, including personal information, to authorized companies or independent contractors (“authorized third parties”) in order to:  (i) provide you with products and services; (ii) install, maintain and repair our products and services; (iii) offer you additional features and services of the type you already registered for with CloudVP; or (v) process information on our behalf.  These authorized third parties have agreed to certain confidentiality protections.

Aside from authorized third parties, ZP Better Together also may disclose to third parties information in aggregate form, that is publicly available, and/or that you intentionally direct ZP Better Together to disclose.

5. Use of Cookies and Similar Tools

We use cookies to ensure that you get the most out of our website. Cookies are small amounts of information in the form of text files that we store on the device you use to access our website.  Some of these cookies are necessary for the website to function or for us to provide you with certain services.  We also use other cookies and similar tools to collect certain analytics data about your use of our website. We work with partners, including Google Analytics and Facebook Business Services, that provide us with certain analytics and advertising services. These partners collect certain information to help us understand how you and others interact with our website, serve advertisements on our behalf on different internet platforms, and measure the performance of those advertisements. They may do so through cookies and similar tools used to collect internet or other electronic network activity information (e.g., IP addresses, access times, or pages visited).

You can find out more information about Google Analytics cookies here [link to Google Analytics information and how to prevent the use of Google Analytics relating to the use or our website by downloading and installing the browser plug-in available here [link to browser plug-in information].

If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies.  For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org).  If you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the website.

Please note that some web browsers may transmit “do-not-track” (“DNT”) signals.  We currently do not respond to DNT settings in your web browser.

6. Links to Other Website

ZP Better Together may provide links to, or automatically produce search results for, third-party websites or resources or third-party information referencing or linking to third-party websites or resources.  ZP Better Together has no control over such third-party websites and resources, and is not responsible for the content or information contained therein.  When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such third parties.  ZP Better Together is not responsible for the privacy or security practices or the content of non-ZP Better Together websites, services, or products.

7. Reasonable Security Measures

ZP Better Together will take reasonable steps and use security measures appropriate to the nature of the information at issue and that comply with applicable laws to protect customers’ personal information against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards always will be successful.

8. Collection, Use, and Sharing of Customer Proprietary Network Information (CPNI)

CPNI is information that ZP Better Together obtains when providing customers with telecommunications services. CPNI is information that relates to the quantity, technical configuration, type, designation, location, and amount of use of a telecommunications service.

Where applicable, ZP Better Together may access, use, share, or disclose CPNI under the following limited circumstances: (i) to provide you with telecommunications services; (iii) for installation, maintenance and repair of our products and services; (iv) to offer you additional features and services of the type you already registered for with CloudVP; (v) in response to legal requirements such as subpoena or court order; (vi) upon request from the FCC’s Telecommunications Relay Service (“TRS”) Fund; (vii) to prevent fraud, abuse, or misuse of the service(s); and (viii) to protect the rights and property of ZP Better Together.

ZP Better Together, including our sub-brands, ZVRS and Purple may also use your CPNI to offer you products and services that may be different from the types of services you already use. ZP Better Together asks for your consent to do this during your registration process.  Your denial or approval will not affect ZP Better Together’s provision of services to you.  At any time, you may choose to opt out of use of your CPNI for marketing purposes.  Your approval or denial is valid until you choose to change it.

Customers have the right to deny any telecommunications provider the right to use, disclose, or permit access to customer CPNI for certain marketing purposes.  Telecommunications providers have a duty under federal law to honor your right to do so and to protect the confidentiality of CPNI.

If your CPNI is used for marketing purposes and you wish to restrict ZP Better Together’s use of your CPNI for marketing purposes, you may contact CloudVP Support at support@purple.us or 866-932-7891.

9. Opt-Out Right and Access to and Ability to Correct Personal Information

Visitors may opt out of having their personal information collected by ZP Better Together disclosed to third parties, or used by ZP Better Together, including our sub-brands ZVRS and Purple, or third parties to send promotional correspondences to the visitor, by contacting ZP Better Together via postal mail, email at the addresses below, or telephone 866-932-7891.

Upon request via postal mail, email, or phone, ZP Better Together will provide to visitors a summary of any personal information retained by ZP Better Together regarding the visitor. Visitors may modify, correct, change or update their personal record or cause their personal record to be removed from ZP Better Together's database. ZP Better Together will only send personal records to the email address on file for the visitor name associated with it.

Visitors may also submit a request to opt-out via postal mail at by contacting our company, ZP Better Together’s marketing department:  ZP Better Together, 11900 N. Jollyville Road #204209, Austin, TX 78759 Attn: Marketing Department or email at help@zvrs.com.

10. Collection of Personal Information from Children

Our products and services are intended for a general audience and are not directed at children under 18.  ZP Better Together does not knowingly solicit or collect personal information from children under the age of 18.  If you are under the age of 18, you are not authorized to register for or use any of our products or services, including our website and CloudVP, or otherwise submit any information to us. If you are a parent or guardian and you believe we have collected information from your child who is under the age of 18, you may contact us at CloudVP Support at 866-932-7891, or via email at support@sivo.me  request that we delete it.  We will delete the information within a reasonable time to the extent required by applicable law.

11. Rights and Information Applicable to California Residents

If you are a California resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose and share your personal information and your potential rights with regard to your personal information under the California Consumer Privacy Act (“CCPA”).  The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used in this section have the meaning given to them in the CCPA.  Under the CCPA, ZP Better Together is a business. For purposes of this section only and with regard to California residents only, personal information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. Personal information does not include deidentified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect the categories of personal information listed above in Section 1, “Personal Information We Collect.”

How We Use Collected Information

We may use your personal information for the business or commercial purposes listed above in Section 3, “Purposes for Collecting and Using Personal Information.”

For more information about our privacy practices, please review our Privacy Policy.

Our Collection, Use, Disclosure, and Sharing of Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

• Depending on how you interact with us, in the preceding 12 months we may have collected all or some of the categories of personal information listed above in Section 1, “Personal Information We Collect.”
• We may have collected personal information from all or some of the categories of sources listed in Section 2, “Sources of Personal Information.”
• We may have collected all or a few of the categories of personal information for the business or commercial purposes listed above in Section 3, “Purposes for Collecting and Using Personal Information.”

Our Disclosure and Sharing of Personal Information

We do not sell your personal information. We do not knowingly sell personal information of California residents under 16 years old.

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:

Category of Personal Information	Category of Third Party
Identifiers (for example your name and online identifiers)	·       Government agencies and their service providers.
Commercial Information (for example records of products or minutes of use)	·       Government agencies and their service providers.
Internet or Electronic Network Activity Information	·       Government agencies and their service providers.

In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in Section 1, “Personal Information We Collect” above, to the following categories of third parties: (i) judicial courts, other regulators or government agents purporting to have jurisdiction over us, our subsidiaries, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.

We may also share your personal information to our service providers, such as information technology and web analytics providers or other entities that have agreed to limitations on the use of your personal information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.

Rights Applicable to California Residents

A user or visitor who is a California resident as defined under the CCPA may have certain rights concerning their personal information, subject to applicable exemptions and limitations, such as the right to:

(1)   Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.

(2)   Request that we delete any personal information about you that we have collected, subject to certain exceptions (“Request to Delete”).

(3)   Request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”):

• • The categories of personal information we have collected about you.
  • The categories of sources from which we collected the personal information.
  • The business or commercial purpose for collecting or selling the personal information, where applicable.
  • The categories of third parties with which we share personal information.
  • The specific pieces of personal information we have collected about you.
  • The categories of personal information we have disclosed about you for a business purpose.

(4)   Not be discriminated against because you exercised any of your rights under the CCPA.

(5)   Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information, including, generally, personal information collected, processed, sold or disclosed pursuant to the Health Insurance Portability and Accountability Act of 1995 and its implementing rules and regulations.  We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete by users or visitors where permitted by the CCPA or another law or regulation.  For example, the FCC requires that we retain certain records for five years and we will continue to abide by this regulatory obligation even if we receive a Request to Delete such information during the relevant period.

How to Submit a CCPA Request

California resident users or visitors may submit Requests to Know or Requests to Delete through the following toll-free telephone number CloudVP Support at 866-932-7891, or via email at support@purple.us.

We are required to provide certain information or delete personal information only in response to verifiable requests made by you or your authorized agent.  When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, phone number, your driver’s license, and email address. Any information gathered in this process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

We will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.

We will try to respond to your Requests to Know or to Requests to Delete within forty-five (45) days of receipt of the request.  If we require more time, we will try to inform you of our need for an extension.  Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.

Keep in mind that we are not required to provide information in response to requests to know more than twice in a 12-month period.  Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.

12. ZP Better Together’s Right to Contact Users

ZP Better Together reserves the right to contact website visitors regarding account status and changes to the subscriber agreement, Privacy Policy, or any other policies or agreements relevant to site visitors.

13. ZP Better Together’s Right to Change this Privacy Policy

The foregoing policy was last updated and is effective as of November 1, 2021.  ZP Better Together reserves the right to change this policy at any time. Changes to the policy will be posted to this page, and if changes are significant, a summary of the changes will be posted at the beginning of the policy.

14. Contact Information

If you have any questions about this policy, you may contact us at CloudVP Support via email at compliancedirector@zvrs.com or via regular mail to the attention of Legal Department, CloudVP Support, 11900 N. Jollyville Road #204209, Austin, TX 78759.