Privacy

Introduction

When you use Zooma, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices.

This policy describes the information we collect, how it is used and shared, and your choices regarding this information, including what information we collect, when we collect it, and how we use it.

Data Collections And Uses

SUMMARY

This policy applies to users of Zooma’s services anywhere in the world, including users of Zooma’s apps, websites, features or other services.

This policy describes how Zooma and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites, features or other services anywhere in the United States or Canada.

This policy also applies to those who provide information to Zooma in connection with an application to use our services, or whose information Zooma otherwise receives in connection with its services (such as contact information of individuals associated with Zooma partners). All those subject to this policy are referred to as users for purposes of this policy.

The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region.

The Information We Collect

SUMMARY

Zooma collects:

* Information that you provide to Zooma, such as when you create your Zooma account.

* Information created when you use our services, such as location, usage and device information.

* Information from other sources, such as Zooma partners and third parties that use Zooma APIs.

* The following information is collected by or on behalf of Zooma:

* Information you provide

* This may include:

User profile: We collect information when you create or update your Zooma account. This may include your name,email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers such as Social Security number, driver’s license or passport if required by law, birth date, photo and signature. This also includes the preferences and settings that you enable for your Zooma account.

Background check information: We may collect background check information if you sign up to use Zooma’s services as a Dental Practice or Dental Professional. This may include information such as your work, certification, or educational history (where permitted by law). This information may be collected by a vendor on Zooma’s behalf.

Demographic data: We may collect demographic information about you, including through user surveys. In some countries, we may also receive demographic information about you from third parties.

User content: We may collect information that you submit when you contact Zooma customer support, provide ratings or compliments for other users, or otherwise contact Zooma.

Information created when you use our services. This may include:

Location Information

Depending on the Zooma services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi.

If you are a Dental Practice or Dental Professional, Zooma collects location information when the Zooma app is running in the foreground (app open and on screen) or background (app open but not on screen) of your device.

If you are a Hygienist and have provided permission for the processing of location data, Zooma collects location information when the Zooma app is running in the foreground. In certain regions, Zooma also collects this information when the Zooma app is running in the background of your device if this collection is enabled through your app settings or device permissions.

Dental Practices and Dental Professionals may use the Zooma app without enabling Zooma to collect their location information. However, this may affect the functionality available on your Zooma app.

Transaction Information

We collect transaction details related to your use of our services, including the type of services you requested or provided, your shift details, shift information, date and time the service was provided, amount charged, distance traveled, and payment method.

Usage information

We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

Device Information

We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Communications data

We enable users to communicate with each other and Zooma through the Zooma apps, websites, and other services. For example, we enable Dental Practices and Dental Professionals to call or text each other (without disclosing their telephone numbers to each other). To provide this service, Zooma receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Zooma may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services and for analytics.

Information from other sources These may include:

* User feedback, such as ratings or compliments.

* Users providing your information in connection with referral programs.

* Users requesting services for or on your behalf.

* Users or others providing information in connection with claims or disputes.

Zooma business partners through which you create or access your Zooma account, such as payment providers, social media services, or apps or websites who use Zooma s APIs or whose API Zooma uses (such as when you get directions to the dental office through Google Maps, Waze, etc.).

* Financial services providers.

* Publicly available sources.

* Marketing service providers.

* Zooma may combine the information collected from these sources with other information in its possession.

How We Use Your Information

SUMMARY

Zooma collects and uses information to enable reliable and convenient transportation, delivery and other products and services. We also use the information we collect:

* To enhance the safety and security of our users and services

* For customer support

* For research and development

* To enable communications to or between users

* To provide promotions or contests

* In connection with legal proceedings

* Zooma does not sell or share your personal information to third parties for third party direct marketing purposes.

Zooma uses the information it collects for purposes including:

* Providing services and features

* Zooma uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:

* Create and update your account.

* Verify your identity.

* Enable services. This includes automated processing of your information to enable payment.

* Process or facilitate payments for those services.

* Offer, obtain, provide or facilitate insurance or financing solutions in connection with our services.

* Enable features that allow you to share information with other people, such as when you submit feedback, office notes, refer a friend to Zooma, or select a preference.

* Enable features to personalize your Zooma account such as preferred offices or Dental Professionals in the future.

* Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

* Safety and security

* We use your data to help maintain the safety, security and integrity of our services and users. This includes, for example:

* Screening Dentist, Dental Practices, Dental Assistants and Dental Hygienists for updates to date qualification, public or private complaints, and compliance issues.

* Using device, location, profile, usage and other information to prevent, detect, and combat fraud or unsafe activities. This includes processing of such information, in certain areas, to identify practices or patterns that indicate fraud or risk of safety incidents. This may also include information from third parties. In certain cases such incidents may lead to deactivation by means of an automated decision making process.

* Using user ratings to encourage improvement by affected users, and as grounds for deactivating users with ratings below a certain minimum as may be required in their region.

* Zooma Technologies Inc. strictly prohibits sending unsolicited messages, including spam, to recipients who do not have a business relationship with Zooma Technologies Inc. and also believes in strict ethical norms for end user communication. To ensure this, we ask any individuals who believe they have received unsolicited messages from us to report any

* Suspected abuse to support@getzooma.com and forward us the suspicious message.

* Customer support

* Zooma uses the information we collect (including recordings of customer support calls or texts after notice to you and with your consent) to assist you when you contact our customer support services, including to:

* Direct your questions to the appropriate customer support person

* Investigate and address your concerns

* Monitor and improve our customer support responses

* Research and development

* We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

* Communications among users

* Zooma uses the information we collect to enable communications between our users. For example, a Dental Office may text or call a Hygienist to confirm shift details, office best practices, or preferred dress code.

* Communications from Zooma

* Zooma may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events.

* Zooma may also use the information to promote and process contests and awards, and serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as an Zooma user.

* Legal proceedings and requirements

* We may use the information we collect to investigate or address claims or disputes relating to your use of Zooma services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

Cookies And Third Party Technologies

SUMMARY

Zooma may use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this policy. Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Zooma uses cookies and similar technologies for purposes such as:

* Authenticating users

* Remembering user preferences and settings

* Determining the popularity of content

* Delivering and measuring the effectiveness of advertising campaigns

Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services. We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services.

Information Sharing And Disclosure

SUMMARY

Some of Zooma’s products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.

Zooma may share the information we collect:

With other users

For example, as a Zooma Dental Professional, we will share your profile information, including Hygienist license number and Government ID with the Dental Practice so they may perform any relevant or required verifications, background checks, or additional screenings. If you are a Dental Practice, we will share with the Dental Professional your address, phone number, main point of contact, and other information related to completing a shift.

With the general public when you submit content to a public forum We love hearing from our users including through public forums such as Zooma blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.

With Zooma service providers and business partners Zooma may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

* Payment processors and facilitators.

* Background check providers (drivers and delivery partners only).

* Cloud storage providers.

* Marketing partners and marketing platform providers.

* Data analytics providers.

* Research partners, including those performing surveys or research projects in partnership with Zooma or on Zooma s behalf.

* Vendors that assist Zooma to enhance the safety and security of its apps.

* Consultants, lawyers, accountants and other professional service providers.

* Insurance and financing partners.

For legal reasons or in the event of a dispute, Zooma may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing your information with law enforcement officials, government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect Zooma s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder, including shift information.

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.With your consent Zooma may share your information other than as described in this policy if we notify you and you consent to the sharing.

Information Retention And Deletion

SUMMARY

Zooma retains user profile and other information for as long as you maintain your Zooma account.

Zooma retains transaction, location, usage and other information for 10 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Zooma thereafter deletes or anonymizes such information in accordance with applicable laws.

Users may request deletion of their accounts at any time. Following such a request, Zooma deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain.

You may request deletion of your account at any time through the Privacy Settings in the Zooma app, or via Zooma website

Following such a request, Zooma deletes the information that it is not required to retain. In certain circumstances, Zooma may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Zooma will delete your account as described above.

Zooma may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users safety and security. For example, if Zooma shuts down a user's account because of unsafe behavior or security incidents, Zooma may retain certain information about that account to prevent that user from opening a new Zooma account in the future.

a. Explanation and copies of your data

You have the right to request an explanation of the information that Zooma has about you and how Zooma uses that information.You also have the right to receive a copy of the information that Zooma collects about you if collected on the basis of consent or because Zooma requires the information to provide the services that you request.

b. Correction

If Zooma has information about you that you believe is inaccurate, you have the right to request correction of your information.

c. Deletion

Users may request deletion of their accounts at any time. Users may request deletion through the Privacy Settings menu in the Zooma app, or via Zooma s website (riders and delivery recipients here; drivers and delivery partners here).We may retain certain information about you as required by law and for legitimate business purposes permitted by law.

Please see the ‘Information Retention & Deletion’ section above for more information regarding Zooma’s retention and deletion practices.

a. The processing is necessary to provide the services and features you request Zooma must collect and use certain information in order to provide its services. This includes:

* User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your shifts and accounts; and to enable you to make payments or receive earnings.

* Background check Information necessary to enable Dental Practices and Dental Professionals to provide services through the Zooma app.

* Transaction information, which is necessary to generate and maintain in connection with your use of Zooma s services.

* Usage information, which is necessary to maintain, optimize and enhance Zooma s services, including to determine, sometimes in combination with other information, incentives, connect riders and drivers, and calculate costs of trips and driver earnings.

* Collection and use of this information is a requirement for using Zooma’s apps.

b. The processing is necessary to protect the vital interests of our users or of others Zooma may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.

c. The processing is necessary for Zooma’s legitimate interests. Zooma collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:

* To maintain and enhance our users’ safety and security. For example, we collect background check information (where permitted by law) to prevent unsafe users from providing services through our apps. We also use personal information to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining information of banned users to prevent their use of Zooma’s apps.

* To prevent, detect and combat fraud in connection with the use of our services. For example, Zooma uses user profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud Zooma or other users.

* To inform law enforcement officials regarding criminal acts or threats to public safety.

* To provide customer support.

* To optimize our service and develop new services. This includes, for example, identifying the best pick up / drop locations, recommending (new) features, improving navigation, and enhancing pricing and matching riders and drivers or delivery recipients and partners.

* For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the safety and security of our services.

* For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.

* To enforce Zooma’s Terms of Service.

d. The processing is necessary for the legitimate interests of other persons or parties Zooma collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. Zooma may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.

e. The processing is necessary to fulfill Zooma’s legal obligations. Zooma is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, Zooma is subject to laws and regulations in many cities and countries that require it to collect and retain information about your trips, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. Zooma uses your information to comply with such laws to the extent they apply to your use of the Zooma apps.

Zooma may also share information with law enforcement, or requests by third parties pursuant to legal processes. For more information about such sharing, please contact us.

Choice and Transperancy

SUMMARY

Zooma provides means for you to see and control the information that Zooma collects, including through:

* In app privacy settings

* Device permissions

* In app ratings pages

* Marketing opt outs

* You may also request that Zooma provide you with explanation, copies or correction of your data.

A. PRIVACY SETTINGS

The Privacy Settings menu in the Zooma Dental Professional app gives users the ability to set or update their location and contacts sharing preferences, and their preferences for receiving mobile notifications from Zooma. Information on these settings, how to set or change these settings, and the effect of turning off these settings are described below.

B. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Zooma app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Zooma app seeks before you first use the app, and your use of the app constitutes your consent.

C. RATINGS LOOK-UP

After every shift, Dental Practices and Dental Professionals are able to rate each other, as well as give feedback on how the shift went. This two way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for both Dental Practices and Dental Professionals.

D. EXPLANATIONS, COPIES AND CORRECTION

You may request that Zooma:

* Provide a detailed explanation regarding the information Zooma has collected about you and how it uses that information.

* Receive a copy of the information Zooma has collected about you.

* Request correction of any inaccurate information that Zooma has about you.

* You can make these requests by contacting Zooma here.

* You can also edit the name, phone number and email address associated with your account through the Settings menu in Zooma’s apps. You can also look up your request, canceled shift, and completed shift history in the Zooma apps.

E. MARKETING OPT-OUTS

You may opt out of receiving promotional emails from Zooma within the app. You may also opt out of receiving emails and other messages from Zooma by following the instructions in those messages. Please note that if you opt out, we may still send you non promotional messages, such as receipts for your shifts or information about your account.

Children’s Privacy

The Services is restricted to individuals eighteen (18) years of age and older and we do not knowingly collect personal information from children under the age of thirteen (13). If we are informed that a user is under the age of thirteen (13), we will immediately close that user’s account. Should you have knowledge that a Zooma user is under the age of thirteen (13), it is your duty to inform us immediately.

Updates To This Policy

SUMMARY

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the Zooma apps or through other means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.