ZP Better Together Privacy Policy

Effective Date: January 1, 2023

CSDVRS, LLC, d/b/a ZVRS and Purple Communications, Inc. (divisions of ZP Better Together, LLC. hereinafter referred as “ZP”) is committed to protecting our users’ and visitors’ privacy. This policy explains how we collect, use, share, and disclose personal information about you when you interact with or use our websites, products, and services.

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, including via a device.

We may collect the following categories of personal information about you:

• Identifiers and similar information such as your name, address, phone number, date of birth, email address, IP address, online identifiers or other similar identifiers.
• Certain information protected under federal or state laws, including government identification documents like a driver’s license, a signature, or financial information.
• Characteristics of protected classifications under federal or certain state laws, including gender or disability.
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, 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 data (e.g., the physical location from which you access ZP’s video relay services).
• Inferences drawn from any of the categories of information identified above to create a profile reflecting your preferences or similar characteristics, including information on your potential interest in new ZP products or services.

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, register for, or purchase a service or product offered by ZP; (ii) send an email, fill out online forms, participate in surveys, or engage in other transactions or interactions with ZP or our service providers; 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 (e.g., IP addresses) through cookies or other Web devices. We also may collect personal information from other sources as permitted by law, including our affiliates, regulatory authorities, third parties we interact with to provide you services (e.g., a hospital or other institution that uses our services at your direction to facilitate your care), or public websites or publicly available sources like government records.

In order to access certain ZP services, including video relay 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 in registration form(s) and when you use our products or services: your name, your address(es) (i.e., physical location from where you access ZP services), your date of birth, the last four digits of your social security number, 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 is known as Customer Proprietary Network Information (“CPNI”).

3. Purposes for Collecting and Using Personal Information

ZP 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 for editorial and feedback purposes, for marketing and promotional purposes, to inform advertisers as to how many visitors have seen or clicked on their advertisements, and to customize the content and layout of ZP’s website. 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. ZP may also use personal information in connection with federal or other legal requirements, such as responding to a subpoena or court order, providing information as required by Federal Communications Commission (“FCC”) regulations, or providing information for purposes of emergency communications. Aggregate data on home servers may be used for internal purposes or provided to third parties such as advertisers.

Personal information which visitors voluntarily provide to ZP (e.g., names, postal and email addresses, phone numbers) may be added to ZP’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, “Use of Customer Proprietary Network Information.”

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 affiliates, meaning entities that are directly or indirectly controlled by us or who share common control with us, for the purposes detailed and subject to the limitations in this 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 video relay products and services; (ii) install, maintain and repair our products and services; (iii) offer you additional video relay features and services of the type you already registered for with ZP; (iv) process 911 calls; or (v) process information on our behalf. These authorized third parties have agreed to certain confidentiality protections.

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

5. Use of Cookies

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, additional detail provided below in Section 6. 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. Analytics and Advertising Information

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 control or limit the collection of your information through these tools by changing the settings on your browser or device, as specified above in Section 5. [You can find out more information about Google Analytics cookies here 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. You can also control which ads you receive on Facebook through your Facebook settings, available here.]

7. Links to Other Website

ZP 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 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 is not responsible for the privacy or security practices or the content of non-ZP websites, services, or products.

8. Reasonable Security Measures

ZP 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.

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

CPNI is information that ZP and other relay providers obtain when providing customers with relay service. CPNI includes the types of relay a customer uses, the amount of relay calls made, and the location of those calls.

ZP will access, use, share, or disclose CPNI under the following limited circumstances: (i) to provide you with video relay service and phones; (ii) to process 911 calls; (iii) for installation, maintenance and repair of our products and services; (iv) to offer you additional video relay features and services of the type you already registered for with ZP; (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.

ZP and its affiliates may also use your CPNI to offer you products and services that may be different from the types of services you already use. ZP asks for your consent to do this during your registration process. Your denial or approval will not affect ZP’s provision of video relay 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 TRS provider the right to use, disclose, or permit access to customer CPNI for certain marketing purposes. TRS providers have a duty under federal law to honor your right to do so and to protect the confidentiality of CPNI.

If you wish to restrict ZP’s use of your CPNI for marketing purposes, you may do the following:

For Purple.

a) Login at https://account.purplevrs.com/

b) Go to the Email & Password section of your User Profile; and

c) Uncheck the CPNI Opt-in checkbox.

Alternatively, you may contact ZP Customer Experience Team (CET) at 1-877-885-3172

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

Visitors may opt out of having their personal information collected by ZP disclosed to third parties, or used by ZP or third parties to send promotional correspondences to the visitor, by contacting ZP via postal mail, email at the addresses below, or telephone 1-877-885-3172, or by checking the appropriate “opt-out” box in the Purple User Profile page. Upon request via postal mail, email, or phone, ZP will provide to visitors a summary of any personal information retained by ZP regarding the visitor. Visitors may modify, correct, change or update their personal record or cause their personal record to be removed from ZP’s database. ZP will only send personal records to the email address on file for the visitor name associated with it. Visitors may also submit request to opt-out via postal mail at: ZP Better Together, 11900 N. Jollyville Road #204209, Austin, TX 78759 Attn: Marketing Department or email at marketing@purple.us

11. Collection of Personal Information from Children

ZP does not knowingly solicit or collect personal information from individuals under the age of 18 without parental consent. If you are under the age of 18, you are not authorized to register for ZP’s services, or submit any other information to us, via our website.

If you are the parent or guardian of a deaf or hard of hearing child under the age of 18 who wishes to use ZP’s products or services, you may register on behalf of your child via our website. After you provide the required registration information, you will receive an email with information regarding your child’s registration. The email will provide instructions for how to verify that you have provided registration information on behalf of your child and that you consent to the collection of certain personal information from your child.

As described further in the email, to provide such verification and consent, you must participate in a live videoconference with a CET representative. You will be required to provide a government-issued photo identification to identify yourself. The email will also provide instructions for how you can delete your child’s registration profile, if you would like.

ZP may collect personal information from your child when necessary to allow your child to use our services and for us to provide associated support, including: first and last name; date of birth; IP address; information necessary to complete or receive a call, including the telephone number your child is calling or the telephone number your child receives the call from; and the date, time, and length of each call. Through this Privacy Policy, ZP is giving you notice that, if you provide consent through the process outlined above, ZP will collect personal information from your child. ZP is located and can be reached at: 11900 N. Jollyville Road #204209, Austin, TX 78759 and can also be reached by phone at 1-877-885-3172 or by email at compliance@purple.us

ZP will not condition your child’s use of ZP’s products and services on your consent to data collection beyond what is reasonably necessary for ZP to provide its products and services to your child. ZP’s products and services do not allow children to make their personal information publicly available.

ZP may use personal information that it collects from your child to provide video relay service support and to allow your child to use our services, such as completing and receiving calls and maintaining a contact list. ZP may also use personal information it collects from your child in connection with federal or other legal requirements, such as responding to a subpoena or court order, providing information as required by FCC regulations, or providing information for purposes of emergency communications.

You have the right to ask ZP to allow you to review information ZP has collected about your child, to stop collecting personal information about your minor child, or to delete information it has on file about your minor child at any time. You may exercise these rights by contacting CET at 1-877-885-3172. ZP will comply with your request within a reasonable time.

12. Rights and Information Applicable to California Residents

If you are a California resident, please review the following information about your potential rights with regard to your personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident employed by ZP or providing service to ZP as an individual contractor or applying for a job with ZP, please review the following information about your potential rights with regard to your personal information under the California Privacy Rights Act (CPRA). The CPRA amends the CCPA to extend the privacy rights to employees, individual contractors and job applicants (hereinafter “worker”). 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 and CPRA. Under the CCPA and CPRA, ZP 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 and CPRA.

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

• In the preceding 12 months: (i) we may have collected all or some of the categories of personal information listed above in Section 1, and (ii) we may have disclosed all or some of the same categories listed in Section 1 for a business purpose.

• We may collect personal information from all or some of the categories of sources listed in Section 2.

• We may collect and use personal information for the business or commercial purposes listed above in Section 3.

• We may share personal information with the categories of third parties listed in Section 4

• We do not sell your personal information. We do work with certain partners that provide us with advertising services that may use cookies or other tracking technologies, as described in more detail above in Section 6.

• We may disclose your personal information to our service 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 or maintained, subject to certain exceptions (“request to delete”). We reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you, where permitted by the CCPA or CPRA or where another law or regulation is applicable. We may retain your personal information if doing so is necessary for us or our service providers to, for example:

• Maintain your access to and usage of video relay services.

• Comply with a legal obligation, for example California Labor Code Section 1198.5 requires business to retain certain records for three years after the worker’s termination.

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

• Complete a transaction for which we collect the personal information, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.

• Use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

• To maintain relationship with a worker as part of duties and responsibilities.

(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 whom 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) Request that we correct inaccurate personal information about you as a worker. When evaluating the accuracy of the personal information at issue, a business must consider the “totality of the circumstances” relating to the contested personal information and use “commercially reasonable efforts” if corrections are necessary. We may require the worker to provide documentation supporting the requested correction and may delete the information instead of correcting it if deletion does not negatively impact the worker.

(5) Request to limit disclosure and use of the workers’ sensitive personal information to the uses that an average worker would expect are reasonably necessary to maintain the worker relationship. Sensitive personal information is a new category of information in the CPRA that includes the processing of biometric information for the purpose of uniquely identifying the worker, personal information collected and analyzed concerning a worker’s health, sex life, or sexual orientation, and any personal information that reveals certain private information including a worker’s social security, driver’s license, state identification card, or passport number; financial account information and access credentials, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of a worker’s communications, or genetic data. This limitation only applies to businesses that collect and use sensitive personal information to infer characteristics about workers.

(6) Not be discriminated or retaliated against because you exercised any of your rights under the CCPA or CPRA.

The CCPA and CPRA do not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA and CPRA do 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 or CPRA Request

California resident users or visitors may submit requests to know or requests to delete through the following toll-free telephone number CET at 1-877-885-3172, or via email at compliance@purple.us.

California workers may submit requests to know, to delete, to correct information or to limit use and disclosure of information by email at compliance@purple.us.

We are required to provide certain information or delete personal information only in response to verifiable requests made by you or your legally authorized agent. We may need to request specific information from you or your agent to help us confirm your identify or your agent’s authorization to act on your behalf and ensure your right to access the requested information. Any information gathered in this process will be used for verification purposes only.

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 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.

13. ZP’s Right to Contact Users

ZP 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.

14. ZP’s Right to Change this Privacy Policy

The foregoing policy was last updated and is effective as of January 1, 2020. ZP 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.

15. Contact Information

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