Without limiting the foregoing and notwithstanding any rights of publicity, privacy or otherwise (whether or not statutory) anywhere in the world, and without any further compensation or right to review or approve any use permitted herein, we may and are hereby authorized to use audio and/or photos and/or visual recording media (and other data) make in compliance with this Privacy Policy (including any voice, image, likeness and appearance) in whole or in part, with or without modification, in connection with providing the Services, training and quality assurance, purposes and improving our Services offerings via streaming, Internet communications and/or mobile communications.

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4. WILL ZESTA SHARE ANY OF THE PERSONAL DATA?

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We do not rent or sell your Personal Data in personally identifiable form to anyone. We may share your Personal Data with third parties as described in this Privacy Policy. 

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De-identified Data. We may de-identify (anonymize) your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide statistical information and/or aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience. However, we never disclose statistical information and/or aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

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Advertisers. In using our Services, Users agree to provide any of the information we have collected from it in non-personally identifiable form to an advertiser, so that the advertiser is able to select the appropriate audience for those advertisements and/or offers. Or, we might allow advertisers to display their ads to Users with similar usage patterns to yours, but we will not disclose usage information to advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach. We may conduct advertising campaigns on third party websites and applications (e.g., Instagram, Facebook, Google, etc.) (collectively, “Third Party Platforms”). In those cases, we may disclose your information in personally identifiable form to the operators of the Third Party Platforms solely to allow them to direct our advertising content to you via the Third Party Platform. 

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Business Partners. In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). Users are able to clearly recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to that transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

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Agents and Contractors. We employ or contract other companies and/or people to perform tasks on our behalf and need to share your information with them to provide products or services to you. For example, we may use a data hosting service provider to store your information and make it available to use for our Services. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them, beyond what is necessary to assist us.

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Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.

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Protection: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary in response to a lawful request by public authorities, including to meet national security or law enforcement requirements; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of our employees, our members, or others.

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5. SOCIAL NETWORKING SERVICES 

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You may sign up and/or log in to your account directly with our App, or through a social networking service (“SNS”). If you sign up via SNS, we will collect certain information about you from that social networking (e.g., Instagram, Facebook, Google, Apple, etc.), depending on your privacy settings with that relevant social networking. 

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If you choose to sign-up and/or log in to your account via an SNS, we will use the Personal Data you have provided to the SNS (such as your name, email address and/or other information you make publicly available via the SNS) to create your account and/or to provide you with our Services and/or our App. 

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If you sign up and/or log in to your account via SNS, you hereby authorize us to collect your Personal Data and/or other information available through your SNS account, including the following information:

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• Facebook: If you sign-up and/or log in using Facebook, Facebook will ask your permission to share certain information from your Facebook account with Zesta. This includes your Facebook user ID, first name, last name, email address (optional), gender, locale, time zone, birthday and profile picture. This information is collected by Facebook and is provided to Zesta under the terms of Facebook’s Privacy Policy. You can control the information that you receive from Facebook using the privacy and data settings in your Facebook account.

 

• Google: If you sign up and/or log in using Google, Google will ask your permission to share certain information from your Google account with Zesta. This includes your Google email address, birthdate (optional), gender (optional), and avatar (optional). This information is collected by Google and is provided to us under the terms of Google’s Privacy Policy. You can regulate the information that we receive from Google by using your Google activity controls. 

 

• Apple: You may also sign-up and/or log in using your Apple-ID. When you sign up and/or log in using your Apple-ID, Apple will ask your permission to share certain information from your Apple account with Zesta. This includes your Apple email address, birthdate (optional), gender (optional), and avatar (optional). This information is collected by Apple and is provided to us under the terms of Apple’s Privacy Policy. You can regulate the information that we receive from Apple using your Apple-ID settings.
   

You represent that you are entitled to use your SNS account for the purposes described herein, without any breach by you of any of the terms and conditions that govern your relationship with the relevant SNS. Please note that your relationship with any SNS is governed solely by the terms, agreements and/or policies of such SNS. Other than what we may share with, or obtain from the SNS (as described herein), the Personal Data the SNS has about you is obtained by the SNS independent of our Service, and Lingopie is not responsible for it. If your SNS account terminates, then functions enabled through the link between your account and your SNS account will terminate as well.

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6. TRANSFERS OF PERSONAL DATA TO A THIRD COUNTRY OR AN INTERNATIONAL ORGANIZATION

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For Users located in the European Economic Area (EEA), all processing of Personal Data is performed in accordance with privacy rights and regulations following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").

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Personal Data about you may be transferred to a third country (i.e., jurisdictions outside the EEA) or to international organizations. In such circumstances, the Company shall take any reasonable efforts to safeguards aimed to ensure the protection of Personal Data about you and provide that enforceable data subject rights and effective legal remedies for data subjects are available. 

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These safeguards and protection will be available if any of the following are met:

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1. The transfer is to a third country or an international organization which the EU Commission decided that they provide an adequate level of protection to the Personal Data that is transferred to them pursuant to Article 45(3) of the GDPR;
    

2. The transfer is according to legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
    

3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR; the clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. 

You may request the Company to be provided with details concerning the safeguards employed by it to protect the Personal Data about you which is transferred to a third country or an international organization, by sending an email to the following address: Support@Zesta.ai.

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7. YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

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If you are a California resident, under the California Consumer Privacy Act of 2018 ("CCPA") you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

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1. What Personal Data we have about you. If you make this request, we will return to you: (1) The categories of Personal Data we have collected about you; (2) The categories of sources from which we collect your Personal Data; (3) The business or commercial purpose for collecting your Personal Data; (4) The categories of third parties with whom we share Personal Data; (5) The specific pieces of Personal Data we have collected about you; (6) A list of categories of Personal Data that we have disclosed for a business purpose, along with the category of any other company we shared it with.
   
   Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the Personal Data we collected about you in the previous 12 months.
    

2. To delete your Personal Data. If you make this request, we will delete the Personal Data we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your Personal Data, you may not be able to use certain functions that require your Personal Data to operate.
    

3. Non-sale of Personal Data. We don’t sell or rent your Personal Data to any third parties for any purpose. We do not sell your Personal Data for monetary consideration. However, under some circumstances, a transfer of Personal Data to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
    

8. SECURITY

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We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. 

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When disclosure of data to third parties is necessary and authorized, we ensure that these third parties guarantee the same level of data protection as that offered to them by us and require contractual obligations so that the data is exclusively processed as per the provisions of this Privacy Policy and with the required confidentiality and security.

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Please Note: We cannot guarantee that our security measures will prevent third-party ‘hackers’ from illegally obtaining information. We take all reasonable measures to prevent such breaches of security, but given the resourcefulness of cyber-criminals, we are unable to guarantee that our security is one hundred percent (100%) breach-proof. Users assume the risk of such breaches to the extent that they may occur despite our reasonable security measures.

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If a User has reason to believe that its interaction with us is no longer secure, it should immediately notify us.

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9. YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA 

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You are entitled to the following rights in respect of the Personal Data about you. The exercise of such rights will be via sending an email requesting to exercise your right to the following email address: Support@Zesta.ai. You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our Services’ features.

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• Right of access 
  You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, where that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) where Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer. 
  
  The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. 
  
  The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others, and therefore if the request will harm the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner. 
   

• Right to rectification
  You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right to have incomplete Personal Data about you completed, including by means of providing a supplementary statement. 
   

• Right to erasure
  You have the right to obtain from the Company the erasure of Personal Data about you where one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to processing of the Personal Data which is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of the Personal Data for direct marketing purposes; (e) the Personal Data has been unlawfully processed; (f) the Personal Data has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.
  
  This right is not applicable to the extent that the processing is necessary: (a) for compliance with a legal obligation which requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise or defense of legal claims.
  
  Please Note: The Company reserve the right to erasure the Personal Data about you, at its sole discretion, when such information is no longer necessary or needed in relation to the purpose for which it was collected or otherwise or after a certain period the Company determined.
   

• Right of restriction of processing
  You have the right to obtain from the Company restriction of processing of Personal Data about you where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data; (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; (c) the Company no longer needs the Personal Data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; (d) where the processing of the Personal Data is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; (e) where the Personal Data is processed for direct marketing purposes, including profiling the extent that it is related to such direct marketing.
  
  Where processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. 
   

• Right to data portability
  You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Data to another controller, where: (a) the processing is based on your consent or on a contract to which you are a party; and (b) the processing is carried out by automated means. 
  
  In exercising your right to data portability, you have the right to have the Personal Data about you transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.
   

• Right to object
  You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you which is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests; in such case, we shall no longer process the Personal Data about you unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
  
  You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. 
   

• Right to withdraw consent
  You may withdraw your consent provided to us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal. Please note that in a case where you will withdraw your consent, we may not be able to provide you with some of our Products and/or Services.
  
  You may be able to add, update, or delete the information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any statistical information and/or aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.
   

10. LINKS TO THIRD PARTY WEBSITES AND/OR APPLICATIONS

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Certain links provided herein permit our users to leave the App, and enter non-Zesta sites, applications or services (which may include but shall not be limited to Instagram). Zesta is not responsible or liable for such linked sites, applications and services' privacy practices and/or any other practices. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. Those linked sites, applications and services are provided solely as a convenience to you. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

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11. CHANGES TO THIS PRIVACY POLICY

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As our Services improve, we may need to adjust this Privacy Policy from time to time. Whenever we do, we will alert you to changes by posting a notice online, notifying you by email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us, those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

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12. CONTACT US

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If you have any questions or concerns regarding our Privacy Policy, please send us a detailed message to Support@Zesta.ai, and we will try to resolve your concerns.

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Last Updated:  March 2025