ZeroAvia, Inc. and its subsidiaries and affiliates (collectively, “ZeroAvia,” “we,” “us,” or “our”) respect and value your privacy. In this General Privacy Notice (“Notice”), we describe our information practices with respect to the ZeroAvia website that posts this Notice.

Information we, our service providers and/or third-party services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, and address (“Personal Information”); and (2) demographic information, such as your company name and details about the question or comment surrounding your inquiries (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Notice). In addition, Personal Information, once “deidentified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. To the extent any non-Personal Information is combined by or on behalf of us with Personal Information we collect directly from you we will treat the combined data as Personal Information under this Privacy Notice.

Generally, you may interact with us, including browsing through the site, without giving us any Personal Information about yourself. When you request information about our products, services, or events, you may voluntarily provide us with Personal Information, including your name, address, phone number and/or email address. We use the Personal Information that you provide to respond to your information requests regarding our services and may also use it for any other purposes not prohibited by applicable law or inconsistent with this Notice or representations made by us in writing at the time of collection. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice and to comply with our legal obligations.

We, our service providers, and/or third-party services may also automatically collect certain information about you when you access or use the site or otherwise contact us (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the site, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law (e.g., an IP address in certain jurisdictions), or to the extent Usage Information is combined by or on behalf of Personal Information that is subject to this Notice, we do not consider Usage Information (excluding, unique device identifiers) to be Personal Information subject to our description of data practices under this Notice and we reserve the right to collect, use, share and transfer Usage Information to the fullest extent not prohibited by applicable law or inconsistent with this Notice or representations made by us in writing at the time of collection.

In addition, ZeroAvia may collect and store the contents of those interactions that you’ve had with us. The cookies, tracking pixels, or similar now and hereafter known technologies or services (“Tracking Technologies”) on our site may collect Usage Information about your activities and interactions with us and the site. For instance, we may use third-party services, such as Google Analytics, that use Tracking Technologies to conduct analytics of our site, and we, our service providers and third-party services may automatically collect Usage Information about your use of the site, including the areas or pages of the site that you visit, the amount of time you spend using the site, the number of times you return, and other site usage data. This information helps us to track and understand how visitors use our site and improve the performance and user experience of our site. See below regarding certain choices you may have regarding these activities.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. Please be aware that if you disable or remove these technologies, some parts of the site may not work and that when you revisit the site your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

One way to potentially identify cookies on our website is to add the free Ghostery plug-in to your browser (www.ghostery.com) which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. We are not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Addon. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html. We are not responsible for the completeness or accuracy of these third-party tools or third-party choice notices or mechanisms.

ZeroAvia may disclose the Personal Information we collect from and about you for the following business purposes: (1) to our employees or third-party vendors, agents, service providers or contractors, if the disclosure will enable them to perform a business function for us; (2) to respond to legal process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (3) as otherwise described to you at the point of collection. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, then such information may be considered an asset of ours and may be sold or transferred to third parties.

The personal data that we collect from you will be stored on our servers inside the European Economic Area (“EEA”). Occasionally, we may have to transfer personal data outside of the EEA. By submitting your personal data, you agree to this transfer, storing or processing of data outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the GDPR and our data protection policies.

ZeroAvia has taken certain physical, administrative, and technical steps to safeguard the Information we collect from and about visitors to our site. While we seek to ensure the integrity and security of our network and systems, we cannot guarantee the security of the information you transmit to us. We encourage you to take precautions to protect your personal data when you are on the Internet.

The site may include hyperlinks to, or include on or in connection with, the site, websites, locations, platforms, applications or services operated by third parties (“third-party service(s)”). These third-party services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the site may permit interactions that you initiate between the site and certain third-party services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content between the site and a third-party service; “liking” or “sharing” our content; and to otherwise connect the site with a third-party service (e.g., to pull or push information to or from the site).

The information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on third-party services.

We are not responsible for, and make no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics service providers and third-party services associated with the site and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light law”) with third parties for their direct marketing purposes absent your consent. To opt-out of future sharing with third parties for their direct marking purposes, contact us privacy@zeroavia.com. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at privacy@zeroavia.com or by sending a letter to ZeroAvia (see contact us). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

California residents also may exercise the following rights under the California Consumer Privacy Act (CCPA):

• Up to two times each year, you may request that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, the categories of third parties with whom we have shared your personal information, any categories of personal information about you that we sold, and the business or commercial purpose for selling your personal information, if applicable.

• You may also request the following:
(i) that we delete personal information that we have collected from you, subject to certain exceptions;
(ii) that we correct inaccurate personal information that we have about you a business; and,
(iii) that we limit the use and disclosure of sensitive personal information collected about them.

To exercise your rights, you can contact us at privacy@zeroavia.com. If you exercise any of your rights, we will not discriminate against you, such as by denying you access to our services or restricting your access to products or services of a certain price or quality.

For purposes of compliance with the CCPA, we make the following disclosures:

• We collect the following categories of personal information: Identifiers, personal information described in Cal. Civ. Code 1798.80, internet or other electronic network activity information, commercial information, and inferences drawn from the preceding categories of personal information.

• We disclose the following categories of personal information for a business purpose: Identifiers, personal information described in Cal. Civ. Code 1798.80, Internet, or other electronic network activity information. We do not sell your personal information.

Protecting children’s privacy is important to us. We do not direct the sites to, nor do we knowingly collect any personal information from, children under the age of thirteen.

ZeroAvia may amend this Notice from time to time. When we do, we will post the change(s) on the site. In some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). However, we will not treat your previously collected Personal Information that is governed by this Notice, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent.

To the extent provided by the law of your jurisdiction, you may have the right to: (a) access certain Personal Information we maintain about you; (b) exercise your right to data portability; (c) request that we update, correct, amend, erase, or restrict your Personal Information; (d) withdraw your consent previously given; (e) request that we not share your Personal Information with third parties for ancillary or competing services; and/or (f) object at any time to the processing of your Personal Information on legitimate grounds relating to your particular situation. We will comply with such requests to the extent required by the applicable law of your jurisdiction, but may not accommodate a request if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may take steps to verify your identity before granting you access to your information. We may apply a charge, to the extent permitted by applicable law, before we provide you with a copy of any of your Personal Information we maintain. You may, depending on your location, have a right to file a complaint with a government regulator if you are not satisfied with our response.

If you have any questions that you would like to ask about this Notice, about our handling of the Information collected on our site, or with a request relating to the section entitled Choices Regarding Your Information, please contact us at privacy@zeroavia.com.

Last Updated: May 04, 2023