Privacy Notice

Effective date: September 3, 2026  
Last updated: September 3, 2026

This Privacy Notice explains how Zentera Systems, Inc. ("Zentera," "we," "us," or "our") collects, uses, discloses, and retains personal information, and describes the rights available to you and how to exercise them. It applies to personal information we collect through www.zentera.net and its subdomains (the "Site"), our marketing and sales activities, our customer and partner portals, our support channels, and events we host or attend.

This notice does not cover:

• Customer data processed by our products. When a customer deploys the CoIP Platform, Ensage AI, or related Zentera products, the customer controls any personal information that transits or is processed by those products. We process that data as a service provider or processor under the customer's agreement, and the customer's own privacy notice governs.
• Job applicants, employees, and contractors. A separate notice at collection is provided during the application and onboarding process.

1. Personal Information We Collect

The table below lists the categories of personal information we have collected in the preceding 12 months, using the categories defined in California Civil Code section 1798.140. We collect this information directly from you, automatically from your device when you use the Site, and from third parties such as business partners, event organizers, data enrichment providers, and publicly available sources.

We do not collect sensitive personal information as defined by the CCPA (for example, government identifiers, precise geolocation, account credentials with access codes, racial or ethnic origin, health data, or biometric data) through the Site. If you submit such information to us voluntarily, we use it only for the purpose for which you provided it.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

2. How We Use Personal Information

We use personal information for the following purposes:

• To operate, secure, and improve the Site and our services
• To respond to demo, trial, contact, and support requests
• To enter into and perform contracts with customers and partners, including licensing, billing, and support
• To send product updates, security notices, and service communications
• To send marketing communications, subject to your right to opt out
• To manage events, webinars, and partner programs
• To measure the effectiveness of our marketing, including through analytics and advertising cookies
• To detect, prevent, and investigate fraud, abuse, and security incidents
• To comply with legal obligations and enforce our agreements

We do not use personal information for automated decision-making that produces legal or similarly significant effects on you.

3. How We Disclose Personal Information

We disclose personal information for business purposes to the following categories of recipients:

• Service providers and processors that act on our instructions, including providers of website hosting and content management, CRM and marketing automation, email delivery, web analytics, customer support, conferencing, cloud infrastructure, and professional services. Our current providers include HubSpot (website hosting, marketing automation, and email), Salesforce (CRM), Google (Google Analytics and Google Tag Manager), and LinkedIn (Insight Tag for advertising measurement).
• Channel and technology partners when you request engagement through a partner, purchase through a partner, or attend a co-hosted event.
• Affiliates under common control with Zentera, for the purposes described in this notice.
• Advertising and analytics providers that set cookies or similar technologies on the Site. This disclosure may constitute "sharing" under the CCPA. You can opt out as described in Section 5.
• Professional advisors such as lawyers, auditors, and insurers.
• Government authorities and other parties when required by law, subpoena, or legal process; to protect the rights, property, or safety of Zentera, our customers, or others; or to enforce our agreements.
• Successors in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case we will provide notice before your personal information becomes subject to a different privacy notice.

We do not sell personal information for monetary consideration.

4. Cookies and Tracking Technologies

The Site uses cookies, pixels, tags, and similar technologies operated by us and by third parties. They fall into the following groups:

• Strictly necessary. Required for the Site to function, including security, load balancing, and recording your cookie preferences.
• Functional. Remember choices such as language or form pre-fill.
• Analytics. Measure Site traffic and usage. Providers are Google Analytics and HubSpot.
• Advertising. Measure campaign performance and support interest-based advertising on LinkedIn. Provider is the LinkedIn Insight Tag.

Third-party tags on the Site are deployed through Google Tag Manager, which itself does not set cookies but loads the analytics and advertising tags listed above according to your cookie preferences.

You can accept or decline non-essential cookies through the cookie banner presented on your first visit, and you can change your choices at any time through the Your Privacy Choices link in the Site footer. A full list of cookies with their providers and lifetimes is available in the cookie preferences panel. Blocking cookies may affect Site functionality.

Opt-out preference signals. The Site recognizes Global Privacy Control (GPC) signals. If your browser or extension sends a GPC signal, we treat it as a request to opt out of the sale or sharing of personal information associated with that browser. We do not respond to "Do Not Track" signals, which have no common industry standard.

5. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information. We extend the rights to know, correct, and delete to all individuals whose personal information we hold, regardless of residence.

• Right to know / access. Request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, the categories of third parties to whom we have disclosed it, and whether we have sold or shared it. By default we provide information covering the preceding 12 months; you may request information about earlier periods (for data collected on or after January 1, 2022) unless doing so would be impossible or involve disproportionate effort.
• Right to correct. Request correction of inaccurate personal information.
• Right to delete. Request deletion of your personal information, subject to exceptions such as completing a transaction, security and fraud prevention, and legal compliance.
• Right to opt out of sale or sharing. Direct us not to sell your personal information or share it for cross-context behavioral advertising. We do not sell personal information. To opt out of sharing through advertising cookies, use the Your Privacy Choices link or enable GPC in your browser. Opt-outs made through cookie controls are browser-specific.
• Right to limit use of sensitive personal information. We do not use sensitive personal information for purposes that would trigger this right.
• Right to data portability. Receive the personal information you provided to us in a portable and readily usable format.
• Right to opt out of marketing. Unsubscribe from marketing email using the link in any message, or contact us. We may continue to send transactional and service communications.
• Right to non-discrimination. We will not deny services, charge different prices, or provide a different level of service because you exercised a privacy right.

5.1 California residents (CCPA/CPRA)

California residents have the rights listed above under the California Consumer Privacy Act as amended by the California Privacy Rights Act. Section 1 of this notice serves as our notice at collection and describes the categories of personal information collected, the purposes, and the retention periods. We do not offer financial incentives in exchange for personal information.

California Civil Code section 1798.83 (the "Shine the Light" law) permits California residents to request information about disclosure of personal information to third parties for those parties' direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

5.2 Residents of other US states

Residents of states with comprehensive consumer privacy laws (including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) may have rights to access, correct, delete, and port personal information, to opt out of targeted advertising, sale, and certain profiling, and to appeal a denied request. Where those laws apply to Zentera, you may exercise these rights using the methods in Section 6. If we deny your request, you may appeal by replying to our response with the word "Appeal" in the subject line. We will respond to appeals within 45 days (60 days for Colorado and Connecticut residents), and if the appeal is denied, we will tell you how to contact your state attorney general.

5.3 Residents of the European Economic Area, United Kingdom, and Switzerland (GDPR)

Zentera is the controller of personal information described in this notice. We process personal information on the following legal bases: performance of a contract or pre-contractual steps at your request; our legitimate interests in operating and marketing our business, securing our systems, and managing customer and partner relationships; your consent, where required (for example, non-essential cookies and certain marketing); and compliance with legal obligations.

In addition to the rights listed above, you have the right to object to processing based on legitimate interests, to restrict processing in certain circumstances, and to withdraw consent at any time without affecting the lawfulness of prior processing. You also have the right to lodge a complaint with your local data protection authority.

Personal information is processed in the United States and in other countries where we or our service providers operate. Where we transfer personal information from the EEA, UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable) or other lawful transfer mechanisms. You may request a copy of the relevant safeguards by contacting us.

6. How to Submit a Privacy Request

You may exercise any of the rights described in Section 5 by any of the following methods:

• Web form: www.zentera.net/privacy-request
• Email: privacy@zentera.net
• Mail: Zentera Systems, Inc., Attn: Privacy, 1525 McCarthy Blvd, Ste 222, Milpitas, CA 95035

What to include. Tell us which right you are exercising, the email address or other identifier associated with your relationship with Zentera, and enough information for us to verify your identity and locate your records.

Verification. We verify requests to know, correct, and delete by matching the information you provide against information we already hold, typically by confirming control of the email address on file. We may ask for additional information where the request concerns specific pieces of personal information or where the risk of harm from an incorrect disclosure is higher. We will not require you to create an account. Requests to opt out of sale or sharing do not require verification.

Authorized agents. You may designate an authorized agent to submit a request on your behalf. We will require the agent to provide your signed written permission and may require you to verify your identity directly with us. Requests submitted under a power of attorney under California Probate Code sections 4121 to 4130 do not require additional authorization.

Timing. We will confirm receipt of a request to know, correct, or delete within 10 business days and respond within 45 days. If we need more time, we will notify you and may extend the period by up to an additional 45 days. We will process opt-out requests within 15 business days. Requests are free of charge unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline the request and explain why.

Requests from customer end users. If your personal information is processed by a Zentera product deployed by one of our customers, please direct your request to that customer. We will assist the customer in responding as required by our agreement with them.

7. Retention

We retain personal information for as long as necessary to fulfill the purposes described in this notice, to comply with legal, accounting, and reporting obligations, to resolve disputes, and to enforce our agreements. Category-specific retention periods are set out in Section 1. When personal information is no longer needed, we delete or de-identify it.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, appropriate to the nature of the information and the risks involved. No transmission or storage method is completely secure, and we cannot guarantee absolute security.

9. Children

The Site is intended for business users and is not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, contact us and we will delete it.

10. Third-Party Sites

The Site may link to websites and services that we do not operate. Their privacy practices are governed by their own notices, and we are not responsible for them.

11. Changes to This Notice

We may update this notice from time to time. We will post the revised notice on this page with a new effective date, and, where changes are material, provide additional notice through the Site or by email. Your continued use of the Site after the effective date constitutes acceptance of the revised notice to the extent permitted by law.

12. Contact Us

Zentera Systems, Inc.
Attn: Privacy
1525 McCarthy Blvd, Ste 222, Milpitas, CA 95035
Email: privacy@zentera.net
Phone: +1 408 436 4811

If you have a disability and need this notice in an alternative format, contact us using the information above.