ZENTO GLOBAL PRIVACY POLICY

Effective Date: 9 August 2026

1. WHO WE ARE
This Privacy Policy explains how Zento Global Solutions Pty Ltd, ABN 34 610 060 690, trading as Zento Global, collects, uses, stores and discloses personal information.

In this Policy, Zento Global, we, us and our refer to Zento Global Solutions Pty Ltd.

Our primary website is zentoglobal.com.

This Policy applies to personal information we collect through our website, programs, coaching and advisory services, digital platforms, events, forms, email communications, social media interactions and other dealings with you.

2. PRIVACY FRAMEWORK AND INTERNATIONAL APPLICATION
Zento Global operates internationally and is committed to handling personal information responsibly and in accordance with privacy laws which apply to our activities.

Depending on your location and our relationship with you, these laws might include:
a) the Australian Privacy Act 1988 (Cth) and Australian Privacy Principles
b) the European Union General Data Protection Regulation (EU GDPR)
c) the United Kingdom General Data Protection Regulation (UK GDPR) and applicable UK data protection legislation
d) applicable United States federal and state privacy and consumer protection laws
e) other privacy and data protection laws which apply to our activities.

Different rights and obligations apply in different jurisdictions. Where a privacy law gives you rights which apply to our handling of your personal information, we will respect those rights in accordance with that law.

3. PERSONAL INFORMATION WE COLLECT
Depending on how you interact with us, we might collect information including:
a) your name
b) email address
c) telephone number
d) business or organisation name
e) job title or role
f) billing or mailing address
g) transaction and purchase information
h) program enrolment and participation information
i) communications you send to us
j) responses to forms, surveys and questionnaires
k) coaching or program information you choose to provide
l) testimonials, reviews or feedback
m) website usage and analytics information
n) IP address, device, browser and technical information
o) marketing preferences
p) other information reasonably necessary to provide a requested product or service.

Payment card information is generally processed by third-party payment providers rather than stored directly by Zento Global.

4. SENSITIVE INFORMATION
Some interactions with Zento Global might involve information which is considered sensitive under applicable privacy law.

Where we collect sensitive information, we will only do so where reasonably necessary for our activities and with your consent or where otherwise permitted by law.

You should avoid providing sensitive personal information which is not relevant to the service you are receiving.

5. HOW WE COLLECT INFORMATION
We collect personal information in several ways, including when you:
a) visit our website
b) complete a website form
c) download a resource
d) subscribe to email communications
e) contact us
f) purchase a product or service
g) enrol in or participate in a program
h) attend coaching, workshops, webinars or events
i) participate in a Zento Global community
j) complete an assessment, questionnaire or survey
k) interact with us through social media
l) provide feedback or a testimonial.

We might also receive information from organisations which purchase services for their employees or participants, referral partners, publicly available business sources and technology providers where permitted by law.

Where practicable, you may interact with us anonymously or using a pseudonym. In some circumstances we need identifying information to provide a service, process a purchase, manage an account or respond effectively to your request.

6. WHY WE COLLECT AND USE PERSONAL INFORMATION
We use personal information for purposes including:
a) providing our products and services
b) administering programs and accounts
c) processing purchases and payments
d) communicating with clients, participants and prospective clients
e) providing customer support
f) delivering coaching and advisory services
g) personalising program or service delivery
h) operating our website and digital platforms
i) improving our products, services and customer experience
j) conducting research, analytics and business planning
k) marketing Zento Global products and services where permitted
l) managing events and communities
m) maintaining security and preventing misuse
n) complying with legal and regulatory obligations.

7. WEBSITE DATA, COOKIES AND ANALYTICS
Our website and technology providers might use cookies and similar technologies.

These technologies help us:
a) operate website functionality
b) understand website usage
c) measure website and marketing performance
d) improve user experience
e) remember preferences
f) support advertising and marketing activities where permitted.

Depending on our technology configuration, information might be processed by services such as Kajabi, Google analytics services, Meta services or other technology providers.

You may control cookies through available website consent tools and your browser or device settings where applicable.

8. LAWFUL BASES FOR PROCESSING UNDER EUROPEAN AND UK PRIVACY LAW
Where the EU GDPR or UK GDPR applies, we process personal data only where we have an appropriate lawful basis.

Depending on the circumstances, our lawful bases include:

Contract
We process personal data where necessary to enter into or perform a contract with you. This includes administering purchases, program enrolments, coaching engagements, accounts, payments, customer support and delivery of products and services.

Consent
We rely on consent where appropriate, including for certain marketing, cookies, tracking technologies or processing of information requiring consent.
Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing which occurred before consent was withdrawn.

Legitimate Interests
We process personal data where necessary for our legitimate business interests and where those interests are not overridden by your rights and interests.
These interests might include:
a) operating and improving our business
b) communicating with existing clients and business contacts
c) understanding how our website, products and services are used
d) improving our programs, services and customer experience
e) maintaining the security of our systems and platforms
f) preventing fraud or misuse
g) conducting appropriate business analytics
h) developing and managing client relationships
i) marketing our products and services where permitted by applicable law.
Where required, we assess our legitimate interests against the impact of processing on individuals.

Legal Obligation
We process personal data where necessary to comply with legal, regulatory, taxation, accounting or other obligations applying to Zento Global.

Other Lawful Bases
In limited circumstances, another lawful basis permitted by applicable privacy law might apply.
Where we process special category or sensitive personal information, we will also identify an appropriate additional legal basis where required.

9. DIRECT MARKETING AND ELECTRONIC COMMUNICATIONS
Where permitted by law, we might use your contact information to send information about Zento Global content, products, services, events and offers which we believe are relevant to you.

We send marketing communications in accordance with the laws applicable to the recipient and the communication.

Where consent is legally required before sending marketing communications, we will obtain the required consent.

Where applicable law permits marketing on another basis, including an existing customer relationship or legitimate interests, we might rely on that basis subject to applicable requirements.

You have the right to opt out of Zento Global marketing communications at any time.

Every marketing email will provide an appropriate unsubscribe mechanism.

We will honour valid marketing opt-out requests and maintain suppression information where necessary to ensure we do not inadvertently resume marketing to someone who has opted out.

Unsubscribing from marketing does not prevent us from sending transactional, account, service or other communications reasonably necessary for an existing relationship with you.

10. HOW WE DISCLOSE PERSONAL INFORMATION
We do not sell or rent your personal information.
We might disclose personal information where reasonably necessary to:
a) technology and hosting providers
b) payment processors
c) email and communications providers
d) analytics and marketing technology providers
e) professional advisers
f) contractors or service providers assisting us in operating our business
g) facilitators or service providers involved in delivering a product or service
h) regulators, courts, government authorities or law enforcement where legally required
i) another party in connection with a business sale, restructure or transfer where permitted by law.
We take reasonable steps to limit disclosures to what is necessary for the relevant purpose.

11. THIRD-PARTY PLATFORMS
Our business uses third-party technology to provide website, learning, communications, payment, analytics, videoconferencing and other functions.

When you interact directly with a third-party service, its own privacy policy and terms might also apply.

We select service providers with regard to their role, security and suitability, but their systems and privacy practices are governed by their own policies.

12. INTERNATIONAL DATA TRANSFERS
Zento Global is based in Australia and operates internationally.

Your personal information might therefore be transferred to, accessed from or stored in countries other than the country in which you live.

Our technology and service providers might also process information in Australia, the United States, Europe and other jurisdictions in which they or their infrastructure operate.

Where the EU GDPR or UK GDPR applies to an international transfer of personal data, we will use an appropriate transfer mechanism where required.

Depending on the circumstances, this might include:
a) an applicable adequacy decision or regulation
b) approved standard contractual clauses or equivalent contractual safeguards
c) another legally recognised transfer mechanism
d) a permitted derogation applying to a specific transfer.

Where Australian privacy law applies, we will take reasonable steps required under Australian law in relation to overseas disclosure of personal information.

You may contact us if you require further information about safeguards applying to an international transfer of your personal information.

13. ARTIFICIAL INTELLIGENCE
Zento Global uses artificial intelligence tools to support selected business activities.

AI might assist with activities such as research, content development, analysis, summarisation, administrative processes, customer support and improvement of our products and services.

We remain responsible for our use of AI systems and apply human oversight appropriate to the activity.

We do not intentionally provide AI systems with personal or confidential information where it is unnecessary for the relevant task.

Where personal information is processed using an AI-enabled service, we treat that processing in accordance with this Privacy Policy and applicable privacy obligations.

As at the effective date of this Policy, Zento Global does not use automated decision-making systems to make decisions which significantly affect an individual's legal rights or interests without appropriate human involvement.

If our use of automated decision-making changes, we will update this Policy as required by applicable law.

14. SECURITY
We take reasonable technical, organisational and administrative steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

No online system or method of electronic storage is completely secure. We therefore do not guarantee absolute security.

15. DATA BREACHES
Where we become aware of a data breach involving personal information, we will assess and respond to the incident in accordance with applicable privacy and data breach laws.

Where notification to affected individuals or a regulator is legally required, we will provide the required notification.

16. DATA RETENTION
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, for legitimate business requirements, or as required by law.

When personal information is no longer required, we take reasonable steps to delete, destroy or de-identify it where appropriate.

17. ACCESS AND CORRECTION
You may request access to personal information we hold about you and ask us to correct information which is inaccurate, out of date, incomplete, irrelevant or misleading.

We might need to verify your identity before processing a request.

There are circumstances in which applicable law permits us to refuse access. If this occurs, we will provide the reasons required by law.

18. RIGHTS OF PEOPLE IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM
Where the EU GDPR or UK GDPR applies to our processing of your personal data, you have rights which might include the right to:
a) obtain information about how we process your personal data
b) request access to your personal data
c) request correction of inaccurate or incomplete personal data
d) request deletion of personal data in applicable circumstances
e) request restriction of processing
f) object to certain processing, including processing based on legitimate interests
g) object to direct marketing
h) withdraw consent where processing relies on consent
i) receive certain personal data in a portable format
j) request transmission of eligible data to another controller where applicable
k) obtain safeguards concerning significant decisions based solely on automated processing where applicable
l) lodge a complaint with an applicable data protection supervisory authority.

These rights are subject to limitations and exceptions under applicable law.

We might need to verify your identity before responding to a rights request.

You will not ordinarily be charged for exercising these rights. Applicable law permits fees or refusal in limited circumstances involving manifestly unfounded or excessive requests.

19. EUROPEAN AND UK REPRESENTATIVES
Where the EU GDPR or UK GDPR requires Zento Global to appoint a representative in the European Economic Area or United Kingdom, we will appoint the required representative and publish their contact information in this Privacy Policy.

The appointment of a representative does not affect Zento Global's responsibility for complying with applicable privacy law.

20. UNITED STATES PRIVACY RIGHTS
Zento Global provides products and services to customers in the United States.

Privacy rights in the United States vary by state and might depend on factors including our activities, revenue, the volume and type of personal information processed and our relationship with you.

Where an applicable US privacy law gives you rights in relation to personal information processed by Zento Global, we will honour those rights as required by that law.

Depending on the applicable law, these rights might include the right to:
a) know or confirm whether we process your personal information
b) access personal information
c) correct inaccurate personal information
d) request deletion of personal information
e) obtain a portable copy of certain personal information
f) opt out of certain forms of targeted advertising, sale or sharing of personal information where applicable
g) limit certain uses of sensitive personal information where applicable
h) appeal a decision concerning a privacy request where required by applicable law
i) exercise privacy rights without unlawful discrimination.

Zento Global does not sell personal information for monetary payment.

Where a US privacy law defines sale, sharing or targeted advertising more broadly, certain advertising or analytics technologies might fall within those definitions depending on how they are configured.

Where required by applicable law, we will provide an appropriate mechanism to opt out of those activities.

You may submit an applicable privacy request using the contact information in this Privacy Policy.

We will verify and respond to requests in accordance with the law which applies to the request.

21. OTHER INTERNATIONAL PRIVACY RIGHTS
If you live outside Australia, the European Economic Area, United Kingdom or United States, local privacy legislation might give you additional rights.

Where those laws apply to Zento Global's processing of your personal information, we will comply with applicable mandatory requirements.

You may contact us using the details in this Privacy Policy to exercise an applicable privacy right.

22. PRIVACY COMPLAINTS AND REGULATORY AUTHORITIES
If you believe we have mishandled your personal information, please contact us and provide enough information for us to understand and investigate your concern.

We will investigate privacy complaints and respond within the period required by applicable law or, where no specific period applies, within a reasonable period.

Depending on where you are located, you might also have the right to complain to an applicable privacy or data protection regulator.

In Australia, this is the Office of the Australian Information Commissioner.

If the EU GDPR applies, you might have the right to lodge a complaint with the competent supervisory authority in the European Economic Area.

If the UK GDPR applies, you might have the right to lodge a complaint with the UK Information Commissioner's Office.

If applicable US state privacy legislation applies, you might have rights through the relevant state regulator or Attorney General.

23. CHILDREN
Our products and services are primarily intended for adults and business users.

We do not knowingly collect personal information directly from children where doing so would be inconsistent with applicable law.

24. EXTERNAL LINKS
Our website or communications might link to websites operated by third parties.

We are not responsible for the privacy practices of independent third-party websites. You should review their privacy policies before providing personal information.

25. CHANGES TO THIS POLICY
We might update this Privacy Policy to reflect changes to our business, technology, practices or legal obligations.

The current version will be published on our website with its effective date.

 26. CONTACT US
For privacy enquiries, access or correction requests, rights requests, complaints or other questions about this Policy, contact:

Zento Global Solutions Pty Ltd
ABN 34 610 060 690
Trading as Zento Global

Website: zentoglobal.com

Effective Date: 9 August 2026
Privacy Policy v2.0