Zephyr Cloud Corporation | zephyrcloud
Effective October 17, 2026 | Last updated October 17, 2026
This Privacy Notice ("Notice") governs Zephyr's collection and processing of Personal Data in the context of your interactions with Zephyr, including where you visit Zephyr's website ("Site"), receive marketing communications, do business with Zephyr on behalf of your organization, or are a user of a Zephyr service procured by your Organization and Zephyr collects and processes Personal Data related to your use of such service. For the purposes of this Notice, "Personal Data" means any information relating to an identified or identifiable individual. "Zephyr" in this Notice refers to the Zephyr Cloud Corporation processing your Personal Data. This Notice addresses Zephyr's own business processing. Customer-directed processing of service content is governed by the applicable customer agreement and DPA, and requests concerning that content should generally be directed to the customer organization.
1. What Information Does Zephyr Collect About You and Why?
Zephyr may ask you to provide Zephyr with Personal Data about yourself in order to provide services to you. Zephyr may collect the following categories of Personal Data about you:
Personal and business identifiers and contact information such as name, job title, company name, contact, shipping and billing information, phone number, email address, photographs, and contact preferences
Internet or other electronic network activity, i.e. technical data such as domain name, browser type and operating system, web pages you view; links you click; your device's IP address; login data e.g. username, account number, password; the length of time you visit Zephyr's Site; the URL or the webpage that led you to Zephyr's Site
Performance and usage data about your use of Zephyr's Services; information you provide to Zephyr to receive technical assistance or during customer service interactions; your interests, demographics, experience with Zephyr's Services, contact preferences and what you enter into any 'free text' boxes in Zephyr's forms;
Commercial information, i.e. transactional data including credit card and payment data, transaction history
Personal Data may be required to determine access eligibility for certain restricted parts of Zephyr's Site or services. Personal Data about you collected online may be combined with information provided off-line or collected from trusted third party sources.
Information Zephyr Collects Automatically, including via Cookies and Similar Tracking Technologies. Zephyr may automatically collect information about your use of Zephyr's Site, or services through cookies, web beacons, and other technologies. Zephyr may combine this information with other information that Zephyr has collected about you such as your user name. In addition, Zephyr may collect, modify and analyze metadata and/or operations data, such as system log files, configuration, performance, usage data and transaction counts, from Zephyr's software or systems hosting the Service, and from your organization's systems, applications, and devices that are used with the Service which relate to system utilization and performance statistics.
2. How Does Zephyr Use Your Information?
Zephyr uses the information collected about you as appropriate and relevant for the following commercial purposes:
to register you as a new customer
to enable you to order products or services, download software updates ("Products")
to provide services to you, including programs, online services and customer support
to allow you to make requests, and register for customized communications programs
to customize the content and information that Zephyr may send or display to you
for marketing and promotional purposes
to assist Zephyr in advertising Zephyr's products and services on third-party websites
to follow up with you after conferences and events
to post testimonials on Zephyr's online properties and, subject to your consent, to use your name with your testimonial
to interact on third-party social networks
to provide online communities and blogs
to facilitate the delivery of education and training
Such information may include among others, your name, location and business contact information, information related to the Services you are using, preferences you have selected while visiting the Site, message content and network identifiers related to contacting Zephyr or using the Site.
Sensitive Personal Data. Zephyr will only process any special categories of Personal Data ("Sensitive Personal Data") relating to you for specific purposes outlined above or in relevant supplemental notices, because either: (1) you have given Zephyr your explicit consent to process that information; (2) the processing is necessary to carry out Zephyr's obligations under applicable law; (3) the processing is necessary for the establishment, exercise or defense of legal claims; or (4) you have made the information public.
3. Legal Basis of Processing
In order to collect, use and otherwise process your Personal Data for the above listed commercial and business purposes, Zephyr may rely on the following legal bases as appropriate and relevant in the specific context:
Zephyr's legitimate interest in providing the Sites and making the Services available to you, provided Zephyr's interest is not outweighed by the risk of harm to your rights and freedoms
Your consent, where Zephyr has obtained your consent to process your Personal Data for certain activities. You may withdraw your consent at any time by using the contextual preference tools available in the communications or in the user interfaces of the products and services Zephyr provides to you. Absent those, please contact Zephyr as explained below. However, please note that your withdrawal of consent will not affect the lawfulness of any use of your Personal Data by Zephyr based on your consent prior to withdrawal
To fulfill any contractual obligations, such as where you have purchased a product or service from Zephyr. For example, Zephyr may require your contact details in order to deliver your order if you have purchased a product from Zephyr
For compliance with Zephyr's legal obligations where applicable laws require Zephyr to process your Personal Data
For fraud prevention and network and information security purposes when providing Services, pursuant to applicable privacy legislation and to the extent necessary and proportionate for preventing fraud and ensuring network and information security.
4. To Whom Does Zephyr Disclose Your Information And Why?
Zephyr may disclose Personal Data collected about you as follows: The categories below apply only where relevant to the actual interaction; they do not represent that Zephyr has subsidiaries, public forums, or a reseller program where none exists.
Site Visitors. Where a public posting feature is actually provided, your username and any information that you post to Zephyr's Site, including, without limitation, reviews, comments, pictures and text will be available to, and searchable by, all users of the Site.
Affiliates or Subsidiaries. Data Zephyr collects about you may be disclosed to Zephyr's affiliates or subsidiaries.
Unaffiliated Third Parties. Certain data about you may be disclosed to select resellers and/or distributors, particularly if you or your company have purchased through a third party before.
Service Providers. Data Zephyr collects about you may be disclosed to third party vendors, service providers, contractors or agents who perform functions on Zephyr's behalf.
Business Transfers. Personal Data Zephyr has collected about you may be transferred to another company as part of a merger, acquisition or divestiture by or of that company.
Consent. Zephyr may disclose your personal information to other recipients for any purpose with your consent.
Legal Obligations and Rights. Zephyr may disclose your Personal Data to any legally entitled recipients: (i) in connection with the establishment, exercise or defense of legal claims; (ii) to comply with laws or to respond to lawful requests or legal process; (iii) for fraud or security monitoring purposes (e.g., to detect and prevent cyberattacks); (iv) to protect the rights of Zephyr or its employees; or (v) as otherwise permitted by applicable law.
If Zephyr discloses your Personal Data, to the extent reasonably practicable and permissible, Zephyr will require its recipients to comply with adequate privacy and confidentiality requirements, and security standards. Personal data collected through and for the purposes of user-requested alerts and service notifications, including but not limited to short code text messages in the U.S. and Canada, will not be disclosed, shared, sold or rented to any affiliated or unaffiliated third parties for marketing purposes.
Cookies and preference mechanisms
Zephyr may use cookies and similar technologies as described in this Notice or any applicable supplemental cookie notice and in accordance with applicable consent and choice requirements. Although a company may not sell Personal Data for money, certain analytics or advertising arrangements can constitute sale or sharing under applicable law.
5. How Does Zephyr Secure Your Personal Data?
Zephyr has implemented administrative, technical, physical, electronic, and managerial procedures to safeguard and secure the information Zephyr collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction and to help maintain data accuracy and ensure that your Personal Data is used appropriately. Where Personal Data is processed by service providers on behalf of Zephyr, Zephyr requires appropriate contractual privacy, confidentiality, and security obligations for those service providers. However, despite these controls, Zephyr cannot completely ensure or warrant the security of your personal data.
6. How Long Does Zephyr Retain Your Personal Data?
Zephyr will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Notice and/or in applicable supplemental notices, unless a longer retention period is required by law. To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.
7. Your Rights
Depending on your country or state of residence you may have some or all of the rights described below with respect to your Personal Data.
Email and Marketing. In most instances, Zephyr gives you options with regard to the Personal Data you provide, including choices with respect to marketing materials. You may manage your receipt of marketing and non-transactional communications by: (i) clicking on the "unsubscribe" link in marketing emails; or (ii) contacting legal@zephyrcloud.com. Any additional preference center will be identified if made available.
Access. You may request information regarding Personal Data that Zephyr collects and holds about you and the source(s) of that information. To access your Personal Data, return to the product, service or web page where you originally entered it and follow the instructions in your user interface or on that web page. If you cannot access your information in this way, please contact Zephyr directly at legal@zephyrcloud.com.
Rectification. You have the right to request that Zephyr rectifies any inaccuracies in relation to the Personal Data Zephyr holds about you.
Erasure. In some circumstances, you have the right to request the erasure of your Personal Data or object to the further processing of your information.
Restriction of Processing. In some circumstances, you have the right to require Zephyr to restrict processing of your Personal Data.
Objection. You have the right to object to any direct marketing or to other processing of your Personal Data based on Zephyr's or on third parties' legitimate interests, unless such interests are compelling enough to override your objection.
Not to be discriminated against for exercising any of your other privacy rights. You may exercise any of your rights in this section without Zephyr discriminating against you in any way. Note however that you may be subject to differentiated treatment if and to the extent that the exercise of your rights materially impacts Zephyr's ability to provide certain services to you (e.g. if you request the deletion of your account information or access credentials, Zephyr may no longer be able to grant you access to restricted areas of Zephyr's websites). Such differentiated treatment is objectively justified and does not constitute discrimination.
Withdraw Consent. Where Zephyr relies on your consent, you may have the right to withdraw consent to Zephyr processing your Personal Data. This will not affect the processing already carried out with your consent.
Not to be subject to decisions based on automated processing. In some circumstances, you have the right not to be subject to decisions based solely on automated processing, and to obtain the human review of any such decisions that significantly affect you.
Complain. If you have a complaint, Zephyr would appreciate the chance to address your concerns; please contact Zephyr at legal@zephyrcloud.com. You may also lodge a complaint with the supervisory data protection authority in the state where you live, work or where an alleged infringement of applicable data protection law occurred.
Change or deletion of information. Please note that if you request a change to or deletion of your Personal Data, Zephyr may still need to retain certain information for record-keeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Data provided until after the completion of such purchase). Some of your information may also remain within Zephyr's systems and other records where necessary for compliance with applicable law.
Copies. You can request a copy of any Personal Data Zephyr holds about you, and of which you don't already have a copy. This service is usually free of charge, although Zephyr has the right to charge a 'reasonable fee' in some circumstances. Any fee must be permitted by applicable law; mandatory free requests remain free.
8. How Are Cross-Border Transfers of Data Performed?
Personal Data may be stored, accessed, or processed across state, regional, or national borders as needed to provide our services and support business operations. Zephyr will comply with all applicable local, regional, national, and other governmental privacy and data-protection laws and regulations governing such processing and transfers, including any required safeguards, notices, consents, or restrictions. Any agreed contractual data-location requirements also apply.
9. What Choices Do You Have Regarding Zephyr's Use Of Your Personal Data?
Zephyr will not use or disclose your Personal Data in ways unrelated to the ones described above without first notifying you and offering a choice, unless Zephyr reasonably considers that Zephyr needs to use it for another reason and that reason is compatible with the original purpose. Please note that Zephyr may process your Personal Data without your knowledge or consent where it is required, or to the extent it is permitted by law.
Zephyr will provide you the opportunity to opt out of certain Zephyr communications. If you have any difficulty exercising your choices, please contact Zephyr.
10. How Can You Contact Zephyr?
You may exercise your rights as described in the "Your Rights" section above, or by visiting the contact pages on Zephyr's website.
If you have questions or concerns about this Notice, or the privacy practices relating to Zephyr's Site or services or wish to contact Zephyr, please contact Zephyr using the details below:
Company name: Zephyr Cloud Corporation (zephyrcloud)
Email address: legal@zephyrcloud.com
Postal address: 934 Harriman St, Great Falls, Virginia 22066, United States
11. What About Children?
Zephyr does not knowingly collect Personal Data relating to children. If you believe that Zephyr may have collected Personal Data from someone under the age of thirteen (13), or under the applicable age of consent in your country, without parental consent, please let Zephyr know using the methods described in the Contact Zephyr section and Zephyr will take appropriate measures to investigate and address the issue promptly.
12. What About California "Shine the Light" Privacy Rights?
California law, under California Civil Code Section 1798.83 (known as the "Shine the Light" law), permits Zephyr's established customers who are California residents to request information regarding the manner in which Zephyr discloses certain categories of your Personal Data to third parties, for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to Zephyr at its designated address and receive the following information:
The categories of information Zephyr disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
The names and addresses of third parties that received such information; and
If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.
You are entitled to receive a copy of this information up to one time per calendar year in a standardized format and the information will not be specific to you individually. Zephyr's designated email address for such requests is the one indicated in the contact details above. Zephyr reserves the right to not respond to requests submitted to addresses other than the addresses specified in this paragraph. In your request, please attest to the fact that you are a California resident. Zephyr reserves the right to require proof of residence. Please allow up to thirty (30) days for a response.
13. What About Changes To This Privacy Notice?
Zephyr may change this Notice from time to time, so please be sure to check back periodically. Zephyr will post any changes to this Notice on Zephyr's Site. If Zephyr makes any changes to this Notice that materially affect Zephyr's practices with regard to the Personal Data Zephyr has previously collected from you, Zephyr will endeavor to provide you with notice in advance of such change by highlighting the change on Zephyr's Site, or by sending you an email message to the email address you have provided.
14. Zephyr managed services, voice, and AI
Customer-directed information may include Microsoft tenant and Azure administration records, configuration and support information, call metadata, service locations, recordings or transcripts where enabled, application records, prompts, generated outputs, tool calls, and workflow approval or usage logs. Collection depends on the service and enabled functionality, not merely on a general ability to access a platform. Customer-owned billing does not mean Zephyr never processes personal information.
Customers are responsible for appropriate notices, instructions, and required consents for their users, callers, recipients, and applications. Zephyr remains responsible for its own activities and legal obligations. Selected providers may process information to deliver an agreed voice, application, or AI function under the applicable contracts. The provider register, DPA, workflow scope, retention, and transfer arrangements must describe that processing accurately.
Zephyr will not use Customer Data to train its own general-purpose models, or authorize provider general-purpose training, without a separate explicit written agreement. No decision with legal or similarly significant effects is authorized solely by this Notice; applicable assessment, notices, authority, and safeguards are required.
15. SMS consent and mobile information
Personal Data collected through and for user-requested alerts, service notifications, or an SMS program, including mobile numbers and text-message opt-in or consent records, will not be sold, rented, or shared with affiliated or unaffiliated third parties for their marketing or promotional purposes. Zephyr may disclose such information to contracted platform providers, carriers, and other vendors only as needed to deliver or support the requested messaging program, subject to appropriate restrictions, or as required by law. This specific restriction controls over any broader marketing, affiliate, distributor, or reseller disclosure language above.
Consent to one campaign is not consent to unrelated marketing, another sender, or another channel. Customer-run programs require their own accurate notices and lawful opt-in and opt-out controls. No messaging program is launched or consent obtained merely by publishing this policy. Carrier registration or vetting is not a legal compliance determination.
16. Exercising your privacy rights
Contact legal@zephyrcloud.com to exercise applicable access, correction, deletion, portability, restriction, objection, consent-withdrawal, or opt-out rights, raise a concern, or submit an appeal where available. Use the subject Privacy Appeal for an appeal. Zephyr will reasonably verify identity and authority and respond within applicable legal time limits. Rights, permitted exceptions, authorized-agent processes, required channels, and regulator information depend on applicable law and Zephyr's actual role; nothing waives nonwaivable rights.
Zephyr Cloud Corporation, 934 Harriman St, Great Falls, Virginia 22066, United States. Legal and privacy contact: legal@zephyrcloud.com.
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