Zuma Internet Privacy Policy

Effective Date: September 3, 2026 Last Updated: September 3, 2026 Version: 2.0

1. Our Commitment to Privacy

At Zuma Internet, we believe your internet provider should earn your trust.

Your internet connection supports your work, your entertainment, your family, and your daily life. We collect the information we need to provide reliable service, support you when you need help, and improve your experience. We do not collect information simply because we can.

Our business model is simple: we make money by providing great internet service. We do not sell your personal information, sell your browsing history, or use your information as an advertising product.

This policy explains what information we collect, why we collect it, how long we keep it, who we share it with, and the choices you have.

1.1 Who and What This Policy Covers

This policy applies to:

• • Customers who subscribe to Zuma internet service, and other members of your household who use the connection;
• • Prospective customers who use our website, our RightPlan tool, or otherwise share information with us before becoming a customer;
• • Visitors to zumainternet.com and our mobile and web applications; and

• People who contact us by phone, chat, email, or through our AI-powered assistants, whether or not they are customers.

This policy does not cover information collected by third parties whose websites or services you reach through your Zuma connection. Their privacy practices are their own.

1.2 Documents That Make Up Our Privacy Commitments

This policy works together with:

• State Privacy Rights Supplement — additional rights and disclosures for residents of specific states. If you live in a state with its own privacy law, that supplement is part of this policy and applies to you.

• Zuma Terms of Service — the agreement governing your service.

1.3 Definitions

Personal information means information that identifies, relates to, describes, or could reasonably be linked with you or your household. It does not include information that has been aggregated or de-identified so that it can no longer reasonably be connected to you.

Network information means information about how your connection and equipment are performing. Some network information is personal information because it is tied to your account.

2. What We Do Not Do

These are commitments, not aspirations. We hold our vendors to them contractually and we audit against them.

2.1 We Never Use Your Internet Service for Advertising

This is the one that matters, and it has no exceptions.

What you do online is not a product we sell. The sites you visit, the devices on your network, how much data you use, when you’re online — none of it is ever sold, rented, licensed, shared with advertisers or data brokers, used to target advertising to you, or used to build a profile of you. Not by Zuma, not by our vendors, not by anyone.

We do not read the content of what you send over your connection. We do not inspect, read, or store the contents of your emails, messages, files, video calls, web pages, or searches.

We do not build browsing profiles. We do not create, retain, or use records of the websites you visit for marketing, advertising, or profiling, and we do not maintain browsing histories tied to your account for any commercial purpose. Your service does include security filtering that checks domain requests to block threats — Section 2.2 explains exactly how that works and how to turn it off.

We do not use your personal information to train general-purpose AI models. We do not use identifiable customer information to train, fine-tune, or improve AI models that are shared broadly, licensed to others, or used to serve customers of other companies. See Section 5.5 for what we do use interaction data for.

We do not require you to give up privacy to get a better price. Our pricing does not depend on your willingness to share data, and we do not offer discounts in exchange for expanded data rights.

We do not sell or share your personal information. We do not sell, rent, or license your information to advertisers, data brokers, or anyone else. We also do not “share” it for cross-context behavioral advertising or targeted advertising, as those terms are defined under state privacy laws. We do not run advertising cookies or tracking pixels on our website, and we do not build audiences for advertising platforms.

We do not run advertising or tracking technology anywhere you are signed in. Not in your account, not in RightPlan, not in support. Your customer relationship with us is not an advertising surface.

2.2 What Your Wi-Fi Service Sees

Zuma includes a managed Wi-Fi service in your subscription, provided through Plume’s HomePass platform. It does real work for you — better coverage, security filtering, device management — and it necessarily sees some things. Here is exactly what.

Domain-level security filtering. Your Zuma service includes network security protection that blocks malicious sites, malware, and known threats before they reach your devices. To do that, the system checks the domains your devices request against threat and category lists. Those domain requests are processed in the Plume cloud, which is how the protection stays current.

This means domain-level request data — the names of sites your devices connect to, not the pages, searches, or content — is processed to deliver the security features included in your service.

Zuma does not use that data to build a browsing profile, to market to you, or for any purpose other than protecting and troubleshooting your connection.

You can turn this off. The HomePass app includes a Privacy Mode that limits what network data leaves your home. Enabling it also turns off the security and content-filtering features, since those are what require the data. It is your call, and we will tell you plainly what you gain and lose. See Privacy Mode instructions.

Parental controls and content management. If you set up parental controls, screen-time limits, or per-person profiles, the system identifies which applications and content categories are in use so it can enforce the limits you set. This is only active for the profiles and devices you configure.

Wi-Fi and device management. Our Wi-Fi platform identifies devices connected to your network and measures how they perform, so we can improve your coverage and fix problems. This includes device identifiers such as MAC addresses, device type and operating system, signal quality, connection times, and where in your home coverage is weak. It also types smart-home and IoT devices so they can be onboarded and monitored for unusual behavior.

Motion detection (Sense). Your equipment is capable of detecting movement in your home by measuring Wi-Fi signal disruption. We leave this off. It is the most personal thing your equipment can do, so it gets its own section and its own decision — see Section 3.4.

Our support tools. Zuma support staff can see your network’s health, pull device logs, and review recent connectivity events when helping you. This lets us diagnose problems without a truck roll. Access is limited to staff working your issue and is logged.

What our Wi-Fi vendor can do with this. Plume, the company behind our Wi-Fi platform, operates under its own privacy policy and retains certain rights over data it derives from network operations. Zuma does not authorize or direct Plume to use Zuma subscriber data for advertising or to serve other internet providers. Plume operates under its own privacy policy and is the owner of data it derives from operating the platform. Zuma is negotiating additional written data protection terms with Plume, and we will update this policy when they are in place.

Legal disclosure. There are circumstances where the law requires us to disclose information and does not permit us to tell you first. See Section 7.3.

3. Information We Collect

3.1 Categories at a Glance

What we collect	Examples	Why we collect it	Do we sell or share it?
Account and contact information	Name, service address, email, phone number, service plan, account credentials	Establish and manage your account, deliver service, communicate with you	No
Billing and payment information	Billing address, payment method token, payment and balance history	Bill you and accept payment	No
Equipment and collections information	Equipment assigned to you, equipment returned or not returned, damage assessments, amounts owed	Recover Zuma equipment and unpaid equipment fees	Shared only with a collection agency, only if you owe an equipment balance — see 7.5
Network and service information	Connection status and uptime, speed, latency, reliability measurements, total data volume, equipment status and diagnostics, outage and trouble history	Activate service, maintain reliability, diagnose problems, plan capacity	No
Connected device and Wi-Fi information	Device identifiers including MAC addresses, device type and operating system, signal quality, connection times, Wi-Fi performance by location in the home, smart-home and IoT device types	Improve your Wi-Fi experience, troubleshoot coverage, onboard and monitor devices	No
Security filtering data	Domain requests checked against threat lists, blocked-domain events, threat detections	Block malicious content and protect your network	No
Parental control data	Application and content categories in use, per profile or device; screen-time activity	Enforce the limits you set up	No
Motion detection data (only if you turn Sense on)	Movement detected in the home via Wi-Fi signal disruption, movement patterns over time	Provide the home-awareness feature you chose to enable. Off unless you turn it on — see 3.4	No
Network diagnostic access	Device logs, connectivity event history, network topology, pulled by Zuma support when working your issue	Diagnose problems without a truck roll	No
Interaction and support records	Support tickets, chat transcripts, call recordings and transcripts, notes, prior troubleshooting steps, recommendations we made	Provide continuous support, resolve disputes, improve service	No
Preferences and service history	Service preferences, equipment history, plan changes, communication preferences	Provide a consistent experience without making you repeat yourself	No
Prospect and RightPlan information	Address serviceability lookup; survey responses about household size, usage needs, and current service	Tell you whether we can serve your address, and recommend the right plan	No
Website and app usage	IP address, browser and device type, pages visited on our site, referring source	Operate and secure our website, understand what’s working	See Cookie Notice
Inferences	Recommended plan tier, likely service need, predicted support issue	Personalize recommendations and support	No

3.2 Where Information Comes From

We collect information:

• • Directly from you — when you sign up, use RightPlan, contact us, or manage your account;
• • Automatically from your service — network, equipment, and Wi-Fi performance data;
• • From your interactions with us — support conversations, in person, by phone, chat, or through our AI assistants;
• • From service providers acting for us — payment processors, our Wi-Fi management platform, and communications providers. Some of this is information they generate about how your network is performing rather than information you gave us; and

• From the network owner — where Zuma operates on a municipal or third-party open-access network, we may receive service address, serviceability, and installation information from the network owner. See Section 7.4.

3.3 Information We Do Not Ask For

No credit check. No deposit. No Social Security number.

Zuma is a prepaid service. We do not run a credit check, require a deposit, or ask for your Social Security number, date of birth, driver’s license, or any other government identification number. We do not verify your identity against third-party databases, and we do not buy or receive credit, demographic, or interest data about you from data brokers.

When you enter your address on our site, we check it against our serviceable footprint. That is a lookup against our own network map — it does not pull any record about you.

We also do not collect or request information about your race, ethnicity, religion, health, sexual orientation, immigration status, precise geolocation, or biometric identifiers, and you should never provide it to us. We do not track your location — we know your service address because we install fiber there, and we do not collect location data from your phone or your devices. If you volunteer sensitive information in a support conversation, we will not use it to make decisions about your account.

Your equipment is capable of motion detection, and we leave it off. Section 3.4 explains it.

Your internet service should not require a credit history.

3.4 Motion Detection (Sense)

Your Zuma Wi-Fi equipment can detect movement in your home. It works by measuring how people moving through a space disrupt the Wi-Fi signals between your devices. No cameras, no microphones — just changes in signal strength.

We want to be direct about what this is: it is a record of when people are moving around inside your home.

How Zuma sets it up:

• It is off unless you turn it on. Your equipment can do this, but we do not switch it on for you. We would rather you choose it than find out later that it was already running.

• We show you the option during setup, explain what it does, and let you decide. One tap either way.

• Alerts stay off unless you turn them on separately. Even with the feature enabled, your phone will not notify you about movement in your home unless you ask it to.

• You can turn it off at any time, from the app or by asking us. Turning it off stops collection immediately.

• We delete motion history 30 days after you turn the feature off.

Who can see it. If you turn it on, whoever administers your Zuma account can see motion history for the home in the app. If other people live in your household, they should know before you enable it.

What Zuma does with it. Nothing, unless you ask us for help with the feature. We do not use motion data for marketing, for plan recommendations, for network planning, or for any purpose other than showing it to you. We do not sell it or share it.

A word about safety. Because this feature shows when people are home and when they are not, it can be misused — for example, by someone monitoring a family member or partner without their knowledge. If you are concerned that someone has access to your account and is using it to track you, contact us at contact@zumainternet.com or 224-407-6844. We will help you check whether the feature is on, turn it off, delete the history, and review who has access to your account. We will do this without notifying the account holder.

If you are in immediate danger, call 911. The National Domestic Violence Hotline is available at 1-800-799-7233.

4. How We Use Information

We use the information we collect to:

• • activate, provide, maintain, and repair your service;
• • diagnose and resolve problems, including proactively;
• • improve network performance, coverage, and capacity planning;
• • bill you, accept payment, and manage your account;
• • verify your identity and protect against fraud and unauthorized use;
• • provide support and remember what you have already told us;
• • recommend plans and features that fit your household;
• • communicate with you about your service and, subject to your choices, about our offerings;
• • improve our products, services, and support in aggregate; and

• comply with law and enforce our agreements.

We limit collection to what is adequate, relevant, and reasonably necessary for these purposes. If we want to use your information for a materially different purpose, we will tell you and, where required, ask first.

5. Artificial Intelligence and Your Data

AI is central to how Zuma delivers a simpler, more personal internet experience. It is also the area where customers most deserve clarity. This section is deliberately detailed.

5.1 You Will Always Know When You Are Talking to AI

When you interact with a Zuma assistant by phone, chat, or text, we tell you it is AI at the start of the conversation. We will never present an AI assistant as a human being.

Most questions are answered faster by our AI assistants than by a call queue, and that is a large part of how we keep your price low. Our assistants can do real work: change your plan, troubleshoot your connection, schedule a technician, explain a charge, and cancel your service.

When AI is not the right tool, a Zuma team member takes over. That happens when:

• • you need an accommodation for a disability;
• • there is a safety issue or an emergency;
• • the assistant has not resolved your issue;
• • you owe an equipment balance and disagree with it; or

• an action falls outside what the assistant is authorized to do.

Our assistants are built to hand off, not to hold on to you.

5.1a Cancelling Is as Easy as Signing Up

You can cancel Zuma service online in your account, or through any channel you can reach us in — chat, phone, or text. Whichever you choose, it takes one step or one conversation.

What we will do: ask you once whether there is something we could fix, and check whether you are moving — because if you are, we would rather transfer your service than lose you. If you are cancelling online, we will confirm you meant to, since disconnecting your internet is not something you want to do by accident.

What we will not do: route you to a retention department, require a phone call, make you explain yourself, ask a second time after you have answered, or bury the cancel button behind anything. If you say no, that is the end of it and your cancellation processes immediately.

You will receive written confirmation with your effective date.

We would rather you be able to leave easily and choose to stay.

5.2 We Record and Transcribe Conversations

Calls and chats with Zuma — including with our AI assistants — are recorded and transcribed. We tell you this at the start of each call. We use these recordings and transcripts to:

• • provide and continue support across conversations;
• • understand your service history;
• • resolve disputes;
• • ensure quality and accuracy; and

• improve our products, services, and support.

If you do not want a call recorded, tell us and we will turn recording off for that call.

5.3 We Do Not Create Voiceprints

We do not create, store, or use voiceprints, faceprints, or other biometric identifiers. We do not use voice recognition to identify or authenticate you, and we do not use your voice to determine who you are.

5.4 How AI Uses Your Account Information

When you interact with Zuma, our systems may draw on information associated with your account — your plan, equipment, service history, prior troubleshooting steps, and stated preferences — so that you do not have to repeat yourself. This is the point of the system, and it is why your experience gets better the longer you are a customer.

5.5 What We Use Interaction Data For

We do use aggregated, anonymized, or de-identified information derived from customer interactions, service performance, and usage patterns to improve our products, services, recommendations, and AI features. For example, we analyze broader trends to understand which plans fit which household needs, what service issues are most common, and where our support falls short. This information is processed so that individual customers cannot be identified, and we do not attempt to re-identify it.

We may also use identifiable interaction data to tune and evaluate Zuma’s own internal support and recommendation systems — the systems that serve you. This data stays within Zuma and its contracted processors. We do not sell it, and we do not use it to build products for other companies. We require our AI vendors by contract to protect it and to use it only to deliver services to Zuma.

5.6 Automated Decisions

Zuma does not use AI to make final decisions that significantly affect you.

Zuma makes no credit decisions at all — there is no credit check, no deposit, and no scoring of any kind that determines whether you can become a customer or what you pay. Our pricing is published and identical for everyone at a given plan.

Our AI assistants recommend plans, diagnose technical issues, answer questions, and carry out changes you ask for. They do not make the final call on decisions that would deny you service or send an unpaid balance to collections. A qualified Zuma team member reviews and has authority to change any such decision.

If you believe an AI-powered recommendation or action associated with your account was wrong, you can ask a Zuma team member to review it. Contact contact@zumainternet.com or 224-407-6844. We will explain what happened, correct any inaccurate information, and re-evaluate the outcome.

5.7 Human Oversight

Every Zuma AI system operates with defined limits on what it can do without human approval. Actions that change your plan, your price, or your service status require either your explicit confirmation or human authorization.

6. How Long We Keep Information

We keep information only as long as we need it to provide service, support our operations, comply with law, or resolve disputes.

While you are a customer, we keep your account, service, support, and equipment records so that we can serve you without making you start over every time you contact us.

After you leave, we keep a limited set of records for a period afterward — long enough to handle final billing, resolve any equipment balance, answer questions about your former service, and meet our legal and tax obligations. Billing and tax records are kept longer than the rest because the law requires it.

Some information is kept for much shorter periods. Call and chat audio recordings are kept for six months. Raw Wi-Fi and per-device telemetry, security filtering events, and motion detection history are kept only briefly — long enough to deliver the feature and troubleshoot problems, not to build a history of your household.

De-identified and aggregated data — information that cannot reasonably be linked back to you or your household — may be kept indefinitely in that form.

Records tied to a legal claim, dispute, or investigation are kept until the matter is resolved.

We are publishing a specific retention schedule with exact periods for each category. Until it is published, the commitments above apply.

Why we keep some things for the life of your service. Your service history, preferences, prior troubleshooting steps, and how your home network actually performs are what let us help you without making you start over every time. That is the product. We keep a summary of how your network behaves rather than a minute-by-minute log of every device in your home — we get the same benefit with far less of your data sitting in one place.

If you pre-registered and we haven’t reached you yet. Fiber construction takes time, and it happens in phases. If you told us to contact you when service reaches your address, we keep your information until we can actually do that — up to four years.

Because that can be a long wait, we email you about once a year to confirm you still want to hear from us. You can tell us to remove you at any time, and one click does it. If four years pass and we still cannot serve your address, we delete your information and let you know.

6.1 If You Leave and Come Back

Customers move, and some of our customers are seasonal. If you restart Zuma service at any address within six months of disconnecting, we reconnect your history — your preferences, equipment record, and prior troubleshooting all come back, so you are not starting from zero.

If more than six months pass, we treat you as a new customer and your prior service history is deleted on the schedule above. We keep only what we are required to retain, such as billing records.

If you asked us to delete your information while you were away, we honor that deletion. Your history will not come back, even inside the six-month window.

6.2 You Can Reset Your History

If you would prefer we clear your stored interaction history and start fresh, contact us at contact@zumainternet.com. We will delete what we are not required to keep, and we will tell you plainly what we must retain and why.

7. When We Share Information

Zuma shares information only when necessary to provide service, operate our business, or comply with law.

7.1 Service Providers

We work with companies that help us deliver service, including payment processors, cloud infrastructure providers, network and Wi-Fi management providers, communications providers, contracted customer support providers who answer calls and messages on Zuma’s behalf, and AI technology providers.

We require our service providers by contract to protect your information and to use it only to deliver services in connection with your Zuma account. Most are required to delete or return it when our relationship ends; where a provider is instead permitted to de-identify it, we say so below.

Where a provider retains broader rights. Some technology providers operate under their own privacy policies and retain rights over data they derive from operating their systems. Where that is the case, we tell you here rather than implying a control we do not have:

• Plume provides the Wi-Fi management platform included with your service. Plume operates under its own privacy policy and retains certain rights over data derived from network operations. Zuma does not authorize or direct Plume to use Zuma subscriber data for advertising or for serving other internet providers, and Zuma is negotiating additional written data protection terms with Plume. When Zuma’s relationship with Plume ends, Plume is permitted to de-identify data it holds rather than delete it.

• Plume may also contact you directly through the HomePass app to send service notifications or to ask you to complete a survey about the Wi-Fi service.

You can ask us for a current list of the companies that help us deliver your service by emailing contact@zumainternet.com.

What we do not permit. No Zuma service provider is authorized to sell your personal information, use it for their own advertising or marketing to you, or include it in advertising audiences built for Zuma or anyone else.

7.2 Affiliates

7.3 Legal Requirements

We may disclose information when required by law, court order, subpoena, warrant, or other valid legal process, and where necessary to protect the safety of any person, to protect against fraud or unauthorized use of our network, or to establish or defend legal claims.

We will notify you before disclosing your information in response to legal process, unless we are legally prohibited from doing so, notice is not permitted by the circumstances, or we believe notice would create a risk of harm to any person. Some legal demands require disclosure and prohibit notification; in those cases we comply with the law.

7.4 Network Owners and Municipal Partners

Zuma operates on open-access fiber networks, some of which are owned by cities or other public entities.

Where Zuma operates on a network we do not own, we may provide the network owner with information necessary to install, activate, maintain, and repair service — including service addresses, service status, installation appointments, and trouble reports. We provide the minimum necessary for these purposes.

Important: information held by a city or other public entity may be subject to that state’s public records or government data practices laws, which are different from this policy and outside Zuma’s control. Zuma requires network owners by contract to limit their use of subscriber information to network operations and to protect it appropriately, but we cannot override a public entity’s legal obligations.

If Zuma ever stopped serving your network. Our agreements with network owners require that customers not be left without internet service if a provider leaves the network. If Zuma ever ceased operating on the network serving your address, we would be required to give the network owner your name and contact information — and potentially to give it to another internet provider on that network — so that someone could contact you about continuing service.

We would tell you before this happened, and we would tell you who received your information. You would be free to choose any provider or none. We would not do this for any other reason, and no provider gets your information while you are our customer.

In Willmar, Minnesota, Zuma operates over the Willmar Connect network, which is owned by the City of Willmar.

7.5 Equipment Fees and Collections

Zuma is prepaid. If you stop paying, your service simply ends — there is no past-due balance, no late fee, and nothing goes to collections.

The one exception is equipment. If Zuma equipment is not returned or comes back damaged, you may owe an equipment fee. If that happens:

1. We will tell you what you owe and why, and give you a chance to return the equipment or dispute the charge.
2. If a payment method is on file, we may charge the fee to it, as described in your Terms of Service.
3. Only if the balance remains unresolved may we refer it to a licensed collection agency. We would share your name, contact information, service address, and the amount owed — nothing more. No service history, no network data, no conversation records.

We do not report to credit bureaus. Zuma does not furnish account or payment information to Equifax, Experian, TransUnion, or any other consumer reporting agency. An unpaid Zuma equipment fee will not appear on your credit report as a Zuma tradeline.

A Zuma team member reviews every account before it is referred to collections.

7.6 Business Transfers

If Zuma is acquired, merged, or transfers assets, customer information may transfer as part of that transaction. Any successor will be required to honor this policy for information collected under it, or to provide you notice and a meaningful opportunity to object before materially changing how that information is used.

7.7 With Your Direction

We share information when you ask us to — for example, with a family member you authorize on your account, or with a third party you direct us to contact.

8. Marketing Communications and Your Choices

We may contact you about Zuma products and services by mail, email, text message, phone, or at your door. You control this.

Channel	How to opt out
Email	Click “unsubscribe” in any marketing email, or contact contact@zumainternet.com
Text message	Reply STOP to any marketing text
Phone	Call 224-407-6844 or contact contact@zumainternet.com
Postal mail	Contact contact@zumainternet.com or call 224-407-6844
Door-to-door	Contact contact@zumainternet.com or call 224-407-6844 to add your address to our do-not-knock list
Opting out of marketing does not stop service-related messages — outage notices, billing statements, appointment confirmations, and security alerts. Those are part of your service.	We honor federal and state Do Not Call and do-not-knock requirements. We do not share your contact information with third parties for their own marketing.

9. Cookies and Website Tracking

Our website uses only two kinds of cookies:

Essential. Required for the site to work — security, load balancing, and remembering what’s in your session.

Analytics. Help us understand which pages people use and where they get stuck, so we can fix things. We use privacy-preserving analytics that do not follow you to other websites.

We do not use advertising cookies, tracking pixels, or cross-site tracking technologies. There is no advertising opt-out here because there is nothing to opt out of. We also do not use session recording or screen-replay tools.

We honor Global Privacy Control signals, though there is no advertising activity for them to stop.

Your browser lets you block or delete cookies at any time. Blocking essential cookies may prevent parts of the site from working.

10. Your Privacy Rights

10.1 Rights Available to Everyone

Regardless of where you live, you may ask us to:

• • Tell you what personal information we have about you and how we use it;
• • Give you a copy of your information in a portable format;
• • Correct information that is inaccurate;
• • Delete information we are not required to keep;
• • Explain an AI-powered recommendation or action associated with your account, and have a person review it;
• • Reset your stored interaction history; and

• Stop marketing communications.

Residents of certain states have additional rights. See our State Privacy Rights Supplement.

10.2 How to Make a Request

• Email: contact@zumainternet.com

• Mail: 1068 Moores Mill Rd NW, Atlanta, GA 30327

You do not need to create an account to make a request.

10.3 Verifying Your Identity

To protect your information, we need to confirm a request is really from you. We will typically ask you to confirm information already associated with your account, or to respond from the email address or phone number on file. For requests involving sensitive information, we may ask for additional verification. If we cannot verify you, we will tell you why.

10.4 Authorized Agents

You may designate someone to make a request on your behalf. We will ask for written authorization signed by you, and we may still contact you directly to confirm.

10.5 How Long We Take

We will confirm receipt of your request promptly and respond within 45 days. If your request is complex, we may extend once by an additional 45 days, and we will tell you why before the first 45 days are up.

There is no charge for up to two requests in a 12-month period. If requests are excessive or repetitive, we may charge a reasonable administrative fee or decline, and we will explain our reasoning.

10.6 If We Say No — Appeals

If we decline your request in whole or in part, we will tell you why and explain how to appeal.

To appeal, reply to our decision or write to contact@zumainternet.com with the word “appeal” in your message. Your appeal is reviewed fresh, by someone who was not involved in the original decision wherever our size allows, and in every case against the original request rather than the decision we already made. We will respond within 45 days, and we may extend once by 60 days where reasonably necessary.

If we deny your appeal, we will provide a written explanation and tell you how to file a complaint with your state Attorney General. We keep records of all appeals for at least 24 months.

10.7 No Retaliation

We will not deny you service, charge you a different price, or give you a lower quality of service because you exercised a privacy right.

11. Security

We use administrative, technical, and organizational safeguards designed to protect customer information, including:

• • encryption of information in transit and at rest;
• • access controls and least-privilege permissions;
• • monitoring and logging of systems and access;
• • limiting employee and contractor access to what their role requires;
• • security requirements in every service provider contract; and

• a documented incident response plan.

No system can guarantee complete security. If a security incident affects your personal information, we will notify you as required by applicable law and, where we can, sooner. Our breach notification obligations vary by state; we comply with the law of your state of residence.

To report a security concern, contact contact@zumainternet.com.

12. Children and Household Members

Zuma accounts are held by adults. We do not knowingly collect personal information from children under 13, and we do not direct our services or marketing to children.

Members of your household who are not account holders — including children — use your Zuma connection. Because we do not track browsing history or build profiles of household members, we do not create records of any individual household member’s online activity. Our Wi-Fi management data identifies devices, not people, and we do not attempt to associate devices with specific individuals.

We do not use information about anyone we know to be under 18 for marketing purposes, and we do not sell or share the personal information of anyone under 18 under any circumstances.

If you believe a child under 13 has provided us personal information, contact contact@zumainternet.com and we will delete it.

13. Accessibility and Languages

This policy is available in every language in which Zuma offers service.

We provide this policy in formats accessible to people with disabilities. If you need this policy in an alternative format, contact contact@zumainternet.com.

14. Changes to This Policy

If we make material changes to this policy, we will notify you before the changes take effect — by email, in your account, or on your bill — and we will explain what changed.

Where a change would materially expand how we use information we already collected about you, we will give you a reasonable opportunity to object or withdraw consent before applying the change to that information.

Previous versions of this policy are available on request at contact@zumainternet.com.

15. State Privacy Rights

Residents of states with their own privacy laws have additional rights and are entitled to additional disclosures. Those are set out in our State Privacy Rights Supplement, which is part of this policy.

The supplement currently covers: [MINNESOTA / IDAHO / WISCONSIN / CALIFORNIA / OTHER STATES AS ADDED].

16. Contact Us

For anything in this policy — questions, requests, appeals, or security concerns — contact:

Email: contact@zumainternet.com Phone: 224-407-6844 Mail: Zuma Internet, Inc., Attn: Privacy, 1068 Moores Mill Rd NW, Atlanta, GA 30327

Privacy at Zuma is owned by David Williams, Chief Executive Officer. We are a small company, and that is deliberate — your request reaches a decision-maker rather than a queue.

If you are appealing a decision we made, say so in your message and we will treat it as an appeal under Section 10.6.