Privacy Policy

Effective Date	07/14/2026
Last Updated	07/14/2026

PNS Communications, LLC Operator of the Zexci Platform

Privacy at a Glance

1. Introduction

PNS Communications, LLC operates the Zexci platform, including its websites, mobile applications, code-scanning and verification services, rewards features, Zexci Pulse surveys and engagement programs, advertiser tools, campaign dashboards, APIs, analytics services, and related products and services.

In this Privacy Policy:

• “PNS,” “Zexci,” “we,” “us,” and “our” mean PNS Communications, LLC and the Zexci platform it operates.
• “Services” means all websites, applications, software, platforms, features, communications, and services offered by or through PNS or Zexci.
• “User” or “you” means a person who accesses or uses the Services.
• “Advertiser” includes an advertiser, campaign sponsor, agency, merchant, publisher, brand, or other business using Zexci’s campaign or analytics services.

This Privacy Policy explains what information we collect, how we use it, when it may be disclosed, the protections applied to it, and the privacy choices available to users.

Certain Services may initially be offered in Beta or limited-release form. Beta status does not reduce the protections described in this Privacy Policy.

2. Our Core Privacy Commitments

PNS and Zexci are designed to provide verified engagement, rewards, campaign analytics, and research results without unnecessarily disclosing a user’s identity.

2.1 We do not sell personal information

PNS and Zexci do not sell users’ personal information for money or other valuable consideration.

We also do not share personal information for cross-context behavioral advertising or permit advertisers to use Zexci information to track users across unrelated businesses, websites, applications, or services.

2.2 We do not give advertisers users’ identities

PNS and Zexci do not provide advertisers, campaign sponsors, data brokers, or marketing companies with a user’s:

• Name.
• Email address.
• Telephone number.
• Residential address.
• Mailing address.
• Zexci account identifier.
• Account credentials.
• Complete personal scan history.
• Complete rewards or redemption history.

An advertiser does not receive this information merely because a user scans a code, participates in a campaign, answers a Zexci Pulse survey, earns points, redeems a reward, or uses another Zexci feature.

Advertisers may receive aggregated campaign results or individual responses associated with a limited campaign-specific pseudonymous identifier, as explained in Section 9.

2.3 Names and addresses receive special protection

PNS and Zexci do not sell, rent, trade, license, or provide users’ names or residential or mailing addresses to advertisers, campaign sponsors, data brokers, or other unaffiliated parties for their own advertising, marketing, profiling, or commercial purposes.

A user’s name or residential or mailing address may be processed or disclosed only when reasonably necessary to:

• Complete a transaction or service expressly requested by the user.
• Deliver a physical reward or product requested by the user.
• Operate the Services through a restricted service provider acting solely for PNS.
• Verify identity or account eligibility.
• Prevent fraud, security incidents, or reward abuse.
• Satisfy tax, accounting, or regulatory obligations.
• Respond to valid local, state, or federal legal process.
• Protect the rights, property, security, or safety of PNS, Zexci, users, or others.
• Complete a corporate transaction subject to confidentiality and applicable law.
• Carry out another purpose expressly authorized by the user.

Where disclosure is necessary, we seek to disclose only the information reasonably required for the specific purpose.

3. Scope of This Privacy Policy

This Privacy Policy applies to information collected through:

• Zexci mobile applications.
• PNS and Zexci websites.
• Zexci code scanners and verification services.
• Zexci-supported QR, DRV, QRV, branded, hybrid, and interactive codes.
• Zexci Scan-Shield and related security features.
• Zexci rewards and wallet features.
• Zexci Pulse surveys, polls, and engagement programs.
• Advertiser and campaign dashboards.
• Campaign analytics and reporting.
• Customer-service and technical-support communications.
• APIs and platform integrations.
• Beta programs, testing programs, and promotional activities referring to this Privacy Policy.

This Privacy Policy does not govern information collected independently by an advertiser, merchant, reward provider, website, application, or other third party after a user knowingly leaves the Zexci environment or submits information directly to that third party.

4. Information We Collect

The information we collect depends on the Services a person uses.

4.1 Account and registration information

We may collect:

• Name.
• Username, handle, or account identifier.
• Email address.
• Telephone number.
• Passwordless login, magic-link, authentication, and session information.
• Age, age range, date of birth, or eligibility confirmation.
• State or country of residence.
• Communication preferences.
• Account settings.
• Consent and authorization records.
• Referral codes and referral status.

We may request a residential or mailing address only when reasonably necessary for a particular transaction, physical fulfillment, legal requirement, eligibility determination, or identity-verification purpose.

4.2 Scan and code-verification information

When a user scans or interacts with a supported code, we may collect or generate:

• The code or serial identifier.
• Campaign identifier.
• Date and time of interaction.
• Code-verification result.
• Whether the code is active, registered, altered, expired, revoked, or suspicious.
• Campaign destination or content presented.
• User selections and call-to-action activity.
• Whether an interaction resulted in a response, signup, conversion, or other campaign event.
• Reward eligibility and points awarded.
• Fraud, duplication, and abuse indicators.
• General campaign-location or regional information.
• Device, application, network, and session information.

4.3 Zexci Pulse information

When a user voluntarily participates in Zexci Pulse, we may collect:

• Survey and poll responses.
• Opinions and feedback.
• Campaign awareness.
• Brand perception.
• Purchase intent.
• Product or advertising preferences.
• Response timing and completion information.
• Survey-quality and consistency signals.
• Eligibility information.
• Reward information associated with participation.
• Voluntarily supplied demographic ranges, such as ZIP code, age range, household size, or gender.

Zexci does not require users to place Social Security numbers, financial-account credentials, passwords, medical diagnoses, or other unnecessary sensitive information into survey responses.

Users should not include directly identifying or confidential information in free-text responses unless a feature expressly requests it and explains why it is needed.

4.3A Who Receives Your Response

Before a user begins a sponsored Zexci Pulse survey, Zexci will identify the applicable advertiser or campaign sponsor and provide the following notice:

The user must affirmatively choose to participate before the survey responses are provided to the identified advertiser.

The campaign-specific pseudonymous identifier is designed to:

• Distinguish responses from different unidentified participants within the applicable campaign.
• Allow the advertiser to recognize multiple responses submitted by the same unidentified participant within that campaign.
• Prevent the advertiser from identifying the participant through the identifier itself.
• Prevent correlation of the participant across unrelated advertisers or campaigns.

Declining to participate will not prevent the user from accessing unrelated Zexci features. However, the user will not receive points or other rewards offered specifically for completing that survey.

Survey responses previously provided to an advertiser with the user’s authorization may remain subject to the advertiser’s permitted retention obligations and cannot necessarily be recalled after delivery. Advertisers are contractually prohibited from attempting to identify pseudonymous participants or combining Zexci survey responses with outside information for that purpose.

4.4 Rewards and wallet information

We may collect or generate:

• Points earned.
• Points pending or held for review.
• Reward balances.
• Reward selections.
• Redemption records.
• Referral rewards.
• Campaigns associated with reward activity.
• Transaction and fulfillment identifiers.
• Gift-card or digital-reward delivery status.
• Eligibility and verification results.
• Information used to identify duplicate accounts, reinstall abuse, automated activity, device farms, or reward manipulation.
• Tax information where legally required.

Rewards are also governed by the applicable Zexci Rewards Program Terms.

4.5 Device and technical information

We may automatically collect:

• Device type and model.
• Operating system.
• Browser or application version.
• Internet Protocol address or a protected representation of it.
• Mobile network or internet service provider.
• Device, installation, or application identifiers used for security.
• Language, region, and time-zone settings.
• Session identifiers.
• Authentication results.
• Device-integrity or attestation results.
• Error, performance, and security information.
• Referring campaign or application source.
• Install, uninstall, and reinstall indicators.
• User-agent information.
• Information about suspected automated or manipulated activity.

Zexci’s consumer-facing applications are not designed to use third-party advertising, cross-app tracking, attribution, session-replay, or consumer advertising analytics SDKs.

4.6 General location information

We may derive general geographic information from:

• An IP address.
• A campaign or code location.
• A voluntarily supplied ZIP code.
• Device settings or permissions, where a feature specifically requests location access.

Precise device location will be collected only when a feature requires it, the user receives appropriate notice, and the user grants the required permission.

PNS and Zexci do not sell precise geolocation information or provide a user’s precise movement history to advertisers for their independent use.

4.7 Camera and image processing

The Zexci scanner uses a device camera to recognize and decode supported codes.

In the ordinary scanning process:

• Camera frames are processed on the user’s device.
• Camera images are not uploaded to PNS.
• Camera frames are not retained by the Zexci platform.
• Only decoded code information is transmitted for verification and campaign processing.
• Zexci does not continuously record the user’s surroundings.

Zexci does not use scanner camera images to identify people or create facial-recognition templates, faceprints, voiceprints, or other biometric identifiers.

If a user separately uploads an image, screenshot, logo, advertisement, or other file, we may process the uploaded content and its associated metadata for the feature requested by the user.

4.8 Advertiser and business-account information

For advertisers and business customers, we may collect:

• Business name and contact information.
• Authorized-user information.
• Campaign content and instructions.
• Brand materials, logos, advertisements, and creative files.
• Campaign destinations.
• Survey questions.
• Reward rules.
• Billing or subscription information.
• Security and access records.
• Campaign-performance and analytics information.
• Communications with PNS or Zexci.

4.9 Customer support and communications

We may collect information a person provides when the person:

• Contacts customer support.
• Sends an email or message.
• Reports a suspicious code.
• Reports fraud or unauthorized activity.
• Challenges a reward decision.
• Submits a privacy request.
• Participates in testing or research.
• Communicates with PNS through another channel.

4.10 Information from service providers and other sources

We may receive limited information from:

• Apple App Attest and Google Play Integrity.
• Hosting, security, and fraud-prevention providers.
• Reward and fulfillment providers.
• Email or communication providers.
• Advertisers supplying campaign information.
• Payment or billing providers when applicable.
• Other parties acting under the user’s direction.

We may combine this information with information collected through the Services when reasonably necessary for the purposes described in this Privacy Policy.

5. How We Use Information

PNS and Zexci may use information to:

• Create, authenticate, maintain, and secure accounts.
• Operate the Zexci scanner and verification services.
• Determine whether a code is authentic, registered, active, altered, revoked, expired, or suspicious.
• Display campaign content and calls to action.
• Award, track, protect, and redeem reward points.
• Administer Zexci Pulse surveys and polls.
• Determine campaign and reward eligibility.
• Verify campaign timing, geographic plausibility, and engagement.
• Prevent duplicate rewards, repeat-install claims, automated scanning, device farming, spoofing, account sharing, and other abuse.
• Provide campaign analytics and advertiser reporting.
• Process transactions and requested reward fulfillment.
• Respond to support inquiries and privacy requests.
• Send transactional, security, account, and reward communications.
• Send promotional communications where permitted.
• Improve platform usability, accessibility, security, and performance.
• Test and develop new services and features.
• Diagnose errors and protect platform integrity.
• Conduct research using aggregated, deidentified, or appropriately pseudonymous information.
• Enforce platform agreements, campaign rules, and Rewards Program Terms.
• Comply with legal, regulatory, accounting, tax, and reporting obligations.
• Establish, exercise, or defend legal claims.
• Complete a merger, financing, acquisition, restructuring, or other corporate transaction.
• Carry out another purpose disclosed when information is collected or authorized by the user.

We will not use personal information for a materially different purpose without providing additional notice or obtaining consent when required by law.

6. How We Disclose Information

PNS and Zexci disclose information only as described in this Privacy Policy.

6.1 Restricted service providers

We may permit contracted service providers to process limited information on our behalf for purposes such as:

• Cloud hosting and storage.
• Account authentication.
• Device integrity and security.
• Fraud prevention.
• Email, text-message, or push-notification delivery.
• Customer support.
• Reward processing and delivery.
• Payment or billing processing.
• Advertiser-side creative and transcription services.
• Application maintenance and error reporting.
• Legal, accounting, auditing, and compliance services.

Service providers are permitted to process information only for authorized services performed for PNS. They are not authorized to sell the information or use it for their own independent advertising, marketing, profiling, or unrelated commercial purposes.

Where practical, we provide service providers with only pseudonymous, limited, or minimum-necessary information.

6.2 At the user’s direction

We may disclose information when a user knowingly requests or authorizes it, including when the user:

• Submits information directly to an advertiser.
• Requests delivery of a reward.
• Requests shipment of a physical item.
• Connects another service.
• Participates in a jointly administered program.
• Asks us to send information to a specified recipient.

Before information is submitted directly to an advertiser or other third party, the user will receive notice where appropriate. The receiving party’s privacy policy will govern its subsequent independent use.

6.3 Legal requirements

We may preserve, access, or disclose information when reasonably necessary to comply with applicable local, state, or federal law or valid legal process, including:

• A court order.
• Search warrant.
• Subpoena.
• Civil investigative demand.
• Regulatory requirement.
• Tax requirement.
• Legally binding governmental request.
• Other valid legal process.

We review legal demands where appropriate and seek to disclose only information reasonably required by the applicable demand.

Where legally permitted and reasonably appropriate, PNS may object to, limit, or challenge a request that appears invalid, excessive, overly broad, or unrelated to a legitimate legal requirement.

PNS may be prohibited by law from notifying a user about a particular request.

6.4 Protection of rights, security, and safety

To the extent permitted by law, we may disclose limited information when reasonably necessary to:

• Detect or prevent fraud.
• Investigate unauthorized access or cyberattacks.
• Prevent reward theft or manipulation.
• Investigate code tampering.
• Enforce platform agreements.
• Protect PNS, Zexci, users, advertisers, or the public.
• Respond to an emergency or threat to safety.
• Defend against claims or legal proceedings.

This provision does not authorize advertisers to use users’ names, addresses, or contact information for independent advertising or marketing.

6.5 Corporate transactions

If PNS is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or transfer of all or part of the PNS or Zexci business, information may be reviewed or transferred as part of that transaction.

Potential purchasers, lenders, investors, advisers, and successors must protect information through appropriate confidentiality and data-protection requirements.

A corporate transaction does not authorize a successor to sell users’ names or residential or mailing addresses to advertisers or data brokers for independent marketing.

7. Protection of Names, Contact Information, and Addresses

PNS and Zexci do not provide users’ names, email addresses, telephone numbers, residential addresses, or mailing addresses to advertisers merely because users interact with a campaign.

These direct identifiers may be processed only for limited purposes, including:

• Account authentication.
• Security and fraud prevention.
• User-requested communications.
• Reward delivery.
• A transaction requested by the user.
• Privacy-request verification.
• Legal or tax compliance.
• Valid legal process.
• Another purpose expressly authorized by the user.

PNS seeks to segregate direct identifiers from advertiser-facing campaign information and restrict access to personnel and providers with a legitimate operational need.

8. No Sale or Cross-Context Behavioral Advertising

PNS and Zexci do not:

• Sell personal information.
• Rent personal information.
• Provide names or addresses to data brokers.
• Share personal information for cross-context behavioral advertising.
• Permit advertisers to identify users across unrelated advertisers through Zexci-provided identifiers.
• Provide advertisers with a universal Zexci identifier.
• Provide advertisers with users’ complete cross-campaign histories.
• Use private Pulse responses for unrelated third-party advertising.

If our practices materially change, we will provide any notice, consent mechanism, or opt-out opportunity required by applicable law before the change applies.

9. Advertiser Reporting and Pseudonymous Information

Advertisers may receive aggregated campaign reporting and, when a user voluntarily authorizes participation in a sponsored Zexci Pulse survey, individual survey responses associated with a campaign-specific pseudonymous identifier. Before the survey begins, Zexci will identify the advertiser receiving the responses and explain what information will and will not be provided.

Campaign reporting may include:

• Total scans.
• Verified and unverified scan counts.
• General regions.
• Time ranges.
• Device or platform categories.
• Interaction and conversion rates.
• Reward activity in aggregate.
• Aggregated survey results.
• Fraud or invalid-activity rates.
• Campaign trends.
• Individual survey responses associated with a limited campaign-specific pseudonymous identifier.

A pseudonymous identifier:

• Does not contain the user’s name.
• Does not contain the user’s email address or telephone number.
• Does not contain the user’s residential or mailing address.
• Does not expose the user’s Zexci account identifier.
• Is designed to prevent correlation across unrelated advertisers or campaigns.

Within an authorized campaign, a pseudonymous identifier may allow the advertiser to recognize that multiple responses came from the same unidentified participant.

Pseudonymous information is not represented as fully anonymous or deidentified when it remains capable of being associated with the same participant.

Advertisers are prohibited from:

• Attempting to identify a pseudonymous participant.
• Combining Zexci information with outside identity information.
• Using Zexci information to build unrelated advertising audiences.
• Selling Zexci survey or engagement information.
• Providing Zexci information to data brokers.
• Using Zexci information for employment, credit, housing, insurance, health-care eligibility, or other legally significant decisions.
• Inferring legally protected sensitive characteristics for advertising or targeting.
• Retaining or disclosing information beyond authorized purposes.

10. Aggregated and Deidentified Information

We may create information that has been aggregated, deidentified, anonymized, or otherwise processed so it cannot reasonably be linked to a particular person.

We may use and disclose such information for:

• Campaign measurement.
• Industry research.
• Product development.
• Security analysis.
• Fraud prevention.
• Business planning.
• Advertiser reporting.
• Public reports and presentations.

We will not attempt to reidentify information maintained as deidentified except where permitted to test the effectiveness of deidentification, protect security, prevent fraud, or comply with law.

Recipients may be contractually prohibited from attempting to reidentify individuals.

11. Rewards and Financial Incentives

Zexci may provide points, gift cards, promotional benefits, or other rewards for eligible activities, including:

• Verified scans.
• Campaign selections.
• Zexci Pulse participation.
• Referrals.
• Other qualifying engagement.

Participation is voluntary.

Certain rewards may require the user to provide information necessary to:

• Determine eligibility.
• Complete a survey.
• Validate the activity.
• Prevent duplicate claims.
• Deliver the reward.
• Comply with applicable law.

A user who chooses not to provide information required for a particular activity may be unable to receive the reward associated with that activity, but may continue using unrelated portions of the Services where available.

Where applicable law requires a separate financial-incentive or loyalty-program notice, PNS will provide that notice before enrollment. The notice may describe:

• The material terms of the program.
• The information involved.
• How to opt in.
• How to withdraw.
• How rewards are determined.
• The relationship between the information and the offered benefit.
• What happens to pending or unused points after withdrawal or account deletion.

Rewards have no cash value except as expressly provided in the applicable Rewards Program Terms. Points may be subject to eligibility requirements, expiration, forfeiture, fraud review, account status, and other program rules.

12. Fraud Prevention and Automated Analysis

PNS may use automated and manual methods to identify:

• Duplicate accounts.
• Repeated reward claims.
• Application uninstall and reinstall abuse.
• Automated or scripted scans.
• Device farms.
• Bots.
• Location or device manipulation.
• Duplicate survey responses.
• Unusually rapid or inconsistent responses.
• Account sharing.
• Attempts to compromise codes, accounts, rewards, or platform systems.

These methods may assign risk indicators to an account, device, session, scan, response, or transaction.

A risk indicator may cause an activity to be:

• Delayed.
• Reviewed.
• Rejected.
• Marked invalid.
• Made ineligible for a reward.
• Subject to additional verification.
• Restricted or suspended.

A risk indicator does not necessarily establish wrongdoing. Users may request review through the support method identified in the applicable Rewards Program Terms or account notice.

PNS is not required to reveal confidential fraud thresholds, security methods, or information that could help a person bypass platform protections.

13. Artificial Intelligence and Transcription Services

PNS may use artificial-intelligence, machine-learning, web-search, and transcription tools to support advertiser-side and platform functions, including:

• Brand identification.
• Advertising and campaign design.
• Color or palette development.
• Processing advertiser-supplied creative materials.
• Transcribing advertiser-supplied advertisements or audio.
• Platform security and fraud prevention.
• Internal testing and product development.

Zexci does not currently send consumer Pulse responses to third-party generative-artificial-intelligence providers.

PNS does not use users’ names, mailing addresses, account credentials, or private Pulse responses to train publicly available or general-purpose artificial-intelligence models.

Service providers processing information for PNS must act under applicable contractual and security restrictions.

14. Blockchain and Analytics Integrity

Zexci does not use blockchain as a repository for consumers’ personal information, complete scan records, survey answers, or engagement histories.

When enabled, Zexci may use blockchain technology to create tamper-evident proof that selected analytics information existed in a particular form at a particular time and has not subsequently been altered.

The blockchain record may contain limited aggregate cryptographic information, such as:

• A Merkle root.
• An opaque batch reference.
• A record count.

The underlying scan, engagement, campaign, survey, and user records remain in Zexci’s controlled off-chain systems.

The intended blockchain commitments do not contain:

• Consumer names.
• Email addresses.
• Telephone numbers.
• Residential or mailing addresses.
• Zexci user identifiers.
• Device identifiers.
• IP addresses.
• Survey answers.
• Complete scan records.
• Per-user pseudonymous identifiers.

The on-chain values are not designed to identify or reasonably permit identification of an individual.

Certain verification processes may allow an authorized party possessing a code identifier and corresponding cryptographic proof to verify that a code or related record was included within a committed batch. A code identifier identifies a code, not the person who scanned it.

Blockchain records may be permanent and technically incapable of deletion. Because consumer personal information and user-to-activity relationships are maintained off-chain, privacy and account-deletion requests are addressed through deletion, restriction, aggregation, or irreversible dissociation within Zexci’s controlled systems.

15. Cookies and Similar Technologies

PNS websites and applications may use cookies, local storage, session identifiers, and similar technologies to:

• Maintain sessions.
• Authenticate accounts.
• Remember settings.
• Prevent fraud.
• Protect rewards.
• Identify technical errors.
• Measure platform performance.
• Understand feature use.
• Maintain security.

PNS does not authorize these technologies to provide users’ names or mailing addresses to third parties for independent advertising.

Disabling technologies necessary for authentication, security, or essential operation may prevent parts of the Services from functioning.

16. Communications

PNS may send:

• Login or magic-link messages.
• Account confirmations.
• Security notices.
• Reward notifications.
• Redemption information.
• Service announcements.
• Privacy and policy updates.
• Customer-support responses.
• Campaign communications requested by the user.
• Promotional communications where permitted.

Users may opt out of promotional emails by using the unsubscribe method in the message.

Users may control push notifications through application or device settings.

Opting out of promotional communications does not prevent PNS from sending necessary account, authentication, security, legal, transactional, or reward-related messages.

17. Data Retention

PNS retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Maintain an account.
• Provide the Services.
• Process and account for rewards.
• Complete transactions.
• Prevent fraud and repeated abuse.
• Maintain security.
• Resolve disputes.
• Enforce agreements.
• Satisfy legal, tax, accounting, and regulatory requirements.
• Establish, exercise, or defend legal claims.

Retention periods may depend on:

• The type and sensitivity of the information.
• The purpose for which it was collected.
• Legal and contractual requirements.
• Fraud and security risks.
• User expectations.
• Whether information can be aggregated or dissociated.
• Applicable limitation periods.

When information is no longer reasonably necessary, PNS may:

• Delete it.
• Deidentify it.
• Aggregate it.
• Irreversibly dissociate it from the user.
• Restrict it from ordinary use.
• Securely isolate it until deletion.

Certain information may be retained after account deletion when reasonably necessary for:

• Fraud prevention.
• Transaction and reward accounting.
• Tax compliance.
• Consent records.
• Legal claims.
• Security investigations.
• Suppression of unwanted communications.
• Compliance with law.

Where retained, PNS seeks to remove or dissociate unnecessary direct identifiers and restrict access.

Information already incorporated into aggregated or deidentified reports may not be removable because it no longer reasonably identifies the user.

18. Account Deletion and Privacy Requests

Users may request account deletion through the methods made available in the Zexci application, website, or privacy-request process.

Account deletion may result in:

• Loss of access to the account.
• Revocation of active sessions.
• Loss or forfeiture of unused points as provided in the Rewards Program Terms.
• Cancellation, completion, or review of pending rewards.
• Deletion of profile and demographic information.
• Deletion or irreversible dissociation of account-linked information.
• Retention of limited records required for fraud, security, tax, accounting, consent, or legal purposes.

Deletion does not require removal of blockchain commitments that contain no consumer personal information or direct user relationship.

PNS may verify the requester’s identity before processing a request.

19. Security

PNS uses administrative, technical, organizational, and physical safeguards designed to protect information against:

• Unauthorized access.
• Loss.
• Theft.
• Alteration.
• Misuse.
• Unauthorized disclosure.
• Fraudulent activity.

Safeguards may include:

• Encryption in transit and at rest where appropriate.
• Authentication controls.
• Device-attestation controls.
• Access restrictions.
• Logging and audit trails.
• Cryptographic verification.
• Segregation of identifying and campaign information.
• Vendor-security requirements.
• Confidentiality obligations.
• Fraud monitoring.
• Incident-response procedures.
• Data-minimization practices.
• Security testing.

No internet transmission, mobile application, database, blockchain, or storage system can be guaranteed to be completely secure.

Users are responsible for protecting their devices, email accounts, and authentication methods and should promptly report suspected unauthorized access.

If a data incident requires notice under applicable law, PNS will provide the required notices.

20. Privacy Rights

Depending on where a user resides and whether applicable law applies to PNS, the user may have the right to:

• Confirm whether PNS processes the user’s personal information.
• Access personal information.
• Obtain a copy of certain information.
• Correct inaccurate information.
• Delete qualifying information.
• Request portability of certain information.
• Withdraw consent for consent-based processing.
• Opt out of qualifying sales or targeted advertising.
• Limit certain uses of sensitive personal information.
• Appeal the denial of a privacy request.
• Use an authorized agent where permitted.
• Receive service without unlawful discrimination for exercising privacy rights.

Because PNS does not sell personal information or share it for cross-context behavioral advertising, an opt-out request may confirm our existing practices rather than require a change.

Submitting a request

Requests may be submitted through:

Email: [email protected]

Mail: Privacy Officer, PNS Communications, LLC, 255 Primera Blvd. Ste160. Lake Mary Fl 32746

The request should describe the right being exercised and provide sufficient information for us to locate the relevant account or records.

Verification

PNS may verify identity through:

• Account access.
• Email confirmation.
• Magic-link authentication.
• Telephone confirmation.
• Transaction or reward information.
• Other reasonable information associated with the request.

PNS will not request more information than reasonably necessary to verify the request.

Appeals

Where applicable, a user may appeal a denied privacy request by replying to the decision or contacting:

Privacy Appeals: [email protected]

PNS will not unlawfully discriminate against a user for exercising an applicable privacy right.

21. California Privacy Notice

This section supplements the remainder of this Privacy Policy for California residents where the California Consumer Privacy Act, as amended, applies.

PNS may collect the following categories of personal information:

• Identifiers.
• Customer-record information.
• Internet or electronic-network activity.
• Commercial and rewards information.
• General geolocation information.
• Audio, visual, or electronic information supplied by advertisers or users.
• Professional or business information for advertiser accounts.
• Inferences concerning campaign engagement or fraud risk.
• Sensitive personal information where specifically required for an authorized feature.

The sources, purposes, recipients, and retention criteria for these categories are described throughout this Privacy Policy.

PNS does not:

• Sell personal information.
• Share personal information for cross-context behavioral advertising.
• Knowingly sell or share the personal information of users under 16.
• Use sensitive personal information to infer characteristics for unrelated advertising.

California residents may exercise applicable rights to know, access, correct, delete, obtain portability, limit certain uses, opt out, and receive equal treatment through the methods in Section 20.

22. Other State Privacy Rights

Residents of other states with applicable consumer privacy laws may have rights concerning:

• Access.
• Correction.
• Deletion.
• Portability.
• Consent withdrawal.
• Targeted advertising.
• Sales of personal information.
• Certain profiling.
• Appeals.

PNS will process valid requests according to the law applicable to the requester and PNS.

23. Children’s Privacy

The Services are not directed to children under 13 years of age.

PNS does not knowingly collect personal information from a child under 13 without legally required parental notice and verifiable parental consent.

If we learn that personal information was collected from a child under 13 without required authorization, we will take reasonable steps to delete it.

A parent or legal guardian who believes a child provided personal information may contact:

Email: [email protected]

Additional age or eligibility restrictions may apply to Pulse surveys, rewards, campaigns, or promotions.

PNS does not knowingly sell or share children’s personal information for targeted advertising.

24. Sensitive Information and Prohibited Uses

PNS does not use scan activity, rewards activity, Pulse responses, or campaign engagement to infer or target advertising based on a user’s:

• Race or ethnicity.
• Religion.
• Sexual orientation.
• Citizenship or immigration status.
• Medical condition.
• Mental or physical health.
• Union membership.
• Precise location associated with a sensitive facility.
• Other legally protected sensitive characteristic.

Advertisers may not use Zexci to request Social Security numbers, passwords, financial-account credentials, medical diagnoses, or other unnecessary sensitive information.

PNS may review or reject advertiser-submitted questions that seek prohibited, excessive, unlawful, or unnecessary sensitive information.

25. Third-Party Websites and Advertisers

Zexci may verify that a code is registered, authentic, unaltered, active, or associated with a stated destination.

Verification does not mean PNS:

• Owns the destination.
• Controls the destination.
• Endorses every product or statement.
• Guarantees the destination’s privacy or security practices.
• Accepts responsibility for information independently collected by the destination operator.

After a user knowingly leaves Zexci or submits information directly to another party, that party’s privacy policy and terms govern its independent practices.

Users should review a third party’s privacy and security practices before providing personal, financial, medical, or other sensitive information.

26. United States Availability

The Services are intended primarily for eligible users in the United States.

Rewards, Pulse participation, and particular campaigns may be limited to United States residents and may be subject to additional age, location, eligibility, and program requirements.

Users should not access restricted features from jurisdictions where their use is prohibited.

27. Changes to This Privacy Policy

PNS may update this Privacy Policy to reflect:

• New features.
• Changes in technology.
• Changes in data practices.
• Security improvements.
• Legal or regulatory requirements.
• Changes in business operations.

The updated policy will display a revised “Last Updated” date.

If a change materially affects how previously collected personal information is used, PNS will provide additional notice or request consent where required by law.

28. Contact Us

Questions, concerns, complaints, and privacy requests may be directed to:

PNS will review privacy complaints and respond in accordance with applicable law.

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